Case: American Gateways v. U.S. Department of Justice

American Gateways v. Department of Justice

Gateways v. U.S. Department of Justice

COMPLAINT against All Defendants ( Filing fee $ 405 receipt number ADCDC-11667823) filed by IMMIGRATION SERVICES AND LEGAL ADVOCACY, Diocesan Migrant & Refugee Services (d/b/a Estrella Del Paso), NATIONAL IMMIGRANT JUSTICE CENTER, Rocky Mountain Immigrant Advocacy Network, AMICA CENTER FOR IMMIGRANT RIGHTS, PENNSYLVANIA IMMIGRATION RESOURCE CENTER, AMERICAN GATEWAYS, GALVESTON-HOUSTON IMMIGRANT REPRESENTATION PROJECT, Immigrant Law Center of Minnesota. (Attachments: # 1 Civil Cover Sheet, # 2 Summons, # 3 Summons, # 4 Summons, # 5 Summons, # 6 Summons, # 7 Summons, # 8 Summons)(Ventresca, Ivano) (Attachment 1 replaced on 5/6/2025) (zjm). (Entered: 05/05/2025)

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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6 Summons

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7 Summons

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8 Summons

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NOTICE of Appearance by Adina Bassin Appelbaum on behalf of All Plaintiffs (Appelbaum, Adina) (Entered: 05/05/2025)

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

NOTICE of Appearance by Ivano Michael Ventresca on behalf of All Plaintiffs (Ventresca, Ivano) (Entered: 05/06/2025)

NOTICE of Appearance by Keren Hart Zwick on behalf of All Plaintiffs (Zwick, Keren) (Entered: 05/06/2025)

SUMMONS (7) Issued Electronically as to PAMELA BONDI, DEPARTMENT OF HOMELAND SECURITY, EXECUTIVE OFFICE FOR IMMIGRATION REVIEW, KRISTI NOEM, SIRCE E. OWEN, US DEPARTMENT OF JUSTICE, U.S. Attorney and U.S. Attorney General (Attachment: # 1 Notice and Consent)(zjm) (Entered: 05/06/2025)

Case Assigned/Reassigned

Case Assigned to Judge Amir H. Ali. (zjm)

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Frederick Evan Benz, Filing fee $ 100, receipt number ADCDC-11674424. Fee Status: Fee Paid. by AMERICAN GATEWAYS, AMICA CENTER FOR IMMIGRANT RIGHTS, DIOCESAN MIGRANT & REFUGEE SERVICES, GALVESTON-HOUSTON IMMIGRANT REPRESENTATION PROJECT, IMMIGRANT LAW CENTER OF MINNESOTA, IMMIGRATION SERVICES AND LEGAL ADVOCACY, NATIONAL IMMIGRANT JUSTICE CENTER, PENNSYLVANIA IMMIGRATION RESOURCE CENTER, ROCKY MOUNTAIN IMMIGRANT ADVOCACY NETWORK. (Attachments: # 1 Declaration Declaration for Pro Hac Vice Admission, # 2 Exhibit Certificate of Good Standing, # 3 Text of Proposed Order Proposed Order)(Appelbaum, Adina) (Entered: 05/07/2025)

MOTION for Preliminary Injunction or Stay by AMERICAN GATEWAYS, AMICA CENTER FOR IMMIGRANT RIGHTS, DIOCESAN MIGRANT & REFUGEE SERVICES, GALVESTON-HOUSTON IMMIGRANT REPRESENTATION PROJECT, IMMIGRANT LAW CENTER OF MINNESOTA, IMMIGRATION SERVICES AND LEGAL ADVOCACY, NATIONAL IMMIGRANT JUSTICE CENTER, PENNSYLVANIA IMMIGRATION RESOURCE CENTER, ROCKY MOUNTAIN IMMIGRANT ADVOCACY NETWORK. (Attachments: # 1 Memorandum in Support of Motion for Preliminary Injunction or Stay, # 2 Declaration of Ivano M. Ventresca and Exhibits, # 3 Declaration of David Faherty (NIJC) in Support, # 4 Declaration of Edith Hinson (Amica Center) in Support, # 5 Declaration of Edna Yang (American Gateways) in Support, # 6 Declaration of Elizabeth Sanchez Kennedy (GHIRP) in Support, # 7 Declaration of Homero Lopez Jr. (ISLA) in Support, # 8 Declaration of Laura Lunn (RMIAN) in Support, # 9 Declaration of Melissa Mari Lopez (Estrella del Paso) in Support, # 10 Declaration of Robyn Meyer Thompson (ILCM) in Support, # 11 Declaration of Ryan Brunsink (PIRC) in Support, # 12 Declaration of Robert Dinerstein in Support, # 13 Text of Proposed Order (Proposed) Order for Preliminary Injunction or Stay, # 14 Certificate of Service)(Ventresca, Ivano) (Entered: 05/07/2025)

1 Memorandum in Support of Motion for Preliminary Injunction or Stay

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2 Declaration of Ivano M. Ventresca and Exhibits

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3 Declaration of David Faherty (NIJC) in Support

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4 Declaration of Edith Hinson (Amica Center) in Support

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5 Declaration of Edna Yang (American Gateways) in Support

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6 Declaration of Elizabeth Sanchez Kennedy (GHIRP) in Support

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7 Declaration of Homero Lopez Jr. (ISLA) in Support

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8 Declaration of Laura Lunn (RMIAN) in Support

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9 Declaration of Melissa Mari Lopez (Estrella del Paso) in Support

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10 Declaration of Robyn Meyer Thompson (ILCM) in Support

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11 Declaration of Ryan Brunsink (PIRC) in Support

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12 Declaration of Robert Dinerstein in Support

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13 Text of Proposed Order (Proposed) Order for Preliminary Injunction or Stay

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14 Certificate of Service

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.Order AND ~Util - Set/Reset Hearings

MINUTE ORDER. The Court will hold a telephonic scheduling conference on May 9, 2025, at 2:00 p.m. to set a briefing schedule for Plaintiffs' 8 motion for a preliminary injunction. Defendants should be prepared to address whether they are willing to preserve the status quo, in full or in material part, as it existed prior to April 25, 2025, until the preliminary injunction motion is briefed and resolved. The parties should be prepared to propose briefing schedules depending on Defendants' answer to the preceding question. Plaintiffs are directed to promptly serve a copy of this order on Defendants. Signed by Judge Amir H. Ali on 5/8/2025. (lcaha3)

NOTICE of Appearance by Andrew I. Warden on behalf of All Defendants (Warden, Andrew) (Entered: 05/09/2025)

Scheduling Conference

.Order AND ~Util - Set/Reset Deadlines

Minute Entry for telephonic proceedings held before Judge Amir H. Ali: Scheduling Conference held on 5/9/2025. Scheduling Order to be entered by the court. (Court Reporter: Timothy Miller) (zkh) Modified on 5/13/2025. (zalh)

MINUTE ORDER. The Court adopts the parties' proposed briefing schedule for Plaintiffs' 8 motion for a preliminary injunction. Defendants shall file their opposition by May 16, 2025. Plaintiffs shall file their reply by May 21, 2025. The Court will hold a hearing thereafter at a date to be determined. Signed by Judge Amir H. Ali on 5/9/2025. (lcaha3)

MINUTE ORDER. The Court adopts the parties' proposed briefing schedule for Plaintiffs' 8 motion for preliminary injunction or stay. Defendants shall file their opposition by May 16, 2025. Plaintiffs shall file their reply by May 21, 2025. The Court will hold a hearing thereafter at a date to be determined. Signed by Judge Amir H. Ali on 5/9/2025. (lcaha3) Modified on 5/29/2025. (zalh)

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Mary Georgevich, Filing fee $ 100, receipt number ADCDC-11685536. Fee Status: Fee Paid. by AMERICAN GATEWAYS, AMICA CENTER FOR IMMIGRANT RIGHTS, DIOCESAN MIGRANT & REFUGEE SERVICES, GALVESTON-HOUSTON IMMIGRANT REPRESENTATION PROJECT, IMMIGRANT LAW CENTER OF MINNESOTA, IMMIGRATION SERVICES AND LEGAL ADVOCACY, NATIONAL IMMIGRANT JUSTICE CENTER, PENNSYLVANIA IMMIGRATION RESOURCE CENTER, ROCKY MOUNTAIN IMMIGRANT ADVOCACY NETWORK. (Attachments: # 1 Declaration Ex. A - Declaration of Mary Georgevich, # 2 Exhibit Ex. B - Certificate of Good Standing, # 3 Text of Proposed Order Ex. C - Proposed Order)(Zwick, Keren) (Entered: 05/13/2025)

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Mark Feldman, Filing fee $ 100, receipt number ADCDC-11685666. Fee Status: Fee Paid. by AMERICAN GATEWAYS, AMICA CENTER FOR IMMIGRANT RIGHTS, DIOCESAN MIGRANT & REFUGEE SERVICES, GALVESTON-HOUSTON IMMIGRANT REPRESENTATION PROJECT, IMMIGRANT LAW CENTER OF MINNESOTA, IMMIGRATION SERVICES AND LEGAL ADVOCACY, NATIONAL IMMIGRANT JUSTICE CENTER, PENNSYLVANIA IMMIGRATION RESOURCE CENTER, ROCKY MOUNTAIN IMMIGRANT ADVOCACY NETWORK. (Attachments: # 1 Declaration Ex. A - Declaration of Mark Feldman, # 2 Exhibit Ex. B - Certificate of Good Standing, # 3 Text of Proposed Order Ex. C - Proposed Order)(Zwick, Keren) (Entered: 05/13/2025)

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Charles Roth, Filing fee $ 100, receipt number ADCDC-11695898. Fee Status: Fee Paid. by AMERICAN GATEWAYS, AMICA CENTER FOR IMMIGRANT RIGHTS, DIOCESAN MIGRANT & REFUGEE SERVICES, GALVESTON-HOUSTON IMMIGRANT REPRESENTATION PROJECT, IMMIGRANT LAW CENTER OF MINNESOTA, IMMIGRATION SERVICES AND LEGAL ADVOCACY, NATIONAL IMMIGRANT JUSTICE CENTER, PENNSYLVANIA IMMIGRATION RESOURCE CENTER, ROCKY MOUNTAIN IMMIGRANT ADVOCACY NETWORK. (Attachments: # 1 Declaration Ex. A - Declaration of Charles Roth, # 2 Exhibit Ex. B - Certificate of Good Standing, # 3 Text of Proposed Order Ex. C - Proposed Order)(Zwick, Keren) (Entered: 05/16/2025)

Memorandum in opposition to re 8 MOTION for Preliminary Injunction or Stay MOTION to Stay filed by PAMELA J. BONDI, DEPARTMENT OF HOMELAND SECURITY, EXECUTIVE OFFICE FOR IMMIGRATION REVIEW, KRISTI NOEM, SIRCE E. OWEN, US DEPARTMENT OF JUSTICE. (Attachments: # 1 Exhibit Owen Declaration, # 2 Exhibit Acacia Contract, # 3 Exhibit NQRP Task Order, # 4 Exhibit FY24 Statement of Work, # 5 Exhibit Termination Order, # 6 Text of Proposed Order)(Warden, Andrew) (Entered: 05/16/2025)

1 Exhibit Owen Declaration

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2 Exhibit Acacia Contract

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3 Exhibit NQRP Task Order

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4 Exhibit FY24 Statement of Work

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5 Exhibit Termination Order

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6 Text of Proposed Order

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MOTION to Dismiss by PAMELA J. BONDI, DEPARTMENT OF HOMELAND SECURITY, EXECUTIVE OFFICE FOR IMMIGRATION REVIEW, KRISTI NOEM, SIRCE E. OWEN, US DEPARTMENT OF JUSTICE. (Attachments: # 1 Exhibit Owen Declaration, # 2 Exhibit Acacia Contract, # 3 Exhibit NQRP Task Order, # 4 Exhibit FY24 Statement of Work, # 5 Exhibit Termination Order, # 6 Exhibit)(Warden, Andrew) (Entered: 05/16/2025)

1 Exhibit Owen Declaration

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2 Exhibit Acacia Contract

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3 Exhibit NQRP Task Order

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4 Exhibit FY24 Statement of Work

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5 Exhibit Termination Order

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6 Exhibit

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Order on Motion for Leave to Appear Pro Hac Vice

MINUTE ORDER granting 10 motion for leave to appear pro hac vice. Attorney Mary Georgevich 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 Amir H. Ali on 5/16/2025. (lcaha3)

MINUTE ORDER granting 11 motion for leave to appear pro hac vice. Attorney Mark Feldman 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 Amir H. Ali on 5/16/2025. (lcaha3)

MINUTE ORDER granting 12 motion for leave to appear pro hac vice. Attorney Charles Roth 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 Amir H. Ali on 5/16/2025. (lcaha3)

PROPOSED BRIEFING SCHEDULE by PAMELA J. BONDI, DEPARTMENT OF HOMELAND SECURITY, EXECUTIVE OFFICE FOR IMMIGRATION REVIEW, KRISTI NOEM, SIRCE E. OWEN, US DEPARTMENT OF JUSTICE. (Welch, Sarah) (Entered: 05/19/2025)

.Order AND ~Util - Set/Reset Deadlines

MINUTE ORDER. The Court is in receipt of Defendants' combined 13 memorandum in opposition to Plaintiffs' motion for a preliminary injunction and 14 motion to dismiss. The Court anticipates holding a joint hearing on both motions. By 6:00 p.m. today, the parties shall propose a revised briefing schedule that accounts for Defendants' motion to dismiss. Signed by Judge Amir H. Ali on 5/19/2025. (lcaha3)

NOTICE of Appearance by Mary Georgevich on behalf of All Plaintiffs (Georgevich, Mary) (Entered: 05/20/2025)

NOTICE of Appearance by Mark Feldman on behalf of All Plaintiffs (Feldman, Mark) (Entered: 05/20/2025)

NOTICE of Appearance by John R. Jacob on behalf of FORMER IMMIGRATION JUDGES & FORMER MEMBERS OF THE BOARD OF IMMIGRATION APPEALS (Jacob, John) (Entered: 05/20/2025)

Unopposed MOTION for Leave to File Amicus Brief by FORMER IMMIGRATION JUDGES & FORMER MEMBERS OF THE BOARD OF IMMIGRATION APPEALS. (Attachments: # 1 Amicus Curiae Brief, # 2 Text of Proposed Order)(Jacob, John) (Entered: 05/20/2025)

Scheduling Order

MINUTE ORDER. The Court adopts the parties' 15 proposed revised briefing schedule. Plaintiffs shall file their combined reply in support of their motion for a preliminary injunction and brief in opposition to Defendants' motion to dismiss by May 23, 2025. Defendants shall file their reply in support of their motion to dismiss by May 30, 2025. Signed by Judge Amir H. Ali on 5/20/2025. (lcaha3)

NOTICE of Appearance by Charles G. Roth on behalf of All Plaintiffs (Roth, Charles) (Entered: 05/22/2025)

STANDING ORDER. The parties are ordered to comply with the directives set forth in the attached standing order. See document for details. Signed by Judge Amir H. Ali on 5/23/2025. (lcaha3) (Entered: 05/23/2025)

RESPONSE re 14 MOTION to Dismiss and Reply In Support of Motion for Preliminary Injunction or Stay filed by AMERICAN GATEWAYS, AMICA CENTER FOR IMMIGRANT RIGHTS, DIOCESAN MIGRANT & REFUGEE SERVICES, GALVESTON-HOUSTON IMMIGRANT REPRESENTATION PROJECT, IMMIGRANT LAW CENTER OF MINNESOTA, IMMIGRATION SERVICES AND LEGAL ADVOCACY, NATIONAL IMMIGRANT JUSTICE CENTER, PENNSYLVANIA IMMIGRATION RESOURCE CENTER, ROCKY MOUNTAIN IMMIGRANT ADVOCACY NETWORK. (Attachments: # 1 Declaration Supplemental Declaration of Laura Lunn (RMIAN) in support, # 2 Declaration Supplemental Declaration of David Faherty (NIJC) in support, # 3 Declaration Supplemental Declaration of Edna Yang (American Gateways) in support, # 4 Declaration Supplemental Declaration of Elizabeth Sanchez Kennedy (GHIRP) in support, # 5 Declaration Supplemental Declaration of Homero Lopez Jr (ISLA) in support, # 6 Declaration Supplemental Declaration of Katherine Conway (Amica Center) in support, # 7 Declaration Supplemental Declaration of Melissa Mari Lopez (Estrella del Paso) in support, # 8 Declaration Supplemental Declaration of Robyn Meyer-Thompson (ILCM) in support, # 9 Declaration Supplemental Declaration of Ryan Brunsink (PIRC) in support, # 10 Text of Proposed Order)(Ventresca, Ivano) Modified docket text on 5/27/2025 (zdp). (Entered: 05/23/2025)

1 Declaration Supplemental Declaration of Laura Lunn (RMIAN) in support

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2 Declaration Supplemental Declaration of David Faherty (NIJC) in support

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3 Declaration Supplemental Declaration of Edna Yang (American Gateways) in support

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4 Declaration Supplemental Declaration of Elizabeth Sanchez Kennedy (GHIRP) in sup

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5 Declaration Supplemental Declaration of Homero Lopez Jr (ISLA) in support

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6 Declaration Supplemental Declaration of Katherine Conway (Amica Center) in suppo

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7 Declaration Supplemental Declaration of Melissa Mari Lopez (Estrella del Paso) i

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8 Declaration Supplemental Declaration of Robyn Meyer-Thompson (ILCM) in support

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9 Declaration Supplemental Declaration of Ryan Brunsink (PIRC) in support

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10 Text of Proposed Order

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REPLY to opposition to motion re 8 Motion for Preliminary Injunction,,,,,, Motion to Stay,,,,, and Opposition to Defendants' Motion to Dismiss filed by AMERICAN GATEWAYS, AMICA CENTER FOR IMMIGRANT RIGHTS, DIOCESAN MIGRANT & REFUGEE SERVICES, GALVESTON-HOUSTON IMMIGRANT REPRESENTATION PROJECT, IMMIGRANT LAW CENTER OF MINNESOTA, IMMIGRATION SERVICES AND LEGAL ADVOCACY, NATIONAL IMMIGRANT JUSTICE CENTER, PENNSYLVANIA IMMIGRATION RESOURCE CENTER, ROCKY MOUNTAIN IMMIGRANT ADVOCACY NETWORK. (Attachments: # 1 Declaration Supplemental Declaration of Laura Lunn (RMIAN) in support, # 2 Declaration Supplemental Declaration of David Faherty (NIJC) in support, # 3 Declaration Supplemental Declaration of Edna Yang (American Gateways) in support, # 4 Declaration Supplemental Declaration of Elizabeth Sanchez Kennedy (GHIRP) in support, # 5 Declaration of Homero Lopez Jr (ISLA) in Support, # 6 Declaration Supplemental Declaration of Katherine Conway (Amica Center) in support, # 7 Declaration Supplemental Declaration of Melissa Mari Lopez (Estrella del Paso) in support, # 8 Declaration Supplemental Declaration of Robyn Meyer-Thompson (ILCM) in support, # 9 Declaration Supplemental Declaration of Ryan Brunsink (PIRC) in support, # 10 Text of Proposed Order)(Ventresca, Ivano) Modified docket text on 5/27/2025 (zdp). (Entered: 05/23/2025)

1 Declaration Supplemental Declaration of Laura Lunn (RMIAN) in support

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2 Declaration Supplemental Declaration of David Faherty (NIJC) in support

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3 Declaration Supplemental Declaration of Edna Yang (American Gateways) in support

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4 Declaration Supplemental Declaration of Elizabeth Sanchez Kennedy (GHIRP) in sup

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5 Declaration of Homero Lopez Jr (ISLA) in Support

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6 Declaration Supplemental Declaration of Katherine Conway (Amica Center) in suppo

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7 Declaration Supplemental Declaration of Melissa Mari Lopez (Estrella del Paso) i

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8 Declaration Supplemental Declaration of Robyn Meyer-Thompson (ILCM) in support

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9 Declaration Supplemental Declaration of Ryan Brunsink (PIRC) in support

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10 Text of Proposed Order

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.Order AND ~Util - Set/Reset Hearings

MINUTE ORDER. The Court will hold a motion hearing on Plaintiffs' 8 motion for a preliminary injunction and Defendants' 14 motion to dismiss on June 2, 2025, at 2:00 p.m. in Courtroom 19. A public access line will be provided for the hearing: the toll-free number is 833-990-9400, and the meeting ID is 771021014. Persons remotely accessing court proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. See In re: Prohibition on Photographing, Recording, Broadcasting, and Livestreaming Judicial Proceedings, Standing Order 24-31 (JEB) (Sept. 18, 2024). Signed by Judge Amir H. Ali on 5/28/2025. (lcaha3)

MINUTE ORDER. The Court will hold a motion hearing on Plaintiffs' 8 motion for preliminary injunction or stay and Defendants' 14 motion to dismiss on June 2, 2025, at 2:00 p.m. in Courtroom 19. A public access line will be provided for the hearing: the toll-free number is 833-990-9400, and the meeting ID is 771021014. Persons remotely accessing court proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. See In re: Prohibition on Photographing, Recording, Broadcasting, and Livestreaming Judicial Proceedings, Standing Order 24-31 (JEB) (Sept. 18, 2024). Signed by Judge Amir H. Ali on 5/28/2025. (lcaha3) Modified on 5/29/2025. (zalh)

REPLY to opposition to motion re 14 Motion to Dismiss, filed by PAMELA J. BONDI, DEPARTMENT OF HOMELAND SECURITY, EXECUTIVE OFFICE FOR IMMIGRATION REVIEW, KRISTI NOEM, SIRCE E. OWEN, US DEPARTMENT OF JUSTICE. (Welch, Sarah) (Entered: 05/30/2025)

Minute Entry for proceedings held before Judge Amir H. Ali: Motion Hearing held on 6/2/2025 re [14 Motion to Dismiss and 8 Motion for Preliminary Injunction. The Court Heard Oral Arguments From The Parties And Will Take The Oral Arguments Under Advisement. (Court Reporter SONJA REEVES.) (mac)

Minute Entry for proceedings held before Judge Amir H. Ali: Motion Hearing held on 6/2/2025 re 14 Motion to Dismiss and 8 Motion for Preliminary Injunction or Stay. The Court Heard Oral Arguments From The Parties And Will Take The Oral Arguments Under Advisement. (Court Reporter: SONJA REEVES) (mac) Modified on 6/9/2025. (zalh)

TRANSCRIPT OF MOTION HEARING before Judge Amir H. Ali held on June 2, 2025; Page Numbers: 1-84. Date of Issuance: June 3, 2025. Court Reporter/Transcriber Sonja L. Reeves, RDR, CRR, Telephone number (202) 354-3246, Transcripts may be ordered by submitting the Transcript Order FormFor the first 90 days after this filing date, the transcript may be viewed at the courthouse at a public terminal or purchased from the court reporter referenced above. After 90 days, the transcript may be accessed via PACER. Other transcript formats, (multi-page, condensed, CD or ASCII) may be purchased from the court reporter.NOTICE RE REDACTION OF TRANSCRIPTS: The parties have twenty-one days to file with the court and the court reporter any request to redact personal identifiers from this transcript. If no such requests are filed, the transcript will be made available to the public via PACER without redaction after 90 days. The policy, which includes the five personal identifiers specifically covered, is located on our website at www.dcd.uscourts.gov. Redaction Request due 6/24/2025. Redacted Transcript Deadline set for 7/4/2025. Release of Transcript Restriction set for 9/1/2025.(Reeves, Sonja) (Entered: 06/03/2025)

Status Report Order

MINUTE ORDER. At yesterday's motion hearing, counsel for Defendants represented that she has become aware that "EOIR either has or is in the process of departing from" policy documents at issue in the parties' briefing. Counsel committed to filing a status report providing the Court with more information about this update by Wednesday, June 4, 2025. The status report shall address whether any policies referenced by the parties are being modified. If so, the report shall describe the modification in detail and identify when the modification occurred or is expected to occur. Signed by Judge Amir H. Ali on 6/3/2025. (lcaha3)

STATUS REPORT by PAMELA J. BONDI, DEPARTMENT OF HOMELAND SECURITY, EXECUTIVE OFFICE FOR IMMIGRATION REVIEW, KRISTI NOEM, SIRCE E. OWEN, US DEPARTMENT OF JUSTICE. (Attachments: # 1 Declaration Owen Declaration, # 2 Exhibit 2021 Policy Manual 1.1, # 3 Exhibit 2021 Policy Manual 1.7, # 4 Exhibit 2025 Memorandum, # 5 Exhibit 2025 Policy Manual 1.1, # 6 Exhibit 2025 Policy Manual 1.6)(Welch, Sarah) (Entered: 06/04/2025)

1 Declaration Owen Declaration

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2 Exhibit 2021 Policy Manual 1.1

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3 Exhibit 2021 Policy Manual 1.7

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4 Exhibit 2025 Memorandum

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5 Exhibit 2025 Policy Manual 1.1

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6 Exhibit 2025 Policy Manual 1.6

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Amended STATUS REPORT by PAMELA J. BONDI, DEPARTMENT OF HOMELAND SECURITY, EXECUTIVE OFFICE FOR IMMIGRATION REVIEW, KRISTI NOEM, SIRCE E. OWEN, US DEPARTMENT OF JUSTICE. (Attachments: # 1 Declaration Owen Declaration, # 2 Exhibit 2021 Policy Manual 1.1, # 3 Exhibit 2021 Policy Manual 1.7, # 4 Exhibit 2025 Memorandum, # 5 Exhibit 2025 Policy Manual 1.1, # 6 Exhibit EOIR Email, # 7 Exhibit 2025 Policy Manual 1.6)(Welch, Sarah) (Entered: 06/04/2025)

1 Declaration Owen Declaration

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2 Exhibit 2021 Policy Manual 1.1

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3 Exhibit 2021 Policy Manual 1.7

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4 Exhibit 2025 Memorandum

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5 Exhibit 2025 Policy Manual 1.1

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6 Exhibit EOIR Email

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7 Exhibit 2025 Policy Manual 1.6

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MOTION for Leave to File Declarations by AMERICAN GATEWAYS, AMICA CENTER FOR IMMIGRANT RIGHTS, DIOCESAN MIGRANT & REFUGEE SERVICES, GALVESTON-HOUSTON IMMIGRANT REPRESENTATION PROJECT, IMMIGRANT LAW CENTER OF MINNESOTA, IMMIGRATION SERVICES AND LEGAL ADVOCACY, NATIONAL IMMIGRANT JUSTICE CENTER, PENNSYLVANIA IMMIGRATION RESOURCE CENTER, ROCKY MOUNTAIN IMMIGRANT ADVOCACY NETWORK. (Attachments: # 1 Exhibit Declaration of Eddie Lopez Lugo, # 2 Exhibit Declaration of Sophie Woodruff, # 3 Text of Proposed Order)(Ventresca, Ivano) (Entered: 06/05/2025)

1 Exhibit Declaration of Eddie Lopez Lugo

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2 Exhibit Declaration of Sophie Woodruff

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3 Text of Proposed Order

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RESPONSE re 26 Status Report, 27 Status Report, filed by AMERICAN GATEWAYS, AMICA CENTER FOR IMMIGRANT RIGHTS, DIOCESAN MIGRANT & REFUGEE SERVICES, GALVESTON-HOUSTON IMMIGRANT REPRESENTATION PROJECT, IMMIGRANT LAW CENTER OF MINNESOTA, IMMIGRATION SERVICES AND LEGAL ADVOCACY, NATIONAL IMMIGRANT JUSTICE CENTER, PENNSYLVANIA IMMIGRATION RESOURCE CENTER, ROCKY MOUNTAIN IMMIGRANT ADVOCACY NETWORK. (Ventresca, Ivano) (Entered: 06/05/2025)

CERTIFICATE OF SERVICE by AMERICAN GATEWAYS, AMICA CENTER FOR IMMIGRANT RIGHTS, DIOCESAN MIGRANT & REFUGEE SERVICES, GALVESTON-HOUSTON IMMIGRANT REPRESENTATION PROJECT, IMMIGRANT LAW CENTER OF MINNESOTA, IMMIGRATION SERVICES AND LEGAL ADVOCACY, NATIONAL IMMIGRANT JUSTICE CENTER, PENNSYLVANIA IMMIGRATION RESOURCE CENTER, ROCKY MOUNTAIN IMMIGRANT ADVOCACY NETWORK re 6 Summons Issued Electronically as to AUSA, 1 Complaint,, . (Attachments: # 1 Exhibit Certified Mail Receipts, # 2 Exhibit Email Service)(Ventresca, Ivano) (Entered: 06/13/2025)

1 Exhibit Certified Mail Receipts

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2 Exhibit Email Service

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RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. PAMELA J. BONDI served on 5/19/2025; DEPARTMENT OF HOMELAND SECURITY served on 5/8/2025; EXECUTIVE OFFICE FOR IMMIGRATION REVIEW served on 5/8/2025; KRISTI NOEM served on 5/8/2025; SIRCE E. OWEN served on 5/8/2025; U.S. DEPARTMENT OF JUSTICE served on 5/9/2025, RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed on United States Attorney General. Date of Service Upon United States Attorney General 5/19/2025., RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed as to the United States Attorney. Date of Service Upon United States Attorney on 5/6/2025. ( Answer due for ALL FEDERAL DEFENDANTS by 7/5/2025.) (See docket entry 30 to view document) (mg) (Entered: 06/18/2025)

Summons Returned Executed as to Federal Defendant AND Summons Returned Executed as to U.S. Attorney General AND Summons Returned Executed as to US Attorney

Order on Motion for Leave to Appear Pro Hac Vice

MINUTE ORDER. The Court is in receipt of the 7 motion for leave of attorney Frederick Evan Benz to appear pro hac vice. Under the comment to Local Civil Rule 83.2(c)(2), "as a general matter, attorneys who engage in the practice of law from an office located in the District of Columbia and who file papers in this Court should be a member of the Bar of this Court and the District of Columbia Bar." Frederick Evan Benz represents that he practices from an office located in the District of Columbia but has not been admitted to either Bar. Accordingly, the 7 motion is denied without prejudice. The Court will grant admission pro hac vice only after Mr. Benz submits applications for admission to the Bar of this Court and the District of Columbia Bar. Signed by Judge Amir H. Ali on 6/30/2025. (lcaha3)

MEMORANDUM OPINION AND ORDER. Plaintiffs' 8 motion for a preliminary injunction is granted. Defendants' 14 motion to dismiss is denied as to count one of the complaint and held in abeyance as to counts two and three. See document for details. Defendants shall file a status report by July 28, 2025, that apprises the Court of Defendants' compliance with this order. Signed by Judge Amir H. Ali on 7/21/2025. (lcaha3) (Entered: 07/21/2025)

AMICUS BRIEF by FORMER IMMIGRATION JUDGES, FORMER MEMBERS OF THE BOARD OF IMMIGRATION APPEALS. (mg) (Entered: 08/04/2025)

DECLARATION by AMERICAN GATEWAYS, AMICA CENTER FOR IMMIGRANT RIGHTS, DIOCESAN MIGRANT & REFUGEE SERVICES, GALVESTON-HOUSTON IMMIGRANT REPRESENTATION PROJECT, IMMIGRANT LAW CENTER OF MINNESOTA, IMMIGRATION SERVICES AND LEGAL ADVOCACY, NATIONAL IMMIGRANT JUSTICE CENTER, PENNSYLVANIA IMMIGRATION RESOURCE CENTER, ROCKY MOUNTAIN IMMIGRANT ADVOCACY NETWORK re 8 MOTION for Preliminary Injunction or Stay MOTION to Stay. (Attachments: # 1 Exhibit Declaration of Sophie Woodruff)(mg) (Entered: 08/04/2025)

MINUTE ORDER. The 19 unopposed motion by former immigration judges and former members of the Board of Immigration Appeals for leave to file an amicus curiae brief is granted. Signed by Judge Amir H. Ali on 7/21/2025. (lcaha3)

Order on Motion for Leave to File

Order on Motion for Leave to File Amicus Brief

MINUTE ORDER. The 19 unopposed motion for leave to file an amicus curiae brief by former immigration judges and former members of the Board of Immigration Appeals is granted. Signed by Judge Amir H. Ali on 7/21/2025. (lcaha3) Modified on 7/28/2025. (zalh)

MINUTE ORDER. Plaintiffs' 28 motion for leave to file declarations is granted. Signed by Judge Amir H. Ali on 7/21/2025. (lcaha3)

STATUS REPORT by PAMELA J. BONDI, DEPARTMENT OF HOMELAND SECURITY, EXECUTIVE OFFICE FOR IMMIGRATION REVIEW, KRISTI NOEM, SIRCE E. OWEN, U.S. DEPARTMENT OF JUSTICE. (Attachments: # 1 Declaration, # 2 Exhibit)(Welch, Sarah) (Entered: 07/28/2025)

1 Declaration

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2 Exhibit

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Unopposed MOTION for Extension of Time to File Answer re 1 Complaint,, by PAMELA J. BONDI, DEPARTMENT OF HOMELAND SECURITY, EXECUTIVE OFFICE FOR IMMIGRATION REVIEW, KRISTI NOEM, SIRCE E. OWEN, U.S. DEPARTMENT OF JUSTICE. (Attachments: # 1 Text of Proposed Order)(Welch, Sarah) (Entered: 07/31/2025)

Status Report Order

Order on Motion for Extension of Time to Answer AND Set/Reset Deadlines

MINUTE ORDER. The Court is in receipt of Defendants' 33 status report. Defendants shall file another status report by 5:00 p.m. on August 1, 2025. Signed by Judge Amir H. Ali on 7/31/2025. (lcaha2)

MINUTE ORDER. Defendants' 34 unopposed motion for an extension of time to answer count one of the complaint is granted. Defendants shall answer count one of the complaint by August 18, 2025. Signed by Judge Amir H. Ali on 7/31/2025. (lcaha2)

STATUS REPORT by PAMELA J. BONDI, DEPARTMENT OF HOMELAND SECURITY, EXECUTIVE OFFICE FOR IMMIGRATION REVIEW, KRISTI NOEM, SIRCE E. OWEN, U.S. DEPARTMENT OF JUSTICE. (Attachments: # 1 Declaration Owen Declaration (Aug. 1, 2025))(Warden, Andrew) (Entered: 08/01/2025)

1 Declaration Owen Declaration (Aug. 1, 2025)

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Extension of Time to File Answer AND Extension of Time to File Document

Order on Motion for Extension of Time to Answer AND Order on Motion for Extension of Time to File AND Set/Reset Deadlines