Case: Doe v. Noem

COMPLAINT against TODD LYONS, KRISTI NOEM ( Filing fee $ 405 receipt number ADCDC-11663786) filed by STUDENT DOE. (Attachments: # 1 Civil Cover Sheet, # 2 Summons Kristi Noem, # 3 Summons Todd Lyons)(Decker, Sarah) (Attachment 1 replaced on 5/5/2025) (znmw). (Entered: 05/04/2025)

1 Civil Cover Sheet

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2 Summons Kristi Noem

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3 Summons Todd Lyons

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SEALED MOTION to Proceed Under Pseudonym by STUDENT DOE. (Attachments: # 1 Text of Proposed Order)(Decker, Sarah) Modified event on 5/4/2025 (znmw). (Entered: 05/04/2025)

MOTION for Temporary Restraining Order by STUDENT DOE. (Attachments: # 1 Text of Proposed Order)(Decker, Sarah) (Entered: 05/04/2025)

1 Text of Proposed Order

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CIVIL COVER SHEET by STUDENT DOE re 1 Complaint filed by STUDENT DOE. Related document: 1 Complaint filed by STUDENT DOE.(Decker, Sarah) (Main Document 4 replaced on 5/5/2025) (znmw). (Entered: 05/04/2025)

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Sarnata Reynolds, Filing fee $ 100, receipt number ADCDC-11663835. Fee Status: Fee Paid. by STUDENT DOE. (Attachments: # 1 Declaration of Sarnata Reynolds, # 2 Text of Proposed Order)(Decker, Sarah) (Entered: 05/04/2025)

REQUEST FOR SUMMONS TO ISSUE United States of America, U.S. Department of Justice 950 Pennsylvania Avenue NW Washington DC 20530 filed by STUDENT DOE. Related document: 1 Complaint filed by STUDENT DOE.(Decker, Sarah) (Entered: 05/04/2025)

REQUEST FOR SUMMONS TO ISSUE United States of America, United States Attorney's Office 601 D Street, NW Washington, DC 20001 filed by STUDENT DOE. Related document: 1 Complaint filed by STUDENT DOE.(Decker, Sarah) (Entered: 05/04/2025)

Notice of Error- New Case

NOTICE OF NEW CASE ERROR regarding 1 Complaint. The following error(s) need correction: Incorrect civil cover sheet. Please locate the Civil Cover Sheet (JS44) form at www.dcd.uscourts.gov/new-case-forms & file using the event Civil Cover Sheet. Missing summonses- U.S. government. When naming a U.S. government agent or agency as a defendant, you must supply a summons for each defendant & two additional summonses for the U.S. Attorney & U.S. Attorney General. Please submit using the event Request for Summons to Issue. COMPLIANCE DEADLINE is by close of business 5/5/2025. This case will not proceed any further until all errors are satisfied. (znmw)

ERRATA Certificate of Good Standing by STUDENT DOE re 5 Motion for Leave to Appear Pro Hac Vice,. (Decker, Sarah) (Entered: 05/05/2025)

Notice of Error

NOTICE OF ERROR regarding 5 MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Sarnata Reynolds, Filing fee $ 100, receipt number ADCDC-11663835. Fee Status: Fee Paid.. The following error(s) need correction: Pro Hac Vice motion must be accompanied by a Certificate of Good Standing issued within the last 30 days (LCvR 83.2(c)(2)). Please file certificate as an Errata (znmw)

Order on Sealed Motion to Proceed Under Pseudonym

MINUTE ORDER: The Court ORDERS that: 1) Plaintiff's 2 Motion to Proceed Under Pseudonym is DENIED WITHOUT PREJUDICE as it does not address the five-factor inquiry that applies to such motions, see In re Sealed Case, 971 F.3d 324, 326-27 (D.C. Cir. 2020); 2) Within fourteen days of the Court's Order, Plaintiff shall file either a new Motion that addresses the factors identified in In re Sealed Case or a Notice advising the Clerk of the Court whether he wishes to proceed under his true name, and, if so, he shall also file his 2 Motion on the public docket as an appendix to that Notice; and 3) If Plaintiff does not file a new Motion or such Notice within fourteen days, the Clerk is directed to terminate the case. The factors identified in In re Sealed Case are: 1) whether the justification asserted by the requesting party is merely to avoid the annoyance and criticism that may attend any litigation or is to preserve privacy in a matter of a sensitive and highly personal nature; 2) whether identification poses a risk of retaliatory physical or mental harm to the requesting party or, even more critically, to innocent non-parties; 3) the ages of the persons whose privacy interests are sought to be protected; 4) whether the action is against a governmental or private party; and, relatedly, 5) the risk of unfairness to the opposing party from allowing an action against it to proceed anonymously. So ORDERED by Chief Judge James E. Boasberg on 5/5/2025. (lcjeb4)

Amended SEALED MOTION to Proceed Under Pseudonym To Proceed Under A Pseudonym And To Seal Or Redact Personally Identifying Information by STUDENT DOE. (Attachments: # 1 Text of Proposed Order)(Decker, Sarah) Modified event on 5/21/2025 (znmw). (Entered: 05/06/2025)

Order on Sealed Motion to Proceed Under Pseudonym AND Set/Reset Deadlines

MINUTE ORDER: The Court has reviewed Plaintiff's 9 Motion to Proceed Under Pseudonym and to File Under Seal. Given the expedited nature of this matter, it determines that a full Opinion is not practical at this time. Believing that Plaintiff has made the required showing on the relevant factors, the Court ORDERS that: 1) The 9 Motion is GRANTED, subject to any further consideration by the United States District Judge to whom this case is randomly assigned; 2) All parties shall use the pseudonym listed in the Complaint in all documents filed in this action; 3) All documents containing personally identifying information shall be filed under seal, with a redacted public filing made simultaneously or promptly thereafter; and 4) Within fourteen days of this Order, Plaintiff shall file on the public docket: i) A pseudonymous version of his 9 Motion and any attachments as a Notice to the Court; and ii) A sealed declaration containing his real name and residential address. So ORDERED by Chief Judge James E. Boasberg on May 28, 2025. (lcjeb4)

SUMMONS (4) Issued Electronically as to TODD LYONS, KRISTI NOEM, U.S. Attorney and U.S. Attorney General (Attachments: # 1 Notice and Consent)(znmw) (Entered: 05/29/2025)

ERRATA by STUDENT DOE re 5 Motion for Leave to Appear Pro Hac Vice,. (Decker, Sarah) (Entered: 05/29/2025)

STATUS REPORT by STUDENT DOE. (Decker, Sarah) (Entered: 05/29/2025)

Case Assigned/Reassigned

Status Report Order

Order on Motion for Leave to Appear Pro Hac Vice

Notice of Error

Case Assigned to Judge Amit P. Mehta. (znmw)

MINUTE ORDER. This matter was assigned to the undersigned today. Recognizing that the 3 Motion for Temporary Restraining Order has been pending since May 5, 2025, Plaintiff shall, by May 30, 2025, at 5 PM, file a Status Report updating the court on (1) any factual developments in this matter since filing, (2) whether emergency relief is still requested, and (3) the status of service on Defendants. Signed by Judge Amit P. Mehta on 5/29/2025. (lcapm1)

MINUTE ORDER amending the court's previous Status Report Order. Plaintiff shall file the above-requested Status Report by today, May 29, 2025, at 4 PM. Signed by Judge Amit P. Mehta on 5/29/2025. (lcapm1)

NOTICE OF ERROR regarding 5 MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Sarnata Reynolds, Filing fee $ 100, receipt number ADCDC-11663835. Fee Status: Fee Paid.. The following error(s) need correction: Document incomplete, missing firm address and phone number on Declaration. Please refile using the event Declaration. Pro Hac Vice motion must be accompanied by a Certificate of Good Standing issued within the last 30 days (LCvR 83.2(c)(2)). Please file certificate as an Errata (mg)

MINUTE ORDER granting 5 Motion for Leave to Appear Pro Hac Vice. Attorney Sarnata Reynolds is hereby admitted pro hac vice to appear in this matter. Counsel should register for e-filing via PACER and file a notice of appearance pursuant to LCvR 83.6(a). Click for instructions. Signed by Judge Amit P. Mehta on 5/29/2025. (lcapm1)

MINUTE ORDER. Plaintiff shall attempt to meet and confer with Defendants' counsel and, by June 3, 2025, file a Joint Status Report that sets forth a schedule for briefing on Plaintiff's 3 Motion for Temporary Restraining Order, which the court converts to a Motion for Preliminary Injunction per Plaintiff's request. Signed by Judge Amit P. Mehta on 5/29/2025. (lcapm1)

NOTICE of Appearance by Peter C. Pfaffenroth on behalf of TODD LYONS, KRISTI NOEM (Pfaffenroth, Peter) (Entered: 06/03/2025)

NOTICE of Appearance by Sarnata Reynolds on behalf of STUDENT DOE (Reynolds, Sarnata) (Entered: 06/03/2025)

Joint STATUS REPORT by TODD LYONS, KRISTI NOEM. (Pfaffenroth, Peter) (Entered: 06/03/2025)

.Order AND ~Util - Set/Reset Deadlines

MINUTE ORDER. Defendants shall file their opposition to Plaintiff's Motion for Preliminary Injunction by June 13, 2025. Plaintiff shall file his reply by June 20, 2025. Signed by Judge Amit P. Mehta on 6/4/2025. (lcapm2)

Unopposed MOTION for Leave to File Supplement to PI Record by STUDENT DOE. (Attachments: # 1 Exhibit New ICE.HSI letter)(Reynolds, Sarnata) (Entered: 06/10/2025)

SUPPLEMENTAL MEMORANDUM to re 3 MOTION for Temporary Restraining Order filed by STUDENT DOE. (mg) (Entered: 06/12/2025)

Order on Motion for Leave to File

MINUTE ORDER granting 16 Plaintiff's Unopposed Motion for Leave to Supplement the Record in Support of Preliminary Injunction. The court hereby accepts the filing of Exhibit A, ECF No. 16-1. Signed by Judge Amit P. Mehta on 6/11/2025. (lcapm2)

MOTION to Dismiss for Lack of Jurisdiction by TODD LYONS, KRISTI NOEM. (Attachments: # 1 Memorandum in Support, # 2 Exhibit A - SEVP Policy, # 3 Exhibit B - Watson Decl., # 4 Exhibit C - SEVIS record of Student Doe (redacted), # 5 Text of Proposed Order)(Pfaffenroth, Peter) (Entered: 06/13/2025)

Memorandum in opposition to re 3 MOTION for Temporary Restraining Order filed by TODD LYONS, KRISTI NOEM. (Attachments: # 1 Exhibit A - SEVP Policy, # 2 Exhibit B - Watson Decl., # 3 Exhibit C - SEVIS record of Student Doe (redacted), # 4 Text of Proposed Order)(Pfaffenroth, Peter) (Entered: 06/13/2025)

1

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ADMINISTRATIVE RECORD Certification by TODD LYONS, KRISTI NOEM. (Attachments: # 1 Certified Index)(Pfaffenroth, Peter) (Entered: 06/13/2025)

NOTICE OF WITHDRAWAL OF APPEARANCE as to STUDENT DOE. Attorney Sarah Decker terminated. (Decker, Sarah) (Entered: 06/18/2025)

REPLY to opposition to motion re 3 Motion for TRO filed by STUDENT DOE.(Attachments: # 1 Proposed Order, # 2 Certificate of Service)(Reynolds, Sarnata) Modified event on 6/23/2025 (mg). (Entered: 06/20/2025)

1 Proposed Order

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2 Certificate of Service

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Memorandum in opposition to re 18 MOTION to Dismiss for Lack of Jurisdiction filed by STUDENT DOE. (See docket entry 22 to view document). (mg) (Entered: 06/23/2025)

Memorandum in opposition to motion

REPLY to opposition to motion re 18 Motion to Dismiss/Lack of Jurisdiction, filed by TODD LYONS, KRISTI NOEM. (Pfaffenroth, Peter) (Entered: 06/27/2025)

STIPULATION of Dismissal by STUDENT DOE. (Reynolds, Sarnata) (Entered: 06/30/2025)

.Order

MINUTE ORDER. Counsel for Plaintiff shall show cause by July 11, 2025, why the court should not sanction her for citing Moms Against Poverty v. Department of State, 2022 WL 17951329 (D.D.C. Dec. 23, 2022), a seemingly non-existent authority found on page three of her response brief, ECF No. 22. The court has found no such case on Westlaw or in the court's electronic docketing system. Signed by Judge Amit P. Mehta on 7/1/2025. (lcapm2)

Set/Reset Deadlines

Set/Reset Deadlines: Counsel's Response to Show Cause order due by 7/11/2025. (zakb)

RESPONSE TO ORDER TO SHOW CAUSE re Order, filed by STUDENT DOE. (Attachments: # 1 Certificate of Service)(Reynolds, Sarnata) (Entered: 07/03/2025)

1 Certificate of Service

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.Order

MINUTE ORDER vacating Order to Show Cause. The court appreciates and credits counsel's candid and contrite response. The court therefore will not impose any sanctions. The court, however, admonishes counsel about her use of AI technology in the future when drafting briefs. That technology is no substitute for counsel's own diligence. If counsel commits a similar error in the future before another judge, she shall notify that court about these proceedings, so as to enable an informed decision on possible sanctions. Signed by Judge Amit P. Mehta on 7/10/2025. (lcapm2)