Case: Inclusiv, Inc. v. U.S. Environmental Protection Agency

1:25-cv-00948 | U.S. District Court for the District of District of Columbia

Filed Date: March 31, 2025

Case Ongoing

Clearinghouse coding complete

Case Summary

This case challenged the freezing of federal grant funds meant for community financial development. Plaintiffs, Inclusiv, Inc., a nonprofit financial institution, filed a lawsuit in the United States District Court for the District of Columbia. The plaintiffs named Citibank, the U.S. Environmental Protection Agency (EPA), and the EPA Administrator as defendants. Inclusiv sought injunctive relief and damages, claiming the defendants unlawfully blocked access to grant funds that had already been …

This case challenged the freezing of federal grant funds meant for community financial development. Plaintiffs, Inclusiv, Inc., a nonprofit financial institution, filed a lawsuit in the United States District Court for the District of Columbia. The plaintiffs named Citibank, the U.S. Environmental Protection Agency (EPA), and the EPA Administrator as defendants. Inclusiv sought injunctive relief and damages, claiming the defendants unlawfully blocked access to grant funds that had already been awarded and disbursed.

The dispute stemmed from the National Clean Investment Fund (NCIF), a program under the Greenhouse Gas Reduction Fund (GGRF), which Congress established through the Inflation Reduction Act of 2022. Inclusiv was selected as a grantee in April 2024 and awarded $1.87 billion under the CCIA grant program, allowing them to make commitments to 108 credit unions to help low and moderate-income communities reduce energy costs, create jobs, and improve financial security. Under the terms of the grant, the funds were held at Citibank, which served as a financial agent under an Account Control Agreement (ACA) executed with the EPA.

The dispute arose in February 2025, when the EPA allegedly froze Inclusiv’s GGRF funds, preventing the organization from distributing them to community lenders. This came following the EPA Administrator’s public remarks expressing his opposition to the GGRF, calling it “criminal” and vowing to recover the funds. On March 11, 2025, the EPA formally terminated Inclusiv’s grant, citing unspecified compliance concerns. Simultaneously, Citibank, which managed Inclusiv’s grant funds under an Account Control Agreement (ACA), declined to process any disbursements. On March 18, 2025, the U.S. District Court for the District of Columbia issued a TRO in Climate United Fund v. Citibank, halting the effects of the March 11 termination letter. In reliance on the TRO order, Inclusiv sought disbursement of funds on March 21. Citibank did not respond to this letter, nor disperse any funds. 

On March 31, Inclusive filed its complaint alleging claims against both the EPA and Citibank. Against the EPA, it claimed the agency’s actions violated the Administrative Procedure Act for engaging in actions that were contrary to federal law and EPA regulations, and for being arbitrary and capricious. It also claimed that the EPA violated the Separation of Powers and the Vesting, Spending and Appropriations, and Take Care Clauses by failing to distribute funds appropriated by Congress. Additionally, Inclusiv claimed the EPA deprived it of the Fifth Amendment right to Due Process by terminating its funds without notice or an opportunity to be heard. Finally, plaintiffs asserted an Ultra Vires claim that the EPA exceeded their constitutional and statutory authority under the “Administrative Procedure Act, the Inflation Reduction Act, the Congressional Budget and Impoundment Control Act, and the Anti-Deficiency Act by withholding obligated funds in contravention of these plain congressional mandates.” Against Citibank, plaintiffs asserted state law claims of breach of contract and conversion. 

Plaintiffs sought a declaration that (1) the notice of termination was void; (2) the suspension of the grant award violated the APA, Separation of Powers, and the Due Process Clause, and exceeded statutory authority conferred on the EPA; (3) and that Citibank’s freezing of Inclusiv’s account was contrary to law and violated their contractual obligations under the ACA. They also requested a permanent injunction prohibiting the enforcement of the March 11 termination letter, and enjoining defendants from “[s]uspending, terminating, or attempting to suspend or terminate Inclusiv’s grant award, except as permitted by governing law.”

On April 1, plaintiffs filed both a preliminary injunction motion and a temporary restraining order (TRO). The preliminary injunction motion requested the Court to prevent the government defendants from enforcing the March 11 termination letter or suspending Inclusiv’s grant award, and Citibank from violating its contractual obligations under the ACA. The TRO requested a restoration of the plaintiffs’ grant funds to its Citibank account, which had been removed when Inclusiv’s CFO checked the balance of its Citibank account on April 1. Plaintiffs previously did not seek a TRO on reliance on the EPA’s statement that they would not move the money while the TRO in Climate United Fund v. Citibank was in effect. There was a dispute over the nature of this removal, as defendants argued this was a routine transfer that occurred monthly. Plaintiffs stated that if the money was returned to their account, they would withdraw their request for TRO. However, they requested that the Court engage in more careful monitoring of the money. 

On April 1, plaintiffs also filed notice of a related case, Climate United Fund v. Citibank. The court consolidated this case with Climate United Fund v. Citibank on April 15. On April 16, in light of the preliminary injunction granted in Climate United Fund v. Citibank and this case's consolidation with Climate United Fund, the Court denied the plaintiffs' motion for preliminary injunction as moot. Further updates on this case can be found on Climate United Fund's Clearinghouse page

Summary Authors

Jillian Snyman (4/2/2025)

Related Cases

Climate United Fund v. Citibank, District of District of Columbia (2025)

People

For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/69825680/parties/inclusiv-inc-v-united-states-environmental-protection-agency/


Judge(s)

Chutkan, Tanya Sue (District of Columbia)

Attorney for Plaintiff

Johnson, Jay Christopher (District of Columbia)

Keraga, Kyle H. (District of Columbia)

Attorney for Defendant

Allen, Kenneth Winn (District of Columbia)

McElroy, Saunders Lee (District of Columbia)

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Documents in the Clearinghouse

Document
1

1:25-cv-00948

Complaint for Declaratory and Injunctive Relief

Inclusiv, Inc. v. United States Environmental Protection Agency

March 31, 2025

March 31, 2025

Complaint
7

1:25-cv-00948

Notice of Designation of Related Civil Cases Pending in This or Any Other United States Court

April 1, 2025

April 1, 2025

Other
6

1:25-cv-00948

Plaintiff Inclusiv, Inc.'s Motion for Preliminary Injunction

April 1, 2025

April 1, 2025

Pleading / Motion / Brief
8

1:25-cv-00948

Plaintiff Inclusive Inc.'s Emergency Motion for Temporary Restraining Order

April 1, 2025

April 1, 2025

Pleading / Motion / Brief
7

1:25-cv-00948

Notice of Designation of Related Civil Cases Pending in This or Any Other United States Court

April 1, 2025

April 1, 2025

Other

Resources

Docket

See docket on RECAP: https://www.courtlistener.com/docket/69825680/inclusiv-inc-v-united-states-environmental-protection-agency/

Last updated Aug. 21, 2025, 9:58 p.m.

ECF Number Description Date Link Date / Link
1

COMPLAINT for Declaratory and Injunctive Relief against All Defendants ( Filing fee $ 405 receipt number ADCDC-11580047) filed by INCLUSIV, INC.. (Attachments: # 1 Civil Cover Sheet Civil Cover Sheet, # 2 Summons Summons - EPA, # 3 Summons Summons - Zeldin, # 4 Summons Summons - McIntosh, # 5 Summons Summons - Citibank, # 6 Summons Summons - Attorney General Pamela Bondi, # 7 Summons Summons - U.S. Attorney Edward R. Martin Jr.)(Keraga, Kyle) (Entered: 03/31/2025)

1 Civil Cover Sheet Civil Cover Sheet

View on PACER

2 Summons Summons - EPA

View on PACER

3 Summons Summons - Zeldin

View on PACER

4 Summons Summons - McIntosh

View on PACER

5 Summons Summons - Citibank

View on PACER

6 Summons Summons - Attorney General Pamela Bondi

View on PACER

7 Summons Summons - U.S. Attorney Edward R. Martin Jr.

View on PACER

March 31, 2025

March 31, 2025

Clearinghouse
2

ENTERED IN ERROR.....NOTICE OF RELATED CASE by INCLUSIV, INC. Case related to Case No. 25-cv-698. (Keraga, Kyle) (Entered: 03/31/2025)

March 31, 2025

March 31, 2025

RECAP
3

LCvR 26.1 CERTIFICATE OF DISCLOSURE of Corporate Affiliations and Financial Interests by INCLUSIV, INC. (Keraga, Kyle) (Entered: 03/31/2025)

March 31, 2025

March 31, 2025

PACER
4

NOTICE of Appearance by Jay Christopher Johnson on behalf of INCLUSIV, INC. (Johnson, Jay) (Entered: 04/01/2025)

April 1, 2025

April 1, 2025

RECAP
5

CIVIL COVER SHEET by INCLUSIV, INC. filed by INCLUSIV, INC..(Keraga, Kyle) (Entered: 04/01/2025)

April 1, 2025

April 1, 2025

PACER
6

MOTION for Preliminary Injunction by INCLUSIV, INC.. (Attachments: # 1 Memorandum in Support, # 2 Exhibit Declaration of Neda Arabshahi, # 3 Exhibit Declaration of John S. Lawson, # 4 Exhibit Declaration of Jared Freeman, # 5 Exhibit Declaration of Greg Hanshaw, # 6 Exhibit Declaration of Ricardo Ledezma, # 7 Exhibit Inclusiv CCIA Grant Agreement (Aug. 8, 2024), # 8 Exhibit Inclusiv CCIA Modified Grant Agreement (Dec. 19, 2024), # 9 Exhibit Account Control Agreement (Nov. 6, 2024), # 10 Exhibit Financial Agency Agreement (Sept. 19, 2024), # 11 Exhibit EPA Letter to Inspector General (Mar. 2, 2025), # 12 Exhibit EPA Letter to Inclusiv (Mar. 4, 2025), # 13 Exhibit EPA Termination Letter to Inclusiv (Mar. 11, 2025), # 14 Exhibit Climate United TRO & Memorandum Opinion (Mar. 18, 2025), # 15 Exhibit Inclusiv Letter to Citibank (Mar. 21, 2025), # 16 Exhibit Inclusiv Response to EPA's March 4 Letter (Mar. 28, 2025), # 17 Text of Proposed Order)(Keraga, Kyle) (Entered: 04/01/2025)

April 1, 2025

April 1, 2025

Clearinghouse
7

NOTICE OF RELATED CASE by INCLUSIV, INC.. Case related to Case No. 25-cv-698. (Keraga, Kyle) (Entered: 04/01/2025)

April 1, 2025

April 1, 2025

Clearinghouse
8

WITHDRAWN PURSUANT TO NOTICE FILED 0402/2025.....Emergency MOTION for Temporary Restraining Order by INCLUSIV, INC.. (Attachments: # 1 Declaration of Jay Johnson and Exhibits, # 2 Declaration of Eben Sheaffer, # 3 Text of Proposed Order)(Keraga, Kyle) Modified on 4/4/2025 (zjm). (Entered: 04/01/2025)

1 Declaration of Jay Johnson and Exhibits

View on PACER

2 Declaration of Eben Sheaffer

View on PACER

3 Text of Proposed Order

View on PACER

April 1, 2025

April 1, 2025

Clearinghouse

Notice of Error- New Case

April 1, 2025

April 1, 2025

PACER

NOTICE OF NEW CASE ERROR regarding 2 Notice of Related Case, 1 Complaint,. The following error(s) need correction: Blank/Incomplete/Missing civil cover sheet. Please file the Civil Cover Sheet (JS44) form at www.dcd.uscourts.gov/new-case-forms using the event Civil Cover Sheet. Blank/Incomplete/Missing Related Case form. Please use the Notice of Designation of Related Cases (CO 932) form at www.dcd.uscourts.gov/new-case-forms and filing using the event Notice of Related Case. Forms filed as fillable PDF. Please file forms in a non-fillable PDF format. COMPLIANCE DEADLINE is by close of business today. This case will not proceed any further until all errors are satisfied. (zsl)

April 1, 2025

April 1, 2025

PACER
10

NOTICE of Appearance by Kenneth Winn Allen on behalf of CITIBANK, N.A. (Allen, Kenneth) (Entered: 04/02/2025)

April 2, 2025

April 2, 2025

PACER
11

LCvR 26.1 CERTIFICATE OF DISCLOSURE of Corporate Affiliations and Financial Interests by CITIBANK, N.A. (Allen, Kenneth) (Entered: 04/02/2025)

April 2, 2025

April 2, 2025

PACER
12

NOTICE of Appearance by Saunders Lee McElroy on behalf of CITIBANK, N.A. (McElroy, Saunders) (Entered: 04/02/2025)

April 2, 2025

April 2, 2025

PACER
13

NOTICE of Withdrawal of Request for Relief by INCLUSIV, INC. re 8 Motion for TRO (Johnson, Jay) (Entered: 04/02/2025)

April 2, 2025

April 2, 2025

RECAP
9

SUMMONS (6) Issued Electronically as to CITIBANK, N.A., W.C. MCINTOSH, UNITED STATES ENVIRONMENTAL PROTECTION AGENCY, LEE ZELDIN, U.S. Attorney, and U.S. Attorney General (Attachments: # 1 Notice and Consent)(zjd) (Entered: 04/02/2025)

April 2, 2025

April 2, 2025

PACER

Case Assigned/Reassigned

April 2, 2025

April 2, 2025

PACER

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

April 2, 2025

April 2, 2025

PACER
14

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Dismas N. Locaria, Filing fee $ 100. Fee Status: Fee Paid. by INCLUSIV, INC.. (Attachments: # 1 Declaration Declaration of D. Locaria, # 2 Good Standing Certificate, # 3 Text of Proposed Order Proposed Order)(Johnson, Jay) (Entered: 04/03/2025)

April 3, 2025

April 3, 2025

PACER
15

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Cogan R.S. Rooney, Filing fee $ 100. Fee Status: Fee Paid. by INCLUSIV, INC.. (Attachments: # 1 Declaration Declaration of C.Rooney, # 2 Good Standing Certificate, # 3 Text of Proposed Order Proposed Order)(Johnson, Jay) (Entered: 04/03/2025)

April 3, 2025

April 3, 2025

PACER
16

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Evan I. Suval, Filing fee $ 100. Fee Status: Fee Paid. by INCLUSIV, INC.. (Attachments: # 1 Declaration Declaration of E. Suval, # 2 Good Standing Certificate, # 3 Text of Proposed Order Proposed Order)(Johnson, Jay) (Entered: 04/03/2025)

April 3, 2025

April 3, 2025

PACER
17

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Lindsay M. Reed, Filing fee $ 100. Fee Status: Fee Paid. by INCLUSIV, INC.. (Attachments: # 1 Declaration Declaration of L. Reed, # 2 Good Standing Certificate, # 3 Text of Proposed Order Proposed Order)(Johnson, Jay) (Entered: 04/03/2025)

April 3, 2025

April 3, 2025

PACER
18

NOTICE of Appearance by Marcus S Sacks on behalf of W.C. MCINTOSH, UNITED STATES ENVIRONMENTAL PROTECTION AGENCY, LEE ZELDIN (Sacks, Marcus) (Entered: 04/07/2025)

April 7, 2025

April 7, 2025

PACER
19

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Emily R. Marcy, Filing fee $ 100. Fee Status: Fee Paid. by INCLUSIV, INC.. (Attachments: # 1 Declaration Declaration of E. Marcy, # 2 Good Standing Certificate, # 3 Text of Proposed Order Proposed Order)(Johnson, Jay) (Entered: 04/07/2025)

April 7, 2025

April 7, 2025

PACER
20

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Taylor M. Sorrells, Filing fee $ 100. Fee Status: Fee Paid. by INCLUSIV, INC.. (Attachments: # 1 Declaration Declaration of T. Sorrells, # 2 Good Standing Certificate, # 3 Text of Proposed Order Proposed Order)(Johnson, Jay) (Entered: 04/07/2025)

April 7, 2025

April 7, 2025

PACER

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

April 7, 2025

April 7, 2025

PACER

MINUTE ORDER: GRANTING Motions for Leave to Appear Pro Hac Vice as to 14 Dismas N. Locaria, 15 Cogan R.S. Rooney, 16 Evan I. Suval, 17 Lindsay M. Reed, 19 Emily R. Marcy, and 20 Taylor M. Sorrells. Dismas N. Locaria, Cogan R.S. Rooney, Evan I. Suval, Lindsay M. Reed, Emily R. Marcy, and Taylor M. Sorrells are hereby admitted pro hac vice to represent Plaintiff Inclusiv, Inc. in this matter. Counsel should register for e-filing via PACER and file a notice of appearance pursuant to LCvR 83.6(a) Click for instructions. Signed by Judge Tanya S. Chutkan on 4/7/2025. (lcer)

April 7, 2025

April 7, 2025

PACER
21

Joint STATUS REPORT by W.C. MCINTOSH, UNITED STATES ENVIRONMENTAL PROTECTION AGENCY, LEE ZELDIN. (Sacks, Marcus) (Entered: 04/08/2025)

April 8, 2025

April 8, 2025

PACER

Payment of Fee- Pro Hac Vice Motion

April 8, 2025

April 8, 2025

PACER

Payment for 20 MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Taylor M. Sorrells, Filing fee $ 100. Fee Status: Fee Paid., 16 MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Evan I. Suval, Filing fee $ 100. Fee Status: Fee Paid., 15 MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Cogan R.S. Rooney, Filing fee $ 100. Fee Status: Fee Paid., 19 MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Emily R. Marcy, Filing fee $ 100. Fee Status: Fee Paid., 17 MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Lindsay M. Reed, Filing fee $ 100. Fee Status: Fee Paid., 14 MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Dismas N. Locaria, Filing fee $ 100. Fee Status: Fee Paid.. ($100). (Johnson, Jay)

April 8, 2025

April 8, 2025

PACER

Payment for 14 MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Dismas N. Locaria, Filing fee $ 100. Fee Status: Fee Paid.. ($100; Receipt number ADCDC-11598472). (Johnson, Jay)

April 8, 2025

April 8, 2025

PACER

Payment for 15 MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Cogan R.S. Rooney, Filing fee $ 100. Fee Status: Fee Paid.. ($100; Receipt number ADCDC-11598484). (Johnson, Jay)

April 8, 2025

April 8, 2025

PACER

Payment for 16 MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Evan I. Suval, Filing fee $ 100. Fee Status: Fee Paid.. ($100; Receipt number ADCDC-11598506). (Johnson, Jay)

April 8, 2025

April 8, 2025

PACER

Payment for 17 MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Lindsay M. Reed, Filing fee $ 100. Fee Status: Fee Paid.. ($100; Receipt number ADCDC-11598515). (Johnson, Jay)

April 8, 2025

April 8, 2025

PACER

Payment for 19 MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Emily R. Marcy, Filing fee $ 100. Fee Status: Fee Paid.. ($100; Receipt number ADCDC-11598524). (Johnson, Jay)

April 8, 2025

April 8, 2025

PACER

Payment for 20 MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Taylor M. Sorrells, Filing fee $ 100. Fee Status: Fee Paid.. ($100; Receipt number ADCDC-11598539). (Johnson, Jay)

April 8, 2025

April 8, 2025

PACER
22

NOTICE of Appearance by Cogan Rooney on behalf of INCLUSIV, INC. (Rooney, Cogan) (Entered: 04/10/2025)

April 10, 2025

April 10, 2025

PACER
23

NOTICE of Appearance by Kevin Paul VanLandingham on behalf of W.C. MCINTOSH, UNITED STATES ENVIRONMENTAL PROTECTION AGENCY, LEE ZELDIN (VanLandingham, Kevin) (Entered: 04/10/2025)

April 10, 2025

April 10, 2025

PACER

.Order AND Terminate Deadlines

April 10, 2025

April 10, 2025

PACER

MINUTE ORDER: Upon consideration of the parties' 21 Joint Status Report, briefing on Plaintiffs' 6 Motion for Preliminary Injunction is stayed until further order of the Court. To the extent the parties would like to proceed with the briefing, the parties shall confer and file a joint status report with an updated briefing schedule. The status report shall be accompanied by a proposed order. Signed by Judge Tanya S. Chutkan on 4/10/2025. (lcer)

April 10, 2025

April 10, 2025

PACER

.Order

April 15, 2025

April 15, 2025

PACER

Create Case Association

April 15, 2025

April 15, 2025

PACER

MINUTE ORDER: Pursuant to Federal Rule of Civil Procedure 42(a)(2), the court will consolidate this case with Case No. 25-cv-698, given the common questions of law and fact between both cases. The parties to this case may submit a Joint Status Report to the court within seven days of the courts decision on the preliminary injunction motions in Case No. 25-cv-698, setting forth whether there are any additional issues specific to Plaintiff Inclusiv, Inc. to address. All filings and papers related to the consolidated cases shall be filed in the lead case: 25-cv-698. Signed by Judge Tanya S. Chutkan on 4/15/2025. (lcer)

April 15, 2025

April 15, 2025

PACER

Cases Consolidated. This case has been consolidated with case 25-cv-00698-TSC pursuant to Order. From this date forward, all pleadings shall be filed ONLY in the lead case, 25-cv-00698-TSC. Parties are advised NOT to elect the SPREAD TEXT option when filing in ECF, as this will result in repetitive docketing. (zjm)

April 15, 2025

April 15, 2025

PACER

Order on Motion for Preliminary Injunction

April 16, 2025

April 16, 2025

PACER

MINUTE ORDER: DENYING as MOOT Plaintiffs' 6 Motion for Preliminary Injunction. See Preliminary Injunction Order and forthcoming Memorandum Opinion in lead case No. 25-cv-698 for details. Signed by Judge Tanya S. Chutkan on 4/16/2025. (lcer)

April 16, 2025

April 16, 2025

PACER

Case Details

State / Territory: District of Columbia

Case Type(s):

Environmental Justice

Presidential/Gubernatorial Authority

Special Collection(s):

Trump Administration 2.0: Challenges to the Government

Trump Administration 2.0: Challenges to the Government (Spending Freezes/Cuts)

Trump Administration 2.0: Challenges to the Government (Environmental Protections)

Key Dates

Filing Date: March 31, 2025

Case Ongoing: Yes

Plaintiffs

Plaintiff Description:

Plaintiff is certified by the U.S. Department of the Treasury as a Community Development Financial Institution (CDFI) and partnered with credit unions to promote financial security and independence for everyday people.

Plaintiff Type(s):

Non-profit NON-religious organization

Public Interest Lawyer: No

Filed Pro Se: No

Class Action Sought: No

Class Action Outcome: Not sought

Defendants

Citibank (Sioux Falls, South Dakota), Private Entity/Person

United States Environmental Protection Agency, Federal

Defendant Type(s):

Jurisdiction-wide

Case Details

Causes of Action:

Ex Parte Young (Federal) or Bivens

Administrative Procedure Act, 5 U.S.C. §§ 551 et seq.

Declaratory Judgment Act, 28 U.S.C. § 2201

Ex parte Young (federal or state officials)

Constitutional Clause(s):

Due Process

Due Process: Procedural Due Process

Spending/Appropriations Clauses

Separation of Powers

Take Care Clause

Available Documents:

Trial Court Docket

Complaint (any)

Outcome

Prevailing Party: None Yet / None

Nature of Relief:

None yet

Source of Relief:

None yet

Issues

General/Misc.:

Funding

Presidential/Gubernatorial Authority:

Impoundment (mandatory spending)