Case: Climate United Fund v. Citibank

COMPLAINT against CITIBANK, N.A., UNITED STATES ENVIRONMENTAL PROTECTION AGENCY, LEE ZELDIN ( Filing fee $ 405 receipt number ADCDC-11528517) filed by CLIMATE UNITED FUND. (Attachments: # 1 Civil Cover Sheet, # 2 Summons - CITIBANK, N.A., # 3 Summons - UNITED STATES ENVIRONMENTAL PROTECTION AGENCY, # 4 Summons - LEE ZELDIN, # 5 Summons - ATTORNEY GENERAL PAMELA BONDI, # 6 Summons - US ATTORNEY GENERAL EDWARD R. MARTIN, JR.)(Unikowsky, Adam) (Entered: 03/08/2025)

1 Civil Cover Sheet

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2 Summons - CITIBANK, N.A.

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3 Summons - UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

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4 Summons - LEE ZELDIN

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5 Summons - ATTORNEY GENERAL PAMELA BONDI

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6 Summons - US ATTORNEY GENERAL EDWARD R. MARTIN, JR.

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MOTION for Temporary Restraining Order by CLIMATE UNITED FUND. (Attachments: # 1 Memorandum in Support, # 2 Declaration of Elizabeth Bafford in Support, # 3 Exhibit 1, # 4 Exhibit 2, # 5 Exhibit 3, # 6 Exhibit 4, # 7 Exhibit 5, # 8 Exhibit 6, # 9 Exhibit 7, # 10 Exhibit 8, # 11 Exhibit 9, # 12 Proposed Order)(Unikowsky, Adam) Modified docket text on 3/10/2025 (mg). (Entered: 03/10/2025)

1 Memorandum in Support

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2 Declaration of Elizabeth Bafford in Support

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3 Exhibit 1

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4 Exhibit 2

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5 Exhibit 3

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6 Exhibit 4

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7 Exhibit 5

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8 Exhibit 6

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9 Exhibit 7

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10 Exhibit 8

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11 Exhibit 9

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12 Proposed Order

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ENTERED IN ERROR.....LCvR 26.1 CERTIFICATE OF DISCLOSURE of Corporate Affiliations and Financial Interests by CLIMATE UNITED FUND (Unikowsky, Adam) Modified on 3/10/2025 (zsl). (Entered: 03/10/2025)

SUMMONS (5) Issued Electronically as to All Defendants, U.S. Attorney and U.S. Attorney General (Attachment: # 1 Notice and Consent)(zsl) (Entered: 03/10/2025)

1 Notice and Consent

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LCvR 26.1 CERTIFICATE OF DISCLOSURE of Corporate Affiliations and Financial Interests by CLIMATE UNITED FUND (Unikowsky, Adam) (Entered: 03/10/2025)

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Gabriel K. Gillett, Filing fee $ 100, receipt number ADCDC-11531560. Fee Status: Fee Paid. by CLIMATE UNITED FUND. (Attachments: # 1 Declaration in Support, # 2 Certificate of Good Standing, # 3 Proposed Order)(Unikowsky, Adam) (Entered: 03/10/2025)

1 Declaration in Support

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2 Certificate of Good Standing

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3 Proposed Order

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NOTICE of Appearance by Kenneth Winn Allen on behalf of CITIBANK, N.A. (Allen, Kenneth) (Entered: 03/10/2025)

NOTICE of Appearance by Saunders Lee McElroy on behalf of CITIBANK, N.A. (McElroy, Saunders) (Entered: 03/10/2025)

.Order

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

Case Assigned to Judge Tanya S. Chutkan. (zsl)

NOTICE OF NEW CASE ERROR regarding 3 LCvR 26.1 Certificate of Disclosure - Corporate Affiliations/Financial Interests. The following error(s) need correction: Blank/Incomplete/Missing form. Form filed as fillable PDF. Please file form in a non-fillable PDF format. (zsl)

MINUTE ORDER: The parties are hereby ORDERED to appear for an in-person hearing on the 2 Motion for Temporary Restraining Order on March 12, 2025, at 4:00 PM in Courtroom 9 before Judge Tanya S. Chutkan. Upon consideration of the parties' proposed briefing schedule, it is further ORDERED that Defendants' Reply is due on March 12, 2025, at 12:00 PM. Plaintiff shall notify counsel for Defendants of the contents of this Minute Order. Signed by Judge Tanya S. Chutkan on 3/10/2025. (zcll)

MINUTE ORDER: The court will provide access for the public to telephonically attend the hearing scheduled for March 12, 2025, at 4:00 PM. The hearing can be accessed by dialing the Toll-Free Number: 833-990-9400 (Meeting ID: 493633106). 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 Tanya S. Chutkan on 3/10/2025. (zcll)

NOTICE of Provisional/Government Not Certified Status re 7 NOTICE of Appearance by Kenneth Winn Allen on behalf of CITIBANK, N.A. (Allen, Kenneth).Your attorney renewal/government certification has not been received. As a result, your membership with the U.S. District & Bankruptcy Courts for the District of Columbia is not in good standing, and you are not permitted to file. Pursuant to Local Civil Rule 83.9, you must immediately correct your membership status by following the appropriate instructions on this page of our website: https://www.dcd.uscourts.gov/attorney-renewal. Please be advised that the presiding judge in this case has been notified that you are currently not in good standing to file in this court. Renewal Due by 3/17/2025. (zhcn)

RESOLVED.....NOTICE of Provisional/Government Not Certified Status re 7 NOTICE of Appearance by Kenneth Winn Allen on behalf of CITIBANK, N.A. (Allen, Kenneth).Your attorney renewal/government certification has not been received. As a result, your membership with the U.S. District & Bankruptcy Courts for the District of Columbia is not in good standing, and you are not permitted to file. Pursuant to Local Civil Rule 83.9, you must immediately correct your membership status by following the appropriate instructions on this page of our website: https://www.dcd.uscourts.gov/attorney-renewal. Please be advised that the presiding judge in this case has been notified that you are currently not in good standing to file in this court. Renewal Due by 3/17/2025. (zhcn) Modified on 3/12/2025 (zhcn).

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Allison N. Douglis, Filing fee $ 100, receipt number ADCDC-11534156. Fee Status: Fee Paid. by CLIMATE UNITED FUND. (Attachments: # 1 Declaration in Support, # 2 Certificate of Good Standing, # 3 Proposed Order)(Unikowsky, Adam) (Entered: 03/11/2025)

1 Declaration in Support

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2 Certificate of Good Standing

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3 Proposed Order

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NOTICE of Appearance by Marcus S Sacks on behalf of UNITED STATES ENVIRONMENTAL PROTECTION AGENCY, LEE ZELDIN (Sacks, Marcus) (Entered: 03/11/2025)

NOTICE of Appearance by Kevin Paul VanLandingham on behalf of UNITED STATES ENVIRONMENTAL PROTECTION AGENCY, LEE ZELDIN (VanLandingham, Kevin) (Entered: 03/11/2025)

LCvR 26.1 CERTIFICATE OF DISCLOSURE of Corporate Affiliations and Financial Interests by CITIBANK, N.A. (McElroy, Saunders) (Entered: 03/11/2025)

NOTICE OF GRANT TERMINATION by UNITED STATES ENVIRONMENTAL PROTECTION AGENCY, LEE ZELDIN (Attachments: # 1 Exhibit 1)(Sacks, Marcus) (Entered: 03/11/2025)

1 Exhibit 1

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Notice of Provisional/Government Not Certified Status

Order on Motion for Leave to Appear Pro Hac Vice AND Order on Motion for Leave to Appear Pro Hac Vice

MINUTE ORDER: GRANTING Motions for Leave to Appear Pro Hac Vice as to 6 Gabriel K. Gillett and 9 Allison N. Douglis. Gabriel K. Gillett and Allison N. Douglis are hereby admitted pro hac vice to represent Plaintiff Climate United Fund in this matter. Counsel should register for e-filing via PACER and file a notice of appearance pursuant to LCvR 83.6(a). Click for instructions. Signed by Judge Tanya S. Chutkan on 3/11/2025. (lcer)

Memorandum in opposition to re 2 Motion for TRO, filed by CITIBANK, N.A.. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Exhibit 7, # 8 Text of Proposed Order)(Allen, Kenneth) (Entered: 03/12/2025)

1 Exhibit 1

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2 Exhibit 2

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3 Exhibit 3

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4 Exhibit 4

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5 Exhibit 5

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6 Exhibit 6

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7 Exhibit 7

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8 Text of Proposed Order

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SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by CITIBANK, N.A. (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Exhibit 1, # 2 Text of Proposed Order)(Allen, Kenneth) (Entered: 03/12/2025)

Memorandum in opposition to re 2 Motion for TRO, filed by UNITED STATES ENVIRONMENTAL PROTECTION AGENCY, LEE ZELDIN. (Attachments: # 1 Declaration Schindel, # 2 Exhibit Exs. to Schindel Decl.)(VanLandingham, Kevin) (Entered: 03/12/2025)

1 Declaration Schindel

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2 Exhibit Exs. to Schindel Decl.

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RESPONSE re 13 Notice (Other) filed by CLIMATE UNITED FUND. (Unikowsky, Adam) (Entered: 03/12/2025)

NOTICE of Appearance by Allison N. Douglis on behalf of CLIMATE UNITED FUND (Douglis, Allison) (Entered: 03/12/2025)

NOTICE of Appearance by David B. Robbins on behalf of CLIMATE UNITED FUND (Robbins, David) (Entered: 03/12/2025)

NOTICE of Appearance by Gabriel K. Gillett on behalf of CLIMATE UNITED FUND (Gillett, Gabriel) (Entered: 03/12/2025)

SEALED Exhibit re 14 Memorandum in opposition filed by CITIBANK, N.A.. (This document is SEALED and only available to authorized persons.)(zjm) Modified on 3/18/2025 to add docket link (zjm). (Entered: 03/13/2025)

MINUTE ORDER: Upon consideration of Defendant Citibank's 15 Motion for Leave to File Under Seal, the court GRANTS the motion for the reasons asserted. Signed by Judge Tanya S. Chutkan on 3/12/2025. (lcer)

Minute Entry for proceedings held before Judge Tanya S. Chutkan: Motion Hearing held on 3/12/2025 re 2 MOTION for Temporary Restraining Order filed by CLIMATE UNITED FUND held and concluded. Minute Order forthcoming. Court Reporter Janice Dickman. (ztl)

Motion Hearing

TRANSCRIPT OF PROCEEDINGS before Judge Tanya S. Chutkan held on March 12, 2025; Page Numbers: 1-44. Date of Issuance: March 14, 2025. Court Reporter: Janice Dickman, Telephone number: 202-354-3267, 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 4/4/2025. Redacted Transcript Deadline set for 4/14/2025. Release of Transcript Restriction set for 6/12/2025.(Dickman, Janice) (Entered: 03/14/2025)

.Order AND ~Util - Set/Reset Deadlines

MINUTE ORDER: Following the Motion Hearing held on 3/12/2025, it is hereby ORDERED that Plaintiff's request for Leave to Amend its Complaint is due by Monday, March 17, 2025, by 5:00PM EST. It is further ORDERED that by Monday, March 17, 2025, by 5:00PM EST, Federal Defendants shall file a declaration addressing the basis for the grant termination, see ECF No. 13, including the proffer of evidence discussed at the hearing. Signed by Judge Tanya S. Chutkan on 3/14/2025. (lcer)

.Order AND ~Util - Set/Reset Hearings

MINUTE ORDER: The parties in No. 25-cv-698, No. 25-cv-735, and No. 25-cv-762, are hereby ORDERED to appear for an in-person motion hearing on the 2 Motion for Temporary Restraining Order on March 17, 2025, at 12:00 PM in Courtroom 9 before Judge Tanya S. Chutkan. The court will provide access for the public to telephonically attend the hearing. The hearing can be accessed by dialing the Toll-Free Number: 833-990-9400 (Meeting ID: 493633106). It is hereby ORDERED that the attendees using the public access telephone line shall adhere to the restrictions outlined in the March 10, 2025, Minute Order. Signed by Judge Tanya S. Chutkan on 3/16/2025. (lcer)

NOTICE of Proposed Order re 2 by CLIMATE UNITED FUND (Attachments: # 1 Proposed Order Granting Temporary Restraining Order)(Unikowsky, Adam) Modified on 3/19/2025 to add docket link (zjm). (Entered: 03/17/2025)

1 Proposed Order Granting Temporary Restraining Order

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AMENDED COMPLAINT against CITIBANK, N.A., UNITED STATES ENVIRONMENTAL PROTECTION AGENCY, LEE ZELDIN filed by CLIMATE UNITED FUND.(Unikowsky, Adam) (Entered: 03/17/2025)

NOTICE of Declaration by UNITED STATES ENVIRONMENTAL PROTECTION AGENCY, LEE ZELDIN (Attachments: # 1 Declaration of Eric Amidon)(VanLandingham, Kevin) (Entered: 03/17/2025)

1 Declaration of Eric Amidon

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NOTICE to the Court by CLIMATE UNITED FUND (Unikowsky, Adam) (Entered: 03/17/2025)

Minute Entry for proceedings held before Judge Tanya S. Chutkan: Motion Hearing held on 3/17/2025 re 2 MOTION for Temporary Restraining Order filed by CLIMATE UNITED FUND. Pursuant to Federal Rule of Civil Procedure 42(a), the Court will consolidate the Civil Cases 25-698, 25-735, 25-762. Minute Order Forthcoming. Court Reporter Jeff Hook. (ztl)

TRANSCRIPT OF MOTION HEARING before Judge Tanya S. Chutkan held on March 17, 2025. Page Numbers: 1 - 45. Date of Issuance: March 18, 2025. Court Reporter: Jeff Hook. Telephone number: 202-354-3373. 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 4/8/2025. Redacted Transcript Deadline set for 4/18/2025. Release of Transcript Restriction set for 6/16/2025.(Hook, Jeff) (Entered: 03/18/2025)

MEMORANDUM OPINION re: Plaintiff's 2 Motion for Temporary Restraining Order. Signed by Judge Tanya S. Chutkan on 3/18/2025. (lcer) (Main Document 28 replaced on 3/19/2025) (zsmc). (Entered: 03/18/2025)

ORDER GRANTING in part and DENYING in part Plaintiff's 2 Motion for Temporary Restraining Order. See Order for details. Signed by Judge Tanya S. Chutkan on 3/18/2025. (lcer) (Entered: 03/18/2025)

Motion Hearing

Joint STATUS REPORT by CLIMATE UNITED FUND. (Unikowsky, Adam) (Entered: 03/19/2025)

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

MINUTE ORDER: Upon consideration of the parties' 30 Joint Status Report, the court adopts and sets the following deadlines: Plaintiffs shall file their motions for a preliminary injunction by March 21, 2025. Defendants shall file an answer to the motions by March 26, 2025. Plaintiffs shall reply by March 28, 2025. For the reasons stated in the 30 Joint Status Report, Plaintiffs shall file a single consolidated opening brief with a 60-page limit and a single consolidated reply brief with a 30-page limit. The court will hold a hearing on Plaintiffs' motions on Wednesday, April 2, 2025, at 12:00 PM in Courtroom 9 before Judge Tanya S. Chutkan. The court will provide access for the public to telephonically attend the hearing. Signed by Judge Tanya S. Chutkan on 3/19/2025. (lcer)

STATUS REPORT by CITIBANK, N.A.. (Allen, Kenneth) (Entered: 03/20/2025)

MINUTE ORDER: The court will provide access for the public to telephonically attend the hearing scheduled for April 2, 2025. The hearing can be accessed by dialing the Toll-Free Number: 833-990-9400 (Meeting ID: 493633106). 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 Tanya S. Chutkan on 3/20/2025. (smc)

.Order

Remark- Consolidation

MINUTE ORDER: As noticed in the March 17 hearing, see March 17, 2025 Min. Order, the court will consolidate cases 25-cv-698, 25-cv-735, and 25-cv-762 pursuant to Federal Rule of Civil Procedure 42(a). All filings and papers related to the consolidated cases shall be filed in the lead case: 25-cv-698. Is if further ORDERED that the parties shall NOT "spread the text" when filing documents in the lead cases. Signed by Judge Tanya S. Chutkan on 3/20/2025. (lcer)

MINUTE ORDER: As noticed in the March 17 hearing, see March 17, 2025 Min. Order, the court will consolidate cases 25-cv-698, 25-cv-735, and 25-cv-762 pursuant to Federal Rule of Civil Procedure 42(a). All filings and papers related to the consolidated cases shall be filed in the lead case: 25-cv-698. It is further ORDERED that the parties shall NOT "spread the text" when filing documents in the lead cases. Signed by Judge Tanya S. Chutkan on 3/20/2025. (lcer) Modified on 3/21/2025 (zsmc).

Cases Consolidated: The following cases have been consolidated with this case: 25-cv-00762-TSC and 25-cv-00735-TSC pursuant to 03/10/20025 Minute Order. From this date forward, all pleadings shall be filed ONLY in this case. Parties are advised NOT to elect the SPREAD TEXT option when filing in ECF, as this will result in repetitive docketing. (zjm)

NOTICE of Appearance by James Gross on behalf of POWER FORWARD COMMUNITIES, INC. (Gross, James) (Entered: 03/21/2025)

MOTION for Preliminary Injunction by CLIMATE UNITED FUND. (Attachments: # 1 Memorandum in Support, # 2 Declaration of Elizabeth Bafford, # 3 Exhibit 1, # 4 Exhibit 2, # 5 Exhibit 3, # 6 Exhibit 4, # 7 Exhibit 5, # 8 Exhibit 6, # 9 Exhibit 7, # 10 Exhibit 8, # 11 Exhibit 9, # 12 Exhibit 10, # 13 Exhibit 11, # 14 Declaration of Vincent Levy, # 15 Exhibit A, # 16 Exhibit B, # 17 Exhibit C, # 18 Exhibit D, # 19 Exhibit E, # 20 Exhibit F, # 21 Exhibit G, # 22 Exhibit H, # 23 Exhibit I, # 24 Exhibit J, # 25 Declaration of Stephen Brown, # 26 Declaration of Jessica Buendia, # 27 Declaration of Eli Hopson, # 28 Declaration of Richard Kauffman, # 29 Declaration of Shaun Donovan, # 30 Declaration of Ari Matusiak, # 31 Declaration of Timothy J. Mayopoulos, # 32 Declaration of John Moon, # 33 Text of Proposed Order)(Unikowsky, Adam) (Entered: 03/21/2025)

1 Memorandum in Support

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2 Declaration of Elizabeth Bafford

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3 Exhibit 1

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4 Exhibit 2

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5 Exhibit 3

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6 Exhibit 4

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7 Exhibit 5

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8 Exhibit 6

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9 Exhibit 7

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10 Exhibit 8

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11 Exhibit 9

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12 Exhibit 10

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13 Exhibit 11

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14 Declaration of Vincent Levy

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15 Exhibit A

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16 Exhibit B

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17 Exhibit C

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18 Exhibit D

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19 Exhibit E

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20 Exhibit F

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21 Exhibit G

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22 Exhibit H

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23 Exhibit I

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24 Exhibit J

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25 Declaration of Stephen Brown

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26 Declaration of Jessica Buendia

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27 Declaration of Eli Hopson

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28 Declaration of Richard Kauffman

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29 Declaration of Shaun Donovan

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30 Declaration of Ari Matusiak

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31 Declaration of Timothy J. Mayopoulos

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32 Declaration of John Moon

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33 Text of Proposed Order

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NOTICE of Appearance by Kevin Chen on behalf of POWER FORWARD COMMUNITIES, INC. (Chen, Kevin) (Entered: 03/24/2025)

NOTICE of Appearance by Beth C. Neitzel on behalf of POWER FORWARD COMMUNITIES, INC. (Neitzel, Beth) (Entered: 03/24/2025)

NOTICE of Appearance by Jack C. Smith on behalf of POWER FORWARD COMMUNITIES, INC. (Smith, Jack) (Entered: 03/24/2025)

NOTICE of Appearance by Vincent Levy on behalf of COALITION FOR GREEN CAPITAL (Levy, Vincent) (Entered: 03/24/2025)

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Noah C. Shaw, Filing fee $ 100, receipt number ADCDC-11565216. Fee Status: Fee Paid. by POWER FORWARD COMMUNITIES, INC.. (Attachments: # 1 Exhibit A, # 2 Exhibit B)(Neitzel, Beth) (Entered: 03/25/2025)

1 Exhibit A

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2 Exhibit B

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Remark- Consolidation

Cases Consolidated: The following cases have been consolidated with this case: 25-cv-00820-TSC. From this date forward, all pleadings shall be filed ONLY in this case. Parties are advised NOT to elect the SPREAD TEXT option when filing in ECF, as this will result in repetitive docketing. (zjm)

ERRATA Certificate of Good Standing by POWER FORWARD COMMUNITIES, INC. re 38 Motion for Leave to Appear Pro Hac Vice,. (Attachments: # 1 Errata Certificate of Good Standing)(Neitzel, Beth) (Entered: 03/26/2025)

NOTICE of Appearance by Jason Elliott James on behalf of ILLINOIS FINANCE AUTHORITY (James, Jason) (Entered: 03/26/2025)

NOTICE of Appearance by Emma Akrawi on behalf of EFFICIENCY MAINE TRUST (Akrawi, Emma) (Entered: 03/26/2025)

NOTICE of Appearance by Scott William Boak on behalf of EFFICIENCY MAINE TRUST (Boak, Scott) (Entered: 03/26/2025)

NOTICE of Appearance by Catherine Rios-Keating on behalf of MINNESOTA CLIMATE INNOVATION FINANCE AUTHORITY (Rios-Keating, Catherine) (Entered: 03/26/2025)

NOTICE of Appearance by Meghan Strong on behalf of CALIFORNIA INFRASTRUCTURE AND ECONOMIC DEVELOPMENT BANK Associated Cases: 1:25-cv-00698-TSC, 1:25-cv-00820-TSC(Strong, Meghan) (Entered: 03/26/2025)

NOTICE of Appearance by Oliver Larson on behalf of MINNESOTA CLIMATE INNOVATION FINANCE AUTHORITY (Larson, Oliver) (Entered: 03/26/2025)

AFFIDAVIT of Mailing re 1 COMPLAINT by MINNESOTA CLIMATE INNOVATION FINANCE AUTHORITY RE SUMMONS AND COMPLAINT. (Attachments: # 1 Certificate of Service)(Rios-Keating, Catherine) Modified on 3/27/2025 to correct event/add docket link (zjm). (Entered: 03/26/2025)

NOTICE of Appearance by Megan Anne Schultz Richards on behalf of CALIFORNIA INFRASTRUCTURE AND ECONOMIC DEVELOPMENT BANK (Richards, Megan) (Entered: 03/26/2025)

RESPONSE re 33 MOTION for Preliminary Injunction filed by CITIBANK, N.A.. (Attachments: # 1 Text of Proposed Order)(Allen, Kenneth) (Entered: 03/26/2025)

1 Text of Proposed Order

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Memorandum in opposition to re 33 Motion for Preliminary Injunction,,, filed by UNITED STATES ENVIRONMENTAL PROTECTION AGENCY, LEE ZELDIN. (Attachments: # 1 Declaration Declaration of Dan Coogan, # 2 Exhibit Exhibits to Coogan Declaration, # 3 Declaration Declaration of Eric Amidon, # 4 Exhibit Exhibits to Amidon Declaration, # 5 Declaration Declaration of Gregg Treml, # 6 Declaration Declaration of Kevin Bailey, # 7 Exhibit Exhibits to Bailey Declaration)(Sacks, Marcus) (Entered: 03/26/2025)

1 Declaration Declaration of Dan Coogan

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2 Exhibit Exhibits to Coogan Declaration

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3 Declaration Declaration of Eric Amidon

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4 Exhibit Exhibits to Amidon Declaration

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5 Declaration Declaration of Gregg Treml

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6 Declaration Declaration of Kevin Bailey

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7 Exhibit Exhibits to Bailey Declaration

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NOTICE OF ERROR regarding 38 MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Noah C. Shaw, Filing fee $ 100, receipt number ADCDC-11565216. Fee Status: Fee Paid.. The following error(s) need correction: Pro Hac Vice motion must be accompanied by a Certificate of Good Standing issued within the last 30 days (LCvR 83.2(c)(2)). Please file certificate as an Errata (zjm)

NOTICE of Appearance by Peter Nathaniel Surdo on behalf of MINNESOTA CLIMATE INNOVATION FINANCE AUTHORITY (Surdo, Peter) (Entered: 03/27/2025)

NOTICE of Appearance by Kevin D. Benish on behalf of COALITION FOR GREEN CAPITAL (Benish, Kevin) (Entered: 03/27/2025)

MOTION for Temporary Restraining Order -- Extending Existing Temporary Restraining Order, by COALITION FOR GREEN CAPITAL. (Attachments: # 1 Text of Proposed Order)(Levy, Vincent) (Entered: 03/28/2025)

1 Text of Proposed Order

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REPLY to opposition to motion re 33 Motion for Preliminary Injunction,,, in Support filed by CLIMATE UNITED FUND. (Unikowsky, Adam) (Entered: 03/28/2025)

MINUTE ORDER: GRANTING Motion for Leave to Appear Pro Hac Vice as to 38 Noah C. Shaw. Noah C. Shaw is hereby admitted pro hac vice to represent Plaintiff Power Forward Communities, Inc. in this matter. Counsel should register for e-filing via PACER and file a notice of appearance pursuant to LCvR 83.6(a) Click for instructions. Signed by Judge Tanya S. Chutkan on 3/30/2025. (lcer)

Unopposed MOTION for Extension of Time to File Answer by CITIBANK, N.A.. (Allen, Kenneth) (Entered: 03/31/2025)

RESPONSE re 33 MOTION for Preliminary Injunction by CITIBANK, N.A.. (Attachments: # 1 Text of Proposed Order)(Allen, Kenneth) Modified on 4/2/2025 to correct event/docket text (zjm). (Entered: 03/31/2025)

1 Text of Proposed Order

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Memorandum in opposition to re 33 Motion for Preliminary Injunction,,, (Opposition to Subgrantee Plaintiffs' Motion for Preliminary Injunction) filed by UNITED STATES ENVIRONMENTAL PROTECTION AGENCY, LEE ZELDIN. (VanLandingham, Kevin) (Entered: 03/31/2025)

ORDER granting Plaintiffs' 52 Motion to Extend Temporary Restraining Order. Signed by Judge Tanya S. Chutkan on 3/31/2025. (lcer) (Entered: 03/31/2025)

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Simon A. de Carvalho, Filing fee $ 100, receipt number ADCDC-11581763. Fee Status: Fee Paid. by CLIMATE UNITED FUND. (Attachments: # 1 Declaration, # 2 Certificate of Good Standing, # 3 Text of Proposed Order)(Unikowsky, Adam) (Entered: 04/01/2025)

1 Declaration

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2 Certificate of Good Standing

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3 Text of Proposed Order

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NOTICE of Appearance by Noah C. Shaw on behalf of POWER FORWARD COMMUNITIES, INC. (Shaw, Noah) (Entered: 04/01/2025)

NOTICE of Filing of Supplemental Record Evidence by COALITION FOR GREEN CAPITAL re 33 Motion for Preliminary Injunction,,, (Attachments: # 1 Exhibit A--Correspondence dated March 28, 2025, # 2 Exhibit B--Correspondence dated March 31, 2025, # 3 Exhibit C--Correspondence dated April 1, 2025)(Levy, Vincent) (Entered: 04/02/2025)

1 Exhibit A--Correspondence dated March 28, 2025

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2 Exhibit B--Correspondence dated March 31, 2025

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3 Exhibit C--Correspondence dated April 1, 2025

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NOTICE of Appearance by Simon De Carvalho on behalf of CLIMATE UNITED FUND (De Carvalho, Simon) (Entered: 04/02/2025)

TRANSCRIPT OF PRELIMINARY INJUNCTION HEARING before Judge Tanya S. Chutkan held on April 2, 2025; Page Numbers: 1-108. Date of Issuance: 4/2/2025. 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 4/23/2025. Redacted Transcript Deadline set for 5/3/2025. Release of Transcript Restriction set for 7/1/2025.(Wayne, Bryan) (Entered: 04/02/2025)

MINUTE ORDER: GRANTING Motion for Leave to Appear Pro Hac Vice as to 58 Simon A. de Carvalho. Simon A. de Carvalho is hereby admitted pro hac vice to represent Plaintiff Climate United Fund in this matter. Counsel should register for e-filing via PACER and file a notice of appearance pursuant to LCvR 83.6(a) Click for instructions. Signed by Judge Tanya S. Chutkan on 4/2/2025. (lcer)

Order on Motion for Extension of Time to Answer AND Set/Reset Deadlines

MINUTE ORDER: GRANTING Defendants' 54 Joint Unopposed Motion to Extend Time. Defendants' responses to Plaintiffs' complaints are due by May 23, 2025. Signed by Judge Tanya S. Chutkan on 4/2/2025. (lcer) Modified on 4/2/2025 to edit language (zcll).

Minute Entry for proceedings held before Judge Tanya S. Chutkan: Motion Hearing held on 4/2/2025 re 33 MOTION for Preliminary Injunction filed by CLIMATE UNITED FUND. The Court takes the arguments under advisement. Ruling forthcoming. (Court Reporter Bryan Wayne.) (zcll)

NOTICE OF SUPPLEMENTAL AUTHORITY by UNITED STATES ENVIRONMENTAL PROTECTION AGENCY, LEE ZELDIN (Attachments: # 1 Exhibit Order, Dept. of Ed v. Cal. (Sup. Ct.))(VanLandingham, Kevin) (Entered: 04/04/2025)

1 Exhibit Order, Dept. of Ed v. Cal. (Sup. Ct.)

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RESPONSE re 63 NOTICE OF SUPPLEMENTAL AUTHORITY regarding Dept of Education v. California (U.S. Apr. 4, 2025) filed by COALITION FOR GREEN CAPITAL. (Levy, Vincent) (Entered: 04/05/2025)