Case: American Council of Learned Societies v. McDonald

The Authors Guild v. National Endowment for the Humanities

President Donald Trump

COMPLAINT against Nate Cavanaugh, Justin Fox, Amy Gleason, Michael McDonald, National Endowment for the Humanities, United States DOGE Service. (Filing Fee $ 405.00, Receipt Number ANYSDC-31017393)Document filed by Modern Language Association of America, American Historical Association, American Council of Learned Societies..(Robinson, John) (Entered: 05/01/2025)

CIVIL COVER SHEET filed..(Robinson, John) (Entered: 05/01/2025)

RULE 7.1 CORPORATE DISCLOSURE STATEMENT. No Corporate Parent. Document filed by American Council of Learned Societies..(Robinson, John) (Entered: 05/01/2025)

RULE 7.1 CORPORATE DISCLOSURE STATEMENT. No Corporate Parent. Document filed by American Historical Association..(Robinson, John) (Entered: 05/01/2025)

RULE 7.1 CORPORATE DISCLOSURE STATEMENT. No Corporate Parent. Document filed by Modern Language Association of America..(Robinson, John) (Entered: 05/01/2025)

FILING ERROR - PDF ERROR REQUEST FOR ISSUANCE OF SUMMONS as to Michael McDonald, National Endowment for the Humanities, United States DOGE Service, Amy Gleason, Nate Cavanaugh, Justin Fox, Pam Bondi, U.S. Attorney's Office for the Southern District of New York, re: 1 Complaint,. Document filed by American Council of Learned Societies, American Historical Association, Modern Language Association of America. (Attachments: # 1 Exhibit Summons - McDonald, # 2 Exhibit Summons - NEH, # 3 Exhibit Summons - DOGE, # 4 Exhibit Summons - Gleason, # 5 Exhibit Summons - Cavanaugh, # 6 Exhibit Summons - Fox, # 7 Exhibit Summons - AG Bondi).(Robinson, John) Modified on 5/2/2025 (gp). (Entered: 05/01/2025)

REQUEST FOR ISSUANCE OF SUMMONS as to Michael McDonald, re: 1 Complaint,. Document filed by American Council of Learned Societies, American Historical Association, Modern Language Association of America..(Robinson, John) (Entered: 05/02/2025)

REQUEST FOR ISSUANCE OF SUMMONS as to National Endowment for the Humanities, re: 1 Complaint,. Document filed by American Council of Learned Societies, American Historical Association, Modern Language Association of America..(Robinson, John) (Entered: 05/02/2025)

REQUEST FOR ISSUANCE OF SUMMONS as to United States DOGE Service, re: 1 Complaint,. Document filed by American Council of Learned Societies, American Historical Association, Modern Language Association of America..(Robinson, John) (Entered: 05/02/2025)

REQUEST FOR ISSUANCE OF SUMMONS as to Amy Gleason, re: 1 Complaint,. Document filed by American Council of Learned Societies, American Historical Association, Modern Language Association of America..(Robinson, John) (Entered: 05/02/2025)

REQUEST FOR ISSUANCE OF SUMMONS as to Nate Cavanaugh, re: 1 Complaint,. Document filed by American Council of Learned Societies, American Historical Association, Modern Language Association of America..(Robinson, John) (Entered: 05/02/2025)

REQUEST FOR ISSUANCE OF SUMMONS as to Justin Fox, re: 1 Complaint,. Document filed by American Council of Learned Societies, American Historical Association, Modern Language Association of America..(Robinson, John) (Entered: 05/02/2025)

FILING ERROR - DEFICIENT - SUMMONS REQUEST PDF ERROR - REQUEST FOR ISSUANCE OF SUMMONS as to Civil process clerk, U.S. Attorney's Office, re: 1 Complaint,. Document filed by American Council of Learned Societies, American Historical Association, Modern Language Association of America..(Robinson, John) Modified on 5/6/2025 (vf). (Entered: 05/02/2025)

FILING ERROR - DEFICIENT - SUMMONS REQUEST PDF ERROR - REQUEST FOR ISSUANCE OF SUMMONS as to Pam Bondi, re: 1 Complaint,. Document filed by American Council of Learned Societies, American Historical Association, Modern Language Association of America..(Robinson, John) Modified on 5/6/2025 (vf). (Entered: 05/02/2025)

MOTION for Lynn D. Eisenberg to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-31025372. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by American Council of Learned Societies, American Historical Association, Modern Language Association of America. (Attachments: # 1 Affidavit in support of motion to appear Pro Hac Vice, # 2 Supplement Certificate of Good Standing, # 3 Supplement Certificate of Good Standing, # 4 Proposed Order to admit Pro Hac Vice).(Eisenberg, Lynn) (Entered: 05/02/2025)

***NOTICE TO ATTORNEY REGARDING PARTY MODIFICATION. Notice to attorney John Robinson. The party information for the following party/parties has been modified: Michael McDonald, Amy Gleason, Nate Cavanaugh, Justin Fox. The information for the party/parties has been modified for the following reason/reasons: party text was omitted. (gp)

Notice to Attorney Regarding Deficient Request for Issuance of Summons

Case Opening Initial Assignment Notice

Notice to Attorney Regarding Party Modification

Notice Regarding Pro Hac Vice Motion

CASE OPENING INITIAL ASSIGNMENT NOTICE: The above-entitled action is assigned to Judge Colleen McMahon. Please download and review the Individual Practices of the assigned District Judge, located at https://nysd.uscourts.gov/judges/district-judges. Attorneys are responsible for providing courtesy copies to judges where their Individual Practices require such. Please download and review the ECF Rules and Instructions, located at https://nysd.uscourts.gov/rules/ecf-related-instructions..(gp)

Magistrate Judge Barbara C. Moses is designated to handle matters that may be referred in this case. Pursuant to 28 U.S.C. Section 636(c) and Fed. R. Civ. P. 73(b)(1) parties are notified that they may consent to proceed before a United States Magistrate Judge. Parties who wish to consent may access the necessary form at the following link: https://nysd.uscourts.gov/sites/default/files/2018-06/AO-3.pdf. (gp)

Case Designation

Case Designated ECF. (gp)

Case Designated ECF

***NOTICE TO ATTORNEY REGARDING DEFICIENT REQUEST FOR ISSUANCE OF SUMMONS. Notice to Attorney John Robinson to RE-FILE Document No. 6 Request for Issuance of Summons. The filing is deficient for the following reason(s): The summons requested was not processed due to multiple summonses attached as one filing. Please file your request for summons either separately or with a rider listing each defendants name. (gp)

>>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. 15 MOTION for Lynn D. Eisenberg to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-31025372. Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (bc)

ORDER FOR ADMISSION PRO HAC VICE granting 15 Motion for Lynn D. Eisenberg to Appear Pro Hac Vice. The motion of Lynn D. Eisenberg for admission Pro Hac Vice in the above captioned case is granted. IT IS HEREBY ORDERED that Applicant is admitted to practice Pro Hac Vice in the above captioned case in the United States District for the Southern District of New York. All attorneys appearing before this Court are subject to the Local Rules of this Court, including the Rules governing discipline of attorneys. Counsel shall immediately forward the Pro Hac Vice fee to the Clerk of Court. (Signed by Judge Colleen McMahon on 5/5/2025) (jjc) (Entered: 05/05/2025)

ORDER SCHEDULING AN INITIAL PRETRIAL CONFERENCE: It is hereby, ORDERED as follows: Counsel receiving this order shall contact all counsel of record ( or where a party is not yet represented, such party) and, if necessary, provide them with a copy of this order. If a conforming case management plan is submitted at least two business days prior to the scheduled initial conference and subsequently approved by the Court, the initial conference will be canceled automatically. If a motion has been filed either before or after the case management plan is approved, and the parties desire a conference, a letter must be submitted to the Court via ECF specifically asking that the initial conference not be canceled. If the parties fail to agree upon such a plan or fail to submit the plan to the Court within the time provided (at least two business days before the conference date), the parties must appear at a conference on 9/4/2025 at 10:30 a.m., in courtroom 24A, 500 Pearl Street, New York, New York, 10007. (Initial Conference set for 9/4/2025 at 10:30 AM in Courtroom 24A, 500 Pearl Street, New York, NY 10007 before Judge Colleen McMahon.) (Signed by Judge Colleen McMahon on 5/5/25) (yv) (Entered: 05/05/2025)

ELECTRONIC SUMMONS ISSUED as to Michael McDonald. (vf) (Entered: 05/06/2025)

ELECTRONIC SUMMONS ISSUED as to National Endowment for the Humanities. (vf) (Entered: 05/06/2025)

ELECTRONIC SUMMONS ISSUED as to United States DOGE Service. (vf) (Entered: 05/06/2025)

ELECTRONIC SUMMONS ISSUED as to Amy Gleason. (vf) (Entered: 05/06/2025)

ELECTRONIC SUMMONS ISSUED as to Nate Cavanaugh. (vf) (Entered: 05/06/2025)

ELECTRONIC SUMMONS ISSUED as to Justin Fox. (vf) (Entered: 05/06/2025)

Notice to Attorney Regarding Deficient Request for Issuance of Summons

***NOTICE TO ATTORNEY REGARDING DEFICIENT REQUEST FOR ISSUANCE OF SUMMONS. Notice to Attorney John Robinson to RE-FILE Document No. 13 Request for Issuance of Summons, 14 Request for Issuance of Summons,. The filing is deficient for the following reason(s): the PDF attached to the docket entry for the issuance of summons is not correct; Defendant party name listed on Summons PDF does not correspond to pleading caption. Re-file the document using the event type Request for Issuance of Summons found under the event list Service of Process - select the correct filer/filers - and attach the correct summons form PDF. (vf)

MOTION for Preliminary Injunction . Document filed by American Council of Learned Societies, American Historical Association, Modern Language Association of America. (Attachments: # 1 Proposed Order Text of proposed order).(Robinson, John) (Entered: 05/14/2025)

1 Proposed Order Text of proposed order

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MEMORANDUM OF LAW in Support re: 24 MOTION for Preliminary Injunction . . Document filed by American Council of Learned Societies, American Historical Association, Modern Language Association of America..(Robinson, John) (Entered: 05/14/2025)

DECLARATION of John Robinson in Support re: 24 MOTION for Preliminary Injunction .. Document filed by American Council of Learned Societies, American Historical Association, Modern Language Association of America. (Attachments: # 1 Exhibit 1 - organization chart, # 2 Exhibit 2 - NEH annual report, # 3 Exhibit 3 - ACLS award, # 4 Exhibit 4 - ACLS award, # 5 Exhibit 5 - AHA award, # 6 Exhibit 6 - AHA award, # 7 Exhibit 7 - MLA award, # 8 Exhibit 8 - MLA award, # 9 Exhibit 9 - Termination example, # 10 Exhibit 10 - Guidance, # 11 Exhibit 11 - Termination email, # 12 Exhibit 12 - Termination email, # 13 Exhibit 13 - Garden NOFO, # 14 Exhibit 14 - Websites, # 15 Exhibit 14 (continued), # 16 Exhibit 15 - Press release).(Robinson, John) (Entered: 05/14/2025)

1 Exhibit 1 - organization chart

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2 Exhibit 2 - NEH annual report

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3 Exhibit 3 - ACLS award

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4 Exhibit 4 - ACLS award

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5 Exhibit 5 - AHA award

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6 Exhibit 6 - AHA award

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7 Exhibit 7 - MLA award

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8 Exhibit 8 - MLA award

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9 Exhibit 9 - Termination example

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10 Exhibit 10 - Guidance

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11 Exhibit 11 - Termination email

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12 Exhibit 12 - Termination email

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13 Exhibit 13 - Garden NOFO

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14 Exhibit 14 - Websites

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15 Exhibit 14 (continued)

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16 Exhibit 15 - Press release

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DECLARATION of Joy Connolly in Support re: 24 MOTION for Preliminary Injunction .. Document filed by American Council of Learned Societies, American Historical Association, Modern Language Association of America..(Robinson, John) (Entered: 05/14/2025)

DECLARATION of James Grossman in Support re: 24 MOTION for Preliminary Injunction .. Document filed by American Council of Learned Societies, American Historical Association, Modern Language Association of America..(Robinson, John) (Entered: 05/14/2025)

DECLARATION of Paula Krebs in Support re: 24 MOTION for Preliminary Injunction .. Document filed by American Council of Learned Societies, American Historical Association, Modern Language Association of America..(Robinson, John) (Entered: 05/14/2025)

DECLARATION of Richard Roe in Support re: 24 MOTION for Preliminary Injunction .. Document filed by American Council of Learned Societies, American Historical Association, Modern Language Association of America..(Robinson, John) (Entered: 05/14/2025)

DECLARATION of John Doe in Support re: 24 MOTION for Preliminary Injunction .. Document filed by American Council of Learned Societies, American Historical Association, Modern Language Association of America..(Robinson, John) (Entered: 05/14/2025)

DECLARATION of Jane Doe in Support re: 24 MOTION for Preliminary Injunction .. Document filed by American Council of Learned Societies, American Historical Association, Modern Language Association of America..(Robinson, John) (Entered: 05/14/2025)

DECLARATION of Katherine S. Newman in Support re: 24 MOTION for Preliminary Injunction .. Document filed by American Council of Learned Societies, American Historical Association, Modern Language Association of America..(Robinson, John) (Entered: 05/14/2025)

DECLARATION of David F. Kotz in Support re: 24 MOTION for Preliminary Injunction .. Document filed by American Council of Learned Societies, American Historical Association, Modern Language Association of America..(Robinson, John) (Entered: 05/14/2025)

DECLARATION of Caroline Gottschalk Druschke in Support re: 24 MOTION for Preliminary Injunction .. Document filed by American Council of Learned Societies, American Historical Association, Modern Language Association of America..(Robinson, John) (Entered: 05/14/2025)

DECLARATION of Christine Wenc in Support re: 24 MOTION for Preliminary Injunction .. Document filed by American Council of Learned Societies, American Historical Association, Modern Language Association of America..(Robinson, John) (Entered: 05/14/2025)

DECLARATION of Michael Martoccio in Support re: 24 MOTION for Preliminary Injunction .. Document filed by American Council of Learned Societies, American Historical Association, Modern Language Association of America..(Robinson, John) (Entered: 05/14/2025)

DECLARATION of Eric Hoyt in Support re: 24 MOTION for Preliminary Injunction .. Document filed by American Council of Learned Societies, American Historical Association, Modern Language Association of America..(Robinson, John) (Entered: 05/14/2025)

DECLARATION of Jeffrey Urbach in Support re: 24 MOTION for Preliminary Injunction .. Document filed by American Council of Learned Societies, American Historical Association, Modern Language Association of America..(Robinson, John) (Entered: 05/14/2025)

DECLARATION of Richard Mocarski in Support re: 24 MOTION for Preliminary Injunction .. Document filed by American Council of Learned Societies, American Historical Association, Modern Language Association of America..(Robinson, John) (Entered: 05/14/2025)

DECLARATION of Krista Caballero in Support re: 24 MOTION for Preliminary Injunction .. Document filed by American Council of Learned Societies, American Historical Association, Modern Language Association of America..(Robinson, John) (Entered: 05/14/2025)

DECLARATION of Suzanne Kite in Support re: 24 MOTION for Preliminary Injunction .. Document filed by American Council of Learned Societies, American Historical Association, Modern Language Association of America..(Robinson, John) (Entered: 05/14/2025)

DECLARATION of Shashank Priya in Support re: 24 MOTION for Preliminary Injunction .. Document filed by American Council of Learned Societies, American Historical Association, Modern Language Association of America..(Robinson, John) (Entered: 05/14/2025)

DECLARATION of Dr. Joseph T. Walsh, Jr. in Support re: 24 MOTION for Preliminary Injunction .. Document filed by American Council of Learned Societies, American Historical Association, Modern Language Association of America..(Robinson, John) (Entered: 05/14/2025)

DECLARATION of Mattie Burkert in Support re: 24 MOTION for Preliminary Injunction .. Document filed by American Council of Learned Societies, American Historical Association, Modern Language Association of America..(Robinson, John) (Entered: 05/14/2025)

DECLARATION of Rachel Kuo in Support re: 24 MOTION for Preliminary Injunction .. Document filed by American Council of Learned Societies, American Historical Association, Modern Language Association of America..(Robinson, John) (Entered: 05/14/2025)

DECLARATION of Laura Morreale in Support re: 24 MOTION for Preliminary Injunction .. Document filed by American Council of Learned Societies, American Historical Association, Modern Language Association of America..(Robinson, John) (Entered: 05/14/2025)

DECLARATION of Lauren Tilton in Support re: 24 MOTION for Preliminary Injunction .. Document filed by American Council of Learned Societies, American Historical Association, Modern Language Association of America..(Robinson, John) (Entered: 05/14/2025)

DECLARATION of Julie M. Weise in Support re: 24 MOTION for Preliminary Injunction .. Document filed by American Council of Learned Societies, American Historical Association, Modern Language Association of America..(Robinson, John) (Entered: 05/14/2025)

DECLARATION of Mark Moe in Support re: 24 MOTION for Preliminary Injunction .. Document filed by American Council of Learned Societies, American Historical Association, Modern Language Association of America..(Robinson, John) (Entered: 05/14/2025)

DECLARATION of Krista Caballero (corrected) in Support re: 24 MOTION for Preliminary Injunction .. Document filed by American Council of Learned Societies, American Historical Association, Modern Language Association of America..(Robinson, John) (Entered: 05/14/2025)

ORDER CONSOLIDATING CASES AND SETTING BRIEFING SCHEDULE re: (24 in 1:25-cv-03657-CM) MOTION for Preliminary Injunction. I have today received word that the plaintiffs in American Council of Learned Societies et al v. McDonald et al (25-cv-03657) have filed a motion for a preliminary injunction. A few hours ago, I also was assigned a related case, The Authors Guild et al v. National Endowment for the Humanities et al (25-cv- 03923), which appears to be substantially identical to the American Council case. I am tentatively consolidating the two cases for all purposes. All filings should be made under the lower docket number, which is 25-cv-03657. If someone can convince me that that consolidation should be undone, I will take care of it next month. If the plaintiffs in Authors Guild intend to join the motion for a preliminary injunction in American Council, or if they wish to make their own separate motion, they have until May 23, 2025 to do so. If the Government wishes to make any cross motions, it must do so by May 30, 2025. Responsive papers in opposition to the preliminary injunction motion(s) are due on June 5, 2025. Reply papers on the preliminary injunction motion(s) AND responses to any cross motions that the Government makes are due on June 13, 2025. Reply papers on any cross motions made by the Government are due on June 20, 2025. In the highly unlikely event that I require oral argument, I will notify the parties. BY ECF TO ALL COUNSEL. SO ORDERED. (Signed by Judge Colleen McMahon on 5/14/2025) (Motions due by 5/30/2025. Replies due by 6/13/2025. Responses due by 6/5/2025) (ar) (Entered: 05/14/2025)

FILING ERROR - DEFICIENT DOCKET ENTRY - MOTION for Michael Lieberman to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-31087741. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Katalin Balog, William Goldstein, Benjamin Holtzman, Lee Jasperse, Nicole Jenkins, Elizabeth Kadetsky, Valarie Orlando, The Authors Guild. (Attachments: # 1 Affidavit Affidavit in Support, # 2 Exhibit Certificate of Good Standing, # 3 Proposed Order Proposed Order).(Lieberman, Michael) Modified on 5/15/2025 (bc). (Entered: 05/15/2025)

NOTICE OF APPEARANCE by Rachael Lightfoot Doud on behalf of Nate Cavanaugh, Justin Fox, Amy Gleason, Michael McDonald, National Endowment for the Humanities, United States DOGE Service. Filed In Associated Cases: 1:25-cv-03657-CM, 1:25-cv-03923-CM.(Doud, Rachael) (Entered: 05/15/2025)

Notice Regarding Deficient Motion to Appear Pro Hac vice

>>>NOTICE REGARDING DEFICIENT MOTION TO APPEAR PRO HAC VICE. Notice to RE-FILE Document No. 53 MOTION for Michael Lieberman to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-31087741. Motion and supporting papers to be reviewed by Clerk's Office staff... The filing is deficient for the following reason(s): Affidavit must be notarized;. Re-file the motion as a Motion to Appear Pro Hac Vice - attach the correct signed PDF - select the correct named filer/filers - attach valid Certificates of Good Standing issued within the past 30 days - attach Proposed Order.. (bc)

MOTION for Michael Lieberman to Appear Pro Hac Vice . Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Katalin Balog, William Goldstein, Benjamin Holtzman, Lee Jasperse, Nicole Jenkins, Elizabeth Kadetsky, Valarie Orlando, The Authors Guild. (Attachments: # 1 Proposed Order Proposed Order, # 2 Affidavit Affidavit, # 3 Exhibit Certificate of Good Standing).(Lieberman, Michael) (Entered: 05/20/2025)

MOTION for Jamie Crooks to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-31110916. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Katalin Balog, William Goldstein, Benjamin Holtzman, Lee Jasperse, Nicole Jenkins, Elizabeth Kadetsky, Valarie Orlando, The Authors Guild. (Attachments: # 1 Proposed Order Proposed Order, # 2 Affidavit Affidavit, # 3 Exhibit Certificate of Good Standing).(Crooks, Jamie) (Entered: 05/20/2025)

Notice Regarding Pro Hac Vice Motion

>>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. 55 MOTION for Michael Lieberman to Appear Pro Hac Vice . Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (bc)

>>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. 56 MOTION for Jamie Crooks to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-31110916. Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (bc)

ORDER FOR ADMISSIONPRO HAC VICE granting 56 Motion for Jamie Crooks to Appear Pro Hac Vice. The motion of Jamie Crooks, for admission to practice Pro Hac Vice in the above captioned action is granted. IT IS HEREBY ORDERED that Applicant is admitted to practice Pro Hac Vice in the above captioned case in the United States District Court for the Southern District of New York. All attorneys appearing before this Court are subject to the Local Rules of this Court, including the Rules governing discipline of attorneys. (Signed by Judge Colleen McMahon on 5/21/25) (yv) (Entered: 05/21/2025)

ORDER FOR ADMISSION PRO HAC VICE granting 55 Motion for Michael Lieberman to Appear Pro Hac Vice. The motion of Michael Lieberman, for admission to practice Pro Hac Vice in the above captioned action is granted. IT IS HEREBY ORDERED that Applicant is admitted to practice Pro Hac Vice in the above captioned case in the United States District Court for the Southern District of New York. All attorneys appearing before this Court are subject to the Local Rules of this Court, including the Rules governing discipline of attorneys. (Signed by Judge Colleen McMahon on 5/21/25) (yv) (Entered: 05/21/2025)

MOTION for Amanda Vaughn to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-31117358. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Katalin Balog, William Goldstein, Benjamin Holtzman, Lee Jasperse, Nicole Jenkins, Elizabeth Kadetsky, Valarie Orlando, The Authors Guild. (Attachments: # 1 Proposed Order Proposed Order, # 2 Affidavit Affidavit, # 3 Exhibit Certificate of Good Standing, # 4 Exhibit Certificate of Good Standing).(Vaughn, Amanda) (Entered: 05/21/2025)

SUMMONS RETURNED EXECUTED. Nate Cavanaugh served on 5/13/2025, answer due 7/14/2025; Justin Fox served on 5/13/2025, answer due 7/14/2025; Amy Gleason served on 5/13/2025, answer due 7/14/2025; Michael McDonald served on 5/13/2025, answer due 7/14/2025; National Endowment for the Humanities served on 5/13/2025, answer due 7/14/2025; United States DOGE Service served on 5/13/2025, answer due 7/14/2025. Service was made by Mail. Document filed by American Historical Association; American Council of Learned Societies; Modern Language Association of America..(Robinson, John) (Entered: 05/21/2025)

NOTICE OF APPEARANCE by Mary Ellen Brennan on behalf of Nate Cavanaugh, Justin Fox, Amy Gleason, Michael McDonald, National Endowment for the Humanities, United States DOGE Service, Nate Cavanaugh, Justin Fox, Amy Gleason, Michael McDonald, United States DOGE Service. Filed In Associated Cases: 1:25-cv-03657-CM, 1:25-cv-03923-CM.(Brennan, Mary) (Entered: 05/21/2025)

CONSENT LETTER MOTION for Extension of Time for defendants to file any cross motions addressed to Judge Colleen McMahon from Mary Ellen Brennan dated May 21, 2025. Document filed by Nate Cavanaugh, Justin Fox, Amy Gleason, Michael McDonald, National Endowment for the Humanities, United States DOGE Service.Filed In Associated Cases: 1:25-cv-03657-CM, 1:25-cv-03923-CM.(Brennan, Mary) (Entered: 05/21/2025)

Notice Regarding Pro Hac Vice Motion

>>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. 59 MOTION for Amanda Vaughn to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-31117358. Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (rju)

ORDER denying (62) Letter Motion for Extension of Time in case 1:25-cv-03657-CM; denying (20) Letter Motion for Extension of Time in case 1:25-cv-03923-CM. The May 14 order does alter Defendants' time to answer or otherwise respond to the complaints. This is why I set the schedule that I did with adequate time set out for opposition papers and replies. To the extent there is overlap, Defendants may reference their motion papers in their subsequent opposition papers. The schedule remains the same. (Signed by Judge Colleen McMahon on 5/22/25) Filed In Associated Cases: 1:25-cv-03657-CM, 1:25-cv-03923-CM (yv) (Entered: 05/22/2025)

ORDER FOR ADMISSION PRO HAC VICE granting 59 Motion for Amanda Vaughn to Appear Pro Hac Vice. The motion of Amanda Vaughn, for admission to practice Pro Hac Vice in the above captioned action is granted. IT IS HEREBY ORDERED that Applicant is admitted to practice Pro Hac Vice in the above captioned case in the United States District Court for the Southern District of New York. All attorneys appearing before this Court are subject to the Local Rules of this Court, including the Rules governing discipline of attorneys. (Signed by Judge Colleen McMahon on 5/22/25) (yv) (Entered: 05/22/2025)

MOTION for Preliminary Injunction . Document filed by Katalin Balog, William Goldstein, Benjamin Holtzman, Lee Jasperse, Nicole Jenkins, Elizabeth Kadetsky, Valarie Orlando, The Authors Guild. (Attachments: # 1 Exhibit Memorandum in Support, # 2 Proposed Order Proposed Order).(Crooks, Jamie) (Entered: 05/23/2025)

1 Exhibit Memorandum in Support

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2 Proposed Order Proposed Order

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DECLARATION of Michael Lieberman in Support re: 65 MOTION for Preliminary Injunction .. Document filed by Katalin Balog, William Goldstein, Benjamin Holtzman, Lee Jasperse, Nicole Jenkins, Elizabeth Kadetsky, Valarie Orlando, The Authors Guild..(Crooks, Jamie) (Entered: 05/23/2025)

DECLARATION of Mary Rasenberger in Support re: 65 MOTION for Preliminary Injunction .. Document filed by The Authors Guild..(Crooks, Jamie) (Entered: 05/23/2025)

DECLARATION of Elizabeth Kadetsky in Support re: 65 MOTION for Preliminary Injunction .. Document filed by Elizabeth Kadetsky. (Attachments: # 1 Exhibit NEH Award Letter, # 2 Exhibit Notice of Grant Termination).(Crooks, Jamie) (Entered: 05/23/2025)

DECLARATION of William Goldstein in Support re: 65 MOTION for Preliminary Injunction .. Document filed by William Goldstein. (Attachments: # 1 Exhibit NEH Award Letter, # 2 Exhibit Notice of Grant Termination, # 3 Exhibit Letter, # 4 Exhibit Email, # 5 Exhibit Email).(Crooks, Jamie) (Entered: 05/23/2025)

DECLARATION of Benjamin Holtzman in Support re: 65 MOTION for Preliminary Injunction .. Document filed by Benjamin Holtzman. (Attachments: # 1 Exhibit Notice of Funding Opportunity, # 2 Exhibit NEH Offer Letter, # 3 Exhibit NEH Award Letter, # 4 Exhibit Notice of Grant Termination).(Crooks, Jamie) (Entered: 05/23/2025)

DECLARATION of Katalin Balog in Support re: 65 MOTION for Preliminary Injunction .. Document filed by Katalin Balog. (Attachments: # 1 Exhibit NEH Award Letter, # 2 Exhibit NEH Award Letter, # 3 Exhibit Appeal of Termination, # 4 Exhibit Appeal Response).(Crooks, Jamie) (Entered: 05/23/2025)

DECLARATION of Valerie Orlando in Support re: 65 MOTION for Preliminary Injunction .. Document filed by Valarie Orlando. (Attachments: # 1 Exhibit NEH Offer Letter, # 2 Exhibit Notice of Grant Termination, # 3 Exhibit Appeal of Termination).(Crooks, Jamie) (Entered: 05/23/2025)

DECLARATION of Nicole Jenkins in Support re: 65 MOTION for Preliminary Injunction .. Document filed by Nicole Jenkins. (Attachments: # 1 Exhibit NEH Award Letter).(Crooks, Jamie) (Entered: 05/23/2025)

DECLARATION of Lee Jasperse in Support re: 65 MOTION for Preliminary Injunction .. Document filed by Lee Jasperse. (Attachments: # 1 Exhibit NEH Award Letter, # 2 Exhibit Email Confirmation, # 3 Exhibit Notice of Termination).(Crooks, Jamie) (Entered: 05/23/2025)

1 Exhibit NEH Award Letter

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2 Exhibit Email Confirmation

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3 Exhibit Notice of Termination

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AMENDED COMPLAINT amending Complaint (ORIGINAL FILED IN CASE 1:25-cv-3923 Doc #22) against Nate Cavanaugh, Justin Fox, Amy Gleason, Michael McDonald, National Endowment for the Humanities, United States DOGE Service.Document filed by Benjamin Holtzman, William Goldstein, Nicole Jenkins, The Authors Guild, Valarie Orlando, Elizabeth Kadetsky, Lee Jasperse, Katalin Balog. (Crooks, Jamie) Modified on 5/27/2025 (gp). (Entered: 05/27/2025)

MOTION to Dismiss . Document filed by Nate Cavanaugh, Justin Fox, Amy Gleason, Michael McDonald, National Endowment for the Humanities, United States DOGE Service..(Brennan, Mary) (Entered: 05/30/2025)

MEMORANDUM OF LAW in Support re: (23 in 1:25-cv-03923-CM) MOTION to Dismiss . . Document filed by Nate Cavanaugh, Justin Fox, Amy Gleason, Michael McDonald, National Endowment for the Humanities, United States DOGE Service. Filed In Associated Cases: 1:25-cv-03657-CM, 1:25-cv-03923-CM.(Brennan, Mary) (Entered: 05/30/2025)

LETTER addressed to Judge Colleen McMahon from Rachael Doud dated June 4, 2025 re: Joint Letter re Case Management Plan. Document filed by Nate Cavanaugh, Justin Fox, Amy Gleason, Michael McDonald, National Endowment for the Humanities, United States DOGE Service. (Attachments: # 1 Exhibit Plaintiffs' Proposed Case Management Plan)Filed In Associated Cases: 1:25-cv-03657-CM, 1:25-cv-03923-CM.(Doud, Rachael) (Entered: 06/04/2025)

1 Exhibit Plaintiffs' Proposed Case Management Plan

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MEMO ENDORSEMENT on re: 78 Letter, filed by Michael McDonald, Justin Fox, Nate Cavanaugh, National Endowment for the Humanities, United States DOGE Service, Amy Gleason. ENDORSEMENT: This order was sent out in my absence as a standard case management tool. I agree that it should not have been sent until the motions contemplated by my previous scheduling order are decided we will not be entering a case management plan. (Signed by Judge Colleen McMahon on 6/5/2025) (vfr) (Entered: 06/05/2025)