Case: Human Rights Defense Center v. Lujan Grisham

Human Rights Defense Center v. Grisham

COMPLAINT For Declaratory and Injunctive Relief and Damages Under the Federal Civil Rights Act, 42 U.S.C. § 1983 against All Defendants ( Filing Fee - Online Payment), filed by Human Rights Defense Center. (Attachments: # 1 Civil Cover Sheet Civil Cover Sheet)(Flores, Adam) (Entered: 10/25/2024)

1 Civil Cover Sheet Civil Cover Sheet

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Summons Issued

Filing and Administrative Fees Received: $ 405 receipt number ANMDC-9608709 re 1 Complaint, filed by Human Rights Defense Center (Payment made via Pay.gov)(Flores, Adam)

United States Magistrate Judge Jennifer M. Rozzoni and United States Magistrate Judge Kevin R. Sweazea assigned. (dr)

PLEASE TAKE NOTICE that this case has been randomly assigned to United States Magistrate Judge Jennifer M. Rozzoni to conduct dispositive proceedings in this matter, including motions and trial. Appeal from a judgment entered by a Magistrate Judge will be to the United States Court of Appeals for the Tenth Circuit. It is the responsibility of the case filer to serve a copy of this Notice upon all parties with the summons and complaint. Consent is strictly voluntary, and a party is free to withhold consent without adverse consequences. Should a party choose to consent, notice should be made no later than 21 days after entry of the Order setting the Rule 16 Initial Scheduling Conference. For e-filers, visit our Web site at www.nmd.uscourts.gov for more information and instructions.[THIS IS A TEXT-ONLY ENTRY. THERE ARE NO DOCUMENTS ATTACHED.] (dr) (Entered: 10/25/2024)

Summons Issued as to Wayne H. Calabrese, Brian R. Evans, GEO Group, Inc., Michelle Lujan Grisham, Gary Maciel, Melanie Martinez, Alisha Tafoya Lucero, and Attorney General. (dr)

MOTION for Preliminary Injunction by Human Rights Defense Center. (Attachments: # 1 Affidavit Marc J. Shinn-Krantz, # 2 Affidavit Paul Wright, # 3 Affidavit John L. Clark) (Flores, Adam) (Entered: 10/25/2024)

NOTICE by Human Rights Defense Center Corporate and Business Entity Disclosure Statement (Flores, Adam) (Entered: 10/25/2024)

NOTICE by Human Rights Defense Center Notice of Good Standing (Flores, Adam) (Entered: 10/25/2024)

PLEASE TAKE NOTICE that this case has been reassigned to United States District Judge Margaret I. Strickland as the trial judge. Under D.N.M.LR-Civ. 10.1, the first page of each document must have the case file number and initials of the assigned judges.Accordingly, further documents filed in this matter must bear the case number and the judges' initials shown in the case caption and the NEF for this document. Kindly reflect this change in your filings. United States Magistrate Judge Jennifer M. Rozzoni no longer assigned to this case.[THIS IS A TEXT-ONLY ENTRY. THERE ARE NO DOCUMENTS ATTACHED.] (jg) (Entered: 10/28/2024)

SUMMONS Returned Executed by Human Rights Defense Center. Michelle Lujan Grisham served on 10/29/2024, answer due 11/19/2024. (Flores, Adam) (Entered: 10/30/2024)

SUMMONS Returned Executed by Human Rights Defense Center. Gary Maciel served on 10/29/2024, answer due 11/19/2024. (Flores, Adam) (Entered: 10/30/2024)

SUMMONS Returned Executed by Human Rights Defense Center. Melanie Martinez served on 10/29/2024, answer due 11/19/2024. (Flores, Adam) (Entered: 10/30/2024)

SUMMONS Returned Executed by Human Rights Defense Center. Alisha Tafoya Lucero served on 10/29/2024, answer due 11/19/2024. (Flores, Adam) (Entered: 10/30/2024)

SUMMONS Returned Executed by Human Rights Defense Center. GEO Group, Inc. served on 11/5/2024, answer due 11/26/2024. (Flores, Adam) (Entered: 11/08/2024)

MOTION for Extension of Time to File Answer to Complaint by Michelle Lujan Grisham. (Carrillo, Raul) (Entered: 11/22/2024)

NOTICE of Appearance by Raul A. Carrillo, Jr on behalf of Michelle Lujan Grisham (Carrillo, Raul) (Entered: 11/22/2024)

ORDER by District Judge Margaret I. Strickland GRANTING 12 State of New Mexico Related Defendants' Motion for Extension of Time to File. Defendants Grisham, Lucero, Martinez, and Maciel shall have up to and including December 12, 2024, to file their Answer and shall have up to and including December 12, 2024, to file their Response to 3 Plaintiff's Motion for Preliminary Injunction. Plaintiff shall have up to and including January 13, 2025, to file a Reply to 3 Plaintiff's Motion for Preliminary Injunction.[THIS IS A TEXT-ONLY ENTRY. THERE ARE NO DOCUMENTS ATTACHED.] (mhs) (Entered: 11/25/2024)

Order on Motion for Extension of Time to Answer

NOTICE by GEO Group, Inc. re 3 MOTION for Preliminary Injunction, 1 Complaint, Entry of Appearance and Notice of Agreed Extension of Time (Jahner, Michael) (Entered: 11/26/2024)

ASSOCIATION of Attorney Licensed Outside the District for Plaintiff Human Rights Defense Center by Adam C. Flores on behalf of: Marc J. Shinn-Krantz Rosen Bien Galvan & Grunfeld LLP 101 Mission Street, Sixth FloorSan Francisco, CA 94105 415-433-6830 Fax 415-433-7104 MShinn-Krantz@rbgg.com (Association Dues - Online Payment) (Flores, Adam)[THIS IS A TEXT-ONLY ENTRY. THERE ARE NO DOCUMENTS ATTACHED.] (Entered: 12/03/2024)

Association Dues Received: $ 100 receipt number ANMDC-9664658 re: # 16 Association of Attorney Licensed Outside the District, filed by Human Rights Defense Center (Payment made via Pay.gov)(Flores, Adam)

ASSOCIATION of Attorney Licensed Outside the District for Plaintiff Human Rights Defense Center by Adam C. Flores on behalf of: Ernest Galvan Rosen Bien Galvan & Grunfeld LLP 101 Mission Street, Sixth FloorSan Francisco, CA 94105 415-433-6830 Fax 415-433-7104 EGalvan@rbgg.com (Association Dues - Online Payment) (Flores, Adam)[THIS IS A TEXT-ONLY ENTRY. THERE ARE NO DOCUMENTS ATTACHED.] (Entered: 12/03/2024)

Association Dues Received: $ 100 receipt number ANMDC-9664679 re: # 17 Association of Attorney Licensed Outside the District, filed by Human Rights Defense Center (Payment made via Pay.gov)(Flores, Adam)

ASSOCIATION of Attorney Licensed Outside the District for Plaintiff Human Rights Defense Center by Adam C. Flores on behalf of: Jonathan P. Picard Human rights Defense Center P.O. Box 1151Lake Worth, Florida 33460 561-360-2523 Fax 561-828-8166 jpicard@humanrightsdefensecenter.org (Association Dues - Online Payment) (Flores, Adam)[THIS IS A TEXT-ONLY ENTRY. THERE ARE NO DOCUMENTS ATTACHED.] (Entered: 12/03/2024)

Association Dues Received: $ 100 receipt number ANMDC-9664694 re: # 18 Association of Attorney Licensed Outside the District, filed by Human Rights Defense Center (Payment made via Pay.gov)(Flores, Adam)

RESPONSE in Opposition re 3 MOTION for Preliminary Injunction filed by GEO Group, Inc.. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E) (Jahner, Michael) (Entered: 12/12/2024)

1 Exhibit A

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2 Exhibit B

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3 Exhibit C

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4 Exhibit D

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5 Exhibit E

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The GEO Group, Inc.'s ANSWER to 1 Complaint, with Jury Demand by GEO Group, Inc.. Related document: 1 Complaint, filed by Human Rights Defense Center.(Jahner, Michael) (Entered: 12/12/2024)

SUMMONS Returned Executed by Human Rights Defense Center. Wayne H. Calabrese served on 12/4/2024, answer due 12/26/2024. (Flores, Adam) (Entered: 12/13/2024)

Order to Show Cause

Order on Motion for Extension of Time to Answer

SUMMONS Returned Executed by Human Rights Defense Center. Brian R. Evans served on 12/4/2024, answer due 12/26/2024. (Flores, Adam) (Entered: 12/13/2024)

ORDER TO SHOW CAUSE by District Judge Margaret I. Strickland.THIS MATTER is before the Court on a sua sponte review of the record. On November 22, 2024, Defendants Michelle Lujan Grisham, Alisha Tafoya Lucero, Melanie Martinez, and Gary Maciel ("State Defendants") filed a Motion for Extension of Time to File an Answer or Other Response to the Complaint and to File a Response to the Motion for Preliminary Injunction ("Motion for Extension"). ECF No. 12 . On November 25, 2024, the Court entered an Order granting the Motion for Extension and providing the State Defendants until and including December 12, 2024 to respond to the Complaint and Motion for Preliminary Injunction. To date, the State Defendants have not responded to the Complaint or the Motion for Preliminary Injunction.Accordingly, Plaintiff shall have until and including December 23, 2024 to file a motion for clerk's entry of default or SHOW CAUSE why this case should not be dismissed as to the State Defendants for lack of prosecution and/or noncompliance with the Court's Orders.[THIS IS A TEXT-ONLY ENTRY. THERE ARE NO DOCUMENTS ATTACHED.] (gri) Modified on 12/17/2024 (jjs). (Entered: 12/13/2024)

Second MOTION for Extension of Time to File Answer by Michelle Lujan Grisham. (Carrillo, Raul) (Entered: 12/13/2024)

ORDER by District Judge Margaret I. Strickland GRANTING 24 State of New Mexico Related Defendants' Unopposed Motion for Second Extension of Time to File Answer or Other Response to Original Complaint and to File Response to Motion for Preliminary Injunction. Defendants Michelle Lujan Grisham, Alisha Tafoya Lucero, Melanie Martinez, and Gary Maciel shall have until and including December 20, 2024, to respond to the 1 Complaint and to file a Response to Plaintiff's 3 Motion for Preliminary Injunction.The Court's December 13, 2024, Order to Show Cause (ECF No. 23) is VACATED.[THIS IS A TEXT-ONLY ENTRY. THERE ARE NO DOCUMENTS ATTACHED.] (gri) (Entered: 12/13/2024)

NOTICE by Brian R. Evans, Wayne H. Calabrese Entry of Appearance and Notice of Agreed Extension of Time (Jahner, Michael) (Entered: 12/20/2024)

ANSWER to 1 Complaint, by Alisha Tafoya Lucero, Melanie Martinez, Gary Maciel. Related document: 1 Complaint, filed by Human Rights Defense Center.(Carrillo, Raul) (Entered: 12/20/2024)

MOTION to Dismiss Party by Michelle Lujan Grisham. (Carrillo, Raul) (Entered: 12/20/2024)

RESPONSE to Motion re 3 MOTION for Preliminary Injunction filed by Alisha Tafoya Lucero. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, # 4 Exhibit) (Carrillo, Raul) (Entered: 12/20/2024)

1 Exhibit

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2 Exhibit

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3 Exhibit

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4 Exhibit

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MOTION to Dismiss for Lack of Jurisdiction (Lack of Personal Jurisdiction) by Brian R. Evans, Wayne H. Calabrese. (Attachments: # 1 Exhibit A, # 2 Exhibit B) (Jahner, Michael) (Entered: 01/10/2025)

1 Exhibit A

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2 Exhibit B

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NOTICE by Brian R. Evans, Wayne H. Calabrese re 19 Response in Opposition to Motion (Notice of Joinder) (Jahner, Michael) (Entered: 01/10/2025)

PLEASE TAKE NOTICE that this case has been reassigned to District Judge Sarah M Davenport as the trial judge. Under D.N.M.LR-Civ. 10.1, the first page of each document must have the case file number and initials of the assigned judges.Accordingly, further documents filed in this matter must bear the case number and the judges' initials shown in the case caption and the NEF for this document. Kindly reflect this change in your filings. District Judge Margaret I. Strickland no longer assigned to this case.[THIS IS A TEXT-ONLY ENTRY. THERE ARE NO DOCUMENTS ATTACHED.] (nr) (Entered: 01/16/2025)

NOTICE by Human Rights Defense Center Notice of Agreed Extensions of Time (Shinn-Krantz, Marc) (Entered: 01/21/2025)

RESPONSE in Opposition re 28 MOTION to Dismiss Party Plaintiff's Opposition to Defendant Grisham's Motion to Dismiss filed by Human Rights Defense Center. (Shinn-Krantz, Marc) (Entered: 01/28/2025)

NOTICE by Human Rights Defense Center re 30 MOTION to Dismiss for Lack of Jurisdiction (Lack of Personal Jurisdiction) Notice of Agreed Extension of Time (Shinn-Krantz, Marc) (Entered: 01/28/2025)

ORDER by Magistrate Judge Kevin R. Sweazea. Telephonic Status Conference set for February 12, 2025 at 10:30 AM to discuss whether to hold a Rule 16 Scheduling Conference. The parties are directed to call Judge Sweazea's teleconference line at 855-244-8681, and enter Meeting Code 2300 989 9447# to be connected to the proceedings. [THIS IS A TEXT-ONLY ENTRY. NO DOCUMENTS ARE ATTACHED]. (ldm) (Entered: 01/29/2025)

Order AND ~Util - Set Hearings

Clerk's Minutes for proceedings held before Magistrate Judge Kevin R. Sweazea: Telephonic Status Conference Regarding Discovery held on February 12, 2025. (ldm) (Entered: 02/12/2025)

INITIAL SCHEDULING ORDER by Magistrate Judge Kevin R. Sweazea. Joint Status Report due by March 17, 2025. Telephonic Rule 16 Scheduling Conference set for March 26, 2025 at 10:00 AM. Counsel and any pro se party shall call (855) 244-8681 and enter Meeting Code 2300 989 9447# to be connected. (ldm) (Entered: 02/12/2025)

NOTICE by Michelle Lujan Grisham OF NON-AVAILABILITY (Carrillo, Raul) (Entered: 02/18/2025)

NOTICE by Human Rights Defense Center re 3 MOTION for Preliminary Injunction, 28 MOTION to Dismiss Party Notice of Agreed Extension of Time (Shinn-Krantz, Marc) (Entered: 02/24/2025)

NOTICE by Michelle Lujan Grisham Non-Availability (Carrillo, Raul) (Entered: 02/27/2025)

RESPONSE in Opposition re 30 MOTION to Dismiss for Lack of Jurisdiction (Lack of Personal Jurisdiction) Pltf's Opposition to Defs Evans and Calabrese's Motion to Dismiss filed by Human Rights Defense Center. (Attachments: # 1 Decl. of P. Wright iso Pltf's Opposition to Defs Evans and Calabrese's Motion to Dismiss) (Shinn-Krantz, Marc) (Entered: 02/28/2025)

REPLY to Response to Motion re 30 MOTION to Dismiss for Lack of Jurisdiction (Lack of Personal Jurisdiction) (Reply in Support of Evans and Calabrese's Motion to Dismiss) filed by Brian R. Evans, Wayne H. Calabrese. (Jahner, Michael) (Entered: 03/13/2025)

NOTICE of Briefing Complete by Brian R. Evans, Wayne H. Calabrese re 30 MOTION to Dismiss for Lack of Jurisdiction (Lack of Personal Jurisdiction) filed by Brian R. Evans, Wayne H. Calabrese (Jahner, Michael) (Entered: 03/13/2025)

Joint Status Report Joint Status Report and Provisional Discovery Plan by Human Rights Defense Center (Shinn-Krantz, Marc) (Entered: 03/17/2025)

REPLY to Response to Motion re 3 MOTION for Preliminary Injunction Plaintiff's Reply to All Defendants' Responses in Opposition to Plaintiff's Motion for Preliminary Injunction filed by Human Rights Defense Center. (Attachments: # 1 Reply Decl of P. Wright in Support of Plaintiff's Motion for Preliminary Injunction) (Shinn-Krantz, Marc) (Entered: 03/21/2025)

1 Reply Decl of P. Wright in Support of Plaintiff's Motion for Preliminary I

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NOTICE of Briefing Complete by Human Rights Defense Center re 3 MOTION for Preliminary Injunction filed by Human Rights Defense Center (Shinn-Krantz, Marc) (Entered: 03/21/2025)

NOTICE of Appearance by April D. White on behalf of Brian R. Evans, Wayne H. Calabrese, GEO Group, Inc. (White, April) (Entered: 03/24/2025)

CERTIFICATE OF SERVICE by Brian R. Evans, Wayne H. Calabrese, GEO Group, Inc. (GEO Defendants Initial Disclosures) (White, April) (Entered: 03/24/2025)

CERTIFICATE OF SERVICE by Alisha Tafoya Lucero State Defendants Initial Disclosures (Carrillo, Raul) (Entered: 03/24/2025)

CERTIFICATE OF SERVICE by Human Rights Defense Center Certificate of Service re Plaintiff's Rule 26(a)(1) Initial Disclosures (Shinn-Krantz, Marc) (Entered: 03/24/2025)

Clerk's Minutes for proceedings held before Magistrate Judge Kevin R. Sweazea: Telephonic Rule 16 Scheduling Conference held on March 26, 2025. (ldm) (Entered: 03/26/2025)

Minute Order

ORDER by Magistrate Judge Kevin R. Sweazea ADOPTING 45 JOINT STATUS REPORT AND PROVISIONAL DISCOVERY PLAN, filed by Human Rights Defense Center. (ldm) (Entered: 03/26/2025)

SCHEDULING ORDER by Magistrate Judge Kevin R. Sweazea. Fact Discovery due by January 30, 2026. Expert Discovery due by March 31, 2026. Dispositive Motions due by April 30, 2026. Consult attached order for additional deadlines. (ldm) (Entered: 03/26/2025)

MINUTE ORDER by Magistrate Judge Kevin R. Sweazea. After consultation with the parties, the Court will monitor the docket and set a status conference for the purpose of setting a date for holding a settlement conference once there is a ruling on the pending motions 2, 28, 30 . Should the parties want a settlement conference sooner, they should jointly contact chambers about setting a status conference. [THIS IS A TEXT-ONLY ENTRY. NO DOCUMENTS ARE ATTACHED.] (ldm) (Entered: 03/26/2025)

NOTICE by Human Rights Defense Center Notice of Good Standing (Attachments: # 1 Exhibit Benjamin Bien-Kahn) (Flores, Adam) (Entered: 04/08/2025)

ASSOCIATION of Attorney Licensed Outside the District for Plaintiff Human Rights Defense Center by Adam C. Flores on behalf of: Benjamin Joseph Bien-Kahn Rosen Bien Galvan & Grunfeld LLP 101 Mission Street, Sixth FloorSan Francisco, CA 94105 415-433-6830 Fax 415-433-7104 BBien-Kahn@rbgg.com (Association Dues - Online Payment) (Flores, Adam)[THIS IS A TEXT-ONLY ENTRY. THERE ARE NO DOCUMENTS ATTACHED.] (Entered: 04/08/2025)

Association Dues Received: $ 100 receipt number ANMDC-9877677 re: # 57 Association of Attorney Licensed Outside the District, filed by Human Rights Defense Center (Payment made via Pay.gov)(Flores, Adam)

Extension of Time to File Response/Reply

Reply to Response to Motion