Case: National Association for the Advancement of Colored People v. United States of America

President Donald Trump

COMPLAINT against Linda McMahon, THE UNITED STATES OF AMERICA, United States Department of Education ( Filing fee $ 405 receipt number AMDDC-11861968.), filed by Mara Greengrass, AFSCME Council 3, NAACP South Carolina State Conference, NAACP Texas State Conference, NAACP Lubbock Branch, National Education Association, Jane Doe 2, National Association for the Advancement of Colored People, Prince George's County Educators' Association, Jane Doe 1, NAACP Florence Branch. (Attachments: # 1 Civil Cover Sheet, # 2 Summons, # 3 Summons, # 4 Summons, # 5 Summons)(Carter, Abigail) (Entered: 03/24/2025)

1 Civil Cover Sheet

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2 Summons

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3 Summons

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4 Summons

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5 Summons

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MOTION to Proceed Under Pseudonyms, to Waive Address Requirement, and for a Protective Order by Jane Doe 1, Jane Doe 2 (Attachments: # 1 Memorandum in Support Memorandum in support)(Sellers, Joseph) (Entered: 03/24/2025)

Local Rule 103.3 Disclosure Statement by Prince George's County Educators' Association (Carter, Abigail) (Entered: 03/25/2025)

PAPERLESS ORDER granting 4 Motion to Appear Pro Hac Vice on behalf of Robert Kim. Directing attorney Robert Kim to register for pro hac vice filing in the District of Maryland through PACER at https://pacer.uscourts.gov/ if attorney has not already done so. The Pro Hac Vice option must be selected when registering. Signed by Clerk on 3/25/2025. (mh4s, Deputy Clerk) (Entered: 03/25/2025)

PAPERLESS ORDER granting 5 Motion to Appear Pro Hac Vice on behalf of Jessica Levin. Directing attorney Jessica Levin to register for pro hac vice filing in the District of Maryland through PACER at https://pacer.uscourts.gov/ if attorney has not already done so. The Pro Hac Vice option must be selected when registering. Signed by Clerk on 3/25/2025. (mh4s, Deputy Clerk) (Entered: 03/25/2025)

PAPERLESS ORDER granting 6 Motion to Appear Pro Hac Vice on behalf of Theresa Luhm. Directing attorney Theresa Luhm to register for pro hac vice filing in the District of Maryland through PACER at https://pacer.uscourts.gov/ if attorney has not already done so. The Pro Hac Vice option must be selected when registering. Signed by Clerk on 3/25/2025. (mh4s, Deputy Clerk) (Entered: 03/25/2025)

PAPERLESS ORDER granting 7 Motion to Appear Pro Hac Vice on behalf of Wendy Lecker. Directing attorney Wendy Lecker to register for pro hac vice filing in the District of Maryland through PACER at https://pacer.uscourts.gov/ if attorney has not already done so. The Pro Hac Vice option must be selected when registering. Signed by Clerk on 3/25/2025. (mh4s, Deputy Clerk) (Entered: 03/25/2025)

Local Rule 103.3 Disclosure Statement by Jane Doe 1 (Sellers, Joseph) (Entered: 03/25/2025)

Local Rule 103.3 Disclosure Statement by Jane Doe 2 (Sellers, Joseph) (Entered: 03/25/2025)

Local Rule 103.3 Disclosure Statement by Mara Greengrass (Sellers, Joseph) (Entered: 03/25/2025)

Local Rule 103.3 Disclosure Statement by National Association for the Advancement of Colored People (Sellers, Joseph) (Entered: 03/25/2025)

Local Rule 103.3 Disclosure Statement by NAACP Florence Branch (Sellers, Joseph) (Entered: 03/25/2025)

Local Rule 103.3 Disclosure Statement by NAACP Lubbock Branch (Sellers, Joseph) (Entered: 03/25/2025)

Local Rule 103.3 Disclosure Statement by NAACP South Carolina State Conference (Sellers, Joseph) (Entered: 03/25/2025)

Local Rule 103.3 Disclosure Statement by NAACP Texas State Conference (Sellers, Joseph) (Entered: 03/25/2025)

Local Rule 103.3 Disclosure Statement by AFSCME Council 3 (Carter, Abigail) (Entered: 03/25/2025)

MOTION to Appear Pro Hac Vice for Marissa Marandola (Filing fee $100, receipt number AMDDC-11865049.) by National Education Association, Prince George's County Educators' Association(Carter, Abigail) (Entered: 03/25/2025)

MOTION to Appear Pro Hac Vice for Alice O'Brien (Filing fee $100, receipt number AMDDC-11865052.) by National Education Association, Prince George's County Educators' Association(Carter, Abigail) (Entered: 03/25/2025)

MOTION to Appear Pro Hac Vice for Ethan Judd (Filing fee $100, receipt number AMDDC-11863412.) by Jane Doe 1, Jane Doe 2, Mara Greengrass, NAACP Florence Branch, NAACP Lubbock Branch, NAACP South Carolina State Conference, NAACP Texas State Conference, National Association for the Advancement of Colored People(Sellers, Joseph) (Entered: 03/25/2025)

MOTION to Appear Pro Hac Vice for Robert Kim (Filing fee $100, receipt number AMDDC-11863503.) by Jane Doe 1, Jane Doe 2, Mara Greengrass, NAACP Florence Branch, NAACP Lubbock Branch, NAACP South Carolina State Conference, NAACP Texas State Conference, National Association for the Advancement of Colored People(Sellers, Joseph) (Entered: 03/25/2025)

MOTION to Appear Pro Hac Vice for Jessica Levin (Filing fee $100, receipt number AMDDC-11863516.) by Jane Doe 1, Jane Doe 2, Mara Greengrass, NAACP Florence Branch, NAACP Lubbock Branch, NAACP South Carolina State Conference, NAACP Texas State Conference, National Association for the Advancement of Colored People(Sellers, Joseph) (Entered: 03/25/2025)

MOTION to Appear Pro Hac Vice for Theresa Luhm (Filing fee $100, receipt number AMDDC-11863535.) by Jane Doe 1, Jane Doe 2, Mara Greengrass, NAACP Florence Branch, NAACP Lubbock Branch, NAACP South Carolina State Conference, NAACP Texas State Conference, National Association for the Advancement of Colored People(Sellers, Joseph) (Entered: 03/25/2025)

MOTION to Appear Pro Hac Vice for Wendy Lecker (Filing fee $100, receipt number AMDDC-11863554.) by Jane Doe 1, Jane Doe 2, Mara Greengrass, NAACP Florence Branch, NAACP Lubbock Branch, NAACP South Carolina State Conference, NAACP Texas State Conference, National Association for the Advancement of Colored People(Sellers, Joseph) (Entered: 03/25/2025)

Local Rule 103.3 Disclosure Statement by National Education Association (Carter, Abigail) (Entered: 03/25/2025)

PAPERLESS ORDER granting 3 Motion to Appear Pro Hac Vice on behalf of Ethan Judd. Directing attorney Ethan Judd to register for pro hac vice filing in the District of Maryland through PACER at https://pacer.uscourts.gov/ if attorney has not already done so. The Pro Hac Vice option must be selected when registering. Signed by Clerk on 3/25/2025. (mh4s, Deputy Clerk) (Entered: 03/25/2025)

Case Reassigned to Judge Julie Rebecca Rubin. Judge Deborah L. Boardman no longer assigned to the case. (jf3s, Deputy Clerk)

Case Assigned/Reassigned

Summons Issued 60 days as to Linda McMahon, The United States of America, United States Department of Education, U.S. Attorney and U.S. Attorney General. (dass, Deputy Clerk) (Entered: 03/26/2025)

MOTION to Appear Pro Hac Vice for Eric Rothschild (Filing fee $100, receipt number AMDDC-11867835.) by National Education Association(Carter, Abigail) (Entered: 03/26/2025)

MOTION to Appear Pro Hac Vice for Aaron S. Ament (Filing fee $100, receipt number AMDDC-11867864.) by National Education Association(Carter, Abigail) (Entered: 03/26/2025)

MOTION to Appear Pro Hac Vice for Jenna Waldman (Filing fee $100, receipt number AMDDC-11870217.) by Jane Doe 1, Jane Doe 2, Mara Greengrass, NAACP Florence Branch, NAACP Lubbock Branch, NAACP South Carolina State Conference, NAACP Texas State Conference, National Association for the Advancement of Colored People(Sellers, Joseph) (Entered: 03/27/2025)

MOTION to Appear Pro Hac Vice for Ryan Wheeler (Filing fee $100, receipt number AMDDC-11870240.) by Jane Doe 1, Jane Doe 2, Mara Greengrass, NAACP Florence Branch, NAACP Lubbock Branch, NAACP South Carolina State Conference, NAACP Texas State Conference, National Association for the Advancement of Colored People(Sellers, Joseph) (Entered: 03/27/2025)

QC NOTICE: 24 Motion to Appear Pro Hac Vice filed by National Education Association, Prince George's County Educators' Association needs to be modified. See attachment for details and corrective actions needed regarding the signature(s) on the motion. (mh4s, Deputy Clerk) (Entered: 03/27/2025)

QC NOTICE: 25 Motion to Appear Pro Hac Vice filed by National Education Association, Prince George's County Educators' Association needs to be modified. See attachment for details and corrective actions needed regarding the signature(s) on the motion. (mh4s, Deputy Clerk) (Entered: 03/27/2025)

CORRECTED MOTION to Appear Pro Hac Vice for Alice O'Brien by National Education Association, Prince George's County Educators' Association. The fee has already been paid.(Carter, Abigail) (Entered: 03/27/2025)

CORRECTED MOTION to Appear Pro Hac Vice for Marissa Marandola by National Education Association, Prince George's County Educators' Association. The fee has already been paid.(Carter, Abigail) (Entered: 03/27/2025)

PAPERLESS ORDER granting 27 Motion to Appear Pro Hac Vice on behalf of Eric Rothschild. Directing attorney Eric Rothschild to register for pro hac vice filing in the District of Maryland through PACER at https://pacer.uscourts.gov/ if attorney has not already done so. The Pro Hac Vice option must be selected when registering. Signed by Clerk on 3/28/2025. (mh4s, Deputy Clerk) (Entered: 03/28/2025)

PAPERLESS ORDER granting 28 Motion to Appear Pro Hac Vice on behalf of Aaron S. Ament. Directing attorney Aaron S. Ament to register for pro hac vice filing in the District of Maryland through PACER at https://pacer.uscourts.gov/ if attorney has not already done so. The Pro Hac Vice option must be selected when registering. Signed by Clerk on 3/28/2025. (mh4s, Deputy Clerk) (Entered: 03/28/2025)

PAPERLESS ORDER granting 29 Motion to Appear Pro Hac Vice on behalf of Jenna Waldman. Directing attorney Jenna Waldman to register for pro hac vice filing in the District of Maryland through PACER at https://pacer.uscourts.gov/ if attorney has not already done so. The Pro Hac Vice option must be selected when registering. Signed by Clerk on 3/31/2025. (mh4s, Deputy Clerk) (Entered: 03/31/2025)

PAPERLESS ORDER granting 30 Motion to Appear Pro Hac Vice on behalf of Ryan Wheeler. Directing attorney Ryan Wheeler to register for pro hac vice filing in the District of Maryland through PACER at https://pacer.uscourts.gov/ if attorney has not already done so. The Pro Hac Vice option must be selected when registering. Signed by Clerk on 3/31/2025. (mh4s, Deputy Clerk) (Entered: 03/31/2025)

PAPERLESS ORDER granting 33 Corrected Motion to Appear Pro Hac Vice on behalf of Alice O'Brien. Directing attorney Alice O'Brien to register for pro hac vice filing in the District of Maryland through PACER at https://pacer.uscourts.gov/ if attorney has not already done so. The Pro Hac Vice option must be selected when registering. Signed by Clerk on 3/31/2025. (mh4s, Deputy Clerk) (Entered: 03/31/2025)

PAPERLESS ORDER granting 34 Corrected Motion to Appear Pro Hac Vice on behalf of Marissa Marandola. Directing attorney Marissa Marandola to register for pro hac vice filing in the District of Maryland through PACER at https://pacer.uscourts.gov/ if attorney has not already done so. The Pro Hac Vice option must be selected when registering. Signed by Clerk on 3/31/2025. (mh4s, Deputy Clerk) (Entered: 03/31/2025)

SUMMONS Returned Executed by AFSCME Council 3, National Education Association, Prince George's County Educators' Association. Linda McMahon served on 4/1/2025, answer due 6/2/2025; The United States of America served on 4/1/2025, answer due 6/2/2025; United States Department of Education served on 4/1/2025, answer due 6/2/2025.(Carter, Abigail) (Entered: 04/04/2025)

NOTICE of Appearance by Daniel Zibel on behalf of National Education Association (Zibel, Daniel) (Entered: 04/28/2025)

NOTICE of Appearance by Michael Benjamin Bruns on behalf of All Defendants (Bruns, Michael) (Entered: 05/22/2025)

Consent MOTION for Extension of Time to File Answer by Linda McMahon (Attachments: # 1 Text of Proposed Order)(Bruns, Michael) (Entered: 05/22/2025)

PAPERLESS ORDER: Upon consideration of Defendants' Consent Motion for an Extension of Time to Respond to Plaintiffs' Complaint (ECF No. 44, the "Motion"), it is this 23rd day of May 2025, hereby ORDERED that the Motion is GRANTED; and further it is ORDERED that Defendants shall respond to Plaintiffs' Complaint on or before June 26, 2025. Signed by Judge Julie Rebecca Rubin on 5/23/2025. (dass, Deputy Clerk) (Entered: 05/23/2025)

MOTION to Appear Pro Hac Vice for Kristin M. Garcia (Filing fee $100, receipt number AMDDC-12014729.) by National Education Association, Prince George's County Educators' Association(Carter, Abigail) Modified per counsel on 6/2/2025 (dass). (Entered: 06/02/2025)

MOTION to Appear Pro Hac Vice for John M. Pellettieri (Filing fee $100, receipt number AMDDC-12014873) by National Education Association, Prince George's County Educators' Association, and AFSCME Council 3. (Carter, Abigail) Modified per counsel on 6/2/2025 (dass). (Entered: 06/02/2025)

PAPERLESS ORDER granting 46 Motion to Appear Pro Hac Vice on behalf of Kristin M. Garcia. Directing attorney Kristin M. Garcia to register for pro hac vice filing in the District of Maryland through PACER at https://pacer.uscourts.gov/ if attorney has not already done so. The Pro Hac Vice option must be selected when registering. Signed by Clerk on 6/3/2025. (mh4s, Deputy Clerk) (Entered: 06/03/2025)

PAPERLESS ORDER granting 47 Motion to Appear Pro Hac Vice on behalf of John M. Pellettieri. Directing attorney John M. Pellettieri to register for pro hac vice filing in the District of Maryland through PACER at https://pacer.uscourts.gov/ if attorney has not already done so. The Pro Hac Vice option must be selected when registering. Signed by Clerk on 6/3/2025. (mh4s, Deputy Clerk) (Entered: 06/03/2025)

Joint MOTION to Stay Entry of a Scheduling Order, Joint MOTION for Extension of Time of Rule 26 Deadlines by AFSCME Council 3, National Education Association, Prince George's County Educators' Association (Attachments: # 1 Text of Proposed Order)(Carter, Abigail) (Entered: 06/16/2025)

PAPERLESS ORDER: Upon consideration of the parties' Joint Motion to Stay Entry of a Scheduling Order and Extend Rule 26 Deadlines at ECF No. 50 (the "Motion"), and in view of this court's practice to issue a scheduling order after the filing of Defendants' answer, it is this 18th day of June 2025, hereby ORDERED that the Motion is DENIED AS MOOT. Signed by Judge Julie Rebecca Rubin on 6/18/2025. (kk5s, Deputy Clerk) (Entered: 06/18/2025)

Consent MOTION for Extension of Time to File Answer by Linda McMahon, The United States of America, United States Department of Education (Attachments: # 1 Text of Proposed Order)(Bruns, Michael) (Entered: 06/23/2025)

PAPERLESS ORDER: Upon consideration of Defendants' Consent Motion for an Extension of Time to Respond to Plaintiffs' Complaint (ECF No. 52, the "Motion"), it is this 25th day of June 2025, ORDERED that the Motion shall be, and is hereby, GRANTED; and further it is ORDERED that Defendants shall respond to the Complaint on or before July 28, 2025. Signed by Judge Julie Rebecca Rubin on 6/25/2025. (ols, Deputy Clerk) (Entered: 06/25/2025)

MOTION to Appear Pro Hac Vice for Leon Dayan (Filing fee $100, receipt number AMDDC-12075287.) by AFSCME Council 3, National Education Association, Prince George's County Educators' Association(Carter, Abigail) (Entered: 07/01/2025)

MOTION to Appear Pro Hac Vice for Kara A. Naseef (Filing fee $100, receipt number AMDDC-12075322.) by AFSCME Council 3, National Education Association, Prince George's County Educators' Association(Carter, Abigail) (Entered: 07/01/2025)

MOTION to Appear Pro Hac Vice for Grace Rybak (Filing fee $100, receipt number AMDDC-12075341.) by AFSCME Council 3, National Education Association, Prince George's County Educators' Association(Carter, Abigail) (Entered: 07/01/2025)

MOTION for Leave to File Excess Pages for Amended Complaint by AFSCME Council 3, Jane Doe 1, Jane Doe 2, Mara Greengrass, NAACP Florence Branch, NAACP Lubbock Branch, NAACP South Carolina State Conference, NAACP Texas State Conference, National Association for the Advancement of Colored People, National Education Association, Prince George's County Educators' Association (Attachments: # 1 Text of Proposed Order)(Carter, Abigail) (Entered: 07/01/2025)

AMENDED COMPLAINT against Linda McMahon, The United States of America, United States Department of Education, filed by Mara Greengrass, AFSCME Council 3, NAACP South Carolina State Conference, NAACP Texas State Conference, NAACP Lubbock Branch, National Education Association, Jane Doe 2, National Association for the Advancement of Colored People, Prince George's County Educators' Association, Jane Doe 1, NAACP Florence Branch. (Attachments: # 1 Amended Complaint Redline)(Carter, Abigail) (Entered: 07/01/2025)

MOTION to Submit Non-Party Pseudonymous Declarations by AFSCME Council 3, Jane Doe 1, Jane Doe 2, Mara Greengrass, NAACP Florence Branch, NAACP Lubbock Branch, NAACP South Carolina State Conference, NAACP Texas State Conference, National Association for the Advancement of Colored People, National Education Association, Prince George's County Educators' Association (Attachments: # 1 Memorandum in Support, # 2 Text of Proposed Order)(Carter, Abigail) (Entered: 07/01/2025)

MOTION for Leave to File Excess Pages for Memorandum in Support of Preliminary Injunction by AFSCME Council 3, Jane Doe 1, Jane Doe 2, Mara Greengrass, NAACP Florence Branch, NAACP Lubbock Branch, NAACP South Carolina State Conference, NAACP Texas State Conference, National Association for the Advancement of Colored People, National Education Association, Prince George's County Educators' Association (Attachments: # 1 Text of Proposed Order)(Carter, Abigail) (Entered: 07/01/2025)

MOTION for Preliminary Injunction by AFSCME Council 3, Jane Doe 1, Jane Doe 2, Mara Greengrass, NAACP Florence Branch, NAACP Lubbock Branch, NAACP South Carolina State Conference, NAACP Texas State Conference, National Association for the Advancement of Colored People, National Education Association, Prince George's County Educators' Association (Attachments: # 1 Memorandum in Support, # 2 Text of Proposed Order, # 3 Index of Exhibits, # 4 Exhibit A - Declaration of Abigail V. Carter, # 5 Exhibit A-1 - Executive Order, Improving Education Outcomes by Empowering Parents, States, and Communities, # 6 Exhibit A-2 - Secretary McMahons March 3, 2025 Speech, Our Departments Final Mission, # 7 Exhibit A-3 - Transcript of Secretary McMahons March 11, 2025 Fox News Interview, # 8 Exhibit A-4 - Transcript of Donald J. Trumps September 13, 2023 Agenda 47 Video, # 9 Exhibit A-5 - Department of Education Webpage, Pending Cases Currently Under Investigation at Elementary-Secondary and Post-Secondary Schools, # 10 Exhibit A-6 - Associated Press Article, Trump Has Called for Dismantling the Education Department. Heres What That Would Mean, # 11 Exhibit A-7 - Transcript of President Donald J. Trumps 2024 TIME Person of the Year Interview, # 12 Exhibit A-8 - Reuters Article, Trump Seeks Executive Order, Cooperation with Congress to Shut Education Department, # 13 Exhibit A-9 - Reuters Article, Trump Says He Wants Education Department to be Closed Immediately, # 14 Exhibit A-10 - Office of Planning, Evaluation, and Policy Development, Directive on Department Grant Priorities, as filed in American Association of Colleges for Teacher Education v. McMahon, No. 1:25-cv-00702 (D. Md. Mar. 17, 2025), Dkt. No. 24-2, # 15 Exhibit A-11 - Department of Education Press Release, U.S. Department of Education Initiates Reduction in Force, # 16 Exhibit A-12 - U.S. Senate Committee on Appropriations Press Release, Pressed by Murray, McMahon Says No Analysis Was Conducted Before Firing Half of the Department of Educations Staff, # 17 Exhibit A-13 - Declaration of Rachel Oglesby, as filed in New York v. McMahon, No. 25-10601-MJJ (D. Mass. June 10, 2025), Dkt. No. 147-1, # 18 Exhibit A-14 - Department of Government Efficiencys February 10, 2025, 7:13 p.m. X Post, # 19 Exhibit A-15 - Department of Government Efficiencys February 10, 2025, 7:43 p.m. X Post, # 20 Exhibit A-16 - Department of Education Press Release, U.S. Department of Education Cancels Additional $350 Million in Woke Spending, # 21 Exhibit A-17 - Office of Federal Student Aid, Fiscal Year 2024 Annual Report, # 22 Exhibit A-18 - Department of Education, Office of Inspector General, Final Audit Report for Audit No. ED-OIG/A19N0002, The Resolution of Discrimination Complaints by the Department's Office for Civil Rights, # 23 Exhibit A-19 - U.S. House of Representatives, Joint Explanatory Statement accompanying Appropriations Act, # 24 Exhibit A-20 - Department of Education, Fiscal Year 2024 Congressional Action, # 25 Exhibit A-21 - Declaration of Rachel Oglesby, as filed in California v. U.S. Department of Education, No. 1:25-cv-10548 (D. Mass. Mar. 12, 2025), Dkt. No. 55-1, # 26 Exhibit A-22 - Hechinger Report Article, Education Department Misses Key Deadline for Delivering Statistics Report, # 27 Exhibit A-23 - Office of Management and Budget, May 2, 2025 Letter on President Trumps Fiscal Year 2026 Budget Request to Senate Committee on Appropriations, # 28 Exhibit A-24 - ProPublica Article, Elon Musks Team Decimates Education Department Arm That Tracks National School Performance, # 29 Exhibit A-25 - National Center for Education Statistics Report, Students With Disabilities, # 30 Exhibit A-26 - USA Facts Article, What Does the Department of Education Do?, # 31 Exhibit A-27 - NPR Article, Education Department stops $1 billion in funding for school mental health, # 32 Exhibit A-28 - Department of Education, Education for the Disadvantaged Fiscal Year 2026 Budget Request, # 33 Exhibit A-29 - Department of Education, Fiscal Year 2025 Higher Education Budget Request, # 34 Exhibit A-30 - U.S. Senator Thom Tillis Press Release, Tillis Statement on Senate Passage of the Bipartisan Safer Communities Act, # 35 Exhibit A-31 - Education Week article, Trump Tells States Hes Holding Back $6.8 Billion for Schools, # 36 Exhibit B - Declaration of Anthony P. Ashton, # 37 Exhibit C - Declaration of Daaiyah Bilal-Threats, # 38 Exhibit D - Declaration of Colleen Campbell, # 39 Exhibit E - Declaration of Miguel Cardona, # 40 Exhibit F - Declaration of Donna L. Christy, # 41 Exhibit G - Declaration of Wisdom Cole, # 42 Exhibit H - Declaration of R. Jason Cottrell, # 43 Exhibit I - Declaration of John Curley, # 44 Exhibit I-1 - Memorandum of Understanding between American Institutes for Research in the Behavioral Sciences and Newton Public Schools, # 45 Exhibit I-2 - February 10, 2025 Email, Stop Order on Charting My Path for Future Success Project, # 46 Exhibit J - Declaration of Doe Declarant #1, # 47 Exhibit K - Declaration of Doe Declarant #2, # 48 Exhibit K-1 - Government Accountability Office, July 27, 2018 Letter to Congress, # 49 Exhibit K-2 - October 29, 2023 Department of Education Decision Memorandum Requesting Approval for the Use of the Secretarys Compromise Authority for Remediating Potential Harm to Borrowers Caused by Return to Repayment Servicing Errors, # 50 Exhibit K-3 - USDS Award Notice Attachments, Attachment 08: Service Level Methodology Performance Metrics, # 51 Exhibit K-4 - USDS Business Operations Servicing Requirements: Attachment 01, USDS Section 17001.010, # 52 Exhibit L - Declaration of Doe Declarant #3, # 53 Exhibit M - Declaration of Doe Declarant #4, # 54 Exhibit N - Declaration of Doe Declarant #5, # 55 Exhibit O - Declaration of Doe Declarant #6, # 56 Exhibit O-1 - Fiscal Year 2024 CMS Report, # 57 Exhibit P - Declaration of Doe Declarant #7, # 58 Exhibit Q - Declaration of Doe Declarant #8, # 59 Exhibit R - Declaration of Doe Declarant #9, # 60 Exhibit R-1 - March 11, 2025 Email, CHCO Notice to Employees Impacted by Reduction in Force (RIF), # 61 Exhibit R-2 - April 10, 2025 Email, Notice of Separation Due to Reduction in Force, # 62 Exhibit S - Declaration of Doe Declarant #10, # 63 Exhibit T - Declaration of Doe Declarant #11, # 64 Exhibit U - Declaration of Doe Declarant #12, # 65 Exhibit V - Declaration of Doe Declarant #13, # 66 Exhibit W - Declaration of Jane Doe #1, # 67 Exhibit X - Declaration of Jane Doe #2, # 68 Exhibit Y - Declaration of David Downey, # 69 Exhibit Z - Declaration of John Q. Easton, # 70 Exhibit AA - Declaration of Montserrat Garibay, # 71 Exhibit BB - Declaration of Rachel Gittleman, # 72 Exhibit CC - Declaration of Terri Gonzales, # 73 Exhibit CC-1 - March 11, 2025 Email, CHCO Notice to Employees Impacted by Reduction in Force (RIF), # 74 Exhibit CC-2 - April 10, 2025 Email, Notice of Separation Due to Reduction in Force, # 75 Exhibit DD - Declaration of Blondie Gordon, # 76 Exhibit EE - Declaration of Mara Greengrass, # 77 Exhibit FF - Declaration of Jessica Heiser, # 78 Exhibit GG - Declaration of Ed Hermes, # 79 Exhibit GG-1 - Department of Education, February 18, 2025 Letter, Grant Award Termination S374A230045, # 80 Exhibit HH - Declaration of Dr. Jerry Johnson, # 81 Exhibit II - Declaration of Denise Joseph, # 82 Exhibit II-1 - January 29, 2025 Email, Administrative Leave Notice, # 83 Exhibit JJ - Declaration of Kris Keranen, # 84 Exhibit KK - Declaration of Dr. John B. King, Jr., # 85 Exhibit LL - Declaration of Emma Leheny, # 86 Exhibit MM - Declaration of Catherine E. Lhamon, # 87 Exhibit NN - Declaration of Marcie Lipsitt, # 88 Exhibit OO - Declaration of Chris Miller, # 89 Exhibit PP - Declaration of Melissa Mills, # 90 Exhibit QQ - Declaration of Skylahr Mimms, # 91 Exhibit RR - Declaration of Patrick Moran, # 92 Exhibit SS - Declaration of Brenda Murphy, # 93 Exhibit TT - Declaration of Sarah Newman, # 94 Exhibit UU - Declaration of Matt Nosanchuk, # 95 Exhibit VV - Declaration of Jose Ortiz, # 96 Exhibit WW - Declaration of Ronald Petracca, # 97 Exhibit XX - Declaration of Alyssa Picard, # 98 Exhibit YY - Declaration of Rebecca Pringle, # 99 Exhibit ZZ - Declaration of Dezmond Rosier, # 100 Exhibit AAA - Declaration of Jada Scott, # 101 Exhibit BBB - Declaration of Hannah Secka, # 102 Exhibit CCC - Declaration of John Shaner, # 103 Exhibit DDD - Declaration of Deborah Spitz, # 104 Exhibit EEE - Declaration of Lisa Tessitore, # 105 Exhibit EEE-1 - Email Automatic Reply, # 106 Exhibit FFF - Declaration of Marianna Vinson, # 107 Exhibit FFF-1 - Department of Education, April 25, 2025 Letter, Notice of Non-Continuation of Grant Award, # 108 Exhibit GGG - Declaration of Mary Wall, # 109 Exhibit HHH - Declaration of Christy Wenger, # 110 Exhibit III - Declaration of Shaniqua Williams, # 111 Exhibit JJJ - Declaration of Elizabeth Witt, # 112 Exhibit LLL - Declaration of Erin Pollard Young, # 113 Exhibit LLL-1 - March 11, 2025 Email, CHCO Notice to Employees Impacted by Reduction in Force (RIF), # 114 Exhibit LLL-2 - April 10, 2025 Email, Notice of Separation Due to Reduction in Force)(Carter, Abigail) (Entered: 07/01/2025)

1 Memorandum in Support

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2 Text of Proposed Order

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3 Index of Exhibits

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4 Exhibit A - Declaration of Abigail V. Carter

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5 Exhibit A-1 - Executive Order, Improving Education Outcomes by Empowering Parent

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6 Exhibit A-2 - Secretary McMahons March 3, 2025 Speech, Our Departments Final Mis

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7 Exhibit A-3 - Transcript of Secretary McMahons March 11, 2025 Fox News Interview

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8 Exhibit A-4 - Transcript of Donald J. Trumps September 13, 2023 Agenda 47 Video

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9 Exhibit A-5 - Department of Education Webpage, Pending Cases Currently Under Inv

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10 Exhibit A-6 - Associated Press Article, Trump Has Called for Dismantling the Edu

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11 Exhibit A-7 - Transcript of President Donald J. Trumps 2024 TIME Person of the Y

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12 Exhibit A-8 - Reuters Article, Trump Seeks Executive Order, Cooperation with Con

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13 Exhibit A-9 - Reuters Article, Trump Says He Wants Education Department to be Cl

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14 Exhibit A-10 - Office of Planning, Evaluation, and Policy Development, Directive

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15 Exhibit A-11 - Department of Education Press Release, U.S. Department of Educati

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16 Exhibit A-12 - U.S. Senate Committee on Appropriations Press Release, Pressed by

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17 Exhibit A-13 - Declaration of Rachel Oglesby, as filed in New York v. McMahon, N

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18 Exhibit A-14 - Department of Government Efficiencys February 10, 2025, 7:13 p.m.

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19 Exhibit A-15 - Department of Government Efficiencys February 10, 2025, 7:43 p.m.

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20 Exhibit A-16 - Department of Education Press Release, U.S. Department of Educati

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21 Exhibit A-17 - Office of Federal Student Aid, Fiscal Year 2024 Annual Report

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22 Exhibit A-18 - Department of Education, Office of Inspector General, Final Audit

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23 Exhibit A-19 - U.S. House of Representatives, Joint Explanatory Statement accomp

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24 Exhibit A-20 - Department of Education, Fiscal Year 2024 Congressional Action

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25 Exhibit A-21 - Declaration of Rachel Oglesby, as filed in California v. U.S. Dep

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26 Exhibit A-22 - Hechinger Report Article, Education Department Misses Key Deadlin

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27 Exhibit A-23 - Office of Management and Budget, May 2, 2025 Letter on President

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28 Exhibit A-24 - ProPublica Article, Elon Musks Team Decimates Education Departmen

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29 Exhibit A-25 - National Center for Education Statistics Report, Students With Di

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30 Exhibit A-26 - USA Facts Article, What Does the Department of Education Do?

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31 Exhibit A-27 - NPR Article, Education Department stops $1 billion in fundin

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32 Exhibit A-28 - Department of Education, Education for the Disadvantaged Fiscal Y

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33 Exhibit A-29 - Department of Education, Fiscal Year 2025 Higher Education Budget

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34 Exhibit A-30 - U.S. Senator Thom Tillis Press Release, Tillis Statement on Senat

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35 Exhibit A-31 - Education Week article, Trump Tells States Hes Holding Back $

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36 Exhibit B - Declaration of Anthony P. Ashton

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37 Exhibit C - Declaration of Daaiyah Bilal-Threats

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38 Exhibit D - Declaration of Colleen Campbell

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39 Exhibit E - Declaration of Miguel Cardona

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40 Exhibit F - Declaration of Donna L. Christy

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41 Exhibit G - Declaration of Wisdom Cole

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42 Exhibit H - Declaration of R. Jason Cottrell

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43 Exhibit I - Declaration of John Curley

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44 Exhibit I-1 - Memorandum of Understanding between American Institutes for Resear

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45 Exhibit I-2 - February 10, 2025 Email, Stop Order on Charting My Path for Future

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46 Exhibit J - Declaration of Doe Declarant #1

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47 Exhibit K - Declaration of Doe Declarant #2

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48 Exhibit K-1 - Government Accountability Office, July 27, 2018 Letter to Congress

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49 Exhibit K-2 - October 29, 2023 Department of Education Decision Memorandum Reque

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50 Exhibit K-3 - USDS Award Notice Attachments, Attachment 08: Service Level Method

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51 Exhibit K-4 - USDS Business Operations Servicing Requirements: Attachment 01, US

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52 Exhibit L - Declaration of Doe Declarant #3

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53 Exhibit M - Declaration of Doe Declarant #4

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54 Exhibit N - Declaration of Doe Declarant #5

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55 Exhibit O - Declaration of Doe Declarant #6

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56 Exhibit O-1 - Fiscal Year 2024 CMS Report

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57 Exhibit P - Declaration of Doe Declarant #7

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58 Exhibit Q - Declaration of Doe Declarant #8

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59 Exhibit R - Declaration of Doe Declarant #9

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60 Exhibit R-1 - March 11, 2025 Email, CHCO Notice to Employees Impacted by Reduct

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61 Exhibit R-2 - April 10, 2025 Email, Notice of Separation Due to Reduction in For

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62 Exhibit S - Declaration of Doe Declarant #10

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63 Exhibit T - Declaration of Doe Declarant #11

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64 Exhibit U - Declaration of Doe Declarant #12

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65 Exhibit V - Declaration of Doe Declarant #13

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66 Exhibit W - Declaration of Jane Doe #1

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67 Exhibit X - Declaration of Jane Doe #2

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68 Exhibit Y - Declaration of David Downey

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69 Exhibit Z - Declaration of John Q. Easton

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70 Exhibit AA - Declaration of Montserrat Garibay

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71 Exhibit BB - Declaration of Rachel Gittleman

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72 Exhibit CC - Declaration of Terri Gonzales

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73 Exhibit CC-1 - March 11, 2025 Email, CHCO Notice to Employees Impacted by Reduc

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74 Exhibit CC-2 - April 10, 2025 Email, Notice of Separation Due to Reduction in Fo

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75 Exhibit DD - Declaration of Blondie Gordon

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76 Exhibit EE - Declaration of Mara Greengrass

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77 Exhibit FF - Declaration of Jessica Heiser

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78 Exhibit GG - Declaration of Ed Hermes

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79 Exhibit GG-1 - Department of Education, February 18, 2025 Letter, Grant Award Te

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80 Exhibit HH - Declaration of Dr. Jerry Johnson

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81 Exhibit II - Declaration of Denise Joseph

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82 Exhibit II-1 - January 29, 2025 Email, Administrative Leave Notice

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83 Exhibit JJ - Declaration of Kris Keranen

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84 Exhibit KK - Declaration of Dr. John B. King, Jr.

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85 Exhibit LL - Declaration of Emma Leheny

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86 Exhibit MM - Declaration of Catherine E. Lhamon

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87 Exhibit NN - Declaration of Marcie Lipsitt

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88 Exhibit OO - Declaration of Chris Miller

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89 Exhibit PP - Declaration of Melissa Mills

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90 Exhibit QQ - Declaration of Skylahr Mimms

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91 Exhibit RR - Declaration of Patrick Moran

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92 Exhibit SS - Declaration of Brenda Murphy

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93 Exhibit TT - Declaration of Sarah Newman

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94 Exhibit UU - Declaration of Matt Nosanchuk

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95 Exhibit VV - Declaration of Jose Ortiz

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96 Exhibit WW - Declaration of Ronald Petracca

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97 Exhibit XX - Declaration of Alyssa Picard

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98 Exhibit YY - Declaration of Rebecca Pringle

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99 Exhibit ZZ - Declaration of Dezmond Rosier

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100 Exhibit AAA - Declaration of Jada Scott

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101 Exhibit BBB - Declaration of Hannah Secka

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102 Exhibit CCC - Declaration of John Shaner

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103 Exhibit DDD - Declaration of Deborah Spitz

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104 Exhibit EEE - Declaration of Lisa Tessitore

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105 Exhibit EEE-1 - Email Automatic Reply

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106 Exhibit FFF - Declaration of Marianna Vinson

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107 Exhibit FFF-1 - Department of Education, April 25, 2025 Letter, Notice of Non-Co

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108 Exhibit GGG - Declaration of Mary Wall

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109 Exhibit HHH - Declaration of Christy Wenger

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110 Exhibit III - Declaration of Shaniqua Williams

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111 Exhibit JJJ - Declaration of Elizabeth Witt

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112 Exhibit LLL - Declaration of Erin Pollard Young

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113 Exhibit LLL-1 - March 11, 2025 Email, CHCO Notice to Employees Impacted by Redu

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114 Exhibit LLL-2 - April 10, 2025 Email, Notice of Separation Due to Reduction in F

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PAPERLESS ORDER granting 54 Motion to Appear Pro Hac Vice on behalf of Leon Dayan. Directing attorney Leon Dayan to register for pro hac vice filing in the District of Maryland through PACER at https://pacer.uscourts.gov/ if attorney has not already done so. The Pro Hac Vice option must be selected when registering. Signed by Clerk on 7/2/2025. (mh4s, Deputy Clerk) (Entered: 07/02/2025)

PAPERLESS ORDER granting 55 Motion to Appear Pro Hac Vice on behalf of Kara A. Naseef. Directing attorney Kara A. Naseef to register for pro hac vice filing in the District of Maryland through PACER at https://pacer.uscourts.gov/ if attorney has not already done so. The Pro Hac Vice option must be selected when registering. Signed by Clerk on 7/2/2025. (mh4s, Deputy Clerk) (Entered: 07/02/2025)

PAPERLESS ORDER granting 56 Motion to Appear Pro Hac Vice on behalf of Grace Rybak. Directing attorney Grace Rybak to register for pro hac vice filing in the District of Maryland through PACER at https://pacer.uscourts.gov/ if attorney has not already done so. The Pro Hac Vice option must be selected when registering. Signed by Clerk on 7/2/2025. (mh4s, Deputy Clerk) (Entered: 07/02/2025)

PAPERLESS ORDER: Upon consideration of Plaintiffs' unopposed Motions for Leave to File Excess Pages at ECF Nos. 57 and 60 (the "Motions"), it is this 2nd day of July 2025, hereby ORDERED that the Motions are GRANTED; and further it is ORDERED that Plaintiffs may file an Amended Complaint of up to 45 pages in length and a memorandum in support of their Motion for Preliminary Injunction of up to 45 pages in length. Signed by Judge Julie Rebecca Rubin on 7/2/2025. (dass, Deputy Clerk) (Entered: 07/03/2025)

ORDER granting Plaintiffs' 59 Motion to Submit Non-Party Pseudonymous Declarations. Signed by Judge Julie Rebecca Rubin on 7/2/2025. (dass, Deputy Clerk) (Entered: 07/03/2025)

Consent MOTION for Leave to File Amici Curiae Brief of Members of Congress by Elizabeth Warren, Charles E. Schumer, Angela Alsobrooks, Richard Blumenthal, Lisa Blunt Rochester, Cory Booker, John Fetterman, Ruben Gallego, Martin Heinrich, Mazie Hirono, Tim Kaine, Andy Kim, Amy Klobuchar, Ben Ray Lujn, Ed Markey, Jeffrey A. Merkley, Patty Murray, Jacky Rosen, Adam B. Schiff, Jeanne Shaheen, Chris Van Hollen, Mark Warner, Raphael Warnock, Peter Welch, Ron Wyden, Jamie Raskin, Robert "Bobby" C. Scott, Rosa L. DeLauro, Hakeem Jeffries, Katherine Clark, Pete Aguilar, Joe Neguse, Gabe Amo, Becca Balint, Nanette Barragn, Joyce Beatty, Wesley Bell, Donald S. Beyer Jr., Sanford D. Bishop, Jr., Suzanne Bonamici, Shontel Brown, Julia Brownley, Nikki Budzinski, Salud O. Carbajal, Andr Carson, Troy A. Carter, Sr., Ed Case, Sean Casten, Kathy Castor, Judy Chu (Attachments: # 1 Exhibit Proposed Amici Curiae Brief, # 2 Text of Proposed Order)(Becker-Cohen, Miriam) (Entered: 07/03/2025)

PAPERLESS ORDER: Upon consideration of the Motion of Members of Congress for Leave to File Amici Curiae Brief in Support of Plaintiffs' Motion for Preliminary Injunction at ECF No. 67 (the "Motion"), it is this 3rd day of July 2025, ORDERED that the Motion shall be, and is hereby, GRANTED. Madam Clerk shall docket the proposed Amici Curiae Brief at ECF No. 67-1. Signed by Judge Julie Rebecca Rubin on 7/3/2025. (dass, Deputy Clerk) (Entered: 07/03/2025)

BRIEF of Members of Congress as Amici Curiae in Support of Plaintiff's 61 MOTION for Preliminary Injunction. (dass, Deputy Clerk) (Entered: 07/03/2025)

Joint MOTION for Extension of Time to File Response/Reply as to 61 MOTION for Preliminary Injunction and for Enlargement of Page Limits by Linda McMahon, The United States of America, United States Department of Education (Attachments: # 1 Text of Proposed Order)(Bruns, Michael) Modified on 7/3/2025 (kb3s). (Entered: 07/03/2025)

PAPERLESS ORDER: Upon consideration of the parties' Joint Proposed Briefing Schedule and Motion for Enlargement of Page Limits at ECF No. 70 (the "Motion"), it is this 3rd day of July 2025, ORDERED that the Motion shall be, and is hereby, GRANTED; and further it is ORDERED that the proposed briefing schedule and requested page limits set forth therein are APPROVED. Signed by Judge Julie Rebecca Rubin on 7/3/2025. (kb3s, Deputy Clerk) (Entered: 07/03/2025)

Consent MOTION for Leave to File Amicus Brief of 75 Former Career Staff of the Department of Education, Office of Civil Rights by Marc Brenman (Attachments: # 1 Exhibit Proposed Amicus Brief in Support of Plaintiffs' Motion for a Preliminary Injunction, # 2 Text of Proposed Order Proposed Order)(Romer-Friedman, Peter) (Entered: 07/08/2025)

PAPERLESS ORDER: Upon consideration of the Motion for Leave to File Amicus Brief at ECF No. 72 (the "Motion"), it is this 9th day of July 2025, ORDERED that the Motion shall be, and is hereby, GRANTED. Madam Clerk shall docket the proposed Amicus Brief in Support of Plaintiffs' Motion for a Preliminary Injunction at ECF No. 72-1. Signed by Judge Julie Rebecca Rubin on 7/9/2025. (dass, Deputy Clerk) (Entered: 07/09/2025)

AMICUS BRIEF in support of Plaintiffs' 61 MOTION for Preliminary Injunction filed by Former U.S. Department of Education, Office for Civil Rights Career Staff. (dass, Deputy Clerk) (Entered: 07/09/2025)

ORDER scheduling hearing on Plaintiffs' 61 Motion for Preliminary Injunction. Signed by Judge Julie Rebecca Rubin on 7/11/2025. (dass, Deputy Clerk) (Entered: 07/11/2025)

ORDER setting electronic device restrictions during further proceedings in this matter. Signed by Judge Julie Rebecca Rubin on 7/11/2025. (dass, Deputy Clerk) (Entered: 07/11/2025)

MOTION to Dismiss for Failure to State a Claim and for Lack of Jurisdiction by Linda McMahon, The United States of America, United States Department of Education (Attachments: # 1 Text of Proposed Order)(Bruns, Michael) (Entered: 07/25/2025)

Memorandum re 77 MOTION to Dismiss for Failure to State a Claim and for Lack of Jurisdiction, 61 MOTION for Preliminary Injunction filed by Linda McMahon, The United States of America, United States Department of Education. (Attachments: # 1 Text of Proposed Order)(Bruns, Michael) (Entered: 07/25/2025)

Joint MOTION for a Proposed Briefing Schedule and Clarification of Page Limits re 77 MOTION to Dismiss for Failure to State a Claim and for Lack of Jurisdiction, 61 MOTION for Preliminary Injunction by AFSCME Council 3, Jane Doe 1, Jane Doe 2, Mara Greengrass, NAACP Florence Branch, NAACP Lubbock Branch, NAACP South Carolina State Conference, NAACP Texas State Conference, National Association for the Advancement of Colored People, National Education Association, Prince George's County Educators Association (Attachments: # 1 Text of Proposed Order)(Carter, Abigail) (Entered: 07/30/2025)

1 Text of Proposed Order

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PAPERLESS ORDER: Upon consideration of the parties' Joint Motion for a Proposed Briefing Schedule and Clarification of Page Limits at ECF No. 79 (the "Motion"), it is this 31st day of July 2025, ORDERED that the Motion shall be, and is hereby, GRANTED; and further it is ORDERED that the proposed briefing schedule and requested page limits set forth therein are APPROVED. Signed by Judge Julie Rebecca Rubin on 7/31/2025. (dass, Deputy Clerk) (Entered: 07/31/2025)

RESPONSE re 77 MOTION to Dismiss for Failure to State a Claim and for Lack of Jurisdiction, 61 MOTION for Preliminary Injunction Plaintiffs' Combined Reply in Support of Motion for Preliminary Injunction and Opposition to Defendants' Motion to Dismiss filed by AFSCME Council 3, Jane Doe 1, Jane Doe 2, Mara Greengrass, NAACP Florence Branch, NAACP Lubbock Branch, NAACP South Carolina State Conference, NAACP Texas State Conference, National Association for the Advancement of Colored People, National Education Association, Prince George's County Educators Association.(Carter, Abigail) (Entered: 08/08/2025)

PAPERLESS ORDER: The hearing scheduled for August 15, 2025, on Plaintiffs' Motion for Preliminary Injunction will be held in Courtroom 3A. Signed by Judge Julie Rebecca Rubin on 8/11/2025. (dass, Deputy Clerk) (Entered: 08/11/2025)

ORDER directing the preliminary injunction hearing shall proceed without live witness testimony and the parties may offer declarations/affidavits as needed and as set forth; setting time limits for argument and rebuttal as set forth. Signed by Judge Julie Rebecca Rubin on 8/13/2025. (dass, Deputy Clerk) (Entered: 08/13/2025)

REPLY to Response to Motion re 77 MOTION to Dismiss for Failure to State a Claim and for Lack of Jurisdiction filed by Linda McMahon, The United States of America, United States Department of Education.(Bruns, Michael) (Entered: 08/14/2025)

Motion Hearing held on 8/15/2025 re 77 MOTION to Dismiss for Failure to State a Claim and for Lack of Jurisdiction filed by The United States of America, Linda McMahon, United States Department of Education, 61 MOTION for Preliminary Injunction filed by NAACP Texas State Conference, Jane Doe 2, AFSCME Council 3, Jane Doe 1, NAACP South Carolina State Conference, NAACP Florence Branch, National Education Association, Mara Greengrass, Prince George's County Educators Association, National Association for the Advancement of Colored People, NAACP Lubbock Branch before Judge Julie Rebecca Rubin. (Russell Carrick - Courtroom 3A)(Court Reporter: Ronda Thomas) (rc2s, Deputy Clerk) (Entered: 08/15/2025)

MEMORANDUM OPINION. Signed by Judge Julie Rebecca Rubin on 8/19/2025. (kns, Deputy Clerk)

MEMORANDUM OPINION. Signed by Judge Julie Rebecca Rubin on 8/21/2025. (dass, Deputy Clerk)