Case: Chung v. Trump

President Donald Trump

President Donald Trump

FILING ERROR - WRONG EVENT TYPE SELECTED FROM MENU - COMPLAINT against Pamela Bondi, William P. Joyce, Todd M. Lyons, Kristi Noem, Marco Rubio, Donald J. Trump. (Filing Fee $ 405.00, Receipt Number ANYSDC-30817442)Document filed by Yunseo Chung..(Levitova, Sonya) Modified on 3/25/2025 (jgo). (Entered: 03/24/2025)

CIVIL COVER SHEET filed..(Levitova, Sonya) (Entered: 03/24/2025)

REQUEST FOR ISSUANCE OF SUMMONS as to Donald J. Trump, Marco Rubio, Pamela Bondi, Kristi Noem, Todd M. Lyons, and William P. Joyce, in their official capacities, re: 1 Complaint. Document filed by Yunseo Chung..(Levitova, Sonya) (Entered: 03/24/2025)

NOTICE OF APPEARANCE by Jordan Wells on behalf of Yunseo Chung..(Wells, Jordan) (Entered: 03/24/2025)

NOTICE OF APPEARANCE OF PRO BONO COUNSEL by Mudassar Hayat Toppa on behalf of Yunseo Chung.(Toppa, Mudassar) (Entered: 03/24/2025)

PROPOSED ORDER TO SHOW CAUSE WITH EMERGENCY RELIEF. Document filed by Yunseo Chung. (Attachments: # 1 Proposed Order Proposed Temporary Restraining Order).(Levitova, Sonya) Proposed Order to Show Cause to be reviewed by Clerk's Office staff. (Entered: 03/24/2025)

1 Proposed Order Proposed Temporary Restraining Order

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DECLARATION of Ramzi Kassem in Support re: 6 Proposed Order to Show Cause With Emergency Relief,. Document filed by Yunseo Chung..(Levitova, Sonya) (Entered: 03/24/2025)

MEMORANDUM OF LAW in Support re: 6 Proposed Order to Show Cause With Emergency Relief, . Document filed by Yunseo Chung..(Levitova, Sonya) (Entered: 03/24/2025)

DECLARATION of Sonya Levitova in Support re: 8 Memorandum of Law in Support. Document filed by Yunseo Chung. (Attachments: # 1 Exhibit A - Politico Article, # 2 Exhibit B - New York Times Article - March 15, 2025, # 3 Exhibit C - NPR Interview, # 4 Exhibit D - Associated Press Article, # 5 Exhibit E - New York Times Article - March 9, 2025, # 6 Exhibit F - The New Republic Article, # 7 Exhibit G - Denton Record-Chronicle Article, # 8 Exhibit H - Redacted - Desk Appearance Ticket, # 9 Exhibit I - Redacted - Text Message, # 10 Exhibit J - Redacted - Administrative Arrest Warrant, # 11 Exhibit K - Redacted - Judicial Search Warrant, # 12 Exhibit L - The Atlantic Article, # 13 Exhibit M - Declaration of Nayantara Bhushan, # 14 Exhibit N - Declaration of Naz Ahmad, # 15 Exhibit O - Original and Amended Notice to Appear for Mahmoud Khalil, # 16 Exhibit P - Redacted - Columbia University Public Safety Email).(Levitova, Sonya) (Entered: 03/24/2025)

1 Exhibit A - Politico Article

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2 Exhibit B - New York Times Article - March 15, 2025

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3 Exhibit C - NPR Interview

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4 Exhibit D - Associated Press Article

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5 Exhibit E - New York Times Article - March 9, 2025

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6 Exhibit F - The New Republic Article

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7 Exhibit G - Denton Record-Chronicle Article

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8 Exhibit H - Redacted - Desk Appearance Ticket

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9 Exhibit I - Redacted - Text Message

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10 Exhibit J - Redacted - Administrative Arrest Warrant

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11 Exhibit K - Redacted - Judicial Search Warrant

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12 Exhibit L - The Atlantic Article

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13 Exhibit M - Declaration of Nayantara Bhushan

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14 Exhibit N - Declaration of Naz Ahmad

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15 Exhibit O - Original and Amended Notice to Appear for Mahmoud Khalil

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16 Exhibit P - Redacted - Columbia University Public Safety Email

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MOTION to Seal Certain Exhibits to ECF No. 9. Document filed by Yunseo Chung. (Attachments: # 1 Proposed Order to Seal).(Levitova, Sonya) (Entered: 03/24/2025)

1 Proposed Order to Seal

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***SELECTED PARTIES***DECLARATION of Sonya Levitova in Support re: 8 Memorandum of Law in Support. Document filed by Yunseo Chung. (Attachments: # 1 Exhibit A - Politico Article, # 2 Exhibit B - New York Times Article - March 15, 2025, # 3 Exhibit C - NPR Interview, # 4 Exhibit D - Associated Press Article, # 5 Exhibit E - New York Times Article - March 9, 2025, # 6 Exhibit F - The New Republic Article, # 7 Exhibit G - Denton Record-Chronicle Article, # 8 Exhibit H - Unredacted - Desk Appearance Ticket, # 9 Exhibit I - Unredacted - Text Message, # 10 Exhibit J - Unredacted - Administrative Arrest Warrant, # 11 Exhibit K - Unredacted - Judicial Search Warrant, # 12 Exhibit L - The Atlantic Article, # 13 Exhibit M - Declaration of Nayantara Bhushan, # 14 Exhibit N - Declaration of Naz Ahmad, # 15 Exhibit O - Original and Amended Notice to Appear for Mahmoud Khalil, # 16 Exhibit P - Unredacted - Columbia University Public Safety Email)Motion or Order to File Under Seal: 10 .(Levitova, Sonya) (Entered: 03/24/2025)

NOTICE OF APPEARANCE OF PRO BONO COUNSEL by Nathan Yaffe on behalf of Yunseo Chung.(Yaffe, Nathan) (Entered: 03/24/2025)

NOTICE OF APPEARANCE OF PRO BONO COUNSEL by Naz Ahmad on behalf of Yunseo Chung.(Ahmad, Naz) (Entered: 03/24/2025)

NOTICE OF APPEARANCE OF PRO BONO COUNSEL by Joshua Nicholas Colangelo-Bryan on behalf of Yunseo Chung.(Colangelo-Bryan, Joshua) (Entered: 03/24/2025)

NOTICE OF APPEARANCE OF PRO BONO COUNSEL by Ramzi Kassem on behalf of Yunseo Chung.(Kassem, Ramzi) (Entered: 03/25/2025)

Notice to Attorney Regarding Deficient Pleading

Case Opening Initial Assignment Notice

***NOTICE TO ATTORNEY REGARDING DEFICIENT PLEADING. Notice to Attorney Sonya Levitova to RE-FILE Document No. 1 Complaint,. The filing is deficient for the following reason(s): the wrong event type was used to file the pleading;. Re-file the pleading using the event type Complaint/Petition in the Nature of Mandamus found under the event list Complaints and Other Initiating Documents - attach the correct signed PDF - select the individually named filer/filers - select the individually named party/parties the pleading is against. (jgo)

CASE OPENING INITIAL ASSIGNMENT NOTICE: The above-entitled action is assigned to Judge Naomi Reice Buchwald. 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)

Case Designation

Magistrate Judge Jennifer Willis 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)

Case Designated ECF

Notice to Court Regarding Proposed Order

Case Designated ECF. (jgo)

***NOTICE TO COURT REGARDING PROPOSED ORDER TO SHOW CAUSE WITH EMERGENCY RELIEF. Document No. 6 Proposed Order to Show Cause With Emergency Relief was reviewed and approved as to form. (km)

ELECTRONIC SUMMONS ISSUED as to Pamela Bondi, William P. Joyce, Todd M. Lyons, Kristi Noem, Marco Rubio, Donald J. Trump..(jgo) (Entered: 03/25/2025)

COMPLAINT IN THE NATURE OF MANDAMUS against Pamela Bondi, William P. Joyce, Todd M. Lyons, Kristi Noem, Marco Rubio, Donald J. Trump.Document filed by Yunseo Chung..(Levitova, Sonya) (Entered: 03/25/2025)

NOTICE OF APPEARANCE by Jeffrey Stuart Oestericher on behalf of Pamela Bondi, William P. Joyce, Todd M. Lyons, Kristi Noem, Marco Rubio, Donald J. Trump..(Oestericher, Jeffrey) (Entered: 03/25/2025)

TEMPORARY RESTRAINING ORDER: 1) Plaintiff-Petitioner's Motion for a Temporary Restraining Order is granted. 2) Defendants-Respondents are enjoined from detaining the Plaintiff-Petitioner pending further order of this Court; 3) Defendants-Respondents are enjoined from transferring the Plaintiff-Petitioner from the jurisdiction of this District pending further order of this Court; 4) Should Defendants-Respondents seek to detain Plaintiff-Petitioner on any asserted basis other than pursuing her removal under 8 U.S.C. § 1227(a)(4)(C) pending the Cou1t's decision on a preliminary injunction, Defendants-Respondents are ordered to provide sufficient advance notice to the Court and counsel, in order to enable Plaintiff Petitioner an opportunity to be heard regarding whether any such asserted basis for detention constitutes a pretext for First Amendment retaliation; and 5) The bond requirement of Federal Rule of Civil Procedure 65(c) is waived. IT IS SO ORDERED. (Signed by Judge Naomi Reice Buchwald on 3/25/2025) (jjc) (Entered: 03/25/2025)

ORDER TO SHOW CAUSE FOR TEMPORARY RESTRAINING ORDER AND PRELIMINARY INJUNCTION: It is ORDERED that the above named Defendants show cause before this Court, at Room 21A United States Courthouse, 500 Pearl Street, in the City, County and State of New York, on May 20, 2025 at 11 o'clock, or as soon thereafter as counsel may be heard, why an order should be issued pursuant to Rule 65 of the Federal Rules of Civil Procedure. ORDERED, that answering papers, if any, must be served by email on Plaintiff-Petitioner's attorneys of record in this action no later than 5:00 p.m. on April 11, 2025 and reply papers, if any, must be served by hand or email upon Defendants-Respondents' attorneys no later than 5:00 p.m. on April 29, 2025. SO ORDERED. Show Cause Hearing set for 5/20/2025 at 11:00 AM in Courtroom 21A, 500 Pearl Street, New York, NY 10007 before Judge Naomi Reice Buchwald. (Signed by Judge Naomi Reice Buchwald on 3/25/2025) (jjc) (Entered: 03/25/2025)

ORDER GRANTING MOTION FOR LEAVE TO FILE DOCUMENTS UNDER SEAL granting 10 Motion to Seal. Upon review of Plaintiff-Petitioner's Motion for Leave to File Supporting Exhibits Under Seal, filed March 24, 2025, IT IS HEREBY ORDERED THAT Plaintiff-Petitioner is permitted to file certain exhibits supporting her Proposed Order to Show Cause for Temporary Restraining Order and/or Preliminary Injunction, in redacted form on the public docket, and in unredacted form under seal. IT IS SO ORDERED. (Signed by Judge Naomi Reice Buchwald on 3/25/2025) (rro) (Entered: 03/26/2025)

NOTICE OF APPEARANCE by Jonathan S. Abady on behalf of Yunseo Chung..(Abady, Jonathan) (Entered: 03/26/2025)

NOTICE OF APPEARANCE by Katherine R. Rosenfeld on behalf of Yunseo Chung..(Rosenfeld, Katherine) (Entered: 03/26/2025)

NOTICE OF APPEARANCE by Jonathan L. Hafetz on behalf of Yunseo Chung..(Hafetz, Jonathan) (Entered: 03/27/2025)

Show Cause Hearing

NOTICE OF APPEARANCE OF PRO BONO COUNSEL by Tarek Ziad Ismail on behalf of Yunseo Chung.(Ismail, Tarek) (Entered: 04/02/2025)

LETTER MOTION for Discovery to Unseal Materials Underlying the Search Warrant Issued on March 13, 2025 addressed to Judge Naomi Reice Buchwald from Sonya Levitova dated April 4, 2025. Document filed by Yunseo Chung..(Levitova, Sonya) (Entered: 04/04/2025)

NOTICE OF APPEARANCE by Elora Mukherjee on behalf of Immigration Lawyers, Law Professors, and Scholars..(Mukherjee, Elora) (Entered: 04/08/2025)

LETTER MOTION to File Amicus Brief on Behalf of More Than 110 Immigration Lawyers, Law Professors, and Scholars addressed to Judge Naomi Reice Buchwald from Elora Mukherjee, on behalf of proposed amici curiae, more than 110 immigration lawyers, law professors, and scholars dated April 8, 2025. Document filed by Immigration Lawyers, Law Professors, and Scholars. (Attachments: # 1 Exhibit AMICUS BRIEF OF MORE THAN 110 IMMIGRATION LAWYERS, LAW PROFESSORS, AND SCHOLARS AS AMICI CURIAE IN SUPPORT OF PETITIONER, # 2 Appendix DECLARATION OF GRAEME BLAIR, Ph.D. AND DAVID HAUSMAN, J.D., Ph.D., # 3 Appendix LIST OF AMICI).(Mukherjee, Elora) (Entered: 04/08/2025)

1 Exhibit AMICUS BRIEF OF MORE THAN 110 IMMIGRATION LAWYERS, LAW PROFESSORS, AND S

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2 Appendix DECLARATION OF GRAEME BLAIR, Ph.D. AND DAVID HAUSMAN, J.D., Ph.D.

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3 Appendix LIST OF AMICI

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ORDER granting 28 Letter Motion to File Amicus Brief. Leave to file the attached amicus curiae brief is granted. So ordered. (Signed by Judge Naomi Reice Buchwald on 4/9/2025) (sgz) (Entered: 04/09/2025)

LETTER MOTION for Discovery on an Expedited Basis addressed to Judge Naomi Reice Buchwald from Sonya Levitova dated April 10, 2025. Document filed by Yunseo Chung. (Attachments: # 1 Exhibit A - Redacted March 2025 Letter by Secretary Rubio).(Levitova, Sonya) (Entered: 04/10/2025)

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NOTICE OF APPEARANCE by Brandon Matthew Waterman on behalf of Pamela Bondi, William P. Joyce, Todd M. Lyons, Kristi Noem, Marco Rubio, Donald J. Trump..(Waterman, Brandon) (Entered: 04/11/2025)

MOTION to Dismiss . Document filed by Pamela Bondi, William P. Joyce, Todd M. Lyons, Kristi Noem, Marco Rubio, Donald J. Trump..(Waterman, Brandon) (Entered: 04/11/2025)

MEMORANDUM OF LAW re: 32 MOTION to Dismiss ., 20 Order to Show Cause,,, 6 Proposed Order to Show Cause With Emergency Relief, 8 Memorandum of Law in Support (Defendants-Respondents' Combined Memorandum of Law In Support of Their Motion to Dismiss AND In Opposition to Plaintiff-Petitioner's Motion for a Preliminary Injunction). Document filed by Pamela Bondi, William P. Joyce, Todd M. Lyons, Kristi Noem, Marco Rubio, Donald J. Trump..(Waterman, Brandon) (Entered: 04/11/2025)

DECLARATION of Marina Vides re: 32 MOTION to Dismiss ., 6 Proposed Order to Show Cause With Emergency Relief, 20 Order to Show Cause,,, 33 Memorandum of Law,, 8 Memorandum of Law in Support . Document filed by Pamela Bondi, William P. Joyce, Todd M. Lyons, Kristi Noem, Marco Rubio, Donald J. Trump..(Waterman, Brandon) (Entered: 04/11/2025)

LETTER addressed to Judge Naomi Reice Buchwald from Brandon M. Waterman dated April 11, 2025 re: Brief summary of the substantive arguments advanced in the Defendants-Respondents' motion to dismiss, in accordance with Section 2(C)(1) of the Court's Individual Practices. Document filed by Pamela Bondi, William P. Joyce, Todd M. Lyons, Kristi Noem, Marco Rubio, Donald J. Trump..(Waterman, Brandon) (Entered: 04/11/2025)

MEMORANDUM OF LAW in Opposition re: 30 LETTER MOTION for Discovery on an Expedited Basis addressed to Judge Naomi Reice Buchwald from Sonya Levitova dated April 10, 2025. . Document filed by Pamela Bondi, William P. Joyce, Todd M. Lyons, Kristi Noem, Marco Rubio, Donald J. Trump..(Oestericher, Jeffrey) (Entered: 04/14/2025)

PROPOSED STIPULATION AND ORDER. Document filed by Yunseo Chung..(Levitova, Sonya) (Entered: 04/18/2025)

STIPULATION AND ORDER: Plaintiff-Petitioner and Defendants-Respondents, through their undersigned counsel, STIPULATE AND AGREE as follows: 1. Plaintiff-Petitioner's opposition to Defendants-Respondents' motion to dismiss will be filed separately from her reply in further support of her motion for a preliminary injunction, in compliance with the length limitations of Local Civil Rule 7.1(c), no later than April 29, 2025. 2. Defendants-Respondents' reply, if any, in further support of their motion to dismiss Plaintiff-Petitioner's case shall be filed no later than May 9, 2025. 3. A facsimile or scanned copy of this stipulation will be considered the same as an original and may be filed with the court electronically. It is so ORDERED. (Responses due by 4/29/2025, Replies due by 5/9/2025.) (Signed by Judge Naomi Reice Buchwald on 4/21/2025) (sgz) (Entered: 04/21/2025)