Case: Victim Rights Law Center v. U.S. Department of Education

1:25-cv-11042 | U.S. District Court for the District of Massachusetts

Filed Date: April 21, 2025

Case Ongoing

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Case Summary

This case challenged the reduction-in-force (RIF) of the Office of Civil Rights by the Department of Education. On March 11, 2025, the Department of Education announced a massive RIF that reduced its workforce by almost half, including more than half of the workforce in the Office of Civil Rights (OCR). The Department also closed seven of OCR's twelve regional offices, terminating all employees who worked in those offices. On April 21, 2025, Victim Rights Law Center, a nonprofit organization se…

On April 21, 2025, Victim Rights Law Center, a nonprofit organization serving the legal needs of sex-based harassment victims, and multiple minor students and their parents filed suit in the District Court for the District of Massachusetts. Represented by private counsel, the plaintiffs sued the United States Department of Education and its Secretary, alleging that the RIF was arbitrary and capricious and contrary to law under the Administrative Procedure Act (APA) and was ultra vires. The defendants' actions, according to the plaintiffs, made it impossible for the OCR to investigate incoming civil rights complaints as required by statute, thereby violating the APA. The plaintiffs asked the court to declare the RIF unlawful, to vacate the RIF and decision to close the regional offices, and to enjoin the defendants from taking action to effectuate the RIF.

This case was assigned to District Judge Myong J. Joun due to its relation to another case, New York v. McMahon, which also challenged this RIF. In that case, Judge Joun issued a preliminary injunction "enjoining the RIF and ordering that the Department be returned to the pre-RIF status quo," and finding that "Consolidated Plaintiffs were likely to succeed in their claims that the mass terminations hamstring the Department’s ability to meet its statutory functions and that the RIF effectively eliminates the Department without Congressional approval, in violation of the APA and the Constitution."

On May 2, the plaintiffs filed a motion for a preliminary injunction, which the court granted on June 18. The court said that, although the case was related to McMahon, in which the court had already granted relief, the "Plaintiffs’ case warrants a separate decision to address the unique harms they are suffering." The court first held that the Civil Service Reform Act did not divest it of jurisdiction in the case, since (as the First Circuit held in McMahon) "Congress did not intend to foreclose the availability of judicial review of mass terminations that effectively incapacitate a statutorily created office." Turning to the merits, the court found that the plaintiffs properly challenged a discrete and final agency action (the defendants' decision to terminate half of OCR's staff) as required by the APA. On the merits of the plaintiffs' claims, the court found that the RIF was arbitrary and capricious since it did not provide a reasoned explanation for the mass terminations, and that it was also contrary to law and ultra vires since OCR will be unable to fulfill its statutory mandates.

The court also found that the plaintiffs would suffer irreparable harm without an injunction, since the student plaintiffs had seen their investigations discontinued since the RIF, and VRLC will continue to have difficulty in accomplishing its mission of providing legal services. Therefore, the court enjoined the defendants from implementing the RIF and ordered OCR to "continue to investigate all complaints alleging violations of federal civil rights laws prohibiting race, sex, and disability-based discrimination under education programs and activities that received federal financial assistance."

On July 21, the defendants filed a motion to vacate the preliminary injunction. The defendants pointed to another case, New York v. McMahon, which also challenged the attempted RIF. The district court granted a preliminary injunction in McMahon, but on July 14, 2025, the Supreme Court granted a stay of the district court's injunction, thereby reflecting the Court's judgment that "the Defendants were likely to succeed on the merits, and that the other equitable considerations also militated against preliminary relief." The defendants argued that this case was practically identical to McMahon and therefore asked the district court to vacate its order granting a preliminary injunction in this case. The defendants also filed a motion to dismiss the case on July 28, arguing that the court lacked jurisdiction and that the plaintiffs had failed to state a claim.

On August 13, 2025, the district court issued an order denying the defendants' motion to vacate or stay the preliminary injunction pending appeal. It reasoned, first, that the Supreme Court's grant of a stay in McMahon did not make or signal a change in controlling law warranting the requested relief. It further rejected the argument that this case was identical to that one, citing the unique harms faced by the plaintiffs here. Finally, it concluded that the defendants had not demonstrated that the equities favored a stay or that that they would otherwise suffer harm, citing their failure to substantially comply with the preliminary injunction. On August 14, defendants appealed the district court's preliminary injunction ruling to the U.S. Court of Appeals for the First Circuit (USCA Case Number 25-1787).

The case is ongoing.

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Summary Authors

Jeremiah Price (6/20/2025)

People

For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/69921190/parties/victim-rights-law-center-v-united-states-department-of-education/

Attorney for Plaintiff

Archer, Patrick Graham (Massachusetts)

Friedman, Jonathan Hale (Massachusetts)

Attorney for Defendant

Bruns, Michael Benjamin (Massachusetts)

George, Abraham R. (Massachusetts)

Lockhart, Donald Campbell (Massachusetts)

Attorney for Plaintiff

Archer, Patrick Graham (Massachusetts)

Friedman, Jonathan Hale (Massachusetts)

Nasrolahi, Leila Nicole (Massachusetts)

Ouellette, Sean R. (Massachusetts)

Skibell, L. Reid (Massachusetts)

Skibell, Lindsay R. (Massachusetts)

Attorney for Defendant

Bruns, Michael Benjamin (Massachusetts)

George, Abraham R. (Massachusetts)

Lockhart, Donald Campbell (Massachusetts)

Patterson, Melissa N. (Massachusetts)

Rosenberg, Brad P. (Massachusetts)

Attorney Contact Information via CourtListener

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Documents in the Clearinghouse

	Document
1 1:25-cv-11042	Complaint for Declaratory and Injunctive Relief	April 21, 2025	April 21, 2025 Complaint
40 1:25-cv-11042	Memorandum and Order on Plaintiffs' Motion for Preliminary Injunction	June 18, 2025	June 18, 2025 Order/Opinion 2025 WL 1704311
60 1:25-cv-11042	Order on Defendants' Motion to Vacate or Alternatively Stay the Preliminary Injunction Pending Appeal	Aug. 13, 2025	Aug. 13, 2025 Order/Opinion 2025 WL 2374176

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Docket

See docket on RECAP: https://www.courtlistener.com/docket/69921190/victim-rights-law-center-v-united-states-department-of-education/

Last updated Aug. 21, 2025, 7:04 p.m.

ECF Number	Description	Date	Link Date / Link
1	COMPLAINT against All Defendants Filing fee: $ 405, receipt number AMADC-10962967 (Fee Status: Filing Fee paid), filed by Victim Rights Law Center, Tara Blunt, T. R., Karen Josefosky, A. J.. (Attachments: # 1 Civil Cover Sheet, # 2 Category Form )(Ouellette, Sean) Modified on 4/21/2025 to edit docket text(SR). (Entered: 04/21/2025) 1 Civil Cover Sheet View on PACER 2 Category Form View on PACER	April 21, 2025	April 21, 2025 Clearinghouse
2	MOTION for Leave to Appear Pro Hac Vice for admission of Jonathan Friedman Filing fee: $ 125, receipt number AMADC-10963218 by Victim Rights Law Center, Tara Blunt, T. R., Karen Josefosky, A. J..(Ouellette, Sean) (Entered: 04/21/2025)	April 21, 2025	April 21, 2025 PACER
3	ELECTRONIC NOTICE of Case Assignment. Judge Myong J. Joun assigned to case. If the trial Judge issues an Order of Reference of any matter in this case to a Magistrate Judge, the matter will be transmitted to Magistrate Judge M. Page Kelley. (JAM) (Entered: 04/21/2025)	April 21, 2025	April 21, 2025 PACER
4	Summons Issued as to Linda McMahon, Craig Trainor, United States Department of Education. Counsel receiving this notice electronically should download this summons, complete one for each defendant and serve it in accordance with Fed.R.Civ.P. 4 and LR 4.1. Summons will be mailed to plaintiff(s) not receiving notice electronically for completion of service. (SR) (Entered: 04/21/2025)	April 21, 2025	April 21, 2025 PACER
5	MOTION for Leave to Appear Pro Hac Vice for admission of Lindsey (Reid) Skibell Filing fee: $ 125, receipt number AMADC-10963259 by Victim Rights Law Center, Tara Blunt, T. R., Karen Josefosky, A. J..(Ouellette, Sean) (Entered: 04/21/2025)	April 21, 2025	April 21, 2025 PACER
6	CORPORATE DISCLOSURE STATEMENT by Victim Rights Law Center. (Ouellette, Sean) (Entered: 04/21/2025)	April 21, 2025	April 21, 2025 PACER
	Notice of Case Assignment	April 21, 2025	April 21, 2025 PACER
7	Judge Myong J. Joun: ELECTRONIC ORDER entered GRANTING 2 Motion for Leave to Appear Pro Hac Vice Added Jonathan Friedman. Attorneys admitted Pro Hac Vice must have an individual PACER account, not a shared firm account, to electronically file in the District of Massachusetts. To register for a PACER account, go the Pacer website at https://pacer.uscourts.gov/register-account. You must put the docket number under ADDITIONAL FILER INFORMATION on your form when registering or it will be rejected.Pro Hac Vice Admission Request Instructions https://www.mad.uscourts.gov/caseinfo/nextgen-pro-hac-vice.htm.A Notice of Appearance must be entered on the docket by the newly admitted attorney. (SP) (Entered: 04/28/2025)	April 28, 2025	April 28, 2025 PACER
8	Judge Myong J. Joun: ELECTRONIC ORDER entered GRANTING 5 Motion for Leave to Appear Pro Hac Vice Added Lindsey Reid Skibell. Attorneys admitted Pro Hac Vice must have an individual upgraded PACER account, not a shared firm account, to electronically file in the District of Massachusetts. Counsel may need to link their CM/ECF account to their upgraded individual pacer account. Instructions on how to link CM/ECF accounts to upgraded pacer account can be found at https://www.mad.uscourts.gov/caseinfo/nextgen-current-pacer-accounts.htm#link-account. (SP) (Entered: 04/28/2025)	April 28, 2025	April 28, 2025 PACER
	Order on Motion for Leave to Appear	April 28, 2025	April 28, 2025 PACER
10	NOTICE of Appearance by L. Reid Skibell on behalf of Tara Blunt, A. J., Karen Josefosky, T. R., Victim Rights Law Center (Skibell, L. Reid) (Entered: 04/29/2025)	April 29, 2025	April 29, 2025 PACER
9	NOTICE of Appearance by Jonathan Hale Friedman on behalf of Tara Blunt, A. J., Karen Josefosky, Victim Rights Law Center (Friedman, Jonathan) (Entered: 04/29/2025)	April 29, 2025	April 29, 2025 PACER
11	Assented to MOTION for Leave to File Excess Pages by Tara Blunt, A. J., Karen Josefosky, T. R., Victim Rights Law Center.(Ouellette, Sean) (Entered: 04/30/2025)	April 30, 2025	April 30, 2025 PACER
12	Judge Myong J. Joun: ELECTRONIC ORDER entered granting 11 Assented-to MOTION for Leave to File Excess Pages by Tara Blunt, A. J., Karen Josefosky, T. R., Victim Rights Law Center. (JL) (Entered: 05/01/2025)	May 1, 2025	May 1, 2025 PACER
13	AFFIDAVIT OF SERVICE Executed by T. R., Tara Blunt, Karen Josefosky, Victim Rights Law Center, A. J.. United States Department of Education served on 4/25/2025, answer due 5/16/2025. Acknowledgement filed by T. R.; Tara Blunt; Karen Josefosky; Victim Rights Law Center; A. J.. (Skibell, L. Reid) (Entered: 05/01/2025)	May 1, 2025	May 1, 2025 PACER
14	AFFIDAVIT OF SERVICE Executed by T. R., Tara Blunt, Karen Josefosky, Victim Rights Law Center, A. J.. Linda McMahon served on 4/25/2025, answer due 5/16/2025. Acknowledgement filed by T. R.; Tara Blunt; Karen Josefosky; Victim Rights Law Center; A. J.. (Skibell, L. Reid) (Entered: 05/01/2025)	May 1, 2025	May 1, 2025 PACER
15	AFFIDAVIT OF SERVICE Executed by T. R., Tara Blunt, Karen Josefosky, Victim Rights Law Center, A. J.. Craig Trainor served on 4/25/2025, answer due 5/16/2025. Acknowledgement filed by T. R.; Tara Blunt; Karen Josefosky; Victim Rights Law Center; A. J.. (Skibell, L. Reid) (Entered: 05/01/2025)	May 1, 2025	May 1, 2025 PACER
	Order on Motion for Leave to File Excess Pages	May 1, 2025	May 1, 2025 PACER
16	SUMMONS Returned Executed as to US Attorney by T. R., Tara Blunt, Karen Josefosky, Victim Rights Law Center, A. J.. (Skibell, L. Reid) (Entered: 05/02/2025)	May 2, 2025	May 2, 2025 PACER
17	NOTICE of Appearance by Brad P. Rosenberg on behalf of Linda McMahon, Craig Trainor, United States Department of Education (Rosenberg, Brad) (Entered: 05/02/2025)	May 2, 2025	May 2, 2025 PACER
18	MOTION for Preliminary Injunction by Tara Blunt, A. J., Karen Josefosky, T. R., Victim Rights Law Center.(Skibell, L. Reid) (Entered: 05/02/2025)	May 2, 2025	May 2, 2025 PACER
19	MEMORANDUM in Support re 18 MOTION for Preliminary Injunction filed by Tara Blunt, A. J., Karen Josefosky, T. R., Victim Rights Law Center. (Skibell, L. Reid) (Entered: 05/02/2025)	May 2, 2025	May 2, 2025 RECAP
20	DECLARATION re 18 MOTION for Preliminary Injunction of Patrick Archer by Tara Blunt, A. J., Karen Josefosky, T. R., Victim Rights Law Center. (Attachments: # 1 Exhibit 1 - Lhmahon Declaration, # 2 Exhibit 2 - Doe Declaration, # 3 Exhibit 3 - Gonzales Declaration, # 4 Exhibit 4 - Doe 7 Declaration, # 5 Exhibit 5 - McMahon Statement, # 6 Exhibit 6 - D.O.E. Press Release, # 7 Exhibit 7 - Smith Declaration, # 8 Exhibit 8 - Trainor Memo, # 9 Exhibit 9 - Doe 3 Declaration, # 10 Exhibit 10 - Suppl. Hamilin Declaration, # 11 Exhibit 11 - D.O.E. Report, # 12 Exhibit 12 - 2024 Fiscal Annual Year Report, # 13 Exhibit 13 - Budget Requests, # 14 Exhibit 14 - Haller Declaration, # 15 Exhibit 15 - Blunt Declaration, # 16 Exhibit 16 - Josefosky Declaration, # 17 Exhibit 17 - Malone Declaration, # 18 Exhibit 18 - Carmona Declaration, # 19 Exhibit 19 - Ehling Declaration, # 20 Exhibit 20 - Echelson Declaration)(Skibell, L. Reid) (Entered: 05/02/2025) 1 Exhibit 1 - Lhmahon Declaration View on RECAP 2 Exhibit 2 - Doe Declaration View on RECAP 3 Exhibit 3 - Gonzales Declaration View on RECAP 4 Exhibit 4 - Doe 7 Declaration View on RECAP 5 Exhibit 5 - McMahon Statement View on RECAP 6 Exhibit 6 - D.O.E. Press Release View on RECAP 7 Exhibit 7 - Smith Declaration View on RECAP 8 Exhibit 8 - Trainor Memo View on RECAP 9 Exhibit 9 - Doe 3 Declaration View on RECAP 10 Exhibit 10 - Suppl. Hamilin Declaration View on RECAP 11 Exhibit 11 - D.O.E. Report View on RECAP 12 Exhibit 12 - 2024 Fiscal Annual Year Report View on RECAP 13 Exhibit 13 - Budget Requests View on RECAP 14 Exhibit 14 - Haller Declaration View on RECAP 15 Exhibit 15 - Blunt Declaration View on RECAP 16 Exhibit 16 - Josefosky Declaration View on RECAP 17 Exhibit 17 - Malone Declaration View on RECAP 18 Exhibit 18 - Carmona Declaration View on RECAP 19 Exhibit 19 - Ehling Declaration View on RECAP 20 Exhibit 20 - Echelson Declaration View on RECAP	May 2, 2025	May 2, 2025 RECAP
21	Proposed Document(s) submitted by Tara Blunt, A. J., Karen Josefosky, T. R., Victim Rights Law Center. Document received: Proposed Order. (Ouellette, Sean) (Entered: 05/06/2025)	May 6, 2025	May 6, 2025 RECAP
22	NOTICE of Appearance by Michael Benjamin Bruns on behalf of Linda McMahon, Craig Trainor, United States Department of Education (Bruns, Michael) (Entered: 05/14/2025)	May 14, 2025	May 14, 2025 PACER
23	Assented to MOTION for Leave to File Excess Pages by Linda McMahon, Craig Trainor, United States Department of Education.(Bruns, Michael) (Entered: 05/14/2025)	May 14, 2025	May 14, 2025 PACER
24	Judge Myong J. Joun: ELECTRONIC ORDER entered granting 23 Assented-to Motion for Leave to File Excess Pages.(JL) (Entered: 05/16/2025)	May 16, 2025	May 16, 2025 PACER
25	MEMORANDUM in Opposition re 18 MOTION for Preliminary Injunction filed by Linda McMahon, Craig Trainor, United States Department of Education. (Bruns, Michael) (Entered: 05/16/2025)	May 16, 2025	May 16, 2025 RECAP
	Order on Motion for Leave to File Excess Pages	May 16, 2025	May 16, 2025 PACER
26	Assented to MOTION for Leave to File 20-Page Reply Brief by Tara Blunt, A. J., Karen Josefosky, T. R., Victim Rights Law Center.(Friedman, Jonathan) (Entered: 05/20/2025)	May 20, 2025	May 20, 2025 PACER
27	Judge Myong J. Joun: ELECTRONIC ORDER entered GRANTING 26 Assented to MOTION for Leave to File 20-Page Reply Brief Motion for Leave to File Document ; Counsel using the Electronic Case Filing System should now file the document for which leave to file has been granted in accordance with the CM/ECF Administrative Procedures. Counsel must include - Leave to file granted on (date of order)- in the caption of the document. (SP) (Entered: 05/21/2025)	May 21, 2025	May 21, 2025 PACER
	Order on Motion for Leave to File Document	May 21, 2025	May 21, 2025 PACER
28	MOTION for Leave to Appear Pro Hac Vice for admission of Leila Nasrolahi Filing fee: $ 125, receipt number AMADC-11027918 by Tara Blunt, A. J., Karen Josefosky, T. R., Victim Rights Law Center.(Ouellette, Sean) (Entered: 05/23/2025)	May 23, 2025	May 23, 2025 PACER
29	Judge Myong J. Joun: ELECTRONIC ORDER entered GRANTING 28 Motion for Leave to Appear Pro Hac Vice Added Leila Nasrolahi. Attorneys admitted Pro Hac Vice must have an individual PACER account, not a shared firm account, to electronically file in the District of Massachusetts. To register for a PACER account, go the Pacer website at https://pacer.uscourts.gov/register-account. You must put the docket number under ADDITIONAL FILER INFORMATION on your form when registering or it will be rejected.Pro Hac Vice Admission Request Instructions https://www.mad.uscourts.gov/caseinfo/nextgen-pro-hac-vice.htm.A Notice of Appearance must be entered on the docket by the newly admitted attorney. (SP) (Entered: 05/23/2025)	May 23, 2025	May 23, 2025 PACER
30	MOTION for Leave to Appear Pro Hac Vice for admission of Patrick Archer Filing fee: $ 125, receipt number AMADC-11028536 by Tara Blunt, A. J., Karen Josefosky, T. R., Victim Rights Law Center.(Ouellette, Sean) (Entered: 05/23/2025)	May 23, 2025	May 23, 2025 PACER
31	REPLY to Response to 18 MOTION for Preliminary Injunction filed by Tara Blunt, A. J., Karen Josefosky, T. R., Victim Rights Law Center. (Skibell, L. Reid) (Entered: 05/23/2025)	May 23, 2025	May 23, 2025 RECAP
	Order on Motion for Leave to Appear	May 23, 2025	May 23, 2025 PACER
32	ELECTRONIC NOTICE Setting Hearing onn 18 MOTION for Preliminary Injunction : Hearing set for 6/5/2025 11:00 AM in Courtroom 20 (In person only) before Judge Myong J. Joun. (JL) (Entered: 05/27/2025)	May 27, 2025	May 27, 2025 PACER
	Notice Setting or Resetting Hearing on Motion	May 27, 2025	May 27, 2025 PACER
33	SUMMONS Returned Executed as to US Attorney by T. R., Tara Blunt, Karen Josefosky, Victim Rights Law Center, A. J.. (Skibell, L. Reid) (Entered: 05/28/2025)	May 28, 2025	May 28, 2025 PACER
34	Notice of Supplemental Authorities re 18 MOTION for Preliminary Injunction (Ouellette, Sean) (Entered: 05/30/2025)	May 30, 2025	May 30, 2025 PACER
35	Judge Myong J. Joun: ELECTRONIC ORDER entered GRANTING 30 Motion for Leave to Appear Pro Hac Vice Added Patrick Archer. Attorneys admitted Pro Hac Vice must have an individual PACER account, not a shared firm account, to electronically file in the District of Massachusetts. To register for a PACER account, go the Pacer website at https://pacer.uscourts.gov/register-account. You must put the docket number under ADDITIONAL FILER INFORMATION on your form when registering or it will be rejected.Pro Hac Vice Admission Request Instructions https://www.mad.uscourts.gov/caseinfo/nextgen-pro-hac-vice.htm.A Notice of Appearance must be entered on the docket by the newly admitted attorney. (SP) (Entered: 06/02/2025)	June 2, 2025	June 2, 2025 PACER
	Order on Motion for Leave to Appear	June 2, 2025	June 2, 2025 PACER
36	Notice of Supplemental Authorities re 18 MOTION for Preliminary Injunction (Attachments: # 1 Supplemental Authority: Carter v. U.S. Dep't of Education)(Rosenberg, Brad) (Entered: 06/03/2025)	June 3, 2025	June 3, 2025 PACER
37	Notice of Supplemental Authorities re 18 MOTION for Preliminary Injunction (Attachments: # 1 Supplemental Authority: Association for Education Finance and Policy v. McMahon and National Academy of Education v. Department of Education)(Rosenberg, Brad) (Entered: 06/04/2025)	June 4, 2025	June 4, 2025 PACER
38	Response by Tara Blunt, A. J., Karen Josefosky, T. R., Victim Rights Law Center to 36 Notice of Supplemental Authorities, 37 Notice of Supplemental Authorities, . (Skibell, L. Reid) (Entered: 06/04/2025)	June 4, 2025	June 4, 2025 PACER
39	Electronic Clerk's Notes for proceedings held before Judge Myong J. Joun: Motion Hearing held on 6/5/2025 re 18 Motion for Preliminary Injunction filed by Karen Josefosky, Victim Rights Law Center, Tara Blunt, T. R., A. J.. The Court heard arguments from the parties as to the pending motion and took the matter under advisement. (Court Reporter: Jamie Halpin at jkhhalpin@gmail.com.)(Attorneys present: Ouellette & Friedman for the plaintiffs; Rosenberg for the government;;) (SKY) (Entered: 06/05/2025)	June 5, 2025	June 5, 2025 PACER
	Motion Hearing	June 5, 2025	June 5, 2025 PACER
40	Judge Myong J. Joun: MEMORANDUM AND ORDER ON PLAINTIFFS' MOTION FOR PRELIMINARY INJUNCTION entered re: Doc. No. 18 For the reasons explained in the attached Memorandum and Order, Plaintiffs' Motion for Preliminary Injunction, [Doc. No. 18 ], is GRANTED. (SKY) (Entered: 06/18/2025)	June 18, 2025	June 18, 2025 Clearinghouse
41	STATUS REPORT Regarding Compliance by Linda McMahon, Craig Trainor, United States Department of Education. (Attachments: # 1 Declaration of Jacqueline Clay)(Rosenberg, Brad) (Entered: 06/23/2025) 1 Declaration of Jacqueline Clay View on RECAP	June 23, 2025	June 23, 2025 RECAP
42	Assented to MOTION for Extension of Time to file status report by one day and to stay Defendants' response to the Complaint by Linda McMahon, Craig Trainor, United States Department of Education.(Bruns, Michael)	June 26, 2025	June 26, 2025 RECAP
43	Judge Myong J. Joun: ELECTRONIC ORDER entered GRANTING [42] Assented to Motion for Extension of Time to file status report by one day and to stay Defendants' response to the Complaint. (SKY)	June 26, 2025	June 26, 2025 PACER
44	STATUS REPORT Regarding Compliance by Linda McMahon, Craig Trainor, United States Department of Education. (Attachments: # (1) Declaration of Rachel Oglesby)(Rosenberg, Brad) 1 Declaration of Rachel Oglesby View on RECAP	July 1, 2025	July 1, 2025 RECAP
45	NOTICE of Appearance by Patrick Graham Archer on behalf of Tara Blunt, A. J., Karen Josefosky, T. R., Victim Rights Law Center (Archer, Patrick) (Entered: 07/03/2025)	July 3, 2025	July 3, 2025 PACER
46	STATUS REPORT Regarding Compliance by Linda McMahon, Craig Trainor, United States Department of Education. (Attachments: # 1 Declaration of Rachel Oglesby)(Rosenberg, Brad) (Entered: 07/08/2025) 1 Declaration of Rachel Oglesby View on RECAP	July 8, 2025	July 8, 2025 PACER
47	STATUS REPORT Regarding Compliance by Linda McMahon, Craig Trainor, United States Department of Education. (Attachments: # 1 Declaration of Rachel Oglesby)(Rosenberg, Brad) (Entered: 07/15/2025) 1 Declaration of Rachel Oglesby View on RECAP	July 15, 2025	July 15, 2025 RECAP
48	MOTION to Vacate 40 Order on Motion for Preliminary Injunction, by Linda McMahon, Craig Trainor, United States Department of Education. (Attachments: # 1 Text of Proposed Order)(Bruns, Michael) (Entered: 07/21/2025) 1 Text of Proposed Order View on PACER	July 21, 2025	July 21, 2025 RECAP
49	STATUS REPORT by Linda McMahon, Craig Trainor, United States Department of Education. (Bruns, Michael) (Entered: 07/22/2025)	July 22, 2025	July 22, 2025 PACER
50	STATUS REPORT Regarding Compliance by Linda McMahon, Craig Trainor, United States Department of Education. (Attachments: # 1 Declaration of Rachel Oglesby)(Rosenberg, Brad) (Entered: 07/22/2025)	July 22, 2025	July 22, 2025 PACER
51	MOTION to Dismiss for Lack of Jurisdiction and for Failure to State a Claim by Linda McMahon, Craig Trainor, United States Department of Education. (Attachments: # 1 Text of Proposed Order)(Rosenberg, Brad) (Entered: 07/28/2025)	July 28, 2025	July 28, 2025 RECAP
52	MEMORANDUM in Support re 51 MOTION to Dismiss for Lack of Jurisdiction and for Failure to State a Claim filed by Linda McMahon, Craig Trainor, United States Department of Education. (Rosenberg, Brad) (Entered: 07/28/2025)	July 28, 2025	July 28, 2025 RECAP
53	STATUS REPORT Regarding Compliance by Linda McMahon, Craig Trainor, United States Department of Education. (Attachments: # 1 Declaration of Rachel Oglesby)(Rosenberg, Brad) (Entered: 07/30/2025) 1 Declaration of Rachel Oglesby View on RECAP	July 30, 2025	July 30, 2025 PACER
54	NOTICE of Appearance by Leila Nicole Nasrolahi on behalf of Tara Blunt, A. J., Karen Josefosky, T. R., Victim Rights Law Center (Nasrolahi, Leila) (Entered: 07/30/2025)	July 30, 2025	July 30, 2025 PACER
55	MEMORANDUM in Opposition re 48 MOTION to Vacate 40 Order on Motion for Preliminary Injunction, filed by Tara Blunt, A. J., Karen Josefosky, T. R., Victim Rights Law Center. (Attachments: # 1 Exhibit July 14 Press Release, # 2 Exhibit Declaration of Terri Gonzales, # 3 Exhibit Declaration of Kathryn Joseph)(Ouellette, Sean) (Entered: 08/04/2025) 1 Exhibit July 14 Press Release View on PACER 2 Exhibit Declaration of Terri Gonzales View on RECAP 3 Exhibit Declaration of Kathryn Joseph View on RECAP	Aug. 4, 2025	Aug. 4, 2025 RECAP
56	STATUS REPORT Regarding Compliance by Linda McMahon, Craig Trainor, United States Department of Education. (Attachments: # 1 Affidavit of Rachel Oglesby)(Bruns, Michael) (Entered: 08/05/2025) 1 Affidavit of Rachel Oglesby View on RECAP	Aug. 5, 2025	Aug. 5, 2025 RECAP
57	REPLY to Response to 48 MOTION to Vacate 40 Order on Motion for Preliminary Injunction, filed by Linda McMahon, Craig Trainor, United States Department of Education. (Bruns, Michael) (Entered: 08/07/2025)	Aug. 7, 2025	Aug. 7, 2025 PACER
58	MEMORANDUM in Opposition re 51 MOTION to Dismiss for Lack of Jurisdiction and for Failure to State a Claim filed by Tara Blunt, A. J., Karen Josefosky, T. R., Victim Rights Law Center. (Ouellette, Sean) (Entered: 08/11/2025)	Aug. 11, 2025	Aug. 11, 2025 PACER
59	STATUS REPORT Regarding Compliance by Linda McMahon, Craig Trainor, United States Department of Education. (Attachments: # 1 Affidavit of Rachel Oglesby)(Bruns, Michael) (Entered: 08/12/2025)	Aug. 12, 2025	Aug. 12, 2025 PACER
60	Judge Myong J. Joun: ORDER entered DENYING 48 Motion to Vacate. (SKY) (Entered: 08/13/2025)	Aug. 13, 2025	Aug. 13, 2025 Clearinghouse
61	NOTICE OF APPEAL as to 40 Order on Motion for Preliminary Injunction, by Linda McMahon, Craig Trainor, United States Department of Education. Fee Status: US Government. NOTICE TO COUNSEL: A Transcript Report/Order Form, which can be downloaded from the First Circuit Court of Appeals web site at http://www.ca1.uscourts.gov MUST be completed and submitted to the Court of Appeals. Counsel shall register for a First Circuit CM/ECF Appellate Filer Account at http://pacer.psc.uscourts.gov/cmecf. Counsel shall also review the First Circuit requirements for electronic filing by visiting the CM/ECF Information section at http://www.ca1.uscourts.gov/cmecf. US District Court Clerk to deliver official record to Court of Appeals by 9/3/2025. (Bruns, Michael) (Entered: 08/14/2025)	Aug. 14, 2025	Aug. 14, 2025 PACER
62	Certified and Transmitted Abbreviated Electronic Record on Appeal to US Court of Appeals re 61 Notice of Appeal. (MAP) (Entered: 08/14/2025)	Aug. 14, 2025	Aug. 14, 2025 PACER
63	USCA Case Number 25-1787 for 61 Notice of Appeal, filed by Linda McMahon, Craig Trainor, United States Department of Education. (MAP) (Entered: 08/14/2025)	Aug. 14, 2025	Aug. 14, 2025 PACER
	USCA Case Number	Aug. 14, 2025	Aug. 14, 2025 PACER
64	Transcript - Appeal	Aug. 18, 2025	Aug. 18, 2025 PACER
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