Case: RFE/RL, Inc. v. Lake

RFE/RL v. Lake

President Donald Trump

COMPLAINT against All Defendants ( Filing fee $ 405 receipt number ADCDC-11550893) filed by RFE/RL, INC.. (Attachments: # 1 Civil Cover Sheet, # 2 Summons, # 3 Summons, # 4 Summons, # 5 Summons, # 6 Summons)(Cheek, Marney) (Entered: 03/18/2025)

1 Civil Cover Sheet

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2 Summons

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3 Summons

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4 Summons

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5 Summons

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6 Summons

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NOTICE of Appearance by Marney Leigh Cheek on behalf of RFE/RL, INC. (Cheek, Marney) (Entered: 03/18/2025)

NOTICE of Appearance by David M. Zionts on behalf of RFE/RL, INC. (Zionts, David) (Entered: 03/18/2025)

NOTICE of Appearance by Thomas R. Brugato on behalf of RFE/RL, INC. (Brugato, Thomas) (Entered: 03/18/2025)

LCvR 26.1 CERTIFICATE OF DISCLOSURE of Corporate Affiliations and Financial Interests LCvR 26.1 Disclosure by RFE/RL, INC. (Cheek, Marney) (Entered: 03/18/2025)

MOTION for Temporary Restraining Order, MOTION for Preliminary Injunction by RFE/RL, INC.. (Attachments: # 1 Memorandum in Support, # 2 Addendum of Statutory Provisions, # 3 Exhibit A, # 4 Exhibit B, # 5 Text of Proposed Order (Temporary Restraining Order), # 6 Text of Proposed Order (Preliminary Injunction))(Cheek, Marney) (Entered: 03/19/2025)

1 Memorandum in Support

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2 Addendum of Statutory Provisions

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3 Exhibit A

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4 Exhibit B

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5 Text of Proposed Order (Temporary Restraining Order)

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6 Text of Proposed Order (Preliminary Injunction)

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Case Assigned/Reassigned

.Order AND ~Util - Set/Reset Deadlines/Hearings

Case Assigned to Judge Royce C. Lamberth. (zsl)

MINUTE ORDER: Government's Response to Plaintiff's Motion 6 due by 3/21/2025; Plaintiff's Reply due by 3/23/2025. TRO/PI Motion Hearing set for 3/24/2025 at 02:00 PM in Courtroom 15- In Person before Judge Royce C. Lamberth. Signed by Judge Royce C. Lamberth on 3/19/2025. (lcrcl3)

SUMMONS (5) Issued Electronically as to All Defendants, U.S. Attorney and U.S. Attorney General (Attachment: # 1 Notice and Consent)(zsl) (Entered: 03/19/2025)

NOTICE of Appearance by Julia Alexandra Heiman on behalf of All Defendants (Heiman, Julia) (Entered: 03/21/2025)

RESPONSE re 6 MOTION for Temporary Restraining Order MOTION for Preliminary Injunction filed by KARI LAKE, VICTOR MORALES, UNITED STATES AGENCY FOR GLOBAL MEDIA. (Attachments: # 1 Text of Proposed Order)(Heiman, Julia) (Entered: 03/21/2025)

1 Text of Proposed Order

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Unopposed MOTION for Leave to File Supplemental Declaration of Stephen Capus by RFE/RL, INC.. (Attachments: # 1 Exhibit A, # 2 Text of Proposed Order)(Cheek, Marney) (Entered: 03/23/2025)

REPLY to opposition to motion re 6 Motion for TRO,, Motion for Preliminary Injunction, filed by RFE/RL, INC.. (Cheek, Marney) (Entered: 03/23/2025)

NOTICE of Appearance by Abigail Stout on behalf of All Defendants (Stout, Abigail) (Main Document 12 replaced on 3/24/2025) (zdp). (Entered: 03/24/2025)

.Order

Motion Hearing

MINUTE ORDER: The court will provide access for the public to telephonically attend the hearing scheduled for March 24, 2025, at 2:00 PM. The hearing can be accessed by dialing the Toll-Free Number: 833-990-9400 (Meeting ID: 720718696). It is hereby ORDERED that the attendees using the public access telephone line shall adhere to the following: persons remotely accessing court proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting any court proceedings (including those held by telephone or videoconference). Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the presiding Judge. Signed by Judge Royce C. Lamberth on 3/24/2025. (smc)

NOTICE of Disbursement Initiation by Defendants by KARI LAKE, VICTOR MORALES, UNITED STATES AGENCY FOR GLOBAL MEDIA (Heiman, Julia) (Entered: 03/24/2025)

Minute Entry for proceedings held before Judge Royce C. Lamberth: Motion Hearing held on 3/24/2025 re 6 MOTION for Temporary Restraining Order MOTION for Preliminary Injunction filed by RFE/RL, INC.. The Court takes the arguments under advisement. Ruling forthcoming. Court Reporter: Chandra Kean. (zcll)

ORDER granting 6 Motion for TRO. See Order for details. Government's Response to Plaintiff's Motion for Preliminary Injunction due by 3/26/2025; Plaintiff's Reply due by 3/28/2025. Signed by Judge Royce C. Lamberth on 3/25/2025. (lcrcl3)

RESPONSE re 6 MOTION for Temporary Restraining Order MOTION for Preliminary Injunction and NOTICE OF WITHDRAWAL OF GRANT TERMINATION filed by KARI LAKE, VICTOR MORALES, UNITED STATES AGENCY FOR GLOBAL MEDIA. (Stout, Abigail) (Entered: 03/26/2025)

TRANSCRIPT OF PROCEEDINGS before Judge Royce C. Lamberth held on March 24, 2025; Page Numbers: 1-36. Date of Issuance: March 26, 2025. Court Reporter/Transcriber Chandra Kean, RMR, Telephone number (202)354-3404. Transcripts may be ordered by submitting the Transcript Order FormFor the first 90 days after this filing date, the transcript may be viewed at the courthouse at a public terminal or purchased from the court reporter referenced above. After 90 days, the transcript may be accessed via PACER. Other transcript formats, (multi-page, condensed, CD or ASCII) may be purchased from the court reporter.NOTICE RE REDACTION OF TRANSCRIPTS: The parties have twenty-one days to file with the court and the court reporter any request to redact personal identifiers from this transcript. If no such requests are filed, the transcript will be made available to the public via PACER without redaction after 90 days. The policy, which includes the five personal identifiers specifically covered, is located on our website at www.dcd.uscourts.gov. ]Redaction Request due 4/17/2025. Redacted Transcript Deadline set for 4/27/2025. Release of Transcript Restriction set for 6/25/2025.(Kean, Chandra) (Entered: 03/27/2025)

Consent MOTION for Leave to File Amicus Brief by REPORTERS COMMITTEE FOR FREEDOM OF THE PRESS. (Attachments: # 1 Exhibit Proposed Amici Brief)(Brown, Bruce) (Entered: 03/28/2025)

REPLY to opposition to motion re 6 Motion for TRO,, Motion for Preliminary Injunction, and Response to Defendants' Notice of Withdrawal of Grant Termination, and Conditional Request for a Further Temporary Restraining Order filed by RFE/RL, INC.. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Text of Proposed Order)(Cheek, Marney) (Entered: 03/28/2025)

NOTICE REGARDING DEFENDANTS' CONTINUED FAILURE TO APPROVE RFE/RL'S FINANCIAL PLAN by RFE/RL, INC. (Cheek, Marney)

.Order AND ~Util - Set/Reset Hearings

MINUTE ORDER: The parties are ORDERED to appear for a Status Conference on Tuesday, 4/8/2025 at 03:00 PM to discuss the parties' latest filings and the pending PI motion. The Status Conference will take place in Courtroom 15- In Person before Judge Royce C. Lamberth. Signed by Judge Royce C. Lamberth on 4/7/2025. (lcrcl3)

NOTICE OF SUPPLEMENTAL AUTHORITY by KARI LAKE, VICTOR MORALES, UNITED STATES AGENCY FOR GLOBAL MEDIA (Stout, Abigail) (Entered: 04/07/2025)

RESPONSE re 20 NOTICE OF SUPPLEMENTAL AUTHORITY filed by RFE/RL, INC.. (Cheek, Marney) (Entered: 04/08/2025)

Status Conference AND ~Util - Set/Reset Deadlines

Minute Entry for proceedings held before Judge Royce C. Lamberth: Status Conference held on 4/8/2025. The parties are directed to provide a status to the Court by 4/10/2025. (Court Reporter: Christine Asif.) (hmc)

ORDER extending TRO (ECF No. 14) for an additional seven days. Signed by Judge Royce C. Lamberth on 4/8/2025. (lcrcl3) (Entered: 04/08/2025)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. KARI LAKE served on 3/27/2025 (Cheek, Marney) (Entered: 04/08/2025)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. UNITED STATES AGENCY FOR GLOBAL MEDIA served on 3/28/2025 (Cheek, Marney) (Entered: 04/08/2025)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. VICTOR MORALES served on 3/28/2025 (Cheek, Marney) (Entered: 04/08/2025)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed as to the United States Attorney. Date of Service Upon United States Attorney on 3/20/2025. Answer due for ALL FEDERAL DEFENDANTS by 5/19/2025. (Cheek, Marney) (Entered: 04/08/2025)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed on United States Attorney General. Date of Service Upon United States Attorney General 3/27/2025. (Cheek, Marney) (Entered: 04/08/2025)

MOTION for Temporary Restraining Order by RFE/RL, INC.. (Attachments: # 1 Memorandum in Support, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Text of Proposed Order)(Cheek, Marney) (Entered: 04/09/2025)

1 Memorandum in Support

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2 Exhibit A

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3 Exhibit B

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4 Exhibit C

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5 Exhibit D

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6 Text of Proposed Order

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MOTION to Vacate 14 Order on Motion for TRO,, Set/Reset Deadlines, by KARI LAKE, VICTOR MORALES, UNITED STATES AGENCY FOR GLOBAL MEDIA. (Stout, Abigail) (Entered: 04/10/2025)

.Order AND ~Util - Set/Reset Deadlines

Joint STATUS REPORT by RFE/RL, INC.. (Cheek, Marney) (Entered: 04/10/2025)

MINUTE ORDER: the Court hereby ORDERS the parties to adhere to the proposed briefing dates as stated in their most recent Joint Status Report (ECF No. 30). Signed by Judge Royce C. Lamberth on 4/10/2025. (lcrcl3)

Memorandum in opposition to re 29 Motion to Vacate filed by RFE/RL, INC.. (Cheek, Marney) (Entered: 04/11/2025)

RESPONSE re 28 MOTION for Temporary Restraining Order filed by KARI LAKE, VICTOR MORALES, UNITED STATES AGENCY FOR GLOBAL MEDIA. (Stout, Abigail) (Entered: 04/11/2025)

Unopposed MOTION for Leave to File Declaration of Joseph Lataille by RFE/RL, INC.. (Attachments: # 1 Exhibit 1, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Text of Proposed Order)(Cheek, Marney) (Entered: 04/12/2025)

1 Exhibit 1

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2 Exhibit A

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3 Exhibit B

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4 Exhibit C

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5 Exhibit D

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6 Text of Proposed Order

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REPLY to opposition to motion re 28 Motion for TRO filed by RFE/RL, INC.. (Cheek, Marney) (Entered: 04/12/2025)

REPLY to opposition to motion re 29 Motion to Vacate filed by KARI LAKE, VICTOR MORALES, UNITED STATES AGENCY FOR GLOBAL MEDIA. (Heiman, Julia) (Entered: 04/13/2025)

.Order AND ~Util - Set/Reset Hearings

MOTION for Extension of Time to File Defendants' Reply, Nunc Pro Tunc by KARI LAKE, VICTOR MORALES, UNITED STATES AGENCY FOR GLOBAL MEDIA. (Attachments: # 1 Text of Proposed Order)(Heiman, Julia) (Entered: 04/13/2025)

1 Text of Proposed Order

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MINUTE ORDER: The parties are ORDERED to appear for a Status Conference on Tuesday, 4/15/2025, at 11:00 AM in Courtroom 15- In Person before Judge Royce C. Lamberth. Signed by Judge Royce C. Lamberth on 4/13/2025. (lcrcl3)

CONSENT TO THE FILING OF AN AMENDED COMPLAINT by RFE/RL, INC.. (Cheek, Marney) (Entered: 04/14/2025)

AMENDED COMPLAINT against All Defendants filed by RFE/RL, INC..(Cheek, Marney) (Entered: 04/14/2025)

Status Conference

.Order

Minute Entry for Status Conference held on 4/15/2025 before Judge Royce C. Lamberth. Parties discussed posture of the case. Court Reporter: Bryan Wayne. (smc)

TRANSCRIPT OF STATUS HEARING before Judge Royce C. Lamberth held on April 15, 2025; Page Numbers: 1-15. Date of Issuance: 4/15/2025. Court Reporter: Bryan A. Wayne. Transcripts may be ordered by submitting the Transcript Order FormFor the first 90 days after this filing date, the transcript may be viewed at the courthouse at a public terminal or purchased from the court reporter referenced above. After 90 days, the transcript may be accessed via PACER. Other transcript formats, (multi-page, condensed, CD or ASCII) may be purchased from the court reporter.NOTICE RE REDACTION OF TRANSCRIPTS: The parties have twenty-one days to file with the court and the court reporter any request to redact personal identifiers from this transcript. If no such requests are filed, the transcript will be made available to the public via PACER without redaction after 90 days. The policy, which includes the five personal identifiers specifically covered, is located on our website at www.dcd.uscourts.gov. Redaction Request due 5/6/2025. Redacted Transcript Deadline set for 5/16/2025. Release of Transcript Restriction set for 7/14/2025.(Wayne, Bryan) (Entered: 04/15/2025)

MINUTE ORDER: On Thursday, April 17, the Court will hold a hearing on the pending preliminary injunction motions in Widakuswara v. Lake, 25-cv-1015, and Abramowitz v. Lake, 25-cv-887. The hearing will begin at 11:30 AM in Courtroom 15. Plaintiffs will present their arguments first; the Court will break for lunch at 12:30 PM and will reconvene at 1:45 PM; and the government will present their argument once the Court reconvenes. Plaintiffs will be provided time to respond. Once the hearing concludes, the Court will take a brief recess. At that point, the Court will hold status conferences for each of the network grantee cases in which there is a pending motion for preliminary relief: RFE/RL v. Lake, 25-cv-799 (RCL); Radio Free Asia v. United States, 25-cv-907 (RCL); and Middle East Broadcasting Networks v. United States, 25-cv-966 (RCL). Counsel in each of the network grantee cases listed above is encouraged to attend the Widakuswara preliminary injunction hearing, given the interrelatedness of the relief sought in each case. Signed by Judge Royce C. Lamberth on 4/15/2025. (lcrcl3)

Notice of Hearing

NOTICE of Hearing:Status Conference set for 4/17/2025 at 3:30 PM in Courtroom 15 (In Person) before Judge Royce C. Lamberth. (smc)

Status Conference

Minute Entry for Status Conference held on 4/17/2025 before Judge Royce C. Lamberth: Parties discussed posture of the case. Preliminary Injunction Motion to be filed early next week. Court Reporter: Sonja Reeves. (smc)

Transcript