Case: Schlacter v. U.S. Department of State

President Donald Trump

COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF against All Defendants ( Filing fee $ 405 receipt number AMDDC-11935897.), filed by Peter Poe, Lia Hepler-Mackey, Kris Koe, Jill Tran, David Doe, Zander Schlacter, Robert Roe. (Attachments: # 1 Exhibit A, # 2 Civil Cover Sheet, # 3 Summons U.S. Department of State, # 4 Summons Secretary Marco Rubio, # 5 Summons United States of America, # 6 Summons U.S. Attorney for District of Maryland)(Gleklen, Jonathan) (Entered: 04/25/2025)

1 Exhibit A

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2 Civil Cover Sheet

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3 Summons U.S. Department of State

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4 Summons Secretary Marco Rubio

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5 Summons United States of America

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6 Summons U.S. Attorney for District of Maryland

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7 Corrected Summons

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MOTION for Other Relief MOTION FOR LEAVE TO PROCEED UNDER PSEUDONYM, TO WAIVE REQUIREMENT UNDER LOCAL RULE 102.2(a) TO PROVIDE ADDRESSES IN COMPLAINT CAPTION, AND FOR A PROTECTIVE ORDER by David Doe, Lia Hepler-Mackey, Kris Koe, Peter Poe, Robert Roe, Zander Schlacter, Jill Tran (Attachments: # 1 Memorandum in Support of Plaintiffs' Motion for Leave to Proceed Under Pseudonym, to Waive Requirement Under Local Rule 102.2(a) to Provide Addresses in Complaint Caption, and for a Protective Order, # 2 Text of Proposed Order)(Gleklen, Jonathan) (Entered: 04/25/2025)

MOTION to Appear Pro Hac Vice for Lori B. Leskin (Filing fee $100, receipt number AMDDC-11935913.) by David Doe, Lia Hepler-Mackey, Kris Koe, Peter Poe, Robert Roe, Zander Schlacter, Jill Tran(Gleklen, Jonathan) (Entered: 04/25/2025)

MOTION to Appear Pro Hac Vice for Allissa Pollard (Filing fee $100, receipt number AMDDC-11935916.) by David Doe, Lia Hepler-Mackey, Kris Koe, Peter Poe, Robert Roe, Zander Schlacter, Jill Tran(Gleklen, Jonathan) (Entered: 04/25/2025)

MOTION to Appear Pro Hac Vice for Carl S. Charles (Filing fee $100, receipt number AMDDC-11935959.) by David Doe, Lia Hepler-Mackey, Kris Koe, Peter Poe, Robert Roe, Zander Schlacter, Jill Tran(Gleklen, Jonathan) (Entered: 04/25/2025)

MOTION to Appear Pro Hac Vice for Karen L. Loewy (Filing fee $100, receipt number AMDDC-11935978.) by David Doe, Lia Hepler-Mackey, Kris Koe, Peter Poe, Robert Roe, Zander Schlacter, Jill Tran(Gleklen, Jonathan) (Entered: 04/25/2025)

MOTION to Appear Pro Hac Vice for Peter C. Renn (Filing fee $100, receipt number AMDDC-11935979.) by David Doe, Lia Hepler-Mackey, Kris Koe, Peter Poe, Robert Roe, Zander Schlacter, Jill Tran(Gleklen, Jonathan) (Entered: 04/25/2025)

MOTION to Appear Pro Hac Vice for Omar Gonzalez-Pagan (Filing fee $100, receipt number AMDDC-11935981.) by David Doe, Lia Hepler-Mackey, Kris Koe, Peter Poe, Robert Roe, Zander Schlacter, Jill Tran(Gleklen, Jonathan) (Entered: 04/25/2025)

MOTION to Appear Pro Hac Vice for Kyle Angelotti (Filing fee $100, receipt number AMDDC-11935984.) by David Doe, Lia Hepler-Mackey, Kris Koe, Peter Poe, Robert Roe, Zander Schlacter, Jill Tran(Gleklen, Jonathan) (Entered: 04/25/2025)

QC NOTICE: 1 Complaint,, filed by David Doe, Kris Koe, Lia Hepler-Mackey, Robert Roe, Zander Schlacter, Peter Poe, Jill Tran was filed incorrectly. **Not all pdf documents (summons) were flattened prior to filing. All pdfs uploaded to CM/ECF MUST BE FLATTENED for all future filings. Failure to comply may result in rejected filings and delays in case processing. **This filing has been corrected by court staff and no further corrective action is required. (bw5s, Deputy Clerk) (Entered: 04/28/2025)

Summons Issued 60 days as to Marco Rubio, U.S. Department of State, United State of America, U.S. Attorney and U.S. Attorney General(bw5s, Deputy Clerk) (Entered: 04/28/2025)

Local Rule 103.3 Disclosure Statement by Zander Schlacter (Gleklen, Jonathan) (Entered: 04/28/2025)

Local Rule 103.3 Disclosure Statement by David Doe (Gleklen, Jonathan) (Entered: 04/28/2025)

Local Rule 103.3 Disclosure Statement by Lia Hepler-Mackey (Gleklen, Jonathan) (Entered: 04/28/2025)

Local Rule 103.3 Disclosure Statement by Kris Koe (Gleklen, Jonathan) (Entered: 04/28/2025)

Local Rule 103.3 Disclosure Statement by Peter Poe (Gleklen, Jonathan) (Entered: 04/28/2025)

Local Rule 103.3 Disclosure Statement by Robert Roe (Gleklen, Jonathan) (Entered: 04/28/2025)

Local Rule 103.3 Disclosure Statement by Jill Tran (Gleklen, Jonathan) (Entered: 04/28/2025)

Case Assigned to Chief Judge George Levi Russell, III. (jf3s, Deputy Clerk)

QC NOTICE: 3 Motion to Appear Pro Hac Vice filed by David Doe, Kris Koe, Lia Hepler-Mackey, Robert Roe, Zander Schlacter, Peter Poe, Jill Tran needs to be modified. See attachment for details and corrective actions needed regarding missing or incomplete information. (mh4s, Deputy Clerk) (Entered: 04/29/2025)

PAPERLESS ORDER granting 4 Motion to Appear Pro Hac Vice on behalf of Allissa Pollard. Directing attorney Allissa Pollard to register for pro hac vice filing in the District of Maryland through PACER at https://pacer.uscourts.gov/ if attorney has not already done so. The Pro Hac Vice option must be selected when registering. Signed by Clerk on 4/29/2025. (mh4s, Deputy Clerk) (Entered: 04/29/2025)

PAPERLESS ORDER granting 5 Motion to Appear Pro Hac Vice on behalf of Carl S Charles. Directing attorney Carl S Charles to register for pro hac vice filing in the District of Maryland through PACER at https://pacer.uscourts.gov/ if attorney has not already done so. The Pro Hac Vice option must be selected when registering. Signed by Clerk on 4/29/2025. (mh4s, Deputy Clerk) (Entered: 04/29/2025)

PAPERLESS ORDER granting 6 Motion to Appear Pro Hac Vice on behalf of Karen Loewy. Directing attorney Karen Loewy to register for pro hac vice filing in the District of Maryland through PACER at https://pacer.uscourts.gov/ if attorney has not already done so. The Pro Hac Vice option must be selected when registering. Signed by Clerk on 4/29/2025. (mh4s, Deputy Clerk) (Entered: 04/29/2025)

PAPERLESS ORDER granting 7 Motion to Appear Pro Hac Vice on behalf of Peter C. Renn. Directing attorney Peter C. Renn to register for pro hac vice filing in the District of Maryland through PACER at https://pacer.uscourts.gov/ if attorney has not already done so. The Pro Hac Vice option must be selected when registering. Signed by Clerk on 4/29/2025. (mh4s, Deputy Clerk) (Entered: 04/29/2025)

PAPERLESS ORDER granting 8 Motion to Appear Pro Hac Vice on behalf of Omar Gonzalez-Pagan. Directing attorney Omar Gonzalez-Pagan to register for pro hac vice filing in the District of Maryland through PACER at https://pacer.uscourts.gov/ if attorney has not already done so. The Pro Hac Vice option must be selected when registering. Signed by Clerk on 4/29/2025. (mh4s, Deputy Clerk) (Entered: 04/29/2025)

PAPERLESS ORDER granting 9 Motion to Appear Pro Hac Vice on behalf of Kyle Angelotti. Directing attorney Kyle Angelotti to register for pro hac vice filing in the District of Maryland through PACER at https://pacer.uscourts.gov/ if attorney has not already done so. The Pro Hac Vice option must be selected when registering. Signed by Clerk on 4/29/2025. (mh4s, Deputy Clerk) (Entered: 04/29/2025)

CORRECTED MOTION to Appear Pro Hac Vice for Lori B. Leskin by David Doe, Lia Hepler-Mackey, Kris Koe, Peter Poe, Robert Roe, Zander Schlacter, Jill Tran. The fee has already been paid.(Gleklen, Jonathan) (Entered: 04/29/2025)

PAPERLESS ORDER granting 26 Corrected Motion to Appear Pro Hac Vice on behalf of Lori B Leskin. Directing attorney Lori B Leskin to register for pro hac vice filing in the District of Maryland through PACER at https://pacer.uscourts.gov/ if attorney has not already done so. The Pro Hac Vice option must be selected when registering. Signed by Clerk on 4/30/2025. (mh4s, Deputy Clerk) (Entered: 04/30/2025)

NOTICE of Appearance by Melissa E Goldmeier, Rebecca Ann Koch on behalf of All Defendants (Goldmeier, Melissa) Modified on 5/6/2025 (bw5s). (Entered: 05/05/2025)

MOTION for Leave to File Excess Pages by David Doe, Lia Hepler-Mackey, Kris Koe, Peter Poe, Robert Roe, Zander Schlacter, Jill Tran (Attachments: # 1 Text of Proposed Order)(Gleklen, Jonathan) (Entered: 05/13/2025)

ORDER granting 29 MOTION for Leave to File Excess Pages. Signed by Chief Judge George Levi Russell, III on 5/13/2025. (bw5s, Deputy Clerk) (Entered: 05/13/2025)

MOTION for Preliminary Injunction by David Doe, Lia Hepler-Mackey, Kris Koe, Peter Poe, Robert Roe, Zander Schlacter, Jill Tran (Attachments: # 1 Text of Proposed Order)(Gleklen, Jonathan) (Entered: 05/14/2025)

Memorandum re 31 MOTION for Preliminary Injunction filed by David Doe, Lia Hepler-Mackey, Kris Koe, Peter Poe, Robert Roe, Zander Schlacter, Jill Tran. (Attachments: # 1 Exhibit A - Declaration of Carl S. Charles, # 2 Exhibit 1 -Executive Order 14168, # 3 Exhibit 2 - Movement Advancement Project, # 4 Exhibit 3 - Sex Marker in Passports, # 5 Exhibit 4 - Understanding the Key U.S. Travel Documents, # 6 Exhibit 4-1 - Immigration (Hotel Records) Order 1972, # 7 Exhibit 4-2 - Bundesmeldegesetz, # 8 Exhibit 5 - Form I-9 Acceptable Documents, # 9 Exhibit 6 - The Report of the 2015 Transgender Survey, # 10 Exhibit 7 - A Report of the 2022 U.S. Transgender Survey, # 11 Exhibit 8 - Use of Names Indicating a Change of Sex (May 4, 1971), # 12 Exhibit 9 - Procedures for Handling Requests for a Change in Gender in Passports, # 13 Exhibit 9-1 - 7 FAM 1300 Appendix M, # 14 Exhibit 9-2 - New Policy on Gender Change in Passports Announced, # 15 Exhibit 9-3 - U.S. Dept of State, Press Release, # 16 Exhibit 9-4 - U.S. Dept of State, Press Release, # 17 Exhibit 10 - Intl Civil Aviation Org., Doc 9303(7th ed. 2015), # 18 Exhibit 11 - Intl Civil Aviation Org., Doc 9303(6th ed. 2006), # 19 Exhibit 11-1 -, # 20 Exhibit 12-1 - Donald J. Trump, Tweet (Dec. 22, 2024), # 21 Exhibit 12-2 - Turning Point USA Donald Trump full speech, # 22 Exhibit 13 - President Trumps Plan to Protect Children, # 23 Exhibit 14 - Trumps Shocking Admission Exposes GOPs Bigoted Agenda,, # 24 Exhibit 15 - What Trumps win and $215m worth of anti-trans ads mean for the future of campaigning, # 25 Exhibit 16 - Why anti-transgender political ads are dominating the airwaves this election, # 26 Exhibit 17 - Trump and Vance make anti-transgender attacks central to their campaigns closing argument, # 27 Exhibit 18 - What the Most Anti-LGBTQ Election in Decades Means for Trans People, # 28 Exhibit 19 - DAVOS 2025: Special address by Donald J. Trump, # 29 Exhibit 20 - Executive Order No. 14187, # 30 Exhibit 20-1 - Executive Order No. 14183, # 31 Exhibit 20-2 - Executive Order No. 14190, # 32 Exhibit 20-3 - Executive Order No. 14201, # 33 Exhibit 21 - Removing Gender Ideology and Restoring the EEOCs Role of Protecting Women in the Workplace, # 34 Exhibit 22 - EEOC instructs staff to sideline all new transgender discrimination cases, employees say, # 35 Exhibit 23 - In battle against transgender rights, Trump targets HUDs housing policies, # 36 Exhibit 24 - Trump orders agencies to scrub 'gender ideology' from contracts, websites, # 37 Exhibit 25 - Some federal web pages still down as agencies implement order defending women, # 38 Exhibit 26 - Government agencies scrub LGBTQ web pages and remove info about trans and intersex people, # 39 Exhibit 27 - References to transgender and queer removed from Stonewall National Monument's web page, # 40 Exhibit 28 - A List of Government Web Pages That Have Gone Dark to Comply With Trump Orders, # 41 Exhibit 29 - Rubio Instructs Staff To Freeze Passport Applications with 'X' Sex Markers, # 42 Exhibit 30 - Shannon K. Kingston, et al., State Department Halts 'X' Passport Gender Marker Applications, # 43 Exhibit 31 - DS-11, DS-82 & DS-5504, # 44 Exhibit 32 - DS-11, DS-82 & DS-5504, # 45 Exhibit 33 - U.S. Dept of State, Bureau of Consular Affairs, Travel.State.Gov Passport Forms (as of May 13, 2025), # 46 Exhibit 34 - Ken Klippenstein (@KenKlippenstein), Substack (Feb. 10, 2025), # 47 Exhibit 35 - Nazi Aggression and Criminality Vol. IV 185-88 (1946),, # 48 Exhibit 36 - U.S. Dept of State, Bureau of Consular Affairs, Travel.State.Gov Before You Go Lesbian, Gay, and Bisexual Travelers (as of May 2, 2025), # 49 Exhibit 37 - U.S. Dept of State, Bureau of Consular Affairs, Travel.State.Gov Before You Go LGBTQI+ Travelers (as of Mar. 22, 2022), # 50 Exhibit 38 - Michael K. Lavers, Transgender people removed from State Department travel page, Washington Blade (Jan. 31, 2025), # 51 Exhibit 39 - White House: Proclamation from President Donald J. Trump on Womens History Month (Mar. 6, 2025), # 52 Exhibit 40 - Adam Serwer, The Cruelty is the Point, THE ATLANTIC (Oct. 3, 2018), # 53 Exhibit B - Expert Declaration of Deanna Adkins, M.D., # 54 Exhibit C - Expert Declaration of Dr. Randi C. Ettner, Ph.D., # 55 Exhibit D - Expert Declaration of Ayden Scheim, PH.D., # 56 Exhibit E - Declaration of Zander Schlacter, # 57 Exhibit F _ Declaration of Lia Hepler Mackey, # 58 Exhibit G - Declaration of Jill Tran, # 59 Exhibit H - Declaration of Kris Koe, # 60 Attachment Attachment to Ex. H - Notice of Filing Document Under Seal, # 61 Exhibit I - Declaration of Peter Poe, # 62 Exhibit Attachment to Ex. I - Notice of Filing Document Under Seal, # 63 Exhibit J - Declaration of David Doe, # 64 Exhibit Attachment to Ex. J - Notice of Filing Document Under Seal, # 65 Exhibit K - Declaration of Robert Roe, # 66 Exhibit Attachment to Ex. K - Notice of Filing Document Under Seal)(Gleklen, Jonathan) Modified on 5/15/2025 (bw5s). (Entered: 05/14/2025)

1 Exhibit A - Declaration of Carl S. Charles

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2 Exhibit 1 -Executive Order 14168

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3 Exhibit 2 - Movement Advancement Project

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4 Exhibit 3 - Sex Marker in Passports

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5 Exhibit 4 - Understanding the Key U.S. Travel Documents

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6 Exhibit 4-1 - Immigration (Hotel Records) Order 1972

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7 Exhibit 4-2 - Bundesmeldegesetz

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8 Exhibit 5 - Form I-9 Acceptable Documents

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9 Exhibit 6 - The Report of the 2015 Transgender Survey

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10 Exhibit 7 - A Report of the 2022 U.S. Transgender Survey

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11 Exhibit 8 - Use of Names Indicating a Change of Sex (May 4, 1971)

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12 Exhibit 9 - Procedures for Handling Requests for a Change in Gender in Passports

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13 Exhibit 9-1 - 7 FAM 1300 Appendix M

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14 Exhibit 9-2 - New Policy on Gender Change in Passports Announced

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15 Exhibit 9-3 - U.S. Dept of State, Press Release

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16 Exhibit 9-4 - U.S. Dept of State, Press Release

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17 Exhibit 10 - Intl Civil Aviation Org., Doc 9303(7th ed. 2015)

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18 Exhibit 11 - Intl Civil Aviation Org., Doc 9303(6th ed. 2006)

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19 Exhibit 11-1 -

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20 Exhibit 12-1 - Donald J. Trump, Tweet (Dec. 22, 2024)

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21 Exhibit 12-2 - Turning Point USA Donald Trump full speech

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22 Exhibit 13 - President Trumps Plan to Protect Children

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23 Exhibit 14 - Trumps Shocking Admission Exposes GOPs Bigoted Agenda,

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24 Exhibit 15 - What Trumps win and $215m worth of anti-trans ads mean for t

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25 Exhibit 16 - Why anti-transgender political ads are dominating the airwaves this

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26 Exhibit 17 - Trump and Vance make anti-transgender attacks central to their camp

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27 Exhibit 18 - What the Most Anti-LGBTQ Election in Decades Means for Trans People

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28 Exhibit 19 - DAVOS 2025: Special address by Donald J. Trump

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29 Exhibit 20 - Executive Order No. 14187

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30 Exhibit 20-1 - Executive Order No. 14183

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31 Exhibit 20-2 - Executive Order No. 14190

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32 Exhibit 20-3 - Executive Order No. 14201

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33 Exhibit 21 - Removing Gender Ideology and Restoring the EEOCs Role of Protecting

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34 Exhibit 22 - EEOC instructs staff to sideline all new transgender discrimination

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35 Exhibit 23 - In battle against transgender rights, Trump targets HUDs housing po

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36 Exhibit 24 - Trump orders agencies to scrub 'gender ideology' from con

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37 Exhibit 25 - Some federal web pages still down as agencies implement order defen

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38 Exhibit 26 - Government agencies scrub LGBTQ web pages and remove info about tra

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39 Exhibit 27 - References to transgender and queer removed from Stonewall National

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40 Exhibit 28 - A List of Government Web Pages That Have Gone Dark to Comply With T

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41 Exhibit 29 - Rubio Instructs Staff To Freeze Passport Applications with 'X&

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42 Exhibit 30 - Shannon K. Kingston, et al., State Department Halts 'X' P

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43 Exhibit 31 - DS-11, DS-82 & DS-5504

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44 Exhibit 32 - DS-11, DS-82 & DS-5504

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45 Exhibit 33 - U.S. Dept of State, Bureau of Consular Affairs, Travel.State.Gov P

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46 Exhibit 34 - Ken Klippenstein (@KenKlippenstein), Substack (Feb. 10, 2025)

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47 Exhibit 35 - Nazi Aggression and Criminality Vol. IV 185-88 (1946),

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48 Exhibit 36 - U.S. Dept of State, Bureau of Consular Affairs, Travel.State.Gov B

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49 Exhibit 37 - U.S. Dept of State, Bureau of Consular Affairs, Travel.State.Gov B

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50 Exhibit 38 - Michael K. Lavers, Transgender people removed from State Department

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51 Exhibit 39 - White House: Proclamation from President Donald J. Trump on Womens

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52 Exhibit 40 - Adam Serwer, The Cruelty is the Point, THE ATLANTIC (Oct. 3, 2018)

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53 Exhibit B - Expert Declaration of Deanna Adkins, M.D.

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54 Exhibit C - Expert Declaration of Dr. Randi C. Ettner, Ph.D.

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55 Exhibit D - Expert Declaration of Ayden Scheim, PH.D.

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56 Exhibit E - Declaration of Zander Schlacter

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57 Exhibit F _ Declaration of Lia Hepler Mackey

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58 Exhibit G - Declaration of Jill Tran

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59 Exhibit H - Declaration of Kris Koe

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60 Attachment Attachment to Ex. H - Notice of Filing Document Under Seal

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61 Exhibit I - Declaration of Peter Poe

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62 Exhibit Attachment to Ex. I - Notice of Filing Document Under Seal

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63 Exhibit J - Declaration of David Doe

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64 Exhibit Attachment to Ex. J - Notice of Filing Document Under Seal

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65 Exhibit K - Declaration of Robert Roe

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66 Exhibit Attachment to Ex. K - Notice of Filing Document Under Seal

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-SEALED - NOTICE of Filing Under Seal Attachment to Ex. K - Robert Roe Declaration by David Doe, Lia Hepler-Mackey, Kris Koe, Peter Poe, Robert Roe, Zander Schlacter, Jill Tran re 32 Memorandum,,,,,,,,,,,,,,,,,,,, (Gleklen, Jonathan) (Entered: 05/14/2025)

-SEALED - NOTICE of Filing Under Seal Attachment to Ex. I - Peter Poe Declaration by David Doe, Lia Hepler-Mackey, Kris Koe, Peter Poe, Robert Roe, Zander Schlacter, Jill Tran re 32 Memorandum,,,,,,,,,,,,,,,,,,,, (Gleklen, Jonathan) (Entered: 05/14/2025)

-SEALED - NOTICE of Filing Under Seal Attachment to Exhibit J - David Doe by David Doe, Lia Hepler-Mackey, Kris Koe, Peter Poe, Robert Roe, Zander Schlacter, Jill Tran re 32 Memorandum,,,,,,,,,,,,,,,,,,,, (Gleklen, Jonathan) (Entered: 05/14/2025)

-SEALED - NOTICE of Filing Under Seal Attachment to Ex. H to Declaration of Kris Koe by David Doe, Lia Hepler-Mackey, Kris Koe, Peter Poe, Robert Roe, Zander Schlacter, Jill Tran re 32 Memorandum,,,,,,,,,,,,,,,,,,,, (Gleklen, Jonathan) (Entered: 05/14/2025)

MOTION to Seal PSEUDONYMOUS PLAINTIFFS UNOPPOSED MOTION FOR PROTECTIVE ORDER SEALING PORTIONS OF THE RECORD by David Doe, Lia Hepler-Mackey, Kris Koe, Peter Poe, Robert Roe, Zander Schlacter, Jill Tran (Attachments: # 1 Text of Proposed Order)(Gleklen, Jonathan) Modified on 5/15/2025 (bw5s). (Entered: 05/14/2025)

-SEALED - NOTICE of Filing Under Seal Ex H Koe Photo CORRECTED by David Doe, Lia Hepler-Mackey, Kris Koe, Peter Poe, Robert Roe, Zander Schlacter, Jill Tran re 36 Notice of Filing Exhibit or Attachment Under Seal, 32 Memorandum,,,,,,,,,,,,,,,,,,,, (Gleklen, Jonathan) (Entered: 05/15/2025)

-SEALED - NOTICE of Filing Under Seal Ex I Poe Photo CORRECTED by David Doe, Lia Hepler-Mackey, Kris Koe, Peter Poe, Robert Roe, Zander Schlacter, Jill Tran re 32 Memorandum,,,,,,,,,,,,,,,,,,,, 34 Notice of Filing Exhibit or Attachment Under Seal (Gleklen, Jonathan) (Entered: 05/15/2025)

-SEALED - NOTICE of Filing Under Seal Ex J Doe Photo CORRECTED by David Doe, Lia Hepler-Mackey, Kris Koe, Peter Poe, Robert Roe, Zander Schlacter, Jill Tran re 32 Memorandum,,,,,,,,,,,,,,,,,,,, 35 Notice of Filing Exhibit or Attachment Under Seal (Gleklen, Jonathan) (Entered: 05/15/2025)

-SEALED - NOTICE of Filing Under Seal Ex K Roe Photo CORRECTED by David Doe, Lia Hepler-Mackey, Kris Koe, Peter Poe, Robert Roe, Zander Schlacter, Jill Tran re 32 Memorandum,,,,,,,,,,,,,,,,,,,, 33 Notice of Filing Exhibit or Attachment Under Seal (Gleklen, Jonathan) (Entered: 05/15/2025)

[FILED IN ERROR] AFFIDAVIT of Service for Complaint and Summons served on All Defendants on May 6 and 9, 2025, filed by David Doe, Lia Hepler-Mackey, Kris Koe, Peter Poe, Robert Roe, Zander Schlacter, Jill Tran. (Attachments: # 1 Exhibit Ex A-US Dept of State, # 2 Exhibit Ex B-Sec of State, # 3 Exhibit Ex C-US Attorney General, # 4 Exhibit Ex D-US Attorney)(Gleklen, Jonathan) Modified on 5/19/2025 (bw5s). (Entered: 05/16/2025)

QC NOTICE: 42 Affidavit of Service, filed by David Doe, Kris Koe, Lia Hepler-Mackey, Robert Roe, Zander Schlacter, Peter Poe, Jill Tran was filed incorrectly. **Wrong event used. Please re-file documents by selecting Service of Process, Summons Returned Executed as to USA, and follow the prompts to set an answer deadline. It has been noted as FILED IN ERROR, and the document link has been disabled. (bw5s, Deputy Clerk) (Entered: 05/19/2025)

SUMMONS Returned Executed by Peter Poe, Lia Hepler-Mackey, Kris Koe, Jill Tran, David Doe, Zander Schlacter, Robert Roe. Marco Rubio served on 5/6/2025, answer due 7/7/2025; U.S. Department of State served on 5/6/2025, answer due 7/7/2025; United State of America served on 5/6/2025, answer due 7/7/2025. (Attachments: # 1 Exhibit - Proof of Service of Process for Marco Rubio, # 2 Exhibit - Proof of Service of Process for Attorney General)(Gleklen, Jonathan) (Entered: 05/20/2025)

1 Exhibit - Proof of Service of Process for Marco Rubio

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2 Exhibit - Proof of Service of Process for Attorney General

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SUMMONS Returned Executed by Peter Poe, Lia Hepler-Mackey, Kris Koe, Jill Tran, David Doe, Zander Schlacter, Robert Roe. United State of America served on 5/9/2025, answer due 7/8/2025.(Gleklen, Jonathan) (Entered: 05/20/2025)

RESPONSE in Opposition re 31 MOTION for Preliminary Injunction filed by Marco Rubio, U.S. Department of State, United State of America. (Attachments: # 1 Exhibit, # 2 Text of Proposed Order)(Goldmeier, Melissa) (Entered: 05/28/2025)

Consent MOTION for Leave to File Excess Pages by Marco Rubio, U.S. Department of State, United State of America (Attachments: # 1 Text of Proposed Order)(Goldmeier, Melissa) (Entered: 05/28/2025)

MOTION to Appear Pro Hac Vice for Hannah Sibiski (Filing fee $100, receipt number AMDDC-12005742.) by David Doe, Lia Hepler-Mackey, Kris Koe, Peter Poe, Robert Roe, Zander Schlacter, Jill Tran(Gleklen, Jonathan) (Entered: 05/28/2025)

MOTION to Appear Pro Hac Vice for Luna Floyd (Filing fee $100, receipt number AMDDC-12005864.) by David Doe, Lia Hepler-Mackey, Kris Koe, Peter Poe, Robert Roe, Zander Schlacter, Jill Tran(Gleklen, Jonathan) (Entered: 05/28/2025)

ORDER granting 47 Consent MOTION for Leave to File Excess Pages. Signed by Chief Judge George Levi Russell, III on 5/28/2025. (bw5s, Deputy Clerk) (Entered: 05/28/2025)

PAPERLESS ORDER granting 48 Motion to Appear Pro Hac Vice on behalf of Hannah Sibiski. Directing attorney Hannah Sibiski to register for pro hac vice filing in the District of Maryland through PACER at https://pacer.uscourts.gov/ if attorney has not already done so. The Pro Hac Vice option must be selected when registering. Signed by Clerk on 5/30/2025. (mh4s, Deputy Clerk) (Entered: 05/30/2025)

PAPERLESS ORDER granting 49 Motion to Appear Pro Hac Vice on behalf of Luna Floyd. Directing attorney Luna Floyd to register for pro hac vice filing in the District of Maryland through PACER at https://pacer.uscourts.gov/ if attorney has not already done so. The Pro Hac Vice option must be selected when registering. Signed by Clerk on 5/30/2025. (mh4s, Deputy Clerk) (Entered: 05/30/2025)

REPLY to Response to Motion re 31 MOTION for Preliminary Injunction filed by David Doe, Lia Hepler-Mackey, Kris Koe, Peter Poe, Robert Roe, Zander Schlacter, Jill Tran.(Gleklen, Jonathan) (Entered: 06/11/2025)

NOTICE by Marco Rubio of Supplemental Authority (Attachments: # 1 Exhibit)(Goldmeier, Melissa) (Entered: 06/26/2025)

RESPONSE re 54 Notice (Other) of Supplemental Authority filed by David Doe, Lia Hepler-Mackey, Kris Koe, Peter Poe, Robert Roe, Zander Schlacter, Jill Tran.(Gleklen, Jonathan) (Entered: 06/30/2025)

Consent MOTION for Extension of Time by Marco Rubio, U.S. Department of State, United State of America (Attachments: # 1 Text of Proposed Order)(Goldmeier, Melissa) (Entered: 07/01/2025)

1 Text of Proposed Order

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ORDER granting 56 Consent MOTION for Extension of Time. Signed by Chief Judge George Levi Russell, III on 7/1/2025. (bw5s, Deputy Clerk) (Entered: 07/01/2025)

STIPULATION PROTECTIVE ORDER REGARDING PSEUDONYMS by David Doe, Lia Hepler-Mackey, Kris Koe, Peter Poe, Robert Roe, Zander Schlacter, Jill Tran(Gleklen, Jonathan) (Entered: 07/16/2025)

ORDER granting 2 MOTION FOR LEAVE TO PROCEED UNDER PSEUDONYM, TO WAIVE REQUIREMENT UNDER LOCAL RULE 102.2(a) TO PROVIDE ADDRESSES IN COMPLAINT CAPTION, AND FOR A PROTECTIVE ORDER. Signed by Chief Judge George Levi Russell, III on 7/22/2025. (bw5s, Deputy Clerk) (Entered: 07/22/2025)

ORDER granting 37 MOTION to Seal PSEUDONYMOUS PLAINTIFFS UNOPPOSED MOTION FOR PROTECTIVE ORDER SEALING PORTIONS OF THE RECORD. Signed by Chief Judge George Levi Russell, III on 7/22/2025. (bw5s, Deputy Clerk) (Entered: 07/22/2025)

STIPULATED PROTECTIVE ORDER REGARDING PSEUDONYMS. Signed by Chief Judge George Levi Russell, III on 7/22/2025. (bw5s, Deputy Clerk) (Entered: 07/22/2025)

NOTICE by David Doe, Lia Hepler-Mackey, Kris Koe, Peter Poe, Robert Roe, Zander Schlacter, Jill Tran re 31 MOTION for Preliminary Injunction of Supplemental Authority (Attachments: # 1 Exhibit Ex. A - Am. Assoc. of Phys. for Human Rts. v. NIH, # 2 Exhibit Ex. B - Doe v. South Carolina)(Gleklen, Jonathan) (Entered: 08/18/2025)

1 Exhibit Ex. A - Am. Assoc. of Phys. for Human Rts. v. NIH

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2 Exhibit Ex. B - Doe v. South Carolina

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RESPONSE re 62 Notice (Other), of Supplemental Authority filed by Marco Rubio, U.S. Department of State, United State of America.(Goldmeier, Melissa) Modified on 8/27/2025 (bw5s). (Entered: 08/26/2025)

QC NOTICE: 63 Response filed by Marco Rubio was filed incorrectly. **The document appears to have been filed on behalf of all defendants; however, Marco Rubio was the only filer selected. In the future, please make sure to select each filer. Your document has been accepted and corrected by Court staff. No changes are needed at this time. (bw5s, Deputy Clerk) (Entered: 08/27/2025)

MEMORANDUM OPINION. Signed by Chief Judge George Levi Russell, III on 9/9/2025. (bw5s, Deputy Clerk) (Entered: 09/09/2025)

ORDER granting Motion for Preliminary Injunction (ECF No. 31 ) as to Plaintiffs Peter Poe, Lia Hepler-Mackey, Kris Koe, Jill Tran, David Doe, and Zander Schlacter's Equal Protection claim (Count I) and denying without prejudice as to all remaining Counts and as to Plaintiff Robert Roe. Signed by Chief Judge George Levi Russell, III on 9/9/2025. (1cc/em 09/09/2025 - bw5s, Deputy Clerk) (Entered: 09/09/2025)

Consent MOTION to Stay Due to Lapse of Appropriations by Marco Rubio, U.S. Department of State, United State of America (Attachments: # 1 Text of Proposed Order)(Goldmeier, Melissa) (Entered: 10/06/2025)

ORDER granting 67 Consent MOTION to Stay Due to Lapse of Appropriations. Signed by Chief Judge George Levi Russell, III on 10/6/2025. (bw5s, Deputy Clerk) (Entered: 10/06/2025)

Case Stayed (bw5s, Deputy Clerk)