1
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COMPLAINT against LORI CHAVEZ-DEREMER, U.S. DEPARTMENT OF LABOR ( Filing fee $ 405 receipt number ADCDC-11617773) filed by AMERICAN CENTER FOR INTERNATIONAL LABOR SOLIDARITY, GLOBAL MARCH AGAINST CHILD LABOUR, AMERICAN INSTITUTES FOR RESEARCH. (Attachments: # 1 Civil Cover Sheet, # 2 Summons U.S. Attorney General, # 3 Summons U.S. Department of Labor, # 4 Summons Secretary of Labor, # 5 Summons U.S. Attorney's Office)(Sansone, Nicolas) (Entered: 04/15/2025)
1 Civil Cover Sheet
View on PACER
2 Summons U.S. Attorney General
View on PACER
3 Summons U.S. Department of Labor
View on PACER
4 Summons Secretary of Labor
View on PACER
5 Summons U.S. Attorney's Office
View on PACER
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April 15, 2025
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April 15, 2025
Clearinghouse
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Case Assigned/Reassigned
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April 15, 2025
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April 15, 2025
PACER
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Case Assigned to Judge Beryl A. Howell. (zsl)
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April 15, 2025
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April 15, 2025
PACER
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2
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STANDING ORDER. Signed by Judge Beryl A. Howell on April 16, 2025. (lcbah2) (Entered: 04/16/2025)
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April 16, 2025
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April 16, 2025
PACER
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3
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SUMMONS (4) Issued Electronically as to LORI CHAVEZ-DEREMER, U.S. DEPARTMENT OF LABOR, U.S. Attorney and U.S. Attorney General (Attachment: # 1 Notice and Consent)(zsl) (Entered: 04/17/2025)
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April 17, 2025
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April 17, 2025
PACER
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4
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NOTICE of Appearance by Allison Marcy Zieve on behalf of All Plaintiffs (Zieve, Allison) (Entered: 04/18/2025)
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April 18, 2025
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April 18, 2025
PACER
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5
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NOTICE of Appearance by Stephanie Garlock on behalf of All Plaintiffs (Garlock, Stephanie) (Entered: 04/21/2025)
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April 21, 2025
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April 21, 2025
PACER
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6
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LCvR 26.1 CERTIFICATE OF DISCLOSURE of Corporate Affiliations and Financial Interests by AMERICAN INSTITUTES FOR RESEARCH (Sansone, Nicolas) (Entered: 04/21/2025)
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April 21, 2025
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April 21, 2025
PACER
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7
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LCvR 26.1 CERTIFICATE OF DISCLOSURE of Corporate Affiliations and Financial Interests by GLOBAL MARCH AGAINST CHILD LABOUR (Sansone, Nicolas) (Entered: 04/21/2025)
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April 21, 2025
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April 21, 2025
PACER
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8
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LCvR 26.1 CERTIFICATE OF DISCLOSURE of Corporate Affiliations and Financial Interests by AMERICAN CENTER FOR INTERNATIONAL LABOR SOLIDARITY (Sansone, Nicolas) (Entered: 04/21/2025)
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April 21, 2025
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April 21, 2025
PACER
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9
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MOTION for Preliminary Injunction by AMERICAN CENTER FOR INTERNATIONAL LABOR SOLIDARITY, AMERICAN INSTITUTES FOR RESEARCH, GLOBAL MARCH AGAINST CHILD LABOUR. (Attachments: # 1 Memorandum in Support, # 2 Declaration of Shawna Bader Blau, # 3 Declaration of David Seidenfeld, # 4 Declaration of Marco Dubbelt, # 5 Declaration of Thea Lee, # 6 Text of Proposed Order)(Garlock, Stephanie) (Entered: 05/05/2025)
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May 5, 2025
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May 5, 2025
PACER
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.Order
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May 6, 2025
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May 6, 2025
PACER
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MINUTE ORDER (paperless), upon consideration of plaintiffs' 9 Motion for Preliminary Injunction, DIRECTING the parties to confer and file jointly, by May 9, 2025, a proposed schedule to govern briefing on plaintiffs' motion, including the parties' position on consolidating plaintiffs' motion with summary judgment on the merits of this case. Signed by Judge Beryl A. Howell on May 6, 2025. (lcbah2)
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May 6, 2025
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May 6, 2025
PACER
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Set/Reset Deadlines
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May 7, 2025
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May 7, 2025
PACER
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Set/Reset Deadlines: Parties Proposed Schedule due by 5/9/2025 (mac)
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May 7, 2025
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May 7, 2025
PACER
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10
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Consent MOTION for Leave to File Amicus Brief in Support of Plaintiffs' Motion for Preliminary Injunction by CONSTITUTIONAL ACCOUNTABILITY CENTER. (Attachments: # 1 Proposed Amicus Brief, # 2 Text of Proposed Order)(Gorod, Brianne) (Entered: 05/07/2025)
1 Proposed Amicus Brief
View on PACER
2 Text of Proposed Order
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May 7, 2025
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May 7, 2025
PACER
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11
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NOTICE of Appearance by Miriam Becker-Cohen on behalf of CONSTITUTIONAL ACCOUNTABILITY CENTER (Becker-Cohen, Miriam) (Entered: 05/07/2025)
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May 7, 2025
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May 7, 2025
PACER
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Order on Motion for Leave to File Amicus Brief
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May 8, 2025
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May 8, 2025
PACER
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MINUTE ORDER (paperless) GRANTING 10 Consent Motion for Leave to File Amicus Brief. Signed by Judge Beryl A. Howell on May 8, 2025. (lcbah2)
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May 8, 2025
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May 8, 2025
PACER
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12
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Unopposed MOTION to Seal Document by AMERICAN CENTER FOR INTERNATIONAL LABOR SOLIDARITY, AMERICAN INSTITUTES FOR RESEARCH, GLOBAL MARCH AGAINST CHILD LABOUR. (Attachments: # 1 Text of Proposed Order)(Garlock, Stephanie) (Entered: 05/08/2025)
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May 8, 2025
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May 8, 2025
PACER
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13
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ERRATA by AMERICAN CENTER FOR INTERNATIONAL LABOR SOLIDARITY, AMERICAN INSTITUTES FOR RESEARCH, GLOBAL MARCH AGAINST CHILD LABOUR re 9 Motion for Preliminary Injunction,. (Attachments: # 1 Declaration of Shawna Bader-Blau (Corrected))(Garlock, Stephanie) (Entered: 05/08/2025)
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May 8, 2025
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May 8, 2025
PACER
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.Order
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May 9, 2025
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May 9, 2025
PACER
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Order on Motion for Miscellaneous Relief
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May 9, 2025
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May 9, 2025
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MINUTE ORDER (paperless) GRANTING plaintiffs' 12 Unopposed Motion to Seal Document and ORDERING the document filed at ECF No. 9-2 to be placed under seal. Signed by Judge Beryl A. Howell on May 9, 2025. (lcbah2)
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May 9, 2025
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May 9, 2025
PACER
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14
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Joint STATUS REPORT Regarding Scheduling by AMERICAN CENTER FOR INTERNATIONAL LABOR SOLIDARITY, AMERICAN INSTITUTES FOR RESEARCH, GLOBAL MARCH AGAINST CHILD LABOUR. (Garlock, Stephanie) (Entered: 05/09/2025)
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May 9, 2025
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May 9, 2025
PACER
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MINUTE ORDER (paperless), upon consideration of the parties' 14 Joint Statement Regarding Scheduling, DIRECTING the parties to file, by 12:00 PM on May 12, 2025, a proposed order reflecting exactly the briefing schedule and procedures proposed by the parties to be adopted to govern resolution of plaintiffs' 9 Motion for Preliminary Injunction. Signed by Judge Beryl A. Howell on May 9, 2025. (lcbah2)
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May 9, 2025
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May 9, 2025
PACER
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Set/Reset Deadlines
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May 11, 2025
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May 11, 2025
PACER
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Set/Reset Deadlines: Proposed Order Reflecting Exactly The Briefing Schedule And Procedures Proposed By The Parties To Be Adopted To Govern Resolution Of Plaintiffs' 9 Motion for Preliminary Injunction due by no later than 12:00PM on 5/12/2025. (mac)
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May 11, 2025
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May 11, 2025
PACER
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15
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NOTICE of Appearance by Charles E.T. Roberts on behalf of All Defendants (Roberts, Charles) (Entered: 05/12/2025)
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May 12, 2025
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May 12, 2025
PACER
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.Order
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May 12, 2025
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May 12, 2025
PACER
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16
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NOTICE of Proposed Order by AMERICAN CENTER FOR INTERNATIONAL LABOR SOLIDARITY, AMERICAN INSTITUTES FOR RESEARCH, GLOBAL MARCH AGAINST CHILD LABOUR re 14 Status Report (Garlock, Stephanie) (Entered: 05/12/2025)
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May 12, 2025
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May 12, 2025
PACER
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MINUTE ORDER (paperless), upon consideration of the parties' 14 Joint Statement Regarding Scheduling and 16 Proposed Scheduling Order, ISSUING the following SCHEDULING ORDER to govern briefing of plaintiffs' 9 Motion for Preliminary Injunction, which shall be treated, pursuant to the agreement of the parties, as a motion for partial summary judgment on Counts I through IV of plaintiffs' complaint, for resolution of which motion the parties do not believe any statement of material facts is necessary, as otherwise required under D.D.C. Local Rule 7(h)(2), see 16 Proposed Scheduling Order; 14 Joint Statement Regarding Scheduling at 1-2:(1) By May 22, 2025, defendants shall file any opposition to plaintiffs' motion; (2) By May 28, 2025, plaintiffs shall file any reply; and(3) A motions hearing, if necessary, will be scheduled for a date after briefing is complete. Signed by Judge Beryl A. Howell on May 12, 2025. (lcbah2)
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May 12, 2025
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May 12, 2025
PACER
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Set/Reset Deadlines
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May 13, 2025
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May 13, 2025
PACER
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Set/Reset Deadlines: Defendants Opposition To Plaintiff's Motion due by 5/22/2025. Plaintiffs Reply due by 5/28/2025. (mac)
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May 13, 2025
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May 13, 2025
PACER
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19
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Memorandum in opposition to re 9 MOTION for Preliminary Injunction filed by LORI CHAVEZ-DEREMER, U.S. DEPARTMENT OF LABOR. (Attachments: # 1 Declaration of Thomas S. Kodiak)(Roberts, Charles) (Entered: 05/22/2025)
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May 22, 2025
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May 22, 2025
PACER
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20
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RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed on United States Attorney General. Date of Service Upon United States Attorney General 4/28/2025. (Attachments: # 1 Exhibit Proof of Service)(Sansone, Nicolas) (Entered: 05/28/2025)
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May 28, 2025
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May 28, 2025
PACER
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21
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RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. LORI CHAVEZ-DEREMER served on 4/28/2025 (Attachments: # 1 Exhibit Proof of Service)(Sansone, Nicolas) (Entered: 05/28/2025)
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May 28, 2025
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May 28, 2025
PACER
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22
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RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. U.S. DEPARTMENT OF LABOR served on 4/28/2025 (Attachments: # 1 Exhibit Proof of Service)(Sansone, Nicolas) (Entered: 05/28/2025)
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May 28, 2025
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May 28, 2025
PACER
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23
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RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed as to the United States Attorney. Date of Service Upon United States Attorney on 4/21/2025. Answer due for ALL FEDERAL DEFENDANTS by 6/20/2025. (Attachments: # 1 Exhibit Proof of Service)(Sansone, Nicolas) (Entered: 05/28/2025)
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May 28, 2025
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May 28, 2025
PACER
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24
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REPLY to opposition to motion re 9 Motion for Preliminary Injunction, filed by AMERICAN CENTER FOR INTERNATIONAL LABOR SOLIDARITY, AMERICAN INSTITUTES FOR RESEARCH, GLOBAL MARCH AGAINST CHILD LABOUR. (Garlock, Stephanie) (Entered: 05/28/2025)
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May 28, 2025
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May 28, 2025
PACER
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.Order
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June 3, 2025
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June 3, 2025
PACER
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MINUTE ORDER (paperless) DIRECTING the parties to appear for a hearing on plaintiffs' 9 Motion for Preliminary Injunction on June 11, 2025, at 10:00 AM in Courtroom 26A- In Person before Judge Beryl A. Howell.Members of the public or media who wish to listen to live audio of the hearing without physically attending the proceeding may do so by dialing the Toll Free Number: 833-990-9400, Meeting ID: 491822013. Any use of the public access telephone line requires adherence to the general prohibition against photographing, recording, livestreaming, and rebroadcasting of court proceedings (including those held by telephone or videoconference), as set out in Standing Order No. 24-31 (JEB), available here: <https://www.dcd.uscourts.gov/sites/dcd/files/Standing Order No. 24-31_001.pdf >. 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 other sanctions deemed necessary by the Court. Signed by Judge Beryl A. Howell on June 3, 2025. (lcbah2)
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June 3, 2025
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June 3, 2025
PACER
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MINUTE ORDER (paperless), in light of the parties' agreement to consolidate consideration of plaintiffs' 9 Motion for Preliminary Injunction "with summary judgment on the merits" of "Counts I through IV of Plaintiffs' complaint," Parties' 14 Joint Statement Regarding Scheduling at 1-2, DIRECTING the parties to file, by 4:00 PM on June 5, 2025, a joint status report clarifying whether defendants' 19 Opposition to Plaintiffs' Motion for Summary Judgment on Counts I-IV and Motion for Preliminary Injunction on Count V should be treated as a cross-motion for summary judgment on Counts I through IV of the 1 Complaint. Signed by Judge Beryl A. Howell on June 3, 2025. (lcbah2)
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June 3, 2025
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June 3, 2025
PACER
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Set/Reset Deadlines
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June 4, 2025
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June 4, 2025
PACER
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Set/Reset Hearings
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June 4, 2025
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June 4, 2025
PACER
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.Order
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June 4, 2025
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June 4, 2025
PACER
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Set/Reset Hearings: Preliminary Injunction Hearing set for 6/11/2025 at 10:00 AM in Courtroom 26A- In Person before Judge Beryl A. Howell. (mac)
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June 4, 2025
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June 4, 2025
PACER
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Set/Reset Deadlines: Parties Joint Status Report due no later than 4:00PM on 6/5/2025. (mac)
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June 4, 2025
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June 4, 2025
PACER
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25
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Joint STATUS REPORT by LORI CHAVEZ-DEREMER, U.S. DEPARTMENT OF LABOR. (Attachments: # 1 Text of Proposed Order)(Roberts, Charles) (Entered: 06/04/2025)
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June 4, 2025
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June 4, 2025
PACER
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MINUTE ORDER (paperless), upon consideration of the parties' 25 Joint Status Report, which filing requests defendants' 19 Opposition to Plaintiffs' Motion for Summary Judgment on Counts I-IV and Motion for a Preliminary Injunction on Count V be treated "as a cross-motion for summary judgment on Counts I through IV of the Complaint if Defendants are given leave to file any reply in support thereof by Monday, June 9," which request plaintiffs "do not oppose," 25 Joint Status Report at 1, GRANTING defendants' request and DIRECTING defendants to file any reply by June 9, 2025. Signed by Judge Beryl A. Howell on June 4, 2025. (lcbah2)
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June 4, 2025
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June 4, 2025
PACER
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Set/Reset Deadlines
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June 5, 2025
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June 5, 2025
PACER
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Set/Reset Deadlines: Defendants Reply due by 6/9/2025. (mac)
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June 5, 2025
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June 5, 2025
PACER
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26
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RESPONSE re 19 Memorandum in Opposition which is being treated as a cross-motion for summary judgment on Counts I through IV of the Complaint filed by LORI CHAVEZ-DEREMER, U.S. DEPARTMENT OF LABOR. (Roberts, Charles) (Entered: 06/09/2025)
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June 9, 2025
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June 9, 2025
RECAP
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Motion Hearing
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June 11, 2025
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June 11, 2025
PACER
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Minute Entry for proceedings held before Judge Beryl A. Howell: Motion Hearing held on 6/11/2025 re 9 Motion for Preliminary Injunction. The Court Heard Oral Arguments From The Parties And This Matter Is Under Advisement. (Court Reporter CHANDREA KEAN.) (mac)
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June 11, 2025
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June 11, 2025
PACER
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27
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Consent MOTION to Stay Complaint Response Deadline by LORI CHAVEZ-DEREMER, U.S. DEPARTMENT OF LABOR. (Attachments: # 1 Text of Proposed Order)(Roberts, Charles) (Entered: 06/17/2025)
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June 17, 2025
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June 17, 2025
PACER
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Order on Motion to Stay
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June 18, 2025
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June 18, 2025
PACER
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MINUTE ORDER (paperless) GRANTING defendants' 27 Consent Motion to Stay Complaint Response Deadline and DIRECTING defendants to respond to the 1 Complaint within 14 days of the Court's decision on the parties' pending 9 and 19 partial cross-motions for summary judgment and plaintiffs' 9 motion for a preliminary injunction as to Count V only. Signed by Judge Beryl A. Howell on June 18, 2025. (lcbah2)
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June 18, 2025
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June 18, 2025
PACER
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28
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Transcript
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June 29, 2025
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June 29, 2025
PACER
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29
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ORDER DENYING plaintiffs' 9 partial motion for summary judgment as to Counts I through IV and motion for a preliminary injunction as to Count V and DENYING defendants' 19 partial cross-motion for summary judgment as to Counts I through IV. See Order for further details. Signed by Judge Beryl A. Howell on June 30, 2025. (lcbah2) (Entered: 06/30/2025)
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June 30, 2025
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June 30, 2025
RECAP
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Set/Reset Deadlines
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June 30, 2025
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June 30, 2025
PACER
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30
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MEMORANDUM OPINION regarding plaintiffs' 9 partial motion for summary judgment as to Counts I through IV and motion for a preliminary injunction as to Count V and defendants' 19 partial cross-motion for summary judgment as to Counts I through IV. Signed by Judge Beryl A. Howell on June 30, 2025. (lcbah2) (Entered: 06/30/2025)
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June 30, 2025
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June 30, 2025
RECAP
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Set/Reset Deadlines: Parties Joint Status Report due by 7/11/2025. (mac)
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June 30, 2025
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June 30, 2025
PACER
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31
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Joint STATUS REPORT by AMERICAN CENTER FOR INTERNATIONAL LABOR SOLIDARITY, AMERICAN INSTITUTES FOR RESEARCH, GLOBAL MARCH AGAINST CHILD LABOUR. (Attachments: # 1 Text of Proposed Order)(Garlock, Stephanie) (Entered: 07/10/2025)
1 Text of Proposed Order
View on RECAP
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July 10, 2025
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July 10, 2025
PACER
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32
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NOTICE of Proposed Order (Revised) by LORI CHAVEZ-DEREMER, U.S. DEPARTMENT OF LABOR re 31 Status Report (Attachments: # 1 Text of Proposed Order)(Roberts, Charles) (Entered: 07/11/2025)
1 Text of Proposed Order
View on RECAP
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July 11, 2025
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July 11, 2025
PACER
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.Order
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July 11, 2025
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July 11, 2025
PACER
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MINUTE ORDER (paperless), upon consideration of the parties' 31 Joint Status Report and 32 Notice of Revised Proposed Order, DIRECTING defendants, by July 25, 2025, to produce the administrative record to plaintiffs and file with the Court a certified list of the contents of the administrative record; FURTHER DIRECTING the parties to file, by August 1, 2025, a joint status report advising the Court of the status of this matter and proposing a schedule to govern further proceedings; and, pursuant to the agreement of the parties, see 32 Notice of Revised Proposed Order, STAYING defendants' obligation to respond to the 1 Complaint pending further order of the Court. Signed by Judge Beryl A. Howell on July 11, 2025. (lcbah2)
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July 11, 2025
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July 11, 2025
PACER
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Set/Reset Deadlines
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July 14, 2025
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July 14, 2025
PACER
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Set/Reset Deadlines: Administrative Record due by 7/25/2025. Parties Joint Status Report due by 8/1/2025. (mac)
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July 14, 2025
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July 14, 2025
PACER
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33
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NOTICE of Appearance by Kaitlin Kerry Eckrote on behalf of LORI CHAVEZ-DEREMER, U.S. DEPARTMENT OF LABOR (Eckrote, Kaitlin) (Entered: 07/17/2025)
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July 17, 2025
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July 17, 2025
PACER
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34
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NOTICE of filing Certification of the Contents of the Administrative Record by LORI CHAVEZ-DEREMER, U.S. DEPARTMENT OF LABOR (Eckrote, Kaitlin) (Entered: 07/25/2025)
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July 25, 2025
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July 25, 2025
PACER
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35
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Joint STATUS REPORT by AMERICAN CENTER FOR INTERNATIONAL LABOR SOLIDARITY, AMERICAN INSTITUTES FOR RESEARCH, GLOBAL MARCH AGAINST CHILD LABOUR. (Attachments: # 1 Text of Proposed Order)(Garlock, Stephanie) (Entered: 07/31/2025)
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July 31, 2025
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July 31, 2025
PACER
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.Order
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Aug. 1, 2025
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Aug. 1, 2025
PACER
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MINUTE ORDER (paperless), upon consideration of the parties' 35 Joint Status Report, DIRECTING the parties to file, by August 8, 2025, another joint status report advising the Court of the status of this matter and proposing a schedule to govern further proceedings. Signed by Judge Beryl A. Howell on August 1, 2025. (lcbah2)
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Aug. 1, 2025
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Aug. 1, 2025
PACER
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Set/Reset Deadlines
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Aug. 1, 2025
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Aug. 1, 2025
PACER
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Set/Reset Deadlines: Parties Joint Status Report due by 8/8/2025. (mac)
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Aug. 1, 2025
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Aug. 1, 2025
PACER
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36
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Joint STATUS REPORT by AMERICAN CENTER FOR INTERNATIONAL LABOR SOLIDARITY, AMERICAN INSTITUTES FOR RESEARCH, GLOBAL MARCH AGAINST CHILD LABOUR. (Attachments: # 1 Text of Proposed Order)(Garlock, Stephanie) (Entered: 08/08/2025)
1 Text of Proposed Order
View on PACER
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Aug. 8, 2025
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Aug. 8, 2025
PACER
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.Order
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Aug. 8, 2025
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Aug. 8, 2025
PACER
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MINUTE ORDER (paperless), upon consideration of the parties' 36 Joint Status Report proposing a briefing schedule for cross-motions for summary judgment, ISSUING the following scheduling order: 1. By September 3, 2025, plaintiffs shall file their motion for summary judgment. 2. By September 24, 2025, defendants shall file their opposition to plaintiffs' motion and their cross-motion for summary judgment. 3. By October 8, 2025, plaintiffs shall file their reply in support of their motion for summary judgment and their opposition to defendants' cross-motion. 4. By October 22, 2025, defendants shall file their reply in support of their cross-motion for summary judgment.5. By October 29, 2025, plaintiffs shall file an appendix of cited portions of the administrative record. Signed by Judge Beryl A. Howell on August 8, 2025. (lcbah4)
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Aug. 8, 2025
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Aug. 8, 2025
PACER
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Set/Reset Deadlines
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Aug. 11, 2025
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Aug. 11, 2025
PACER
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