Case: Robert F. Kennedy Human Rights v. U.S. Department of Homeland Security

COMPLAINT against KRISTI NOEM, U.S. DEPARTMENT OF HOMELAND SECURITY ( Filing fee $ 405 receipt number ADCDC-11642729) filed by ROBERT F. KENNEDY HUMAN RIGHTS, URBAN JUSTICE CENTER, SOUTHERN BORDER COMMUNITIES COALITION. (Attachments: # 1 Civil Cover Sheet, # 2 Summons, # 3 Summons, # 4 Summons, # 5 Summons)(Gilbride, Karla) (Entered: 04/24/2025)

1 Civil Cover Sheet

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2 Summons

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3 Summons

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4 Summons

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5 Summons

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LCvR 26.1 CERTIFICATE OF DISCLOSURE of Corporate Affiliations and Financial Interests by ROBERT F. KENNEDY HUMAN RIGHTS (Gilbride, Karla) (Entered: 04/24/2025)

LCvR 26.1 CERTIFICATE OF DISCLOSURE of Corporate Affiliations and Financial Interests by SOUTHERN BORDER COMMUNITIES COALITION (Gilbride, Karla) (Entered: 04/24/2025)

LCvR 26.1 CERTIFICATE OF DISCLOSURE of Corporate Affiliations and Financial Interests by URBAN JUSTICE CENTER (Gilbride, Karla) (Entered: 04/24/2025)

Notice of Error- New Case

NOTICE OF NEW CASE ERROR regarding 1 Complaint,. The following error(s) need correction: Invalid/No signature. Please file the signed document using the event Errata. All filings must have an original signature or /s/ Attorney Name to represent an electronic signature of the filer. COMPLIANCE DEADLINE is by close of business today. This case will not proceed any further until all errors are satisfied. (zsl)

NOTICE of Appearance by Sarah Decker on behalf of ROBERT F. KENNEDY HUMAN RIGHTS (Decker, Sarah) (Entered: 04/25/2025)

ERRATA by ROBERT F. KENNEDY HUMAN RIGHTS, SOUTHERN BORDER COMMUNITIES COALITION, URBAN JUSTICE CENTER re 1 Complaint,. (Gilbride, Karla) (Entered: 04/25/2025)

NOTICE of Appearance by Sarah Telo Gillman on behalf of ROBERT F. KENNEDY HUMAN RIGHTS (Gillman, Sarah) Modified docket text on 4/28/2025 (zdp). (Entered: 04/26/2025)

Case Assigned/Reassigned

Case Assigned to Judge Ana C. Reyes. (zsl)

STANDING ORDER. The Court hereby ORDERS the parties to comply with its Standing Order. See Standing Order for details. Signed by Judge Ana C. Reyes on 4/28/2025. (lcacr3) (Entered: 04/28/2025)

SUMMONS (4) Issued Electronically as to All Defendants, U.S. Attorney and U.S. Attorney General (Attachments: # 1 Notice and Consent)(znmw) (Entered: 04/29/2025)

NOTICE of Appearance by Skye Perryman on behalf of ROBERT F. KENNEDY HUMAN RIGHTS, SOUTHERN BORDER COMMUNITIES COALITION, URBAN JUSTICE CENTER (Perryman, Skye) (Entered: 04/30/2025)

NOTICE of Appearance by Brian D. Netter on behalf of ROBERT F. KENNEDY HUMAN RIGHTS, SOUTHERN BORDER COMMUNITIES COALITION, URBAN JUSTICE CENTER (Netter, Brian) (Entered: 04/30/2025)

NOTICE of Appearance by Michael C. Martinez on behalf of ROBERT F. KENNEDY HUMAN RIGHTS, SOUTHERN BORDER COMMUNITIES COALITION, URBAN JUSTICE CENTER (Martinez, Michael) (Entered: 04/30/2025)

RESOLVED.....NOTICE of Provisional/Government Not Certified Status re 12 NOTICE of Appearance by Michael C. Martinez on behalf of ROBERT F. KENNEDY HUMAN RIGHTS, SOUTHERN BORDER COMMUNITIES COALITION, URBAN JUSTICE CENTER (Martinez, Michael).Your attorney renewal/government certification has not been received. As a result, your membership with the U.S. District & Bankruptcy Courts for the District of Columbia is not in good standing, and you are not permitted to file. Pursuant to Local Civil Rule 83.9, you must immediately correct your membership status by following the appropriate instructions on this page of our website: https://www.dcd.uscourts.gov/attorney-renewal. Please be advised that the presiding judge in this case has been notified that you are currently not in good standing to file in this court. Renewal Due by 5/7/2025. (zhcn) 5/2/2025 (zapb).

Notice of Provisional/Government Not Certified Status

NOTICE of Appearance by Anthony Enriquez on behalf of All Plaintiffs (Enriquez, Anthony) (Entered: 05/06/2025)

NOTICE of Appearance by Christine L. Coogle on behalf of ROBERT F. KENNEDY HUMAN RIGHTS, SOUTHERN BORDER COMMUNITIES COALITION, URBAN JUSTICE CENTER (Coogle, Christine) (Entered: 05/07/2025)

MOTION for Preliminary Injunction by ROBERT F. KENNEDY HUMAN RIGHTS, SOUTHERN BORDER COMMUNITIES COALITION, URBAN JUSTICE CENTER. (Attachments: # 1 Memorandum in Support, # 2 Index of Exhibits, # 3 Declaration Declaration of Anthony Enriquez, # 4 Declaration Declaration of Joy Ziegeweid, # 5 Declaration Declaration of Lilian Serrano, # 6 Declaration Declaration of Pedro Rios, # 7 Declaration Declaration of Margaret Cargioli, # 8 Declaration Declaration of Deborah Fleischaker, # 9 Declaration Declaration of Alex Doe, # 10 Declaration Declaration of Debra Rogers, # 11 Declaration Declaration of Kelsey Vitullo, # 12 Declaration Declaration of Sister Tracey Horan, # 13 Declaration Declaration of Laura St. John, # 14 Declaration Declaration of Mayra Jones, # 15 Declaration Declaration of Alicia de la O, # 16 Declaration Declaration of Christine Brito, # 17 Declaration Declaration of Zain Lakhani, # 18 Declaration Declaration of Susu D'Andrea, # 19 Declaration Declaration of Timothy Fallon, # 20 Declaration Declaration of Jodi Ziesemer, # 21 Text of Proposed Order)(Gilbride, Karla) (Entered: 05/08/2025)

1 Memorandum in Support

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2 Index of Exhibits

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3 Declaration Declaration of Anthony Enriquez

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4 Declaration Declaration of Joy Ziegeweid

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5 Declaration Declaration of Lilian Serrano

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6 Declaration Declaration of Pedro Rios

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7 Declaration Declaration of Margaret Cargioli

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8 Declaration Declaration of Deborah Fleischaker

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9 Declaration Declaration of Alex Doe

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10 Declaration Declaration of Debra Rogers

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11 Declaration Declaration of Kelsey Vitullo

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12 Declaration Declaration of Sister Tracey Horan

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13 Declaration Declaration of Laura St. John

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14 Declaration Declaration of Mayra Jones

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15 Declaration Declaration of Alicia de la O

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16 Declaration Declaration of Christine Brito

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17 Declaration Declaration of Zain Lakhani

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18 Declaration Declaration of Susu D'Andrea

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19 Declaration Declaration of Timothy Fallon

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20 Declaration Declaration of Jodi Ziesemer

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21 Text of Proposed Order

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ERRATA by ROBERT F. KENNEDY HUMAN RIGHTS, SOUTHERN BORDER COMMUNITIES COALITION, URBAN JUSTICE CENTER re 15 Motion for Preliminary Injunction,,,,. (Gilbride, Karla) (Entered: 05/08/2025)

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MINUTE ORDER. The Court ORDERS the parties to file a joint proposed briefing schedule for the 15 Motion for Preliminary Injunction by 10am on May 12, 2025. Because counsel for Defendants has not yet entered an appearance in this case, the Court also ORDERS Plaintiffs to ensure that Defendants are aware of this Minute Order. Signed by Judge Ana C. Reyes on 5/9/2025. (lcacr3)

NOTICE of stipulated briefing schedule by ROBERT F. KENNEDY HUMAN RIGHTS, SOUTHERN BORDER COMMUNITIES COALITION, URBAN JUSTICE CENTER re Order, (Gilbride, Karla) (Entered: 05/12/2025)

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Set/Reset Deadlines/Hearings

MINUTE ORDER. Pursuant to 17 Notice of Stipulated Briefing Schedule, the Court ORDERS the parties abide by the following schedule: 1. Defendants will file their opposition to Plaintiffs' Motion for a Preliminary Injunction on or before 11:59 PM on Wednesday, May 14, 2025.2. Plaintiffs will file their reply in support of their Motion for a Preliminary Injunction on or before 11:59 PM on Friday, May 16, 2025.The Court ORDERS the parties to appear for a hearing on the Motion for a Preliminary Injunction at 3pm on May 19, 2025, in Courtroom 12. Signed by Judge Ana C. Reyes on 5/12/2025. (lcacr3)

Set/Reset Deadlines/Hearings: Response to 15 due by 5/14/2025. Reply due by 5/16/2025. Evidentiary Hearing set for 5/19/2025 at 3:00 PM in Courtroom 12 before Judge Ana C. Reyes. (zcdw)

NOTICE of Appearance by Tiberius T Davis on behalf of KRISTI NOEM, U.S. DEPARTMENT OF HOMELAND SECURITY (Davis, Tiberius) (Main Document 18 replaced on 5/14/2025) (zdp). (Entered: 05/13/2025)

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MINUTE ORDER. The Court ORDERS that the May 19 hearing will take place at 1pm, not 3pm, as previously stated. Signed by Judge Ana C. Reyes on 5/13/2025. (lcacr3)

Memorandum in opposition to re 15 MOTION for Preliminary Injunction filed by KRISTI NOEM, U.S. DEPARTMENT OF HOMELAND SECURITY. (Attachments: # 1 Exhibit Declaration)(Hall, Christopher) (Entered: 05/14/2025)

1 Exhibit Declaration

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MINUTE ORDER. The Court ORDERS the parties to attend a zoom status conference today at 1pm to discuss how the hearing on May 19 will proceed. The Court apologizes for the late notice, but it is the only time available before Monday. Signed by Judge Ana C. Reyes on 5/15/2025. (lcacr3)

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Set/Reset Deadlines/Hearings

Status Conference AND ~Util - Set/Reset Deadlines/Hearings

Set/Reset Deadlines/Hearings: Status Conference set for 5/15/2025 at 1:00 PM via videoconference before Judge Ana C. Reyes. (zcdw)

Minute Entry for proceedings held before Judge Ana C. Reyes: Status Conference held on 5/15/2025. Parties directed to file a Joint Status Report by 10:00 AM on 5/16/2025. (Court Reporter: Lisa Moreira) (zcdw)

Minute Entry for video proceedings held before Judge Ana C. Reyes: Status Conference held on 5/15/2025. Parties directed to file a Joint Status Report by 10:00 AM on 5/16/2025. (Court Reporter: Lisa Moreira) (zcdw)

NOTICE of Appearance by Adina H. Rosenbaum on behalf of All Plaintiffs (Rosenbaum, Adina) (Entered: 05/15/2025)

Joint STATUS REPORT Regarding Court's Minute Order by KRISTI NOEM, U.S. DEPARTMENT OF HOMELAND SECURITY. (Davis, Tiberius) (Entered: 05/16/2025)

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NOTICE of Appearance by Medha Raman on behalf of ROBERT F. KENNEDY HUMAN RIGHTS (Raman, Medha) (Entered: 05/16/2025)

MINUTE ORDER. Pursuant to 21 Joint Status Report, the Court will move forward with Monday's hearing. The Court ORDERS Mr. Sartini to appear in person. The Court has no set end time for the hearing, and so the parties will have the chance to argue and present evidence and testimony for as long as they may need. The parties should be prepared for the hearing to last all afternoon. Plaintiffs should make available any declarants that Defendants wish to cross examine. The Court ORDERS Defendants to provide Plaintiffs with a list of declarants that Defendants wish to cross examine, if any, by 6pm today. The Court also ORDERS the parties to meet and confer and agree to a format for the proceedings -- whether the parties will conduct direct and cross or whether the parties would prefer for the Court to guide the examinations. While the parties should be prepared to address any issue in their briefs, the Court is particularly concerned with the ripeness, standing, and irreparable harm arguments, and so the parties should expect the hearing to focus on those issues. Signed by Judge Ana C. Reyes on 5/16/2025. (lcacr3)

AMICUS BRIEF by STATE OF NEW YORK, STATE OF ARIZONA, STATE OF CALIFORNIA, STATE OF COLORADO, STATE OF DELAWARE, STATE OF HAWAII, STATE OF CONNECTICUT, state of illinois, STATE OF MAINE, STATE OF MARYLAND, COMMONWEALTH OF MASSACHUSETTS, STATE OF MICHIGAN, STATE OF MINNESOTA, STATE OF NEVADA, STATE OF NEW JERSEY, STATE OF NORTH CAROLINA, STATE OF OREGON, STATE OF RHODE ISLAND, STATE OF VERMONT, STATE OF WASHINGTON, DISTRICT OF COLUMBIA. (Murdukhayeva, Ester) (Entered: 05/16/2025)

REPLY to opposition to motion re 15 Motion for Preliminary Injunction,,,, filed by ROBERT F. KENNEDY HUMAN RIGHTS. (Gilbride, Karla) (Entered: 05/16/2025)

Unopposed MOTION supplement record re 15 MOTION for Preliminary Injunction by ROBERT F. KENNEDY HUMAN RIGHTS. (Attachments: # 1 Declaration second declaration of Anthony Enriquez, # 2 Text of Proposed Order proposed order granting unopposed motion to supplement record)(Gilbride, Karla) (Entered: 05/17/2025)

Order on Motion for Miscellaneous Relief

MINUTE ORDER granting Plaintiffs' 25 Motion to Supplement Record. Plaintiffs may file the Second Declaration of Anthony Enriquez. Signed by Judge Ana C. Reyes on 5/17/2025. (lcacr3)

Joint STATUS REPORT Regarding the Court's May 16 Minute Order by ROBERT F. KENNEDY HUMAN RIGHTS, SOUTHERN BORDER COMMUNITIES COALITION, URBAN JUSTICE CENTER. (Martinez, Michael) (Entered: 05/17/2025)

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MINUTE ORDER. The May 19, 2025 hearing will be made accessible to the public via the Courtroom Public Access Line. However, the Public Access Line will not be available during testimony. The Public Access telephone number is 1-833-990-9400, and the meeting ID is 787605272. Signed by Judge Ana C. Reyes on 5/18/2025. (lcacr3)

NOTICE OF CORRECTION by KRISTI NOEM, U.S. DEPARTMENT OF HOMELAND SECURITY (Attachments: # 1 Declaration Corrected Sartini Declaration)(Davis, Tiberius) (Entered: 05/18/2025)

1 Declaration Corrected Sartini Declaration

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MINUTE ORDER. As discussed in Thursday's status conference, today's hearing will begin at 11am, not 1pm. The Public Access Line information remains the same. Signed by Judge Ana C. Reyes on 5/19/2025. (lcacr3)

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Evidentiary Hearing AND ~Util - Set/Reset Deadlines/Hearings

Minute Entry for proceedings held before Judge Ana C. Reyes: Evidentiary Hearing begun and held on 5/19/2025 re the Motion 15 for a Preliminary Injunction. Evidentiary Hearing continued to 5/20/2025 at 10:30 AM in Courtroom 12 before Judge Ana C. Reyes. (Court Reporters: Jan Dickman (AM) and Christine Asif (PM). Defendant's witness: Ronald Sartini. (zcdw)

Exhibit List by PLAINTIFFS. (zcdw) (Entered: 05/19/2025)

NOTICE in response to Court's inquiry by KRISTI NOEM, U.S. DEPARTMENT OF HOMELAND SECURITY (Davis, Tiberius) (Entered: 05/20/2025)

Evidentiary Hearing

Minute Entry for proceedings held before Judge Ana C. Reyes: Evidentiary Hearing resumed and concluded on 5/20/2025 re the Motion 15 for a Preliminary Injunction. Motion heard and taken under advisement. Defendants directed to notify the Court within 24 hours of any personnel changes within the CIS Ombudsman Office. Parties directed to submit a joint status report after Mr. Sartini's meeting with the U.S. Department of Homeland Security. (Court Reporter: Christine Asif). (zcdw)

NOTICE regarding Court's Minute Order by KRISTI NOEM, U.S. DEPARTMENT OF HOMELAND SECURITY (Attachments: # 1 Declaration of Ronald Sartini)(Davis, Tiberius) (Entered: 05/21/2025)

1 Declaration of Ronald Sartini

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RESPONSE re 30 Notice (Other) filed by ROBERT F. KENNEDY HUMAN RIGHTS. (Attachments: # 1 Declaration declaration of Brian Doe)(Gilbride, Karla) (Entered: 05/22/2025)

1 Declaration declaration of Brian Doe

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MINUTE ORDER. Given Plaintiffs' 31 Response, the Court ORDERS the parties to appear today for a 4pm status conference. At least one attorney from each side must be present in person. The rest may appear via videoconference. Interested parties may dial in using the Public Access Line. Signed by Judge Ana C. Reyes on 5/22/2025. (lcacr3)

Status Conference

Minute Entry for proceedings held before Judge Ana C. Reyes: Status Conference held (hybrid) on 5/22/2025. Oral discussion heard. Forthcoming Order. (Court Reporter Christine Asif) (znbn)

MINUTE ORDER. As stated on the record at today's status conference, the Court ORDERS the Government to provide the information requested by the Court on the record no later than 8:00 PM tonight. Signed by Judge Ana C. Reyes on 05/22/2025. (lcacr2)

Order

NOTICE of Declaration of Nicole C. Barksdale-Perry by KRISTI NOEM, U.S. DEPARTMENT OF HOMELAND SECURITY (Attachments: # 1 Affidavit)(Hall, Christopher) (Entered: 05/22/2025)

1 Affidavit

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MINUTE ORDER. The Court will hold a hearing in this matter tomorrow morning at 9:30 AM. The Court requests that at least one of Mr. Sartini, Ms. Barksdale Perry, or the forthcoming declarant be present at the hearing. The other two should remain available to appear virtually if necessary. Signed by Judge Ana C. Reyes on 5/22/2025. (lcacr1)

NOTICE of Declaration of Troup Hemenway by KRISTI NOEM, U.S. DEPARTMENT OF HOMELAND SECURITY (Attachments: # 1 Declaration)(Hall, Christopher) (Entered: 05/22/2025)

1 Declaration

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.Order

Evidentiary Hearing AND ~Util - Set/Reset Deadlines/Hearings

Order

MINUTE ORDER. Today's hearing will be made accessible to the public via the Courtroom Public Access Line. The Public Access telephone number is 1-833-990-9400, and the meeting ID is 787605272. Signed by Judge Ana C. Reyes on 5/23/2025. (lcacr3)

Set/Reset Deadlines/Hearings

Set/Reset Deadlines/Hearings: Status Conference set for 5/23/2025 at 9:30 AM in Courtroom 12 (Audio Line Available) before Judge Ana C. Reyes. (zcdw)

Evidentiary Hearing

MOTION for Temporary Restraining Order by ROBERT F. KENNEDY HUMAN RIGHTS. (Attachments: # 1 Memorandum in Support, # 2 Text of Proposed Order proposed order granting TRO)(Gilbride, Karla) (Entered: 05/23/2025)

1 Memorandum in Support

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2 Text of Proposed Order proposed order granting TRO

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Minute Entry for hybrid proceedings held before Judge Ana C. Reyes: Evidentiary Hearing held on 5/23/2025 re Motion 34 for Temporary Restraining Order. Motion heard and denied without prejudice. Motion 15 for Preliminary Injunction remains under advisement. Parties directed to provide confirmation that the job vacancies can be posted, by 5/27/2025. Parties directed to submit a joint status report by 12:00 PM on 6/2/2025, to include a declaration from Mr. Sartini. Court Reporter: Christine Asif. Defendant's witnesses: Nicole Barksdale-Perry and Ronald Sartini. (zcdw)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed as to the United States Attorney. Date of Service Upon United States Attorney on 5/12/2025. Answer due for ALL FEDERAL DEFENDANTS by 7/11/2025. (Gilbride, Karla) (Entered: 05/27/2025)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. U.S. DEPARTMENT OF HOMELAND SECURITY served on 5/19/2025 (Gilbride, Karla) (Entered: 05/27/2025)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. KRISTI NOEM served on 5/14/2025 (Gilbride, Karla) (Entered: 05/27/2025)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed on United States Attorney General. Date of Service Upon United States Attorney General 5/15/2025. (Gilbride, Karla) (Entered: 05/27/2025)

Joint STATUS REPORT regarding Court's May 23 Order by KRISTI NOEM, U.S. DEPARTMENT OF HOMELAND SECURITY. (Davis, Tiberius) (Entered: 05/27/2025)

STATUS REPORT in Response to May 23 Order by KRISTI NOEM, U.S. DEPARTMENT OF HOMELAND SECURITY. (Attachments: # 1 Declaration of Ronald Sartini)(Davis, Tiberius) (Entered: 06/02/2025)

1 Declaration of Ronald Sartini

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.Order

MINUTE ORDER. The Court has received Defendants' 40 Status Report and thanks Defendants and Mr. Sartini for the updates on the hiring process. The Court ORDERS Defendants to file another status report providing further updates on or before July 2, 2025. Signed by Judge Ana C. Reyes on 6/2/2025. (lcacr3)

Order

STATUS REPORT by ROBERT F. KENNEDY HUMAN RIGHTS. (Attachments: # 1 Declaration declaration of Karla Gilbride with exhibits)(Gilbride, Karla) (Entered: 06/02/2025)

1 Declaration declaration of Karla Gilbride with exhibits

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MINUTE ORDER. Given Plaintiffs' 41 Status Report, the Court ORDERS the parties to contact the courtroom deputy to set up a hearing for the week of June 9. Signed by Judge Ana C. Reyes on 6/2/2025. (lcacr3)

Notice of Hearing

NOTICE of Hearing: Status Conference set for 6/12/2025 at 11:00 AM in Courtroom 12 before Judge Ana C. Reyes. (zcdw)

Set/Reset Deadlines/Hearings

Set/Reset Deadlines/Hearings: Status Conference reset via videoconference on 6/12/2025 at 11:00 AM before Judge Ana C. Reyes. (zcdw)

STATUS REPORT by ROBERT F. KENNEDY HUMAN RIGHTS. (Attachments: # 1 Declaration Second Declaration of Lilian Serrano, # 2 Declaration Second Declaration of Tracey Horan, # 3 Declaration Second Declaration of Mayra Jones, # 4 Declaration Declaration of Javier Hidalgo, # 5 Declaration Declaration of Taylor Doe, # 6 Declaration Third Declaration of Anthony Enriquez)(Gilbride, Karla) (Entered: 06/11/2025)

1 Declaration Second Declaration of Lilian Serrano

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2 Declaration Second Declaration of Tracey Horan

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3 Declaration Second Declaration of Mayra Jones

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4 Declaration Declaration of Javier Hidalgo

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5 Declaration Declaration of Taylor Doe

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6 Declaration Third Declaration of Anthony Enriquez

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.Order

Order