Case: Abramowitz v. Lake

Widakuswara v. Lake

U.S. Court of Appeals for the District of Columbia Circuit

Widakuswara v. Lake

U.S. Court of Appeals for the District of Columbia Circuit

President Donald Trump

COMPLAINT against All Defendants ( Filing fee $ 405 receipt number ADCDC-11566992) filed by J. Doe 2, MICHAEL ABRAMOWITZ, J. DOE 1, Anthony Michael LaBruto. (Attachments: # 1 Civil Cover Sheet, # 2 Civil Cover Sheet, # 3 Summons Lake Summons, # 4 Summons Morales Summons, # 5 Summons USAGM Summons, # 6 Summons Bondi Summons, # 7 Summons Martin Summons)(Schultz, William) (Attachment 1 replaced on 3/26/2025) (zmtm). (Entered: 03/26/2025)

1 Civil Cover Sheet

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2 Civil Cover Sheet

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3 Summons Lake Summons

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4 Summons Morales Summons

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5 Summons USAGM Summons

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6 Summons Bondi Summons

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7 Summons Martin Summons

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Notice of Error- New Case

.Order AND ~Util - Set/Reset Deadlines

NOTICE OF RELATED CASE. Case related to (Schultz, William) (Entered: 03/26/2025)

Order on Sealed Motion to Proceed Under Pseudonym

SEALED MOTION to Proceed Under Pseudonym filed by J. DOE 1, J. Doe 2 (Attachments: # 1 Memorandum in Support Memorandum in Support of Motion, # 2 Declaration J. Doe 1 Declaration, # 3 Declaration J. Doe 2 Declaration, # 4 Text of Proposed Order Proposed Order)(Schultz, William) (Entered: 03/26/2025)

Case Assigned/Reassigned

MOTION for Temporary Restraining Order, MOTION for Preliminary Injunction by MICHAEL ABRAMOWITZ, Anthony Michael LaBruto, J. DOE 1, J. Doe 2. (Attachments: # 1 Motion for Preliminary Injunction, # 2 Memorandum in Support of Motions for Temporary Restraining Order and Preliminary Injunction, # 3 Exhibit A, # 4 Exhibit B, # 5 Declaration of Abramowitz, # 6 Declaration of J. Doe 1, # 7 Declaration of J. Doe 2, # 8 Declaration of LaBruto, # 9 Text of Proposed Order of Temporary Restraining Order, # 10 Text of Proposed Order of Preliminary Injunction)(Schultz, William) (Entered: 03/26/2025)

1 Motion for Preliminary Injunction

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2 Memorandum in Support of Motions for Temporary Restraining Order and Preliminary

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3 Exhibit A

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4 Exhibit B

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5 Declaration of Abramowitz

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6 Declaration of J. Doe 1

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7 Declaration of J. Doe 2

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8 Declaration of LaBruto

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9 Text of Proposed Order of Temporary Restraining Order

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10 Text of Proposed Order of Preliminary Injunction

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Order

NOTICE OF NEW CASE ERROR regarding 1 Complaint. The following error(s) need correction: (1) Incorrect civil cover sheet. Please locate the Civil Cover Sheet (JS44) form here and file, in a non-fillable PDF format, using the event "Civil Cover Sheet." (2) The related case form lists "RFE/RL, Inc., v. Kari Lake, et al., Case No. 25 Civ. 779 (D.D.C. 2025)" as a related case. The case caption and number do not match. Please file a new related case form correcting this. (zjd)

CIVIL COVER SHEET by J. DOE 2, MICHAEL ABRAMOWITZ, J. DOE 1, ANTHONY MICHAEL LABRUTO re 1 Complaint, filed by J. DOE 2, MICHAEL ABRAMOWITZ, J. DOE 1, ANTHONY MICHAEL LABRUTO. Related document: 1 Complaint, filed by J. DOE 1, ANTHONY MICHAEL LABRUTO, MICHAEL ABRAMOWITZ, J. DOE 2.(Schultz, William) (Entered: 03/26/2025)

NOTICE OF RELATED CASE by MICHAEL ABRAMOWITZ, ANTHONY MICHAEL LABRUTO, J. DOE 1, J. DOE 2. Case related to Case No. 25-cv-00799. (Schultz, William) (Entered: 03/26/2025)

NOTICE of Appearance by Margaret M. Dotzel on behalf of All Plaintiffs (Dotzel, Margaret) (Entered: 03/26/2025)

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Brian Beaton, Jr., Filing fee $ 100, receipt number ADCDC-11567994. Fee Status: Fee Paid. by MICHAEL ABRAMOWITZ, ANTHONY MICHAEL LABRUTO, J. DOE 1, J. DOE 2. (Attachments: # 1 Declaration In Support of Motion to Appear Pro Hac Vice, # 2 Exhibit Certificate of Good Standing, # 3 Text of Proposed Order)(Schultz, William) (Entered: 03/26/2025)

MINUTE ORDER: Believing that Plaintiffs John Doe 1 and John Doe 2 have made the required showing on the relevant factors, the Court ORDERS that: 1) Plaintiffs' 3 Sealed Motion to Proceed Under Pseudonym is GRANTED; and 2) They shall be permitted to proceed pseudonymously unless and until the assigned judge determines otherwise. Given the expedited nature of this matter, the Court determines that a full Opinion is not practical at this time. So ORDERED by Chief Judge James E. Boasberg on 3/26/2025. (lcjeb4)

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

SUMMONS (5) Issued Electronically as to All Defendants, U.S. Attorney and U.S. Attorney General (Attachments: # 1 Notice and Consent)(zmtm) (Entered: 03/26/2025)

MINUTE ORDER: Government's Response due by 3/28/2025 at 1:00 pm. Signed by Judge Royce C. Lamberth on 3/26/2025. (lcrcl3)

NOTICE of Appearance by Brenda A. Gonzalez Horowitz on behalf of KARI LAKE, VICTOR MORALES, UNITED STATES AGENCY FOR GLOBAL MEDIA (Gonzalez Horowitz, Brenda) (Entered: 03/26/2025)

NOTICE of Appearance by Stephanie R. Johnson on behalf of KARI LAKE, VICTOR MORALES, UNITED STATES AGENCY FOR GLOBAL MEDIA (Johnson, Stephanie) (Entered: 03/26/2025)

NOTICE of Voluntary Dismissal re J. Doe 1 by J. DOE 1 (Schultz, William) (Entered: 03/28/2025)

Memorandum in opposition to re 4 Motion for TRO,,, Motion for Preliminary Injunction,, filed by KARI LAKE, VICTOR MORALES, UNITED STATES AGENCY FOR GLOBAL MEDIA. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Declaration of Crystal Thomas)(Gonzalez Horowitz, Brenda) (Entered: 03/28/2025)

1 Exhibit 1

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2 Exhibit 2

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3 Exhibit 3

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4 Declaration of Crystal Thomas

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

MOTION for Order to Set a Preliminary Injunction Briefing Schedule by MICHAEL ABRAMOWITZ, ANTHONY MICHAEL LABRUTO, J. DOE 2. (Schultz, William) (Entered: 03/31/2025)

Memorandum in opposition to re 15 Motion for Order filed by KARI LAKE, VICTOR MORALES, UNITED STATES AGENCY FOR GLOBAL MEDIA. (Attachments: # 1 Exhibit A, Widakuswara Mem. Op. (ECF No. 54))(Johnson, Stephanie) (Entered: 04/01/2025)

Memorandum in opposition to motion

MOTION to Stay All Proceedings by KARI LAKE, VICTOR MORALES, UNITED STATES AGENCY FOR GLOBAL MEDIA. (Attachments: # 1 Exhibit A, Widakuswara Mem. Op. (ECF No. 54))(Johnson, Stephanie) (Entered: 04/01/2025)

1 Exhibit A, Widakuswara Mem. Op. (ECF No. 54)

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ENTERED IN ERROR.....Memorandum in opposition to re 15 Motion for Order filed by KARI LAKE, VICTOR MORALES, UNITED STATES AGENCY FOR GLOBAL MEDIA. (See docket entry [17 to view document) (zdp) Modified on 4/1/2025; duplicate of docket entry 16 (zdp). (Entered: 04/01/2025)

RESPONSE re 17 MOTION to Stay All Proceedings Plaintiffs' Response in Opposition filed by MICHAEL ABRAMOWITZ, ANTHONY MICHAEL LABRUTO, J. DOE 2. (Attachments: # 1 Declaration of Michael Abramowitz)(Schultz, William) (Entered: 04/02/2025)

1

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NOTICE OF SUPPLEMENTAL AUTHORITY by KARI LAKE, VICTOR MORALES, UNITED STATES AGENCY FOR GLOBAL MEDIA (Attachments: # 1 Exhibit A)(Gonzalez Horowitz, Brenda) (Entered: 04/04/2025)

ORDER: Status Report due by 4/9/2025. Signed by Judge Royce C. Lamberth on 4/7/2025. (lcrcl3) (Entered: 04/07/2025)

Joint STATUS REPORT by KARI LAKE, VICTOR MORALES, UNITED STATES AGENCY FOR GLOBAL MEDIA. (Johnson, Stephanie) (Entered: 04/09/2025)

Notice of Hearing on Motion

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

NOTICE of Hearing on 4 MOTION for Preliminary Injunction: Motion Hearing set for 4/17/2025 at 11:30 AM in Courtroom 15 (In Person) before Judge Royce C. Lamberth. (smc)

MINUTE ORDER: the parties will adhere to the briefing schedule in Widakuswara v. Lake, 25-cv-1015. The government's Response to Plaintiff's Motion for a Preliminary Injunction is due by 4/14/2025. Plaintiff's Reply is due by 4/16/2025 at 12:00 pm. Preliminary Injunction Hearing set for 4/17/2025 at 11:30 AM in Courtroom 15- In Person before Judge Royce C. Lamberth. Signed by Judge Royce C. Lamberth on 4/10/2025. (lcrcl3)

MOTION for Leave to File Amicus Brief by AMICI FORMER US FOREIGN POLICY AND NATIONAL SECURITY OFFICIALS AND OTHER EXPERTS ON PUBLIC DIPLOMACY. (Attachments: # 1 Appendix Proposed Amicus Brief, # 2 Declaration, # 3 Declaration, # 4 Declaration, # 5 Declaration, # 6 Declaration, # 7 Declaration)(Cedarbaum, Jonathan) (Entered: 04/11/2025)

Memorandum in opposition to re 4 Motion for TRO,,, Motion for Preliminary Injunction,, filed by KARI LAKE, VICTOR MORALES, UNITED STATES AGENCY FOR GLOBAL MEDIA. (Attachments: # 1 Exhibit 1, LaBruto Personal Services Contract, # 2 Exhibit 2, J. Doe II Personal Services Contract, # 3 Exhibit 3, USAGM Personal Services Contractor Handbook, # 4 Exhibit 4, Declaration of Crystal Thomas)(Gonzalez Horowitz, Brenda) (Entered: 04/14/2025)

1 Exhibit 1, LaBruto Personal Services Contract

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2 Exhibit 2, J. Doe II Personal Services Contract

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3 Exhibit 3, USAGM Personal Services Contractor Handbook

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4 Exhibit 4, Declaration of Crystal Thomas

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ORDER regarding logistics for the preliminary injunction hearing on Thursday, April 17, 2025. See Order for details. Signed by Judge Royce C. Lamberth on 4/15/2025. (lcrcl3) (Entered: 04/15/2025)

REPLY to opposition to motion re 4 Motion for TRO,,, Motion for Preliminary Injunction,, filed by MICHAEL ABRAMOWITZ, J. DOE 2, ANTHONY MICHAEL LABRUTO. (Schultz, William) (Entered: 04/16/2025)

.Order

NOTICE of Appearance by Abigail Stout on behalf of All Defendants (Stout, Abigail) (Entered: 04/16/2025)

MINUTE ORDER: The court will provide access for the public to telephonically attend the hearing scheduled for April 17, 2025, at 11:30 AM. The hearing can be accessed by dialing the Toll-Free Number: 833-990-9400 (Meeting ID: 720718696). It is hereby ORDERED that the attendees using the public access telephone line shall adhere to the following: persons remotely accessing court proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting any court proceedings (including those held by telephone or videoconference). Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the presiding Judge. Signed by Judge Royce C. Lamberth on 4/16/2025. (smc)

Motion Hearing

Minute Entry for Motion Hearing held on 4/17/2025 before Judge Royce C. Lamberth: re 4 MOTION for Temporary Restraining Order, MOTION for Preliminary Injunction . Oral arguments heard and TAKEN UNDER ADVISEMENT. Court Reporter: Sonja Reeves. (smc)

TRANSCRIPT OF MOTION HEARING before Judge Royce C. Lamberth held on April 17, 2025; Page Numbers: 1-118. Date of Issuance: April 18, 2025. Court Reporter/Transcriber Sonja L. Reeves, RDR, CRR, Telephone number (202) 354-3246, Transcripts may be ordered by submitting the Transcript Order FormFor the first 90 days after this filing date, the transcript may be viewed at the courthouse at a public terminal or purchased from the court reporter referenced above. After 90 days, the transcript may be accessed via PACER. Other transcript formats, (multi-page, condensed, CD or ASCII) may be purchased from the court reporter.NOTICE RE REDACTION OF TRANSCRIPTS: The parties have twenty-one days to file with the court and the court reporter any request to redact personal identifiers from this transcript. If no such requests are filed, the transcript will be made available to the public via PACER without redaction after 90 days. The policy, which includes the five personal identifiers specifically covered, is located on our website at www.dcd.uscourts.gov. Redaction Request due 5/9/2025. Redacted Transcript Deadline set for 5/19/2025. Release of Transcript Restriction set for 7/17/2025.(Reeves, Sonja) (Entered: 04/18/2025)

ORDER granting 4 Motion for Preliminary Injunction. See Order, and accompanying Memorandum Opinion in Widakuswara v. Lake, 25-cv-1015, for details. Signed by Judge Royce C. Lamberth on 4/22/2025. (lcrcl3) (Entered: 04/22/2025)

NOTICE OF INTERLOCUTORY APPEAL as to 29 Order on Motion for Preliminary Injunction by KARI LAKE, VICTOR MORALES, UNITED STATES AGENCY FOR GLOBAL MEDIA. Fee Status: No Fee Paid. Parties have been notified. (Gonzalez Horowitz, Brenda) (Entered: 04/24/2025)

Transmission of the Notice of Appeal, Order Appealed (Memorandum Opinion), and Docket Sheet to US Court of Appeals. The Court of Appeals docketing fee was not paid because the appeal was filed by the government re 30 Notice of Interlocutory Appeal. (znmw) (Entered: 04/24/2025)

MOTION to Stay re 29 Order on Motion for Preliminary Injunction by KARI LAKE, VICTOR MORALES, UNITED STATES AGENCY FOR GLOBAL MEDIA. (Attachments: # 1 Declaration of Roman Napoli, # 2 Declaration of Crystal Thomas)(Gonzalez Horowitz, Brenda) (Entered: 04/24/2025)

1 Declaration of Roman Napoli

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2 Declaration of Crystal Thomas

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USCA Case Number 25-5145 for 30 Notice of Interlocutory Appeal filed by UNITED STATES AGENCY FOR GLOBAL MEDIA, VICTOR MORALES, KARI LAKE. (znmw)

RESPONSE re 32 MOTION to Stay re 29 Order on Motion for Preliminary Injunction Pending Appeal filed by MICHAEL ABRAMOWITZ, J. DOE 2, ANTHONY MICHAEL LABRUTO. (Attachments: # 1 Exhibit)(Schultz, William) (Entered: 04/25/2025)

1 Exhibit

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USCA Case Number

ORDER denying 32 Motion to Stay. See Order for details. Signed by Judge Royce C. Lamberth on 4/25/2025. (lcrcl3) (Entered: 04/25/2025)

Supplemental Record on Appeal transmitted to US Court of Appeals re 34 Order on Motion to Stay ; USCA Case Number 25-5145. (znmw) (Entered: 04/25/2025)

ORDER of USCA as to 30 Notice of Interlocutory Appeal filed by UNITED STATES AGENCY FOR GLOBAL MEDIA, VICTOR MORALES, KARI LAKE ; USCA Case Number 25-5145. (zdp) (Entered: 05/02/2025)

MOTION for Order to Show Cause by MICHAEL ABRAMOWITZ, J. DOE 2, ANTHONY MICHAEL LABRUTO. (Attachments: # 1 Text of Proposed Order, # 2 Declaration of Michael Abramowitz, # 3 USCA Order)(Schultz, William) Modified docket text on 5/29/2025 (zdp). (Entered: 05/28/2025)

1 Text of Proposed Order

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2 Declaration of Michael Abramowitz

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3 USCA Order

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AFFIDAVIT OF SERVICE by MICHAEL ABRAMOWITZ, J. DOE 2, ANTHONY MICHAEL LABRUTO. (Schultz, William) (Entered: 05/29/2025)

Summons Returned Executed as to Federal Defendant AND Summons Returned Executed as to U.S. Attorney General AND Summons Returned Executed as to US Attorney

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. KARI LAKE served on 5/19/2025; VICTOR MORALES served on 5/19/2025; UNITED STATES AGENCY FOR GLOBAL MEDIA served on 5/19/2025, RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed on United States Attorney General. Date of Service Upon United States Attorney General 5/19/2025., RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed as to the United States Attorney. Date of Service Upon United States Attorney on 5/19/2025. ( Answer due for ALL FEDERAL DEFENDANTS by 7/18/2025.)(See docket entry 38 to view document) (zdp) (Entered: 05/29/2025)

NOTICE of Defendants' Intent to Oppose Plaintiffs' Motion for Order Within the Time Contemplated By the Local Civil Rules by KARI LAKE, VICTOR MORALES, UNITED STATES AGENCY FOR GLOBAL MEDIA (Gonzalez Horowitz, Brenda) (Entered: 05/29/2025)

ORDER: Defendants' Response to Plaintiffs' Motion for Order to Show Cause due by 6/4/2025. Signed by Judge Royce C. Lamberth on 5/30/2025. (lcrcl3) (Entered: 05/30/2025)

NOTICE of Appearance by Brian Beaton, Jr on behalf of MICHAEL ABRAMOWITZ, J. DOE 2, ANTHONY MICHAEL LABRUTO (Beaton, Brian) (Main Document 42 replaced on 6/3/2025) (zdp). (Entered: 06/02/2025)

MOTION to Stay by KARI LAKE, VICTOR MORALES, UNITED STATES AGENCY FOR GLOBAL MEDIA. (Attachments: # 1 Text of Proposed Order)(Johnson, Stephanie) (Entered: 06/02/2025)

1 Text of Proposed Order

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Memorandum in opposition to re 37 MOTION for Order to Show Cause filed by KARI LAKE, VICTOR MORALES, UNITED STATES AGENCY FOR GLOBAL MEDIA. (Attachments: # 1 Declaration of Leili Soltani, # 2 Declaration of Jeff Reber)(Gonzalez Horowitz, Brenda) (Entered: 06/04/2025)

1 Declaration of Leili Soltani

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2 Declaration of Jeff Reber

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Consent MOTION for Briefing Schedule Regarding Plaintiffs' Motions for an Order to Show Cause by MICHAEL ABRAMOWITZ, J. DOE 2, ANTHONY MICHAEL LABRUTO. (Schultz, William) (Entered: 06/10/2025)

RESPONSE re 43 MOTION to Stay filed by MICHAEL ABRAMOWITZ, J. DOE 2, ANTHONY MICHAEL LABRUTO. (Schultz, William) (Entered: 06/10/2025)

ORDER granting 45 Motion for Briefing Schedule. Plaintiffs' Reply due by 6/20/2025. Signed by Judge Royce C. Lamberth on 6/11/2025. (lcrcl3) (Entered: 06/11/2025)

ORDER granting 45 Motion for Briefing Schedule. Plaintiffs' Reply due by 6/20/2025. Signed by Judge Royce C. Lamberth on 6/11/2025. (lcrcl3) (Entered: 06/11/2025)

REPLY to opposition to motion re 43 Motion to Stay filed by KARI LAKE, VICTOR MORALES, UNITED STATES AGENCY FOR GLOBAL MEDIA. (Johnson, Stephanie) (Entered: 06/16/2025)

Reply to opposition to motion

Reply to opposition to motion

REPLY to opposition to motion re 37 Motion for Order to Show Cause, filed by MICHAEL ABRAMOWITZ, J. DOE 2, ANTHONY MICHAEL LABRUTO. (Attachments: # 1 Text of Proposed Order, # 2 Exhibit A, # 3 Exhibit B)(Beaton, Brian) (Entered: 06/19/2025)

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

MINUTE ORDER: The parties are ORDERED to appear for a hearing on the pending Motions for Order to Show Cause, in both 25-cv-1015 and 25-cv-887. The hearing will take place on Monday, 6/23/2025 at 11:00 AM in Courtroom 15- In Person before Judge Royce C. Lamberth. Signed by Judge Royce C. Lamberth on 6/20/2025. (lcrcl3)

Transcript

Transcript

Minute Entry for Motion Hearing held before Judge Royce C. Lamberth on 6/23/2025. Oral arguments submitted on Plaintiffs' Motion 37 (in 25-cv-887 (RCL)) for Order to Show Cause and Plaintiffs' Motion 112 (in 25-cv-1015 (RCL)) for Order to Show Cause Regarding Defendants' Violation of Part (3) of the Preliminary Injunction. Motions taken under advisement; forthcoming Order. (Court Reporter: Bryan Wayne) (lsj)

Minute Entry for Motion Hearing held before Judge Royce C. Lamberth on 6/23/2025. Oral arguments submitted on Plaintiffs' Motion 37 (in 25-cv-887 (RCL)) for Order to Show Cause and Plaintiffs' Motion 112 (in 25-cv-1015 (RCL)) for Order to Show Cause Regarding Defendants' Violation of Part (3) of the Preliminary Injunction. Motions taken under advisement; forthcoming Order. (Court Reporter: Bryan Wayne) (lsj)

Motion Hearing

Motion Hearing

ORDER: Defendants' Supplemental Memorandum regarding the Motions for Order to Show Cause due by 6/27/2025. Plaintiffs' Reply due by 7/2/3035. Motion to Stay 43 in case 1:25-cv-887-RCL, and Motion to Stay 114 in case 1:25-cv-1015-RCL are hereby DENIED. See Order for details. Signed by Judge Royce C. Lamberth on 6/23/2025. (lcrcl3) (Entered: 06/23/2025)

ORDER: Defendants' Supplemental Memorandum regarding the Motions for Order to Show Cause due by 6/27/2025. Plaintiffs' Reply due by 7/2/3035. Motion to Stay 43 in case 1:25-cv-887-RCL, and Motion to Stay 114 in case 1:25-cv-1015-RCL are hereby DENIED. See Order for details. Signed by Judge Royce C. Lamberth on 6/23/2025. (lcrcl3) (Entered: 06/23/2025)

Extension of Time to

Extension of Time to

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

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

Response to Order of the Court

1 Declaration of Frank Wuco

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2 Exhibit 1 to Wuco Declaration (Global Media and VOA Personnel)

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3 June 3, 2025, Congressional Notification

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4 June 20, 2025, Congressional Notification

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Reply to (non-motion) Document

Reply to (non-motion) Document

.Order

.Order