Case: Mahmoud Khalil v. Joyce

2:25-cv-01963 | U.S. District Court for the District of New Jersey

Filed Date: March 9, 2025

Case Ongoing

Clearinghouse coding complete

Case Summary

This case is one of numerous lawsuits challenging the Trump administration’s abrupt termination of immigration visas—mostly student or work visas—with no notice to the visa-holders and with dubious or no legal basis. You can see all of the cases here. This case challenges the detention and attempted deportation of student activist Mahmoud Khalil, a leader of the campus protests against the war in Gaza at Columbia University throughout the spring of 2024. Khalil was a lawful permanent resident o…

This case is one of numerous lawsuits challenging the Trump administration’s abrupt termination of immigration visas—mostly student or work visas—with no notice to the visa-holders and with dubious or no legal basis. You can see all of the cases here.

This case challenges the detention and attempted deportation of student activist Mahmoud Khalil, a leader of the campus protests against the war in Gaza at Columbia University throughout the spring of 2024. Khalil was a lawful permanent resident of the United States in possession of a green card who had recently completed his graduate studies at Columbia. On March 8, 2025, agents from the Department of Homeland Security (“DHS”) detained Khalil at his apartment, stating that his student visa had been revoked. When Khalil produced documentation showing that he held a green card, not a student visa, the agents responded that they were revoking his green card instead. The DHS agents did not show Khalil any documentation authorizing his detention or his green card revocation.

The next day, March 9, 2025, the government issued Khalil a “notice to appear”, stating that his deportation was sought under Section 237(a)(4)(C)(i) of the Immigration and Nationality Act (“INA”), a rarely-used provision that permits removal where the Secretary of State has reasonable ground to believe continued presence of the individual in the U.S. “would have potentially serious adverse foreign policy consequences.”

Initial Petition in the Southern District of New York

That same day, Khalil filed a petition for a writ of habeas corpus in the United States District Court for the Southern District of New York against William P. Joyce, the Acting Director of the New York Field Office of Immigration and Customs Enforcement (“ICE”); Caleb Vitello, the Acting Director of ICE; Kristi Noem, the DHS Secretary; and Pamela Bondi, the U.S. Attorney General. Khalil alleged that his detention and attempted deportation constituted retaliation, discrimination, and prior restraint in violation of his First Amendment right to free speech and his Fifth Amendment right to due process. Khalil sought an order releasing him from custody, an injunction prohibiting the government from transferring him outside the Court’s jurisdiction, and a declaration that the government’s actions violated the First and Fifth Amendments. He also requested that he be granted bail pending the adjudication of his habeas petition under Mapp v. Reno, 241 F.3d 221 (2d Cir. 2001). Khalil was represented by lawyers from the ACLU, New York Civil Liberties Union, Center for Constitutional Rights, Creating Law Enforcement Accountability & Responsibility (“CLEAR”) Project, and private counsel. The case was assigned to U.S. District Judge Jesse M. Furman.

Hours after he filed his habeas petition, Khalil was moved to a detention facility in Louisiana. In response, and in order to retain its jurisdiction, Judge Furman gave notice that Khalil was not to be removed from the United States unless and until the court ordered otherwise. Khalil also filed a motion to compel the respondents to return him to the Southern District of New York.

An initial hearing was held on March 12, 2025. The respondents argued for a change of venue to New Jersey or Louisiana, where Khalil had been held, while Khalil requested he be returned to the Southern District of New York. In response, the Court ordered Respondents to file a motion to transfer or dismiss for improper venue by 11:59 pm that day. Briefing on that motion and Khalil’s motion to compel his return to New York was scheduled to be completed by March 17, 2025. Judge Furman kept in place his March 10 order that Khalil was not to be removed from the United States until the Court ordered otherwise.

The respondents' ensuing motion to dismiss or transfer venue, filed on March 12, argued that jurisdiction didn't lie in the Southern District of New York because a habeas petitioner must file his petition in the district in which he is being held under Rumsfeld v. Padilla, 542 U.S. 426 (2004). The respondents asserted since Khalil was being held in Jena, Louisiana, the Western District of Louisiana was the proper venue. 

Khalil filed an Amended Petition on March 13, adding President Donald J. Trump and U.S. Secretary of State Marco Rubio as respondents. The Amended Petition also added a claim that Secretary Rubio’s determination under the INA that Khalil’s continued presence in the U.S. would adversely affect foreign policy interests violated the Administrative Procedure Act (“APA”).

On March 14, the court issued a memo endorsement adopting the parties’ proposed briefing schedule. Pursuant to this schedule, Khalil filed a motion for bail under Mapp v. Reno on March 14. Respondents are scheduled to file their opposition to the bail motion by March 19 or one day after the Court rules on their motion to dismiss or transfer venue, whichever is sooner. Khalil is also expected to file a motion for a preliminary injunction by March 17, with briefing on that motion to be completed by March 28.

In accordance with the court’s March 12 order, the respondents filed their opposition to Khalil’s motion to compel his return to New York on March 14. Khalil filed his opposition to the respondents’ motion to dismiss or transfer venue on the same day, arguing that venue was proper under exceptions recognized in Padilla and because Respondent Joyce, who is based in New York City, was Khalil's "immediate custodian" at the time that he filed his habeas petition on March 9. On March 16, Judge Furman ordered the parties to supplement their briefings on the motion to dismiss or transfer to address the two federal statutes authorizing a transfer of venue, 28 U.S.C. § 1404(a) and 28 U.S.C. § 1406(a). The parties filed supplemental briefs addressing the transfer statutes the next day.

Khalil filed a motion for a preliminary injunction on March 17, 2025, asking the court to preliminarily release him, enjoin Secretary Rubio's determination under INA Section 237(a)(4)(C)(i), and enjoin the respondents from enforcing a policy "of targeting for detention and removal noncitizens who engage in
constitutionally protected expressive activity in the United States in support of Palestinian rights or critical of Israel." In addition to this motion, Khalil also filed a reply in support of his motion to compel his transfer the same day.

Transfer to the District of New Jersey

On March 19, 2025, Judge Furman transferred the case to the District Court for the District of New Jersey, finding that because Khalil was detained in Elizabeth, New Jersey at the time his habeas petition was filed, that court had jurisdiction over the matter under the general rule that petitioners must challenge their detention in the district of their confinement. The opinion rejected the respondents' argument that the case should be transferred to the Western District of Louisiana, finding that the relevant inquiry is where khalil was confined at the time he filed his habeas petition, not where he is currently confined. The Court further found that the filing of the petition in the Southern District of New York was not an error by Khalil's attorney because at the time of filing, his attorney had a good faith reasonable belief that Khalil was being held in New York, given that DHS refused to provide her any information about Khalil's whereabouts. Judge Furman emphasized that his March 10 order barring the government from removing Khalil remained in effect unless and until the New Jersey court ordered otherwise. The case was assigned to Judge Michael E. Farbiarz of the U.S. District Court for the District of New Jersey.

The next day, the respondents renewed their motion to transfer the case to the Western District of Louisiana, arguing that Judge Furman erred in transferring the case to New Jersey. 

Also on March 20, Khalil filed an amended brief in support of his motion for bail, adding a case from the Third Circuit (where the District of New Jersey sits), Lucas v. Hadden, 790 F.2d 365 (3d Cir. 1986) that allows federal courts to grant bail to habeas petitioners. The respondents filed their opposition to the amended bail motion on March 23.

On March 21, Khalil filed a supplemental brief to his motion to compel his return, asking that he be returned to the District of New Jersey. The respondents filed a supplemental brief in opposition to the return motion later that day, and Khalil filed his reply on March 24. Also on March 24, Khalil filed his opposition to the respondents' renewed motion to transfer the case to Louisiana.

The next day, Khalil filed an amended brief in support of his motion for a preliminary injunction ("PI"). 

Judge Farbiarz denied the respondents' motion to transfer on April 1, also stating that a habeas court has jurisdiction when khalil was physically present in that court's district at the time of filing. After finding that Khalil was in New Jersey at the time his habeas petition was filed, the court concluded that jurisdiction was proper in New Jersey. Notably, the court asked the parties to submit briefings on whether it should issue an order under 28 U.S.C. § 1292(b), which allows district judges in civil actions to ask an appeals court to review an otherwise unappealable decision where the issue "involves a controlling question of law as to which there is substantial ground for difference of opinion." Under § 1292(b), the court of appeals then decides whether it will permit an appeal.

The respondents filed a letter the next day stating that they believed an interlocutory appeal was appropriate in this case. The same day, the respondents also filed their opposition to Khalil's amended PI motion, once again arguing that the court lacked jurisdiction and separately arguing that Khalil was unlikely to succeed on his claims.

Khalil filed a letter opposing certification of an interlocutory appeal on April 3. He also filed an amended complaint on the same day, adding as a respondent the warden at the ICE facility in New Jersey where he was being held at the time his petition was filed.

Interlocutory Appeal to the Third Circuit

On April 4, Judge Farbiarz certified an interlocutory appeal to the Court of Appeals for the Third Circuit, finding that the three prongs of 28 U.S.C. § 1292(b)-a controlling question of law, a substantial ground for difference of opinion, and a material advancement of the ultimate termination of the litigation-were met in this case. However, the court indicated that proceedings in the district court would not be stayed while the appeal went forward.

Ongoing Proceedings in the District of New Jersey

Khalil filed a letter on April 4, 2025, requesting a hearing on his pending motions for release pending adjudication and/or to compel his return to New Jersey, as his wife was due to give birth imminently.

On April 11, a Louisiana immigration judge in a separate proceeding ruled that Khalil could be removed from the United States. The judge held that Khalil was deportable under 8 U.S.C 1227 (a)(4)(C)(i) and the requirements for deportation had been met by the government.

Despite the immigration judge's ruling, the New Jersey District Court held that it could retain jurisdiction over the case on April 29, 2025. The government argued that there were "two jurisdiction stripping" statutes that would nullify the district court's jurisdiction over the habeas petition: Section 1252(b)(9) and Section 1252 (g). The court found both arguments unpersuasive. Judge Farbiarz explained that 1252(b)(9) only applies when a final order of removal has been entered and that the criteria for 1252(g) had not been met in this situation. Thus, the court retains jurisdiction under the habeas corpus statute. A few days later, on May 1, 2025, the court denied the request for certification of an interlocutory appeal. 

Khalil's wife went into labor eight days earlier than expected on April 20, 2025. Khalil then moved for urgent bail release. This motion was terminated later that day. 

On May 1, 2025, Khalil filed a third amended complaint in the District Court of New Jersey. The amended complaint argued that venue is proper in New Jersey and included claims that the government engaged in further retaliatory actions after the commencement of the lawsuit.

In response, the government filed a motion to dismiss for lack of subject matter jurisdiction and improper venue on May 5, 2025. First, the government argued the court does not have authority to hear the challenge to removability pursuant to 8 U.S.C. §§ 1252(g), (b)(9). Secondly, the government argued that venue is improper because the Supreme Court has reiterated that for habeas petitions, jurisdiction lies in the district of confinement. Since Khalil is confined in Louisiana, venue would be proper in Louisiana. Further, according to traditional venue considerations, the government argued that venue in Louisiana is proper because the events giving rise to the petition are related to Khalil's detention in Louisiana. The court denied the motion to dismiss for want of venue on May 9, 2025 finding the government did not persuasively explain why the venue considerations would favor dismissal. The court also held that the jurisdictional claims were already addressed by the court and reaffirmed in a recent ruling by the Second Circuit. See Ozturk v. Hyde.

  
On May 14, Khalil asked the court for a preliminary injunction to stop federal officials from removing him from the United States. On May 28, the court found that although Khalil might succeed on the merits of his vagueness requirement, he had not addressed the other legal requirements for a preliminary injunction. The court also rejected Khalil’s second argument — that his removal was based on an unconstitutional federal policy — because it wasn’t fully explained. The court provisionally declined to grant a preliminary injunction, but allowed further briefing responsive to its concerns.

Khalil accordingly submitted a two-page addendum to his preliminary injunction motion on June 4. In it, he described the irreparable harms he was suffering due to his detention, including emotional, economic, and reputational damage. He also argued that his detention was unjustified because the government hadn’t shown he was a flight risk or a danger to the public.

On June 11, the court granted the preliminary injunction. It agreed that Khalil was suffering serious harm — such as missing the birth of his child, damage to his free speech rights, and loss of income and reputation. The court believed that Khalil’s detention was likely due to the Secretary of State’s determination, not the immigration charges that were filed afterward. Since lawful permanent residents are rarely detained during removal proceedings, and because of the chilling effect on  free speech, the court found that granting the injunction served the public interest.

On June 13, Khalil asked the court to order his release. The government responded that the injunction only blocked removal based on the Secretary of State’s determination, not on other grounds — specifically, the charges related to Khalil’s permanent residency application. The government pointed out that while the court had said it was “unlikely” Khalil would be detained for those charges, it hadn’t ruled that such detention would be illegal.

That same day, the court denied Khalil’s request for release. Judge Farbiarz referred back to the May 28 opinion and said Khalil still hadn’t shown why it would be unlawful for the government to detain him based on the second set of charges. The court suggested that Khalil ask the immigration judge handling his case for bail.

In response, on June 18, Khalil moved for release pursuant to his pending motion for bail, or in alternative, his return to New Jersey. Khalil argued that the release would not circumvent immigration proceedings. He pointed to other recent cases where petitioners in habeas cases were released on bond despite being ineligible for immigration bond. Khalil also argued that his release would be necessary to ensure an effective habeas remedy considering the extraordinary nature of the circumstances of his detention.

Two days later, June 20, 2025, Judge Farbriaz granted the motion for release on bail, and denied the government's request for a stay of the release. The court ordered that Khalil be released from immigration custody that day pursuant pursuant to bail conditions to be set by a magistrate judge. Judge Farbriaz ordered that the bail conditions must not include electronic monitoring nor that a bond be immediately posted, holding that the evidentiary record did not demonstrate any necessity for such measures. 

The magistrate judge conditions were set that same day, requiring Khalil to surrender his passport(s) and any travel documents to ICE, and restricting his movements to New York and Michigan generally; New Jersey and Louisiana for court appearances and attorney visits only, and Washington D.C. for lobbying/legislative purposes only. Khalil was accordingly released. The government immediately appealed and moved for a stay pending appeal. The motion to stay pending appeal was denied with the court finding that the government did not demonstrate irreparable harm caused by Khalil's release.

On June 25, 2025, the petitioner alleged that ICE officials handed him an "Order of Release on Recognizance," which included a requirement that Mr. Khalil regularly report in writing or in person to an ICE duty officer. The government responded that requiring Khalil to report is not contrary to the Court's order and is consistent with ICE's regular release practices.

Clarification on June 11 Preliminary Injunction

In addition, the petitioner contended that the court's preliminary order enjoining the Respondents from "seeking to remove the petitioner from the United States based on the Secretary of State's determination" enjoined the government from litigating removability charges. The petitioner alleged that "seeking" encompassed any DHS pursuit of removal based on the aforementioned charges. The government declined to give a substantive response to the scope of the preliminary injunction. The judge ordered briefing on the issue from both parties.

On July 17, the court clarified three ways the meaning of its June 11 preliminary injunction:

  1. The court agreed that the government must promptly vacate or amend the immigration judge's decision to the extent it found the petitioner removable from the United States on the basis of the Secretary of State's determination.
  2. Since the immigration judge's assessment that the petitioner's ineligibility for asylum was not based on the Secretary of State's determination, it is not covered by the preliminary injunction.
  3. Not meaningfully ruling on the petitioner's waiver of removability in the immigration court amounts to "seeking to remove the petitioner from the United States based on the Secretary of State's determination."

The government immediately moved to stay these alterations to the June 11 preliminary injunction pending an appeal. This motion was denied in part and granted in part. The order was "stayed only insofar as it requires Appellants to cause the Immigration Judge to cause the Immigration Judge to consider the appellee's request for waiver of removability."

Second Motion for a Preliminary Injunction

On July 9, the petitioner moved for a new preliminary injunction enjoining the respondents from seeking to remove Khalil based on the additional charges of inadmissibility ("post-hoc charges"). The court ordered the Khalil explain why he should get "two-bites at the apple." Khalil claimed that parties are routinely permitted to seek further preliminary relief on factual and legal bases not yet raised or where further developments warrant it. He alleged that the government's decision to detain him solely on the post-hoc charges accorded after the ruling on the first motion. Khalil stated the court should entertain the motion on its merits due to the ongoing irreparable harm he is experiencing.

This motion was denied on August 8, 2025. The court refused to "exercise its discretion to allow what would mainly be a second bite at the apple." Judge Farbriaz found the new motion to be essentially the old motion in "new packaging." On balance, only old facts appeared to be at the core of the new motion.

The case is ongoing. 

Summary Authors

Meredith Ulle (3/15/2025)

Jinan Abufarha (6/21/2025)

People

For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/69757814/parties/khalil-v-joyce/


Judge(s)
Attorney for Plaintiff
Attorney for Defendant
Expert/Monitor/Master/Other

AHMAD, NAZ (New Jersey)

ANELLO, FARRIN R. (New Jersey)

AZMY, BAHER (New Jersey)

BARRON, KYLE (New Jersey)

Belsher, Amy (New York)

Attorney for Defendant

show all people

Documents in the Clearinghouse

Document
2

1:25-cv-01935

Petition for Writ of Habeas Corpus

M.K. v. Joyce

U.S. District Court for the Southern District of New York

March 9, 2025

March 9, 2025

Complaint

Notice to Appear

Matter of Mahmoud Khalil

No Court

March 9, 2025

March 9, 2025

Complaint
11

1:25-cv-01935

Memorandum of Law in Support of Petitioner's Motion to Compel Respondents to Return Petitioner to this District

Khalil v. Joyce

U.S. District Court for the Southern District of New York

March 10, 2025

March 10, 2025

Pleading / Motion / Brief
9

1:25-cv-01935

Notice of Conference

M.K. v. Joyce

U.S. District Court for the Southern District of New York

March 10, 2025

March 10, 2025

Order/Opinion

2025 WL 750599

24

1:25-cv-01935

Letter re. schedule

Khalil v. Joyce

U.S. District Court for the Southern District of New York

March 11, 2025

March 11, 2025

Pleading / Motion / Brief
30

1:25-cv-01935

Notice of Motion

Khalil v. Joyce

U.S. District Court for the Southern District of New York

March 12, 2025

March 12, 2025

Pleading / Motion / Brief
31

1:25-cv-01935

Respondent's Memorandum of Law in Support of their Motion to Dismiss or to Transfer the Case

Khalil v. Joyce

U.S. District Court for the Southern District of New York

March 12, 2025

March 12, 2025

Pleading / Motion / Brief
29

1:25-cv-01935

Order

Khalil v. Joyce

U.S. District Court for the Southern District of New York

March 12, 2025

March 12, 2025

Order/Opinion
31

1:25-cv-01935

Respondents' Memorandum of Law in Support of their Motion to Dismiss or Transfer the Case

U.S. District Court for the Southern District of New York

March 12, 2025

March 12, 2025

Pleading / Motion / Brief
38

1:25-cv-01935

Amended Petition for Writ of Habeas Corpus and Complaint

U.S. District Court for the Southern District of New York

March 13, 2025

March 13, 2025

Complaint

Docket

See docket on RECAP: https://www.courtlistener.com/docket/69757814/khalil-v-joyce/

Last updated Aug. 26, 2025, 2:30 a.m.

ECF Number Description Date Link Date / Link
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NOTICE OF APPEARANCE by Kyle Barron on behalf of M.K...(Barron, Kyle) (Entered: 03/09/2025)

March 9, 2025

March 9, 2025

RECAP
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PETITION FOR WRIT OF HABEAS CORPUS pursuant to 28 U.S.C. 2241. (Filing Fee $ 5.00, Receipt Number ANYSDC-30735794)Document filed by M.K...(Greer, Amy) (Entered: 03/09/2025)

March 9, 2025

March 9, 2025

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CIVIL COVER SHEET filed..(Greer, Amy) (Entered: 03/09/2025)

March 9, 2025

March 9, 2025

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NOTICE OF APPEARANCE by Jeffrey Stuart Oestericher on behalf of William P. Joyce, Caleb Vitello, Kristi Noem, Pamela Bondi..(Oestericher, Jeffrey) (Entered: 03/10/2025)

March 10, 2025

March 10, 2025

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MOTION to Compel Respondents to Return Petitioner to this District . Document filed by M.K.. (Attachments: # 1 Exhibit Declaration of Amy Greer, Esq.).(Kassem, Ramzi) Modified on 3/24/2025 (mxw, ). (Entered: 03/10/2025)

1 Exhibit Declaration of Amy Greer, Esq.

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March 10, 2025

March 10, 2025

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NOTICE OF APPEARANCE by Brandon Matthew Waterman on behalf of William P. Joyce, Caleb Vitello, Kristi Noem, Pamela Bondi..(Waterman, Brandon) (Entered: 03/10/2025)

March 10, 2025

March 10, 2025

RECAP
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CERTIFICATE OF SERVICE of Summons and Petition for Writ of Habeas Corpus. Pamela Bondi served on 3/10/2025, answer due 3/31/2025; William P. Joyce served on 3/10/2025, answer due 3/31/2025; Kristi Noem served on 3/10/2025, answer due 3/31/2025; Caleb Vitello served on 3/10/2025, answer due 3/31/2025. Service was made by Email. Document filed by M.K...(Azmy, Baher) (Entered: 03/10/2025)

March 10, 2025

March 10, 2025

RECAP
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NOTICE OF APPEARANCE by Baher Azmy on behalf of M.K...(Azmy, Baher) (Entered: 03/10/2025)

March 10, 2025

March 10, 2025

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NOTICE OF APPEARANCE by Samah Mcgona Sisay on behalf of M.K...(Sisay, Samah) (Entered: 03/10/2025)

March 10, 2025

March 10, 2025

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NOTICE OF APPEARANCE by Diala Shamas on behalf of M.K...(Shamas, Diala) (Entered: 03/10/2025)

March 10, 2025

March 10, 2025

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NOTICE OF APPEARANCE OF PRO BONO COUNSEL by Ramzi Kassem on behalf of M.K..(Kassem, Ramzi) (Entered: 03/10/2025)

March 10, 2025

March 10, 2025

RECAP
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NOTICE OF APPEARANCE OF PRO BONO COUNSEL by Shezza Abboushi Dallal on behalf of M.K..(Abboushi Dallal, Shezza) (Entered: 03/10/2025)

March 10, 2025

March 10, 2025

RECAP
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NOTICE OF CONFERENCE, It is hereby ORDERED that counsel for all parties appear for a conference with the Court on March 12, 2025 at 11:30 a.m. in Courtroom 1105 of the Thurgood Marshall Courthouse, 40 Centre Street, New York, New York. Counsel must confer in advance of the conference and submit a joint letter, no later than March 11, 2025, at 5:00 p.m., indicating whether the conference is necessary and addressing how the Court should handle the present Petition. If counsel do not believe a conference is required, and that briefing is appropriate, counsel should propose a briefing schedule (expedited or otherwise) in the joint letter. No later than today, March 10, 2025, Petitioner's counsel is directed (1) to serve Respondents with a copy of the petition and accompanying papers, along with a copy of this Order, by e-mail to the United States Attorney's Office for the Southern District of New York and by overnight mail, and (2) to promptly file proof of such service on the docket. Counsel for Respondents shall promptly enter notices of appearance. SO ORDERED. ( Status Conference set for 3/12/2025 at 11:30 AM in Courtroom 1105, 40 Centre Street, New York, NY 10007 before Judge Jesse M. Furman.) (Signed by Judge Jesse M. Furman on 3/10/25) (yv) (Entered: 03/10/2025)

March 10, 2025

March 10, 2025

RECAP

***NOTICE TO ATTORNEY REGARDING PARTY MODIFICATION. Notice to attorney Kyle Barron. The party information for the following party/parties has been modified: all defendants. The information for the party/parties has been modified for the following reason/reasons: party text was omitted. (gp)

March 10, 2025

March 10, 2025

PACER

CASE OPENING INITIAL ASSIGNMENT NOTICE: The above-entitled action is assigned to Judge Jesse M. Furman. Please download and review the Individual Practices of the assigned District Judge, located at https://nysd.uscourts.gov/judges/district-judges. Attorneys are responsible for providing courtesy copies to judges where their Individual Practices require such. Please download and review the ECF Rules and Instructions, located at https://nysd.uscourts.gov/rules/ecf-related-instructions..(gp)

March 10, 2025

March 10, 2025

PACER

Magistrate Judge Sarah Netburn is designated to handle matters that may be referred in this case. Pursuant to 28 U.S.C. Section 636(c) and Fed. R. Civ. P. 73(b)(1) parties are notified that they may consent to proceed before a United States Magistrate Judge. Parties who wish to consent may access the necessary form at the following link: https://nysd.uscourts.gov/sites/default/files/2018-06/AO-3.pdf. (gp)

March 10, 2025

March 10, 2025

PACER

Case Designated ECF. (gp)

March 10, 2025

March 10, 2025

PACER

Case Designated ECF. (gp)

March 10, 2025

March 10, 2025

PACER
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AFFIDAVIT OF SERVICE of petition and accompanying papers served on United States Attorney's Office for the Southern District of New York on 3/11/2025. Service was accepted by Gary Dowling. Document filed by M.K.. (Attachments: # 1 Exhibit Stamped copy of cover lever).(Sisay, Samah) (Entered: 03/11/2025)

1 Exhibit Stamped copy of cover lever

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March 11, 2025

March 11, 2025

RECAP
15

NOTICE OF APPEARANCE by Robert Andrew Hodgson on behalf of M.K...(Hodgson, Robert) (Entered: 03/11/2025)

March 11, 2025

March 11, 2025

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NOTICE OF APPEARANCE by Molly Knopp Biklen on behalf of M.K...(Biklen, Molly) (Entered: 03/11/2025)

March 11, 2025

March 11, 2025

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NOTICE OF APPEARANCE by Amy Belsher on behalf of M.K...(Belsher, Amy) (Entered: 03/11/2025)

March 11, 2025

March 11, 2025

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NOTICE OF APPEARANCE by Veronica Salama on behalf of M.K...(Salama, Veronica) (Entered: 03/11/2025)

March 11, 2025

March 11, 2025

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NOTICE OF APPEARANCE by Esha Bhandari on behalf of M.K...(Bhandari, Esha) (Entered: 03/11/2025)

March 11, 2025

March 11, 2025

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NOTICE OF APPEARANCE by Vera Eidelman on behalf of M.K...(Eidelman, Vera) (Entered: 03/11/2025)

March 11, 2025

March 11, 2025

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NOTICE OF APPEARANCE by Brett Max Kaufman on behalf of M.K...(Kaufman, Brett) (Entered: 03/11/2025)

March 11, 2025

March 11, 2025

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NOTICE OF APPEARANCE by Noor Zafar on behalf of M.K...(Zafar, Noor) (Entered: 03/11/2025)

March 11, 2025

March 11, 2025

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NOTICE OF APPEARANCE by Omar C. Jadwat on behalf of M.K...(Jadwat, Omar) (Entered: 03/11/2025)

March 11, 2025

March 11, 2025

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LETTER addressed to Judge Jesse M. Furman from Baher Azmy dated 3/11/25 re: Joint Letter. Document filed by M.K., William P. Joyce, Caleb Vitello, Kristi Noem, Pamela Bondi..(Azmy, Baher) (Entered: 03/11/2025)

March 11, 2025

March 11, 2025

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NOTICE OF APPEARANCE by Brian Matthew Hauss on behalf of M.K...(Hauss, Brian) (Entered: 03/11/2025)

March 11, 2025

March 11, 2025

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NOTICE: The conference scheduled for March 12, 2025, at 11:30 a.m. will be held in Courtroom 110 (NOT Judge Furman's usual courtroom.) -- Alexandra Smallman, Courtroom Deputy to the Hon. Jesse M. Furman.

March 11, 2025

March 11, 2025

PACER
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NOTICE OF APPEARANCE by Joshua Lewis Dratel on behalf of M.K...(Dratel, Joshua) (Entered: 03/12/2025)

March 12, 2025

March 12, 2025

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NOTICE OF APPEARANCE by Lindsay Anne Lewis on behalf of M.K...(Lewis, Lindsay) (Entered: 03/12/2025)

March 12, 2025

March 12, 2025

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LETTER addressed to Judge Jesse M. Furman from Robert J. Tolchin, Esq. dated 3-12-25 re: seeking review of public access restrictions for documents filed in this proceeding. Document filed by Shurat HaDin - Israel Law Center..(Tolchin, Robert) (Entered: 03/12/2025)

March 12, 2025

March 12, 2025

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ORDER As stated on the record during the conference held earlier today: With the consent of both parties, the Court orders that the limitations on remote access to electronic files otherwise applicable in this case, see Fed. R. Civ. P. 5.2(c), are lifted. Accordingly, the Clerk of Court is directed to lift all viewing restrictions on the docket - i.e., to make all prior filings electronically available to the public - and to update the docket to conform with the caption of this Order. All future filings shall be publicly available unless the Court grants leave to file something under seal or in redacted form. Any application to file a document in such a manner shall be made in accordance with the Court's Individual Rules and Practices for Civil Cases, available at https://nysd.uscourts.gov/hon-jesse-m-furman. The Government shall file its Motion to Transfer or Dismiss for Improper Venue by 11:59 p.m. tonight. Briefing on that motion and Petitioner's Motion to Compel Respondents to Return Petitioner to this District, see ECF No. 11, shall then proceed as follows: The parties shall file their oppositions by March 14, 2025, at 11:59 p.m.; and the parties shall file their replies by March 17, 2025, at 5:00 p.m. Petitioner shall file an Amended Petition no later than March 13, 2025, at 9:00 p.m. After the Amended Petition is filed, the parties shall confer and then file a joint letter, no later than March 14, 2025, at 12:00 p.m., proposing next steps, including an expedited schedule for any additional motion practice. With the consent of the Government, Petitioner shall be granted at least one privileged attorney-client call (of at least one hour) today and at least one such call (also of at least one hour) tomorrow. The Government raised no objection to the temporary relief that the Court granted in its Notice of Conference entered on March 10, 2025. See ECF No. 9, at 1 ("To preserve the Courts jurisdiction pending a ruling on the petition, Petitioner shall not be removed from the United States unless and until the Court orders otherwise." (citing cases)). Accordingly, that order remains in effect. SO ORDERED. (Amended Pleadings due by 3/13/2025., Motions due by 3/12/2025., Replies due by 3/17/2025., Responses due by 3/14/2025) (Signed by Judge Jesse M. Furman on 3/12/2025) (jca) (Entered: 03/12/2025)

March 12, 2025

March 12, 2025

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30

MOTION to Dismiss or Transfer. Document filed by William P. Joyce, Caleb Vitello, Kristi Noem, Pamela Bondi..(Waterman, Brandon) (Entered: 03/12/2025)

March 12, 2025

March 12, 2025

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31

MEMORANDUM OF LAW in Support re: 30 MOTION to Dismiss or Transfer. . Document filed by William P. Joyce, Caleb Vitello, Kristi Noem, Pamela Bondi. (Attachments: # 1 Exhibit Transcript from Suraiya v. Cioppa).(Waterman, Brandon) (Entered: 03/12/2025)

1 Exhibit Transcript from Suraiya v. Cioppa

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March 12, 2025

March 12, 2025

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32

DECLARATION of Acting Field Office Director William P. Joyce in Support re: 30 MOTION to Dismiss or Transfer.. Document filed by William P. Joyce, Caleb Vitello, Kristi Noem, Pamela Bondi..(Waterman, Brandon) (Entered: 03/12/2025)

March 12, 2025

March 12, 2025

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Minute Entry for proceedings held before Judge Jesse M. Furman: Conference held on 3/12/2025. Court reporter present. (ab)

March 12, 2025

March 12, 2025

PACER
33

MOTION for Kyle Barron to Withdraw as Attorney . Document filed by Mahmoud Khalil. (Attachments: # 1 Proposed Order Granting Motion to Withdraw as Counsel).(Barron, Kyle) (Entered: 03/13/2025)

1 Proposed Order Granting Motion to Withdraw as Counsel

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March 13, 2025

March 13, 2025

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34

ORDER GRANTING MOTION TO WITHDRAW AS COUNSEL FOR PETITIONER granting 33 MOTION for Kyle Barron to Withdraw as Attorney. IT IS HEREBY ORDERED that Kyle Barron is withdrawn as counsel for Petitioner and shall be removed from the Case Management/Electronic Case Files (CM/ECF) notification in the above-captioned proceeding. The Clerk of Court is directed to terminate ECF No. 33. SO ORDERED. Attorney Kyle Barron terminated (Signed by Judge Jesse M. Furman on 3/13/2025) (jca) (Entered: 03/13/2025)

March 13, 2025

March 13, 2025

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35

ORDER By Order entered yesterday, the Court directed the Clerk of Court to lift the restrictions otherwise applicable under Rule 5.2(c) of the Federal Rules of Civil Procedure. See ECF No. 29. The Court has been advised by the Clerk of Court that the only (or easiest) way to accomplish that for filings going forward is to change the nature of suit code. Accordingly, the Clerk of Court is directed to change the nature of suit code to No. 530, "Habeas Corpus," thereby lifting the limitations on remote electronic access to the docket imposed by Rule 5.2(c). SO ORDERED. (Signed by Judge Jesse M. Furman on 3/13/2025) (jca) (Entered: 03/13/2025)

March 13, 2025

March 13, 2025

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36

DECLARATION of Acting Field Office Director William P. Joyce (SUPPLEMENTAL) in Support re: 30 MOTION to Dismiss or Transfer.. Document filed by William P. Joyce, Caleb Vitello, Kristi Noem, Pamela Bondi..(Waterman, Brandon) (Entered: 03/13/2025)

March 13, 2025

March 13, 2025

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37

LETTER addressed to Judge Jesse M. Furman from Brandon M. Waterman dated March 13, 2025 re: Supplemental Declaration of William P. Joyce. Document filed by William P. Joyce, Caleb Vitello, Kristi Noem, Pamela Bondi..(Waterman, Brandon) (Entered: 03/13/2025)

March 13, 2025

March 13, 2025

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38

FIRST AMENDED COMPLAINT against Pamela Bondi, William P. Joyce, Kristi Noem, Shurat HaDin - Israel Law Center, Caleb Vitello, Donald J. Trump, Marco Rubio.Document filed by Mahmoud Khalil..(Belsher, Amy) (Entered: 03/13/2025)

March 13, 2025

March 13, 2025

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39

LETTER addressed to Judge Jesse M. Furman from Robert Hodgson dated March 13, 2025 re: Redline pursuant to Individual Rule 1B. Document filed by Mahmoud Khalil. (Attachments: # 1 Exhibit Redline (Amended and Original Petitions) pursuant to Individual Rule 1B).(Hodgson, Robert) (Entered: 03/13/2025)

1 Exhibit Redline (Amended and Original Petitions) pursuant to Individual Rule 1B

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March 13, 2025

March 13, 2025

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40

JOINT LETTER addressed to Judge Jesse M. Furman from AUSA Jeffrey Oestericher dated 03/14/2025 re: Parties' competing proposed briefing schedules. Document filed by Donald J. Trump, Marco Rubio, William P. Joyce, Caleb Vitello, Kristi Noem, Pamela Bondi..(Oestericher, Jeffrey) (Entered: 03/14/2025)

March 14, 2025

March 14, 2025

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41

REQUEST FOR ISSUANCE OF SUMMONS as to Donald J. Trump, re: 38 Amended Complaint. Document filed by Mahmoud Khalil..(Biklen, Molly) (Entered: 03/14/2025)

March 14, 2025

March 14, 2025

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42

REQUEST FOR ISSUANCE OF SUMMONS as to Marco Rubio, re: 38 Amended Complaint. Document filed by Mahmoud Khalil..(Biklen, Molly) (Entered: 03/14/2025)

March 14, 2025

March 14, 2025

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43

MEMO ENDORSEMENT on 40 Letter re Parties' competing proposed briefing schedules: The Court hereby adopts Petitioner's proposed briefing schedule for the motion for a preliminary injunction. Petitioner shall file his motion for bail by tonight at 11:59 p.m. Respondents shall file any opposition to that motion by 11:59 p.m. one business day after the Court rules on Respondents' Motion to Dismiss or Transfer or by 11:59 p.m. on Wednesday, March 19, 2025, whichever is sooner. Petitioner shall file any reply by 11:59 p.m. one business day after Respondents file their opposition. SO ORDERED. (Signed by Judge Jesse M. Furman on 3/14/2025) (ab) (Entered: 03/14/2025)

March 14, 2025

March 14, 2025

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44

TRANSCRIPT of Proceedings re: CONFERENCE held on 3/12/2025 before Judge Jesse M. Furman. Court Reporter/Transcriber: Amy Walker, (212) 805-0300. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 4/4/2025. Redacted Transcript Deadline set for 4/14/2025. Release of Transcript Restriction set for 6/12/2025..(McGuirk, Kelly) (Entered: 03/14/2025)

March 14, 2025

March 14, 2025

PACER
45

NOTICE OF FILING OF OFFICIAL TRANSCRIPT Notice is hereby given that an official transcript of a CONFERENCE proceeding held on 3/12/2025 has been filed by the court reporter/transcriber in the above-captioned matter. The parties have seven (7) calendar days to file with the court a Notice of Intent to Request Redaction of this transcript. If no such Notice is filed, the transcript may be made remotely electronically available to the public without redaction after 90 calendar days....(McGuirk, Kelly) (Entered: 03/14/2025)

March 14, 2025

March 14, 2025

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46

NOTICE OF APPEARANCE OF PRO BONO COUNSEL by Alina Das on behalf of Mahmoud Khalil.(Das, Alina) (Entered: 03/14/2025)

March 14, 2025

March 14, 2025

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47

MEMORANDUM OF LAW in Opposition re: 11 MOTION to Compel Respondents to Return Petitioner to this District . . Document filed by William P. Joyce, Caleb Vitello, Kristi Noem, Pamela Bondi..(Waterman, Brandon) (Entered: 03/14/2025)

March 14, 2025

March 14, 2025

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48

DECLARATION of Acting Field Office Director, New York City Field Office, William P. Joyce in Opposition re: 11 MOTION to Compel Respondents to Return Petitioner to this District .. Document filed by William P. Joyce, Caleb Vitello, Kristi Noem, Pamela Bondi..(Waterman, Brandon) (Entered: 03/14/2025)

March 14, 2025

March 14, 2025

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49

DECLARATION of Field Office Director, New Orleans Field Office, Mellissa Harper in Opposition re: 11 MOTION to Compel Respondents to Return Petitioner to this District .. Document filed by William P. Joyce, Caleb Vitello, Kristi Noem, Pamela Bondi..(Waterman, Brandon) (Entered: 03/14/2025)

March 14, 2025

March 14, 2025

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50

MEMORANDUM OF LAW in Opposition re: 30 MOTION to Dismiss or Transfer. . Document filed by Mahmoud Khalil. (Attachments: # 1 Exhibit Declaration of Veronica R. Salama).(Kaufman, Brett) (Entered: 03/14/2025)

1 Exhibit Declaration of Veronica R. Salama

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March 14, 2025

March 14, 2025

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51

NOTICE OF APPEARANCE OF PRO BONO COUNSEL by Mudassar Hayat Toppa on behalf of Mahmoud Khalil.(Toppa, Mudassar) (Entered: 03/14/2025)

March 14, 2025

March 14, 2025

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52

NOTICE of of Motion. Document filed by Mahmoud Khalil. (Attachments: # 1 Proposed Order for release).(Sisay, Samah) Modified on 3/24/2025 (mxw, ). (Entered: 03/15/2025)

1 Proposed Order for release

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March 14, 2025

March 14, 2025

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53

MOTION for release . Document filed by Mahmoud Khalil..(Sisay, Samah) (Entered: 03/15/2025)

March 15, 2025

March 15, 2025

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54

LETTER MOTION to Seal addressed to Judge Jesse M. Furman from Alina Das dated March 14, 2025. Document filed by Mahmoud Khalil..(Sisay, Samah) (Entered: 03/15/2025)

March 15, 2025

March 15, 2025

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55

DECLARATION of Noor Ramez Abdalla in Support re: 53 MOTION for release .. Document filed by Mahmoud Khalil..(Sisay, Samah) (Entered: 03/15/2025)

March 15, 2025

March 15, 2025

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56

DECLARATION of Samah Sisay in Support re: 54 LETTER MOTION to Seal addressed to Judge Jesse M. Furman from Alina Das dated March 14, 2025.. Document filed by Mahmoud Khalil. (Attachments: # 1 Exhibit B, # 2 Exhibit C, # 3 Exhibit D, # 4 Exhibit E, # 5 Exhibit F, # 6 Exhibit G).(Sisay, Samah) (Entered: 03/15/2025)

1 Exhibit B

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2 Exhibit C

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3 Exhibit D

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4 Exhibit E

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5 Exhibit F

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6 Exhibit G

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March 15, 2025

March 15, 2025

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57

***SELECTED PARTIES***DECLARATION of Samah Sisay in Support re: 54 LETTER MOTION to Seal addressed to Judge Jesse M. Furman from Alina Das dated March 14, 2025.. Document filed by Mahmoud Khalil, Pamela Bondi, William P. Joyce, Kristi Noem, Marco Rubio, Donald J. Trump, Caleb Vitello. (Attachments: # 1 Exhibit B, # 2 Exhibit C, # 3 Exhibit D, # 4 Exhibit E, # 5 Exhibit F, # 6 Exhibit G)Motion or Order to File Under Seal: 54 .(Sisay, Samah) (Entered: 03/15/2025)

March 15, 2025

March 15, 2025

PACER
58

DECLARATION of Samah Sisay in Support re: 53 MOTION for release .. Document filed by Mahmoud Khalil. (Attachments: # 1 Exhibit H).(Sisay, Samah) (Entered: 03/15/2025)

1 Exhibit H

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March 15, 2025

March 15, 2025

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59

LETTER MOTION for Leave to File delayed filing of Petitioner's Motion for Release addressed to Judge Jesse M. Furman from Samah Sisay dated March 15, 2025. Document filed by Mahmoud Khalil. (Attachments: # 1 Exhibit A).(Sisay, Samah) (Entered: 03/15/2025)

1 Exhibit A

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March 15, 2025

March 15, 2025

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60

LETTER addressed to Judge Jesse M. Furman from Samah Sisay dated March 15, 2025 re: Respondents Consent to Petitioner's Motion For Leave to File. Document filed by Mahmoud Khalil..(Sisay, Samah) (Entered: 03/15/2025)

March 15, 2025

March 15, 2025

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61

ORDER temporarily granting 54 Letter Motion to Seal: The Court will assess whether to keep the materials at issue sealed or redacted when deciding the underlying motion. (HEREBY ORDERED by Judge Jesse M. Furman)(Text Only Order) (Furman, Jesse) (Entered: 03/15/2025)

March 15, 2025

March 15, 2025

PACER
62

ORDER granting 59 Letter Motion for Leave to File delayed filing of Petitioner's Motion for Release: The motion is granted on consent. See ECF No. 60 . (HEREBY ORDERED by Judge Jesse M. Furman)(Text Only Order) (Furman, Jesse) (Entered: 03/15/2025)

March 15, 2025

March 15, 2025

PACER
63

ORDER with respect to 30 Motion to Dismiss or Transfer: Per the attached Order, the parties are directed to address (in Respondents' forthcoming reply and in a supplemental submission by Petitioner) the import, if any, of certain statutes. SEE ORDER FOR DETAILS. (Signed by Judge Jesse M. Furman on 3/16/25) (Furman, Jesse) (Entered: 03/16/2025)

March 16, 2025

March 16, 2025

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64

ELECTRONIC SUMMONS ISSUED as to Marco Rubio..(pc) (Entered: 03/17/2025)

March 17, 2025

March 17, 2025

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65

ELECTRONIC SUMMONS ISSUED as to Donald J. Trump..(pc) (Entered: 03/17/2025)

March 17, 2025

March 17, 2025

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66

MOTION for Preliminary Injunction . Document filed by Mahmoud Khalil..(Hodgson, Robert) Modified on 3/24/2025 (mxw, ). (Entered: 03/17/2025)

March 17, 2025

March 17, 2025

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67

MEMORANDUM OF LAW in Support re: 66 MOTION for Preliminary Injunction . . Document filed by Mahmoud Khalil..(Hodgson, Robert) (Entered: 03/17/2025)

March 17, 2025

March 17, 2025

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68

DECLARATION of Veronica Salama in Support re: 66 MOTION for Preliminary Injunction .. Document filed by Mahmoud Khalil. (Attachments: # 1 Exhibit Exhibit A, # 2 Exhibit Exhibit B, # 3 Exhibit Exhibit C, # 4 Exhibit Exhibit D).(Hodgson, Robert) (Entered: 03/17/2025)

1 Exhibit Exhibit A

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2 Exhibit Exhibit B

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3 Exhibit Exhibit C

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4 Exhibit Exhibit D

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March 17, 2025

March 17, 2025

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69

PROPOSED ORDER. Document filed by Mahmoud Khalil. Related Document Number: 66 ..(Hodgson, Robert) Proposed Order to be reviewed by Clerk's Office staff. (Entered: 03/17/2025)

March 17, 2025

March 17, 2025

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70

SUPPLEMENTAL MEMORANDUM OF LAW in Opposition re: 30 MOTION to Dismiss or Transfer. In Response to Court's March 16 Order. Document filed by Mahmoud Khalil..(Kaufman, Brett) (Entered: 03/17/2025)

March 17, 2025

March 17, 2025

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71

REPLY MEMORANDUM OF LAW in Support re: 30 MOTION to Dismiss or Transfer. . Document filed by Pamela Bondi, William P. Joyce, Kristi Noem, Marco Rubio, Donald J. Trump, Caleb Vitello..(Waterman, Brandon) (Entered: 03/17/2025)

March 17, 2025

March 17, 2025

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72

DECLARATION of Second Supplemental Declaration of Acting New York City Field Office Director William P. Joyce in Support re: 30 MOTION to Dismiss or Transfer.. Document filed by Pamela Bondi, William P. Joyce, Kristi Noem, Marco Rubio, Donald J. Trump, Caleb Vitello..(Waterman, Brandon) (Entered: 03/17/2025)

March 17, 2025

March 17, 2025

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73

REPLY MEMORANDUM OF LAW in Support re: 11 MOTION to Compel Respondents to Return Petitioner to this District . . Document filed by Mahmoud Khalil. (Attachments: # 1 Exhibit Declaration of Mahmoud Khalil, # 2 Exhibit Declaration of Katherine Kim, Esq., # 3 Exhibit Declaration of Laura Rodriguez, Esq.).(Kassem, Ramzi) (Entered: 03/17/2025)

1 Exhibit Declaration of Mahmoud Khalil

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2 Exhibit Declaration of Katherine Kim, Esq.

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3 Exhibit Declaration of Laura Rodriguez, Esq.

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March 17, 2025

March 17, 2025

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74

CONSENT LETTER MOTION for Leave to File Excess Pages addressed to Judge Jesse M. Furman from Brandon M. Waterman dated March 17, 2025. Document filed by Pamela Bondi, William P. Joyce, Kristi Noem, Marco Rubio, Donald J. Trump, Caleb Vitello..(Waterman, Brandon) (Entered: 03/17/2025)

March 17, 2025

March 17, 2025

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75

ORDER granting 74 CONSENT LETTER MOTION for Leave to File Excess Pages. (HEREBY ORDERED by Judge Jesse M. Furman)(Text Only Order) (Furman, Jesse) (Entered: 03/17/2025)

March 17, 2025

March 17, 2025

PACER

***NOTICE TO ATTORNEY REGARDING PARTY MODIFICATION. Notice to attorney Amy Belsher. The party information for the following party/parties has been modified: Donald J. Trump, Marco Rubio. The information for the party/parties has been modified for the following reason/reasons: party role was entered incorrectly;. (pc)

March 17, 2025

March 17, 2025

PACER

***NOTICE TO COURT REGARDING PROPOSED ORDER. Document No. 69 Proposed Order was reviewed and approved as to form. (nd)

March 17, 2025

March 17, 2025

PACER

***NOTICE TO COURT REGARDING PROPOSED ORDER. Document No. 69 Proposed Order was reviewed and approved as to form. (nd)

March 17, 2025

March 17, 2025

PACER
76

FILING ERROR - DEFICIENT DOCKET ENTRY - MOTION for Sidra Mahfooz to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-30786736. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Mahmoud Khalil. (Attachments: # 1 Affidavit Affidavit of Sidra Mahfooz, # 2 Supplement Certificate of Good Standing - Sidra Mahfooz, # 3 Proposed Order Proposed Order Granting Pro Hac Vice).(Mahfooz, Sidra) Modified on 3/19/2025 (bc). (Entered: 03/18/2025)

1 Affidavit Affidavit of Sidra Mahfooz

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2 Supplement Certificate of Good Standing - Sidra Mahfooz

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3 Proposed Order Proposed Order Granting Pro Hac Vice

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March 18, 2025

March 18, 2025

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77

FILING ERROR - DEFICIENT DOCKET ENTRY - MOTION for Tyler Takemoto to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-30787082. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Mahmoud Khalil. (Attachments: # 1 Affidavit Affidavit of Tyler Takemoto, # 2 Supplement Certificate of Good Standing - Tyler Takemoto, # 3 Proposed Order Proposed Order Granting Pro Hac Vice).(Takemoto, Tyler) Modified on 3/19/2025 (bc). (Entered: 03/18/2025)

1 Affidavit Affidavit of Tyler Takemoto

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2 Supplement Certificate of Good Standing - Tyler Takemoto

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3 Proposed Order Proposed Order Granting Pro Hac Vice

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March 18, 2025

March 18, 2025

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78

OPINION AND ORDER granting in part and denying in part 30 MOTION to Dismiss or Transfer: For the reasons explained in the Opinion, the Court DENIES the Government's motion to dismiss the Petition but GRANTS its motion to transfer, albeit to the District of New Jersey, not to the Western District of Louisiana. The Court's 9 March 10, 2025 Order barring the Government from removing Petitioner (to which the Government has never raised an objection and which the Government has not asked the Court to lift in the event of transfer) shall remain in effect unless and until the transferee court orders otherwise. The Clerk of Court is directed to transfer the case to the United States District Court for the District of New Jersey forthwith, without regard for Local Civil Rule 83.1, which provides that "the Clerk [of Court], unless otherwise ordered, shall upon the expiration of seven (7) days effectuate the transfer of the case to the transferee court." (Signed by Judge Jesse M. Furman on 3/19/2025) (tro) (Entered: 03/19/2025)

March 19, 2025

March 19, 2025

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79

Certified Copy of Transfer Order and docket received, Case transferred in from District of New York Southern; Case Number 1:25-cv-01935. Original file certified copy of transfer order and docket sheet received. (Entered: 03/19/2025)

March 19, 2025

March 19, 2025

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80

NOTICE of Appearance by NAZ AHMAD on behalf of Mahmoud Khalil (AHMAD, NAZ) (Entered: 03/19/2025)

March 19, 2025

March 19, 2025

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81

ORDER that the Petitioner shall not be removed from the United States unless and until the Court issues a contrary Order. Signed by Judge Michael E. Farbiarz on 3/19/2025. (mxw, ) (Entered: 03/19/2025)

March 19, 2025

March 19, 2025

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82

NOTICE of Appearance by DHRUMAN YOGESH SAMPAT on behalf of PAMELA BONDI, William P. Joyce, KRISTI NOEM, MARCO RUBIO, DONALD J. TRUMP, CALEB VITELLO (SAMPAT, DHRUMAN) (Entered: 03/19/2025)

March 19, 2025

March 19, 2025

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83

NOTICE of Appearance by JEANNE LOCICERO on behalf of Mahmoud Khalil (LOCICERO, JEANNE) (Entered: 03/19/2025)

March 19, 2025

March 19, 2025

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84

Letter from Respondents with a Joint Request to Vacate Current Briefing Schedule and Proposed Competing Briefing Schedules for Future Briefing. (SAMPAT, DHRUMAN) (Entered: 03/19/2025)

March 19, 2025

March 19, 2025

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Case Transferred Out - District Court Transfer

March 19, 2025

March 19, 2025

PACER

>>>NOTICE REGARDING DEFICIENT MOTION TO APPEAR PRO HAC VICE. Notice to RE-FILE Document No. 76 MOTION for Sidra Mahfooz to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-30786736. Motion and supporting papers to be reviewed by Clerk's Office staff... The filing is deficient for the following reason(s): Wrong Judges name on Proposed Order;. Re-file the motion as a Motion to Appear Pro Hac Vice - attach the correct signed PDF - select the correct named filer/filers - attach valid Certificates of Good Standing issued within the past 30 days - attach Proposed Order.. (bc)

March 19, 2025

March 19, 2025

PACER

>>>NOTICE REGARDING DEFICIENT MOTION TO APPEAR PRO HAC VICE. Notice to RE-FILE Document No. 77 MOTION for Tyler Takemoto to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-30787082. Motion and supporting papers to be reviewed by Clerk's Office staff... The filing is deficient for the following reason(s): Wrong Judges Name on proposed order;. Re-file the motion as a Motion to Appear Pro Hac Vice - attach the correct signed PDF - select the correct named filer/filers - attach valid Certificates of Good Standing issued within the past 30 days - attach Proposed Order.. (bc)

March 19, 2025

March 19, 2025

PACER

>>>NOTICE REGARDING DEFICIENT MOTION TO APPEAR PRO HAC VICE. Notice to RE-FILE Document No. 77 MOTION for Tyler Takemoto to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-30787082. Motion and supporting papers to be reviewed by Clerk's Office staff... The filing is deficient for the following reason(s): Wrong Judges Name on proposed order;. Re-file the motion as a Motion to Appear Pro Hac Vice - attach the correct signed PDF - select the correct named filer/filers - attach valid Certificates of Good Standing issued within the past 30 days - attach Proposed Order.. (bc)

March 19, 2025

March 19, 2025

PACER

CASE TRANSFERRED OUT ELECTRONICALLY from the U.S.D.C. Southern District of New York to the United States District Court - District of District of New Jersey. (tro)

March 19, 2025

March 19, 2025

PACER
85

SCHEDULING ORDER. Signed by Judge Michael E. Farbiarz on 3/20/2025. (ro, ) (Entered: 03/20/2025)

March 20, 2025

March 20, 2025

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Case Details

State / Territory: New Jersey

Case Type(s):

Speech and Religious Freedom

Immigration and/or the Border

Special Collection(s):

Trump Administration 2.0: Challenges to the Government

Key Dates

Filing Date: March 9, 2025

Case Ongoing: Yes

Plaintiffs

Plaintiff Description:

Plaintiff is a Columbia University student who was heavily involved in pro-Palestine demonstrations on Columbia's campus in late 2023 and early 2024. He is of Palestinian heritage and is a legal permanent resident of the United States.

Attorney Organizations:

Center for Constitutional Rights (CCR)

Legal Services/Legal Aid

ACLU Affiliates (any)

ACLU Immigrants' Rights Project

New York Civil Liberties Union (NYCLU)

Public Interest Lawyer: Yes

Filed Pro Se: No

Class Action Sought: No

Class Action Outcome: Not sought

Defendants

U.S. Department of Homeland Security (- United States (national) -), Federal

U.S. Department of Justice (- United States (national) -), Federal

President Donald J. Trump (- United States (national) -), Federal

U.S. Department of State (- United States (national) -), Federal

Defendant Type(s):

Law-enforcement

Jurisdiction-wide

Case Details

Causes of Action:

Administrative Procedure Act, 5 U.S.C. §§ 551 et seq.

Habeas Corpus, 28 U.S.C. §§ 2241-2253; 2254; 2255

All Writs Act, 28 U.S.C. § 1651

Constitutional Clause(s):

Due Process

Suspension Clause

Freedom of speech/association

Special Case Type(s):

Habeas

Available Documents:

Trial Court Docket

Complaint (any)

Outcome

Prevailing Party: None Yet / None

Nature of Relief:

None

Source of Relief:

None

Content of Injunction:

Preliminary relief denied

Issues

Immigration/Border:

Constitutional rights

Deportation - procedure