Case: American Federation of Government Employees AFL-CIO v. Noem

COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF against defendant(s) Kristi Noem, Adam Stahl, Transportation Security Administration, U.S. Department of Homeland Security (Receipt # AWAWDC-8880571) Attorney Robert H Lavitt added to party American Federation of Government Employees AFL-CIO(pty:pla), Attorney Robert H Lavitt added to party American Federation of Government Employees AFL-CIO TSA Local 1121(pty:pla), Attorney Robert H Lavitt added to party Communications Workers of America AFL-CIO(pty:pla), Attorney Robert H Lavitt added to party Association of Flight Attendants-CWA AFL-CIO (pty:pla) filed by Communications Workers of America AFL-CIO, American Federation of Government Employees AFL-CIO TSA Local 1121, American Federation of Government Employees AFL-CIO, Association of Flight Attendants-CWA AFL-CIO. (Attachments: # 1 Civil Cover Sheet, # 2 Summons, # 3 Summons, # 4 Summons, # 5 Summons, # 6 Summons, # 7 Summons)(Lavitt, Robert) (Entered: 03/13/2025)

1 Civil Cover Sheet

View on RECAP

2 Summons

View on RECAP

3 Summons

View on RECAP

4 Summons

View on RECAP

5 Summons

View on RECAP

6 Summons

View on RECAP

7 Summons

View on RECAP

CORPORATE DISCLOSURE STATEMENT indicating no Corporate Parents and/or Affiliates. Filed pursuant to Fed.R.Civ.P 7.1(a)(1). Filed by Association of Flight Attendants-CWA AFL-CIO. (Lavitt, Robert) (Entered: 03/14/2025)

Add and Terminate Judges

CORPORATE DISCLOSURE STATEMENT indicating no Corporate Parents and/or Affiliates. Filed pursuant to Fed.R.Civ.P 7.1(a)(1). Filed by American Federation of Government Employees AFL-CIO. (Lavitt, Robert) (Entered: 03/14/2025)

CORPORATE DISCLOSURE STATEMENT indicating no Corporate Parents and/or Affiliates. Filed pursuant to Fed.R.Civ.P 7.1(a)(1). Filed by American Federation of Government Employees AFL-CIO TSA Local 1121. (Lavitt, Robert) (Entered: 03/14/2025)

CORPORATE DISCLOSURE STATEMENT indicating no Corporate Parents and/or Affiliates. Filed pursuant to Fed.R.Civ.P 7.1(a)(1). Filed by Communications Workers of America AFL-CIO. (Lavitt, Robert) (Entered: 03/14/2025)

Judge Marsha J. Pechman added. (AVC)

Summons(es) Electronically Issued as to Teal Luthy Miller, Adam Stahl, Kristi Noem, Pam Bondi, Transportation Security Administration, and United States Department of Homeland Security. (Attachments: # 1 Summons, # 2 Summons, # 3 Summons, # 4 Summons, # 5 Summons)(AVC) (Entered: 03/14/2025)

APPLICATION OF ATTORNEY J. Alexander Rowell FOR LEAVE TO APPEAR PRO HAC VICE for All Plaintiffs (Fee Paid) Receipt No. AWAWDC-8889375 (Lavitt, Robert) (Entered: 03/19/2025)

Order on Application for Leave to Appear Pro Hac Vice

APPLICATION OF ATTORNEY Abigail V. Carter FOR LEAVE TO APPEAR PRO HAC VICE for All Plaintiffs (Fee Paid) Receipt No. AWAWDC-8889398 (Lavitt, Robert) (Entered: 03/19/2025)

ORDER re 7 Application for Leave to Appear Pro Hac Vice, 8 Application for Leave to Appear Pro Hac Vice. The Court ADMITS Attorneys James Alexander Rowell and Abigail V Carter for Plaintiffs American Federation of Government Employees AFL-CIO, American Federation of Government Employees AFL-CIO TSA Local 1121, Association of Flight Attendants-CWA AFL-CIO, Communications Workers of America AFL-CIO, by Clerk Ravi Subramanian. No document associated with this docket entry, text only.NOTE TO COUNSEL: Local counsel agrees to sign all filings and to be prepared to handle the matter, including the trial thereof, in the event the applicant is unable to be present on any date scheduled by the court, pursuant to LCR 83.1(d).(AVC) (Entered: 03/19/2025)

APPLICATION OF ATTORNEY Rushab B. Sanghvi FOR LEAVE TO APPEAR PRO HAC VICE for Plaintiff American Federation of Government Employees AFL-CIO (Fee Paid) Receipt No. AWAWDC-8890960 (Lavitt, Robert) (Entered: 03/19/2025)

APPLICATION OF ATTORNEY Andres M. Grajales FOR LEAVE TO APPEAR PRO HAC VICE for Plaintiff American Federation of Government Employees AFL-CIO (Fee Paid) Receipt No. AWAWDC-8890981 (Lavitt, Robert) (Entered: 03/19/2025)

Notice to PHV and Local Counsel Unable to Process Application

Application for Leave to Appear Pro Hac Vice 10, Application for Leave to Appear Pro Hac Vice 11 by attorney Rushab B. Sanghvi and Andres M. Grajales will not be processed at this time. The Pro Hac attorney must submit a Pro Hac Vice access request via Manage My Account on PACER, under the Maintenance tab. See page 2 of the Pro Hac Vice Application Guide for detailed instructions. Please contact the Attorney Admissions Clerk at 206-370-8400 or WAWD_Admissions@wawd.uscourts.gov with additional questions. (Ad hoc Attorney Rushab B. Sanghvi and Andres M. Grajales) (HH)

ORDER re 11 Application for Leave to Appear Pro Hac Vice. The Court ADMITS Attorney Andres Myles Grajales for Plaintiff American Federation of Government Employees AFL-CIO, by Clerk Ravi Subramanian. No document associated with this docket entry, text only.NOTE TO COUNSEL: Local counsel agrees to sign all filings and to be prepared to handle the matter, including the trial thereof, in the event the applicant is unable to be present on any date scheduled by the court, pursuant to LCR 83.1(d).(HH) (Entered: 03/21/2025)

Order on Application for Leave to Appear Pro Hac Vice

ORDER re 10 Application for Leave to Appear Pro Hac Vice. The Court ADMITS Attorney Rushab Sanghvi for Plaintiff American Federation of Government Employees AFL-CIO, by Clerk Ravi Subramanian. No document associated with this docket entry, text only.NOTE TO COUNSEL: Local counsel agrees to sign all filings and to be prepared to handle the matter, including the trial thereof, in the event the applicant is unable to be present on any date scheduled by the court, pursuant to LCR 83.1(d).(HH) (Entered: 03/25/2025)

Order on Application for Leave to Appear Pro Hac Vice

APPLICATION OF ATTORNEY Pooja Chaudhuri FOR LEAVE TO APPEAR PRO HAC VICE for All Plaintiffs (Fee Paid) Receipt No. AWAWDC-8906249 (Lavitt, Robert) (Entered: 03/31/2025)

Notice to PHV and Local Counsel Unable to Process Application

Order on Application for Leave to Appear Pro Hac Vice

APPLICATION OF ATTORNEY Norman Eisen FOR LEAVE TO APPEAR PRO HAC VICE for All Plaintiffs (Fee Paid) Receipt No. AWAWDC-8906256 (Lavitt, Robert) (Entered: 03/31/2025)

ORDER re 15 Application for Leave to Appear Pro Hac Vice. The Court ADMITS Attorney Norman Larry Eisen for Plaintiffs American Federation of Government Employees AFL-CIO, American Federation of Government Employees AFL-CIO TSA Local 1121, Association of Flight Attendants-CWA AFL-CIO, and the Communications Workers of America AFL-CIO, by Clerk Ravi Subramanian. No document associated with this docket entry, text only.NOTE TO COUNSEL: Local counsel agrees to sign all filings and to be prepared to handle the matter, including the trial thereof, in the event the applicant is unable to be present on any date scheduled by the court, pursuant to LCR 83.1(d).(AVC) (Entered: 03/31/2025)

Application for Leave to Appear Pro Hac Vice 14 by attorney Pooja Chaudhuri will not be processed at this time. The Pro Hac attorney must submit a Pro Hac Vice access request via Manage My Account on PACER, under the Maintenance tab. See page 2 of the Pro Hac Vice Application Guide for detailed instructions. Please contact the Attorney Admissions Clerk at 206-370-8400 or WAWD_Admissions@wawd.uscourts.gov with additional questions. (Ad hoc Attorney Pooja Chaudhuri) (AVC)

ORDER re 14 Application for Leave to Appear Pro Hac Vice. The Court ADMITS Attorney Pooja Chaudhuri for Plaintiffs American Federation of Government Employees AFL-CIO, American Federation of Government Employees AFL-CIO TSA Local 1121, Association of Flight Attendants-CWA AFL-CIO, and the Communications Workers of America AFL-CIO, by Clerk Ravi Subramanian. No document associated with this docket entry, text only.NOTE TO COUNSEL: Local counsel agrees to sign all filings and to be prepared to handle the matter, including the trial thereof, in the event the applicant is unable to be present on any date scheduled by the court, pursuant to LCR 83.1(d).(AVC) (Entered: 04/01/2025)

Order on Application for Leave to Appear Pro Hac Vice

MOTION for Preliminary Injunction, filed by Plaintiffs' American Federation of Government Employees AFL-CIO and American Federation of Government Employees AFL-CIO TSA Local 1121 All Plaintiffs. Oral Argument Requested. (Attachments: # 1 Proposed Order) Noting Date 5/9/2025, (Lavitt, Robert) Modified to correct filing parties on 4/8/2025 (MJV). (Entered: 04/04/2025)

DECLARATION of Amelia Glymph filed by Plaintiffs American Federation of Government Employees AFL-CIO, American Federation of Government Employees AFL-CIO TSA Local 1121 re 18 MOTION for Preliminary Injunction (Attachments: # 1 Exhibit Exhibits 1-8)(Lavitt, Robert) (Entered: 04/04/2025)

DECLARATION of Scott Lewis filed by Plaintiffs American Federation of Government Employees AFL-CIO, American Federation of Government Employees AFL-CIO TSA Local 1121 re 18 MOTION for Preliminary Injunction (Lavitt, Robert) (Entered: 04/04/2025)

CERTIFICATE OF SERVICE by Plaintiffs American Federation of Government Employees AFL-CIO, American Federation of Government Employees AFL-CIO TSA Local 1121 re 18 MOTION for Preliminary Injunction, 20 Declaration, 19 Declaration, (Lavitt, Robert) (Entered: 04/07/2025)

CERTIFICATE OF SERVICE by All Plaintiffs re 6 Summons Issued, 1 Complaint,,, (Attachments: # 1 Exhibit A)(Lavitt, Robert) (Entered: 04/07/2025)

CERTIFICATE OF SERVICE by Plaintiffs American Federation of Government Employees AFL-CIO, American Federation of Government Employees AFL-CIO TSA Local 1121 re 21 Certificate of Service, 18 MOTION for Preliminary Injunction, 20 Declaration, 19 Declaration, (Lavitt, Robert) (Entered: 04/14/2025)