Case: Widakuswara v. Lake

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

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

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

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

President Donald Trump

COMPLAINT against KARI LAKE, in her official capacity as Senior Advisor to the Acting CEO of the U.S. Agency for Global Media, U.S. AGENCY FOR GLOBAL MEDIA, VICTOR MORALES, in his official capacity as Acting CEO of the U.S. Agency for Global Media. (Filing Fee $ 405.00, Receipt Number ANYSDC-30810020)Document filed by REPORTERS WITHOUT BORDERS, INC., KATHRYN NEEPER, AMERICAN FEDERATION OF STATE, COUNTY AND MUNICIPAL EMPLOYEES (AFSCME), AMERICAN FOREIGN SERVICE ASSOCIATION (AFSA), JESSICA JERREAT, AMERICAN FEDERATION OF GOVERNMENT EMPLOYEES (AFGE), PATSY WIDAKUSWARA, JOHN DOES 1-4, THE NEWSGUILD-CWA, REPORTERS SANS FRONTIRES..(Celli, Andrew) [Transferred from New York Southern on 4/4/2025.] (Entered: 03/21/2025)

FILING ERROR - PDF ERROR - CIVIL COVER SHEET filed..(Celli, Andrew) Modified on 3/24/2025 (jgo). [Transferred from New York Southern on 4/4/2025.] (Entered: 03/21/2025)

RULE 7.1 CORPORATE DISCLOSURE STATEMENT. No Corporate Parent. Document filed by AMERICAN FEDERATION OF GOVERNMENT EMPLOYEES (AFGE), AMERICAN FEDERATION OF STATE, COUNTY AND MUNICIPAL EMPLOYEES (AFSCME), AMERICAN FOREIGN SERVICE ASSOCIATION (AFSA), THE NEWSGUILD-CWA..(Celli, Andrew) [Transferred from New York Southern on 4/4/2025.] (Entered: 03/21/2025)

FILING ERROR - DEFICIENT DOCKET ENTRY - SIGNATURE ERROR - RULE 7.1 CORPORATE DISCLOSURE STATEMENT. No Corporate Parent. Document filed by REPORTERS SANS FRONTIRES, REPORTERS WITHOUT BORDERS, INC...(Celli, Andrew) Modified on 3/25/2025 (lb). [Transferred from New York Southern on 4/4/2025.] (Entered: 03/21/2025)

NOTICE OF APPEARANCE by Daniel Eisenberg on behalf of AMERICAN FEDERATION OF GOVERNMENT EMPLOYEES (AFGE), AMERICAN FEDERATION OF STATE, COUNTY AND MUNICIPAL EMPLOYEES (AFSCME), AMERICAN FOREIGN SERVICE ASSOCIATION (AFSA), JESSICA JERREAT, JOHN DOES 1-4, KATHRYN NEEPER, THE NEWSGUILD-CWA, PATSY WIDAKUSWARA..(Eisenberg, Daniel) [Transferred from New York Southern on 4/4/2025.] (Entered: 03/21/2025)

NOTICE OF APPEARANCE by Nicholas Bourland on behalf of AMERICAN FEDERATION OF GOVERNMENT EMPLOYEES (AFGE), AMERICAN FEDERATION OF STATE, COUNTY AND MUNICIPAL EMPLOYEES (AFSCME), AMERICAN FOREIGN SERVICE ASSOCIATION (AFSA), JESSICA JERREAT, JOHN DOES 1-4, KATHRYN NEEPER, THE NEWSGUILD-CWA, PATSY WIDAKUSWARA..(Bourland, Nicholas) [Transferred from New York Southern on 4/4/2025.] (Entered: 03/21/2025)

NOTICE OF APPEARANCE by Debra Lea Greenberger on behalf of AMERICAN FEDERATION OF GOVERNMENT EMPLOYEES (AFGE), AMERICAN FEDERATION OF STATE, COUNTY AND MUNICIPAL EMPLOYEES (AFSCME), AMERICAN FOREIGN SERVICE ASSOCIATION (AFSA), JESSICA JERREAT, JOHN DOES 1-4, KATHRYN NEEPER, THE NEWSGUILD-CWA, PATSY WIDAKUSWARA..(Greenberger, Debra) [Transferred from New York Southern on 4/4/2025.] (Entered: 03/21/2025)

MOTION To Proceed Under Pseudonyms . Document filed by JOHN DOES 1-4..(Celli, Andrew) [Transferred from New York Southern on 4/4/2025.] (Entered: 03/23/2025)

DECLARATION of Andrew G. Celli, Jr. in Support re: 8 MOTION To Proceed Under Pseudonyms .. Document filed by JOHN DOES 1-4..(Celli, Andrew) [Transferred from New York Southern on 4/4/2025.] (Entered: 03/23/2025)

DECLARATION of John Doe 1 in Support re: 8 MOTION To Proceed Under Pseudonyms .. Document filed by JOHN DOES 1-4..(Celli, Andrew) [Transferred from New York Southern on 4/4/2025.] (Entered: 03/23/2025)

DECLARATION of John Doe 2 in Support re: 8 MOTION To Proceed Under Pseudonyms .. Document filed by JOHN DOES 1-4..(Celli, Andrew) [Transferred from New York Southern on 4/4/2025.] (Entered: 03/23/2025)

DECLARATION of John Doe 3 in Support re: 8 MOTION To Proceed Under Pseudonyms .. Document filed by JOHN DOES 1-4..(Celli, Andrew) [Transferred from New York Southern on 4/4/2025.] (Entered: 03/23/2025)

DECLARATION of John Doe 4 in Support re: 8 MOTION To Proceed Under Pseudonyms .. Document filed by JOHN DOES 1-4..(Celli, Andrew) [Transferred from New York Southern on 4/4/2025.] (Entered: 03/23/2025)

MEMORANDUM OF LAW in Support re: 8 MOTION To Proceed Under Pseudonyms . . Document filed by JOHN DOES 1-4..(Celli, Andrew) [Transferred from New York Southern on 4/4/2025.] (Entered: 03/23/2025)

PROPOSED ORDER TO SHOW CAUSE WITH EMERGENCY RELIEF. Document filed by AMERICAN FEDERATION OF GOVERNMENT EMPLOYEES (AFGE), AMERICAN FEDERATION OF STATE, COUNTY AND MUNICIPAL EMPLOYEES (AFSCME), AMERICAN FOREIGN SERVICE ASSOCIATION (AFSA), JESSICA JERREAT, JOHN DOES 1-4, KATHRYN NEEPER, REPORTERS SANS FRONTIRES, REPORTERS WITHOUT BORDERS, INC., THE NEWSGUILD-CWA, PATSY WIDAKUSWARA..(Celli, Andrew) Proposed Order to Show Cause to be reviewed by Clerk's Office staff. [Transferred from New York Southern on 4/4/2025.] (Entered: 03/24/2025)

DECLARATION of Andrew G. Celli, Jr. in Support re: 15 Proposed Order to Show Cause With Emergency Relief,,. Document filed by AMERICAN FEDERATION OF GOVERNMENT EMPLOYEES (AFGE), AMERICAN FEDERATION OF STATE, COUNTY AND MUNICIPAL EMPLOYEES (AFSCME), AMERICAN FOREIGN SERVICE ASSOCIATION (AFSA), JESSICA JERREAT, JOHN DOES 1-4, KATHRYN NEEPER, REPORTERS SANS FRONTIRES, REPORTERS WITHOUT BORDERS, INC., THE NEWSGUILD-CWA, PATSY WIDAKUSWARA. (Attachments: # 1 Exhibit A - Continuing the Reduction of the Federal Bureaucracy - The White House, # 2 Exhibit B - The Voice of Radical America - The White House, # 3 Exhibit C - Kari Lake Press Release 3.15.25, # 4 Exhibit D - Truth Social Post 12.11.24, # 5 Exhibit E - Musk Tweet 2.9.25, # 6 Exhibit F - Lake Tweet 3.17.25, # 7 Exhibit G - Lake Tweet 3.19.25, # 8 Exhibit H - Lake Tweet 3.13.25, # 9 Exhibit I - Administrative Leave Info Email, # 10 Exhibit J - Kari Lake Welcome Email, # 11 Exhibit K - Victor Morales Email re Newswire, # 12 Exhibit L - Lake Tweet 3.15.25, # 13 Exhibit M - Dryden Declaration, # 14 Exhibit N - Hickey Declaration, # 15 Exhibit O - Bruttin Declaration, # 16 Exhibit P - Schleuss Declaration, # 17 Exhibit Q - Herman Declaration, # 18 Exhibit R - Widakuswara Declaration, # 19 Exhibit S - Jerreat Declaration, # 20 Exhibit T - Neeper Declaration, # 21 Exhibit U - John Doe 1 Declaration, # 22 Exhibit V - John Doe 2 Declaration, # 23 Exhibit W - John Doe 3 Declaration, # 24 Exhibit X - John Doe 4 Declaration, # 25 Exhibit Y - Weimers Declaration, # 26 Exhibit Z - Rapid Response 47 Tweet 3.15.25, # 27 Exhibit AA - Important Information Request Email).(Celli, Andrew) [Transferred from New York Southern on 4/4/2025.] (Entered: 03/24/2025)

MEMORANDUM OF LAW in Support re: 15 Proposed Order to Show Cause With Emergency Relief,, . Document filed by AMERICAN FEDERATION OF GOVERNMENT EMPLOYEES (AFGE), AMERICAN FEDERATION OF STATE, COUNTY AND MUNICIPAL EMPLOYEES (AFSCME), AMERICAN FOREIGN SERVICE ASSOCIATION (AFSA), JESSICA JERREAT, JOHN DOES 1-4, KATHRYN NEEPER, REPORTERS SANS FRONTIRES, REPORTERS WITHOUT BORDERS, INC., THE NEWSGUILD-CWA, PATSY WIDAKUSWARA..(Celli, Andrew) [Transferred from New York Southern on 4/4/2025.] (Entered: 03/24/2025)

***NOTICE TO ATTORNEY REGARDING DEFICIENT CIVIL COVER SHEET. Notice to attorney Andrew G. Celli to RE-FILE Document No. 2 Civil Cover Sheet. The filing is deficient for the following reason(s): the PDF attached to the docket entry for the civil cover sheet is not correct; the PDF was not properly signed by the attorney;. Re-file the document using the event type Civil Cover Sheet found under the event list Other Documents and attach the correct PDF. Use civil cover sheet issued by S.D.N.Y. dated December 4, 2024. The S.D.N.Y. Civil Cover Sheet dated December 4, 2024 is located athttp://nysd.uscourts.gov/forms/civil-cover-sheet-2.. (jgo) [Transferred from New York Southern on 4/4/2025.]

CASE OPENING INITIAL ASSIGNMENT NOTICE: The above-entitled action is assigned to Judge J. Paul Oetken. 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..(jgo) [Transferred from New York Southern on 4/4/2025.]

Magistrate Judge Gary Stein 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. (jgo) [Transferred from New York Southern on 4/4/2025.]

***NOTICE TO COURT REGARDING PROPOSED ORDER TO SHOW CAUSE WITH EMERGENCY RELIEF. Document No. 15 Proposed Order to Show Cause With Emergency Relief,, was reviewed and approved as to form. (nd) [Transferred from New York Southern on 4/4/2025.]

Case Designated ECF. (jgo) [Transferred from New York Southern on 4/4/2025.]

***NOTICE TO ATTORNEY REGARDING PARTY MODIFICATION. Notice to attorney Andrew G. Celli. The party information for the following party/parties has been modified: PATSY WIDAKUSWARA; JESSICA JERREAT; KATHRYN NEEPER; JOHN DOES 1-4; REPORTERS SANS FRONTIRES; REPORTERS WITHOUT BORDERS, INC.; AMERICAN FEDERATION OF STATE, COUNTY AND MUNICIPAL EMPLOYEES (AFSCME); AMERICAN FEDERATION OF GOVERNMENT EMPLOYEES (AFGE); AMERICAN FOREIGN SERVICE ASSOCIATION (AFSA); THE NEWSGUILD-CWA; KARI LAK; VICTOR MORALES; U.S. AGENCY FOR GLOBAL MEDIA. The information for the party/parties has been modified for the following reason/reasons: party name was entered in all caps;. (jgo) [Transferred from New York Southern on 4/4/2025.]

CIVIL COVER SHEET filed..(Celli, Andrew) [Transferred from New York Southern on 4/4/2025.] (Entered: 03/24/2025)

ORDER: The parties shall appear telephonically for a scheduling conference today, March 24, 2025, at 11:00 a.m. Counsel shall call (855) 244-8681 and use ID code 23128287066 at that time. (HEREBY ORDERED by Judge J. Paul Oetken) (Text Only Order) (lw) [Transferred from New York Southern on 4/4/2025.] (Entered: 03/24/2025)

NOTICE OF APPEARANCE by Danielle Marryshow on behalf of Kari Lake, Victor Morales, U.S. Agency for Global Media..(Marryshow, Danielle) [Transferred from New York Southern on 4/4/2025.] (Entered: 03/24/2025)

NOTICE OF APPEARANCE by Tomoko Onozawa on behalf of Kari Lake, Victor Morales, U.S. Agency for Global Media..(Onozawa, Tomoko) [Transferred from New York Southern on 4/4/2025.] (Entered: 03/24/2025)

ORDER: Counsel for the parties are directed to appear for a hearing on Plaintiffs' motion for a temporary restraining order on March 28, 2025, at 10:00 a.m. in Courtroom 318 of the Thurgood Marshall United States Courthouse, 40 Foley Square, New York, NY 10007. Any responsive submission on behalf of Defendants shall be filed by March 27, 2025, at 5:00 p.m., notwithstanding the deadline discussed during the March 24, 2025 telephone conference. SO ORDERED. ( Responses due by 3/27/2025, Motion Hearing set for 3/28/2025 at 10:00 AM in Courtroom 318, Thurgood Marshall U.S. Courthouse, 40 Foley Square, New York, NY 10007 before Judge J. Paul Oetken.) (Signed by Judge J. Paul Oetken on 3/24/2025) (vfr) [Transferred from New York Southern on 4/4/2025.] (Entered: 03/24/2025)

NOTICE OF APPEARANCE by Teague Pryde Paterson on behalf of American Federation of State, County and Municipal Employees (AFSCME)..(Paterson, Teague) [Transferred from New York Southern on 4/4/2025.] (Entered: 03/24/2025)

Minute Entry for proceedings held before Judge J. Paul Oetken: Telephonic Scheduling Conference held on 3/24/2025. Hearing on Plaintiffs' motion for a temporary restraining order is scheduled for March 28, 2025, at 10:00 a.m. in Courtroom 318 of 40 Foley Square. (bh) [Transferred from New York Southern on 4/4/2025.]

LETTER addressed to Judge J. Paul Oetken from Andrew G. Celli, Jr. dated March 25, 2025 re: TRO. Document filed by American Federation of Government Employees (AFGE), American Federation of State, County and Municipal Employees (AFSCME), American Foreign Service Association (AFSA), John Does 1-4, Jessica Jerreat, Kathryn Neeper, Reporters Sans Frontieres, Reporters Without Borders, Inc., The Newsguild-CWA, Patsy Widakuswara..(Celli, Andrew) [Transferred from New York Southern on 4/4/2025.] (Entered: 03/25/2025)

***NOTICE TO ATTORNEY REGARDING DEFICIENT RULE 7.1 CORPORATE DISCLOSURE STATEMENT. Notice to Attorney Andrew G. Celli to RE-FILE Document No. 4 Rule 7.1 Corporate Disclosure Statement,. The filing is deficient for the following reason(s): The Attorney who signed the PDF is not the Attorney who electronically file the Rule 7.1 Corporate Disclosure Statement;. Re-file the document using the event type Rule 7.1 Corporate Disclosure Statement found under the event list Other Documents - select the correct filer/filers - attach the correct signed PDF - when prompted with the message "Are there any corporate parents or other affiliates?", select the Yes or No radio button - If Yes - enter the corporate parent/other affiliate, click the Search button - select the correct corporate parent/other affiliate name from the search results list or if no person found, create a new corporate parent/other affiliate - select the party to whom the corporate parent/other affiliate should be linked - add corporate parent/other affiliate names one at a time. (lb) [Transferred from New York Southern on 4/4/2025.]

FILING ERROR - PDF ERROR - FIRST MOTION for Raeka Safai to Appear Pro Hac Vice on behalf of AFSA. Filing fee $ 200.00, receipt number ANYSDC-30822054. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by American Foreign Service Association (AFSA). Return Date set for 3/25/2025 at 11:57 AM. (Attachments: # 1 Proposed Order AFSA PHV Proposed Order, # 2 Exhibit Certificate of Good Standing).(Safai, Raeka) Modified on 3/25/2025 (bc). [Transferred from New York Southern on 4/4/2025.] (Entered: 03/25/2025)

RULE 7.1 CORPORATE DISCLOSURE STATEMENT. No Corporate Parent. Document filed by American Federation of Government Employees (AFGE)..(Eisen, Norman) [Transferred from New York Southern on 4/4/2025.] (Entered: 03/25/2025)

MOTION for Robin F. Thurston to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-30824958. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by American Federation of Government Employees (AFGE), American Federation of State, County and Municipal Employees (AFSCME), American Foreign Service Association (AFSA), The Newsguild-CWA. (Attachments: # 1 Affidavit of Robin F. Thurston in support of Motion for Admission Pro Hac Vice, # 2 Exhibit Certificate of Good Standing, # 3 Proposed Order Proposed Order).(Thurston, Robin) [Transferred from New York Southern on 4/4/2025.] (Entered: 03/25/2025)

LETTER addressed to Judge J. Paul Oetken from AUSA Tomoko Onozawa dated March 25, 2025 re: Plaintiffs' Letter Regarding TRO and Administrative Stay (ECF No. 24). Document filed by Kari Lake, Victor Morales, U.S. Agency for Global Media..(Onozawa, Tomoko) [Transferred from New York Southern on 4/4/2025.] (Entered: 03/25/2025)

>>>NOTICE REGARDING DEFICIENT MOTION TO APPEAR PRO HAC VICE. Notice to RE-FILE Document No. 25 FIRST MOTION for Raeka Safai to Appear Pro Hac Vice on behalf of AFSA. Filing fee $ 200.00, receipt number ANYSDC-30822054. Motion and supporting papers to be reviewed by Clerk's Office staff. The filing is deficient for the following reason(s): Missing notarized affidavit/declaration and your motion must be signed;. 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) [Transferred from New York Southern on 4/4/2025.]

>>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. 27 MOTION for Robin F. Thurston to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-30824958. Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (bc) [Transferred from New York Southern on 4/4/2025.]

NOTICE OF APPEARANCE by David Zachary Seide on behalf of John Does 1-4, Jessica Jerreat, Kathryn Neeper, Patsy Widakuswara..(Seide, David) [Transferred from New York Southern on 4/4/2025.] (Entered: 03/26/2025)

FILING ERROR - DEFICIENT DOCKET ENTRY - FIRST MOTION for Matthew Stark Blumin to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-30829660. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by American Federation of State, County and Municipal Employees (AFSCME). Return Date set for 3/27/2025 at 11:00 AM..(Blumin, Matthew) Modified on 3/26/2025 (rju). [Transferred from New York Southern on 4/4/2025.] (Entered: 03/26/2025)

FILING ERROR - DEFICIENT DOCKET ENTRY - FIRST MOTION for Georgina Yeomans to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-30829721. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by American Federation of State, County and Municipal Employees (AFSCME). Return Date set for 3/27/2025 at 11:00 AM..(Yeomans, Georgina) Modified on 3/26/2025 (rju). [Transferred from New York Southern on 4/4/2025.] (Entered: 03/26/2025)

>>>NOTICE REGARDING DEFICIENT MOTION TO APPEAR PRO HAC VICE. Notice to RE-FILE Document No. 30 FIRST MOTION for Matthew Stark Blumin to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-30829660. Motion and supporting papers to be reviewed by Clerk's Office staff... The filing is deficient for the following reason(s): missing Certificate of Good Standing from Supreme Court of Florida and Pennsylvania; all of your certificates must be filed together;. 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.. (rju) [Transferred from New York Southern on 4/4/2025.]

>>>NOTICE REGARDING DEFICIENT MOTION TO APPEAR PRO HAC VICE. Notice to RE-FILE Document No. 31 FIRST MOTION for Georgina Yeomans to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-30829721. Motion and supporting papers to be reviewed by Clerk's Office staff... The filing is deficient for the following reason(s): missing Certificate of Good Standing from Supreme Court of Conn, all certificates must be filed together;. 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.. (rju) [Transferred from New York Southern on 4/4/2025.]

AMENDED MOTION for Raeka Safai to Appear Pro Hac Vice on behalf of AFSA. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by American Foreign Service Association (AFSA). Return Date set for 3/26/2025 at 02:45 PM. (Attachments: # 1 Affidavit Affidavit R Safai, # 2 Exhibit MD Cert of Good Standing, # 3 Exhibit DC Cert of Good Standing, # 4 Proposed Order Proposed Order Admission PHV).(Safai, Raeka) [Transferred from New York Southern on 4/4/2025.] (Entered: 03/26/2025)

>>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. 32 AMENDED MOTION for Raeka Safai to Appear Pro Hac Vice on behalf of AFSA. Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (rju) [Transferred from New York Southern on 4/4/2025.]

LETTER addressed to Judge J. Paul Oetken from Andrew G. Celli, Jr. dated March 26, 2025 re: Planned Employee Terminations and Supplemental Authority in Further Support of Motion for TRO. Document filed by American Federation of Government Employees (AFGE), American Federation of State, County and Municipal Employees (AFSCME), American Foreign Service Association (AFSA), John Does 1-4, Jessica Jerreat, Kathryn Neeper, Reporters Sans Frontieres, Reporters Without Borders, Inc., The Newsguild-CWA, Patsy Widakuswara. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C).(Celli, Andrew) [Transferred from New York Southern on 4/4/2025.] (Entered: 03/26/2025)

LETTER MOTION for Extension of Time to File Response/Reply as to 17 Memorandum of Law in Support, addressed to Judge J. Paul Oetken from AUSA Tomoko Onozawa dated March 26, 2025. Document filed by Kari Lake, Victor Morales, U.S. Agency for Global Media..(Onozawa, Tomoko) [Transferred from New York Southern on 4/4/2025.] (Entered: 03/26/2025)

LETTER addressed to Judge J. Paul Oetken from AUSA Tomoko Onozawa dated March 26, 2025 re: Request to Transfer Venue to the District of Columbia. Document filed by Kari Lake, Victor Morales, U.S. Agency for Global Media..(Onozawa, Tomoko) [Transferred from New York Southern on 4/4/2025.] (Entered: 03/26/2025)

ORDER denying 34 Letter Motion for Extension of Time to File Response/Reply: Denied. The TRO hearing will proceed as scheduled on Friday, March 28, 2025, at 10:00 a.m. in Courtroom 318, 40 Foley Square. Counsel for the parties should be prepared to address the merits of Plaintiffs' motion for a TRO as well as Defendants' request to transfer venue. As previously ordered, any written response by Defendants on the merits of the TRO motion shall be filed by Thursday, March 27, 2025, at 5:00 p.m. Any written response by Plaintiffs to Defendants' request to transfer venue shall also be filed by Thursday, March 27, 2025, at 5:00 p.m. SO ORDERED. (HEREBY ORDERED by Judge J. Paul Oetken)(Text Only Order) (Oetken, J.) [Transferred from New York Southern on 4/4/2025.] (Entered: 03/26/2025)

FILING ERROR - PDF ERROR - FIRST MOTION for Sharon L Papp to Appear Pro Hac Vice on behalf of AFSA. Filing fee $ 200.00, receipt number ANYSDC-30834109. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by American Foreign Service Association (AFSA). Return Date set for 3/27/2025 at 09:01 AM. (Attachments: # 1 Affidavit Affidavit S Papp, # 2 Exhibit DC Cert Good Standing, # 3 Exhibit VA Cert of Good Standing, # 4 Proposed Order Proposed Order Admission PHV).(Safai, Raeka) Modified on 3/27/2025 (bc). [Transferred from New York Southern on 4/4/2025.] (Entered: 03/27/2025)

>>>NOTICE REGARDING DEFICIENT MOTION TO APPEAR PRO HAC VICE. Notice to RE-FILE Document No. 37 FIRST MOTION for Sharon L Papp to Appear Pro Hac Vice on behalf of AFSA. Filing fee $ 200.00, receipt number ANYSDC-30834109. Motion and supporting papers to be reviewed by Clerk's Office staff. The filing is deficient for the following reason(s): missing Certificate of Good Standing from Supreme Court of Virginia;. 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) [Transferred from New York Southern on 4/4/2025.]

ORDER granting 27 Motion to Appear Pro Hac Vice. Granted. So ordered. (HEREBY ORDERED by Judge J. Paul Oetken)(Text Only Order) (bh) [Transferred from New York Southern on 4/4/2025.] (Entered: 03/27/2025)

ORDER granting 32 Motion to Appear Pro Hac Vice. Granted. So ordered. (HEREBY ORDERED by Judge J. Paul Oetken)(Text Only Order) (bh) [Transferred from New York Southern on 4/4/2025.] (Entered: 03/27/2025)

LETTER addressed to Judge J. Paul Oetken from Andrew G. Celli, Jr. dated Mar. 27, 2025 re: Opposition to Defendants' Motion to Transfer (Dkt. 35). Document filed by American Federation of Government Employees (AFGE), American Federation of State, County and Municipal Employees (AFSCME), American Foreign Service Association (AFSA), John Does 1-4, Jessica Jerreat, Kathryn Neeper, Reporters Sans Frontieres, Reporters Without Borders, Inc., The Newsguild-CWA, Patsy Widakuswara. (Attachments: # 1 Exhibit A, # 2 Exhibit B).(Bourland, Nicholas) [Transferred from New York Southern on 4/4/2025.] (Entered: 03/27/2025)

BRIEF re: 17 Memorandum of Law in Support, Defendants' Brief in Opposition to Plaintiffs' TRO Motion. Document filed by Kari Lake, Victor Morales, U.S. Agency for Global Media..(Onozawa, Tomoko) [Transferred from New York Southern on 4/4/2025.] (Entered: 03/27/2025)

FILING ERROR - PDF ERROR - MOTION for Joshua Kolb to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-30839434. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by American Federation of Government Employees (AFGE), American Federation of State, County and Municipal Employees (AFSCME), Reporters Sans Frontieres, Reporters Without Borders, Inc.. (Attachments: # 1 Proposed Order Proposed Order, # 2 Supplement Certificate of Good Standing).(Kolb, Joshua) Modified on 3/27/2025 (bc). [Transferred from New York Southern on 4/4/2025.] (Entered: 03/27/2025)

DECLARATION of Crystal G. Thomas re: 41 Brief . Document filed by Kari Lake, Victor Morales, U.S. Agency for Global Media..(Onozawa, Tomoko) [Transferred from New York Southern on 4/4/2025.] (Entered: 03/27/2025)

FILING ERROR - PDF ERROR - MOTION for Norman Eisen to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-30839549. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by American Federation of Government Employees (AFGE), American Federation of State, County and Municipal Employees (AFSCME), Reporters Sans Frontieres, Reporters Without Borders, Inc.. (Attachments: # 1 Proposed Order Proposed Order, # 2 Supplement Certificate of Good Standing).(Eisen, Norman) Modified on 3/27/2025 (bc). [Transferred from New York Southern on 4/4/2025.] (Entered: 03/27/2025)

FILING ERROR - PDF ERROR - AMENDED MOTION for Joshua Kolb to Appear Pro Hac Vice . Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by American Federation of Government Employees (AFGE), American Federation of State, County and Municipal Employees (AFSCME), Reporters Sans Frontieres, Reporters Without Borders, Inc.. (Attachments: # 1 Proposed Order Proposed Order, # 2 Supplement Certificate of Good Standing).(Kolb, Joshua) Modified on 3/27/2025 (bc). [Transferred from New York Southern on 4/4/2025.] (Entered: 03/27/2025)

>>>NOTICE REGARDING DEFICIENT MOTION TO APPEAR PRO HAC VICE. Notice to RE-FILE Document No. 42 MOTION for Joshua Kolb to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-30839434. Motion and supporting papers to be reviewed by Clerk's Office staff... The filing is deficient for the following reason(s): Missing notarized affidavit/declaration;. 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) [Transferred from New York Southern on 4/4/2025.]

>>>NOTICE REGARDING DEFICIENT MOTION TO APPEAR PRO HAC VICE. Notice to RE-FILE Document No. 44 MOTION for Norman Eisen to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-30839549. Motion and supporting papers to be reviewed by Clerk's Office staff... The filing is deficient for the following reason(s): Missing notarized affidavit/declaration;. 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) [Transferred from New York Southern on 4/4/2025.]

>>>NOTICE REGARDING DEFICIENT MOTION TO APPEAR PRO HAC VICE. Notice to RE-FILE Document No. 45 AMENDED MOTION for Joshua Kolb to Appear Pro Hac Vice . Motion and supporting papers to be reviewed by Clerk's Office staff... The filing is deficient for the following reason(s): Missing notarized affidavit/declaration;. 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) [Transferred from New York Southern on 4/4/2025.]

MOTION for Joshua Kolb to Appear Pro Hac Vice . Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by American Federation of Government Employees (AFGE), American Federation of State, County and Municipal Employees (AFSCME), Reporters Sans Frontieres, Reporters Without Borders, Inc.. (Attachments: # 1 Proposed Order Proposed Order, # 2 Supplement Certificate of Good Standing, # 3 Affidavit Notarized ffidavit).(Kolb, Joshua) [Transferred from New York Southern on 4/4/2025.] (Entered: 03/27/2025)

NOTICE OF APPEARANCE by David A. Schulz on behalf of John Does 1-4, Jessica Jerreat, Kathryn Neeper, Patsy Widakuswara..(Schulz, David) [Transferred from New York Southern on 4/4/2025.] (Entered: 03/27/2025)

NOTICE OF APPEARANCE by Tobin Raju on behalf of John Does 1-4, Jessica Jerreat, Kathryn Neeper, Patsy Widakuswara..(Raju, Tobin) [Transferred from New York Southern on 4/4/2025.] (Entered: 03/27/2025)

MOTION to File Amicus Brief in Support of Plaintiffs. Document filed by Reporters Committee for Freedom of the Press. (Attachments: # 1 Exhibit Proposed Amicus Brief).(Weeks, Lin) [Transferred from New York Southern on 4/4/2025.] (Entered: 03/28/2025)

MOTION for Norman L. Eisen to Appear Pro Hac Vice . Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by American Federation of Government Employees (AFGE), American Federation of State, County and Municipal Employees (AFSCME), Reporters Sans Frontieres, Reporters Without Borders, Inc.. (Attachments: # 1 Proposed Order Proposed Order, # 2 Affidavit PHV Affidavit, # 3 Supplement Certificate of Good Standing).(Eisen, Norman) [Transferred from New York Southern on 4/4/2025.] (Entered: 03/28/2025)

Minute Entry for proceedings held before Judge J. Paul Oetken: Hearing on Plaintiffs' motion for a temporary restraining order held. Decision reserved. See transcript. (bh) [Transferred from New York Southern on 4/4/2025.]

>>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. 46 MOTION for Joshua Kolb to Appear Pro Hac Vice . Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (bc) [Transferred from New York Southern on 4/4/2025.]

>>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. 50 MOTION for Norman L. Eisen to Appear Pro Hac Vice . Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (bc) [Transferred from New York Southern on 4/4/2025.]

ORDER granting 49 Letter Motion to File Amicus Brief: Granted. (HEREBY ORDERED by Judge J. Paul Oetken)(Text Only Order) (Oetken, J.) [Transferred from New York Southern on 4/4/2025.] (Entered: 03/28/2025)

ORDER granting 46 Motion for Joshua Kolb to Appear Pro Hac Vice: GRANTED. (HEREBY ORDERED by Judge J. Paul Oetken)(Text Only Order) (Oetken, J.) [Transferred from New York Southern on 4/4/2025.] (Entered: 03/28/2025)

ORDER granting 50 Motion for Norman L. Eisen to Appear Pro Hac Vice: GRANTED. (HEREBY ORDERED by Judge J. Paul Oetken)(Text Only Order) (Oetken, J.) [Transferred from New York Southern on 4/4/2025.] (Entered: 03/28/2025)

OPINION AND ORDER For the foregoing reasons, Plaintiffs' motion for a temporary restraining order is GRANTED. IT IS HEREBY ORDERED that, pending the hearing and determination of Plaintiffs' motion for a preliminary injunction, Defendants, and those acting in concert with them, are temporarily enjoined from taking any further actions to implement or effectuate the March 14, 2025 Executive Order entitled "Continuing the Reduction of the Federal Bureaucracy" as to USAGM and the March 15, 2025 email issued to all VOA staff, or take any action to reduce USAGM's workforce (whether employees, contractors, or grantees), included but not limited to (i) proceeding with any further attempt to terminate, reduce-in-force, place on leave, or furlough any USAGM employee, or contractor, (ii) terminating (or proceeding with terminating as announced) any USAGM grant or contract or proceeding with terminating any USAGM Personal Services Contractors (PSCs) who received notice after March 14, 2025 that their contract would be terminated, including but not limited to John Doe 3 and John Doe 4 who received notice that their contracts would be terminated on March 31, 2025, or (iii) closing any USAGM office or requiring employees or contractors in overseas offices to return to the United States. SO ORDERED. (Signed by Judge J. Paul Oetken on 3/28/2025) (jca) [Transferred from New York Southern on 4/4/2025.] (Entered: 03/28/2025)

MOTION for Kristin Bateman to Appear Pro Hac Vice . Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by American Federation of Government Employees (AFGE), American Federation of State, County and Municipal Employees (AFSCME), American Foreign Service Association (AFSA), The Newsguild-CWA. (Attachments: # 1 Affidavit of Kristin Bateman in support of Motion for Admission Pro Hac Vice, # 2 Exhibit Certificate of Good Standing, # 3 Proposed Order Proposed Order).(Bateman, Kristin) Modified on 4/2/2025 (rju). Modified on 4/3/2025 (rju). [Transferred from New York Southern on 4/4/2025.] (Entered: 04/02/2025)

Pro Hac Vice Fee Payment: for 55 MOTION for Kristin Bateman to Appear Pro Hac Vice . Motion and supporting papers to be reviewed by Clerk's Office staff.. Filing fee $ 200.00, receipt number ANYSDC-30867258..(Bateman, Kristin) [Transferred from New York Southern on 4/4/2025.]

LETTER addressed to Judge J. Paul Oetken from Danielle J. Marryshow dated April 2, 2025 re: Defendants' Motion to Transfer Venue. Document filed by Kari Lake, Victor Morales, U.S. Agency for Global Media..(Marryshow, Danielle) [Transferred from New York Southern on 4/4/2025.] (Entered: 04/02/2025)

>>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. 55 MOTION for Kristin Bateman to Appear Pro Hac Vice . Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (rju) [Transferred from New York Southern on 4/4/2025.]

LETTER addressed to Judge J. Paul Oetken from Andrew G. Celli, Jr. dated April 3, 2025 re: Proposed Schedule for Preliminary Injunction Briefing and in Response to Defendants' April 2, 2025 Letter. Document filed by American Federation of Government Employees (AFGE), American Federation of State, County and Municipal Employees (AFSCME), American Foreign Service Association (AFSA), John Does 1-4, Jessica Jerreat, Kathryn Neeper, Reporters Sans Frontieres, Reporters Without Borders, Inc., The Newsguild-CWA, Patsy Widakuswara..(Celli, Andrew) [Transferred from New York Southern on 4/4/2025.] (Entered: 04/03/2025)

TRANSCRIPT of Proceedings re: ORAL ARGUMENT held on 3/28/2025 before Judge J. Paul Oetken. Court Reporter/Transcriber: Lisa O'Brien, (212) 805-0320. 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 4/24/2025. Redacted Transcript Deadline set for 5/5/2025. Release of Transcript Restriction set for 7/2/2025..(McGuirk, Kelly) [Transferred from New York Southern on 4/4/2025.] (Entered: 04/03/2025)

NOTICE OF FILING OF OFFICIAL TRANSCRIPT Notice is hereby given that an official transcript of a ORAL ARGUMENT proceeding held on 3/28/2025 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) [Transferred from New York Southern on 4/4/2025.] (Entered: 04/03/2025)

LETTER addressed to Judge J. Paul Oetken from AUSA Tomoko Onozawa dated April 3, 2025 re: Proposed Schedule for Preliminary Injunction Briefing and in response to Plaintiffs' April 3, 2025 Letter [Dkt. No. 57]. Document filed by Kari Lake, Victor Morales, U.S. Agency for Global Media..(Onozawa, Tomoko) [Transferred from New York Southern on 4/4/2025.] (Entered: 04/03/2025)

ORDER: For the foregoing reasons, Defendants' motion to transfer venue pursuant to 28 U.S.C. § 1404(a) is GRANTED. Notwithstanding the transfer to the United States District Court for the District of Columbia, the temporary restraining order issued by this Court on March 28, 2025 (ECF No. 54) remains in full force and effect unless and until modified, extended, or vacated by the transferee court. See, e.g., Khalil v. Joyce, ---F. Supp. 3d. ---, No. 25-CV-1935, 2025 WL 849803, at *14 (S.D.N.Y. Mar. 19, 2025) (ordering that a stay of removal remain in place until a transferee court modified it); Perficient, Inc. v. Priore, No. 16-CV-249, 2016 WL 866090, at *6 (E.D. Mo. Mar. 7, 2016) ("As this Court has jurisdiction over the defendant, the Temporary Restraining Order remains in full force and effect [after transfer] until its scheduled expiration date."); Valassis Commc'ns, Inc. v. News Corp., No. 13-14654, 2017 WL 4230646, at *5 (E.D. Mich. Sept. 25, 2017) (concurrently entering a preliminary injunction and granting a motion to transfer); Vendavo, Inc. v. Long, 397 F. Supp. 3d 1115, 1148-49 (N.D. Ill. 2019) (same). The Clerk of Court is directed to transfer this case to the United States District Court for the District of Columbia. Further, the Clerk shall effectuate the transfer of the case immediately, notwithstanding the seven-day period provided for in Local Rule 83.1, which is hereby waived. SO ORDERED. (Signed by Judge J. Paul Oetken on 4/4/2025) (vfr) [Transferred from New York Southern on 4/4/2025.] (Entered: 04/04/2025)

Case Transferred Out

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 Columbia.(vfr) [Transferred from New York Southern on 4/4/2025.]

Case transferred in from District of New York Southern; Case Number 1:25-cv-02390. Original file,transfer order and docket sheet received. (Entered: 04/04/2025)

NOTICE of Appearance by Georgina C. Yeomans on behalf of AMERICAN FEDERATION OF STATE, COUNTY AND MUNICIPAL EMPLOYEES (AFSCME) (Yeomans, Georgina) (Entered: 04/04/2025)

NOTICE OF RELATED CASE by AMERICAN FEDERATION OF STATE, COUNTY AND MUNICIPAL EMPLOYEES (AFSCME). Case related to Case No. 25-cv-887. (Attachments: # 1 Supplement Additional Related Cases)(Yeomans, Georgina) (Entered: 04/04/2025)

NOTICE of Appearance by Matthew Stark Blumin on behalf of AMERICAN FEDERATION OF STATE, COUNTY AND MUNICIPAL EMPLOYEES (AFSCME) (Blumin, Matthew) (Main Document 65 replaced on 4/7/2025) (zdp). (Main Document 65 replaced on 4/7/2025) (zdp). (Entered: 04/07/2025)

NOTICE of Appearance by Daniel M. Eisenberg on behalf of AMERICAN FEDERATION OF GOVERNMENT EMPLOYEES (AFGE), AMERICAN FEDERATION OF STATE, COUNTY AND MUNICIPAL EMPLOYEES (AFSCME), AMERICAN FOREIGN SERVICE ASSOCIATION (AFSA), JOHN DOES 1-4, JESSICA JERREAT, KATHRYN NEEPER, NEWSGUILD-CWA, PATSY WIDAKUSWARA (Eisenberg, Daniel) (Entered: 04/07/2025)

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Andrew G. Celli, Jr., Filing fee $ 100, receipt number ADCDC-11597636. Fee Status: Fee Paid. by AMERICAN FEDERATION OF GOVERNMENT EMPLOYEES (AFGE), AMERICAN FEDERATION OF STATE, COUNTY AND MUNICIPAL EMPLOYEES (AFSCME), AMERICAN FOREIGN SERVICE ASSOCIATION (AFSA), JOHN DOES 1-4, JESSICA JERREAT, KATHRYN NEEPER, NEWSGUILD-CWA, PATSY WIDAKUSWARA. (Attachments: # 1 Declaration Declaration of Andrew G. Celli, Jr., # 2 Exhibit Certificate of Good Standing)(Eisenberg, Daniel) (Entered: 04/08/2025)

Notice of Provisional/Government Not Certified Status

Case directly reassigned to Judge Royce C. Lamberth as related. Judge Carl J. Nichols is no longer assigned to the case. (ztnr) (Entered: 04/08/2025)

NOTICE of Provisional/Government Not Certified Status re 63 NOTICE of Appearance by Georgina C. Yeomans on behalf of AMERICAN FEDERATION OF STATE, COUNTY AND MUNICIPAL EMPLOYEES (AFSCME) (Yeomans, Georgina).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 4/15/2025. (zapb)

RESOLVED.....NOTICE of Provisional/Government Not Certified Status re 63 NOTICE of Appearance by Georgina C. Yeomans on behalf of AMERICAN FEDERATION OF STATE, COUNTY AND MUNICIPAL EMPLOYEES (AFSCME) (Yeomans, Georgina).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 4/15/2025. (zapb) Modified on 4/9/2025 (zhcn).

NOTICE of Appearance by Brenda A. Gonzalez Horowitz on behalf of All Defendants (Gonzalez Horowitz, Brenda) (Entered: 04/08/2025)

ORDER: Proposed Briefing Schedule due by 4/9/2025. See Order for details. Signed by Judge Royce C. Lamberth on 4/8/2025. (lcrcl3) (Entered: 04/08/2025)

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Nicholas Bourland, Filing fee $ 100, receipt number ADCDC-11600261. Fee Status: Fee Paid. by AMERICAN FEDERATION OF GOVERNMENT EMPLOYEES (AFGE), AMERICAN FEDERATION OF STATE, COUNTY AND MUNICIPAL EMPLOYEES (AFSCME), AMERICAN FOREIGN SERVICE ASSOCIATION (AFSA), JOHN DOES 1-4, JESSICA JERREAT, KATHRYN NEEPER, NEWSGUILD-CWA, PATSY WIDAKUSWARA. (Attachments: # 1 Declaration Declaration of Nicholas Bourland, # 2 Exhibit Certificate of Good Standing)(Eisenberg, Daniel) (Entered: 04/08/2025)

NOTICE of Appearance by Stephanie R. Johnson on behalf of KARI LAKE, VICTOR MORALES, U.S. AGENCY FOR GLOBAL MEDIA (Johnson, Stephanie) (Entered: 04/08/2025)

MOTION to Vacate 54 Memorandum & Opinion,,,,, and Dissolve March 28, 2025 Temporary Restraining Order by KARI LAKE, VICTOR MORALES, U.S. AGENCY FOR GLOBAL MEDIA. (Gonzalez Horowitz, Brenda) (Entered: 04/08/2025)