Case: Mid-Atlantic Equity Consortium, Inc. v. U.S. Department of Education

President Donald Trump

President Donald Trump

COMPLAINT for Declaratory and Injunctive Relief against All Defendants ( Filing fee $ 405 receipt number CDCDC-11677830) filed by SOMERVILLE-FAYETTE NAACP, MID-ATLANTIC EQUITY CONSORTIUM, INC., NAACP TENNESSEE STATE CONFERENCE, NATIONAL ASSOCIATION FOR THE ADVANCEMENT OF COLORED PEOPLE. (Attachments: # 1 Civil Cover Sheet, # 2 Summons (U.S. Department of Education), # 3 Summons (Linda McMahon), # 4 Summons (U.S. Department of Justice), # 5 Summons (Pamela Bondi), # 6 Exhibit 1 - Appeal of Grant Award Termination Grant Award S004D220002 (Mar. 12, 2025))(McLaurin, Charles) Modified on 5/9/2025 to correct the docket text(zmtm). (Entered: 05/08/2025)

1 Civil Cover Sheet

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2 Summons (U.S. Department of Education)

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3 Summons (Linda McMahon)

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4 Summons (U.S. Department of Justice)

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5 Summons (Pamela Bondi)

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6 Exhibit 1 - Appeal of Grant Award Termination Grant Award S004D220002 (Mar. 12,

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NOTICE OF RELATED CASE by MID-ATLANTIC EQUITY CONSORTIUM, INC., NAACP TENNESSEE STATE CONFERENCE, NATIONAL ASSOCIATION FOR THE ADVANCEMENT OF COLORED PEOPLE, SOMERVILLE-FAYETTE NAACP. Case related to Case No. 1:25-cv-01079-PLF. (McLaurin, Charles) (Entered: 05/08/2025)

LCvR 26.1 CERTIFICATE OF DISCLOSURE of Corporate Affiliations and Financial Interests of MID-ATLANTIC EQUITY CONSORTIUM, INC. by MID-ATLANTIC EQUITY CONSORTIUM, INC., NAACP TENNESSEE STATE CONFERENCE, NATIONAL ASSOCIATION FOR THE ADVANCEMENT OF COLORED PEOPLE, SOMERVILLE-FAYETTE NAACP (McLaurin, Charles) (Entered: 05/08/2025)

LCvR 26.1 CERTIFICATE OF DISCLOSURE of Corporate Affiliations and Financial Interests of NATIONAL ASSOCIATION FOR THE ADVANCEMENT OF COLORED PEOPLE by MID-ATLANTIC EQUITY CONSORTIUM, INC., NAACP TENNESSEE STATE CONFERENCE, NATIONAL ASSOCIATION FOR THE ADVANCEMENT OF COLORED PEOPLE, SOMERVILLE-FAYETTE NAACP (McLaurin, Charles) (Entered: 05/08/2025)

LCvR 26.1 CERTIFICATE OF DISCLOSURE of Corporate Affiliations and Financial Interests of NAACP TENNESSEE STATE CONFERENCE by MID-ATLANTIC EQUITY CONSORTIUM, INC., NAACP TENNESSEE STATE CONFERENCE, NATIONAL ASSOCIATION FOR THE ADVANCEMENT OF COLORED PEOPLE, SOMERVILLE-FAYETTE NAACP (McLaurin, Charles) (Entered: 05/08/2025)

LCvR 26.1 CERTIFICATE OF DISCLOSURE of Corporate Affiliations and Financial Interests of SOMERVILLE-FAYETTE NAACP by MID-ATLANTIC EQUITY CONSORTIUM, INC., NAACP TENNESSEE STATE CONFERENCE, NATIONAL ASSOCIATION FOR THE ADVANCEMENT OF COLORED PEOPLE, SOMERVILLE-FAYETTE NAACP (McLaurin, Charles) (Entered: 05/08/2025)

Case Assigned/Reassigned

Case Assigned to Judge Paul L. Friedman. (zmtm)

SUMMONS (4) Issued Electronically as to LINDA MCMAHON, UNITED STATES DEPARTMENT OF EDUCATION, U.S. Attorney and U.S. Attorney General (Attachments: # 1 Notice and Consent)(zmtm) (Entered: 05/09/2025)

REQUEST FOR SUMMONS TO ISSUE to U.S. Attorney for D.C. filed by SOMERVILLE-FAYETTE NAACP, MID-ATLANTIC EQUITY CONSORTIUM, INC., NAACP TENNESSEE STATE CONFERENCE, NATIONAL ASSOCIATION FOR THE ADVANCEMENT OF COLORED PEOPLE. Related document: 1 Complaint,, filed by NAACP TENNESSEE STATE CONFERENCE, NATIONAL ASSOCIATION FOR THE ADVANCEMENT OF COLORED PEOPLE, MID-ATLANTIC EQUITY CONSORTIUM, INC., SOMERVILLE-FAYETTE NAACP.(McLaurin, Charles) (Entered: 05/16/2025)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed on United States Attorney General. Date of Service Upon United States Attorney General 5/14/2025. (McLaurin, Charles) (Entered: 05/19/2025)

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

SUMMONS (1) Reissued Electronically as to U.S. Attorney. (mg) (Entered: 05/21/2025)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. UNITED STATES DEPARTMENT OF EDUCATION served on 5/21/2025 (McLaurin, Charles) (Entered: 05/21/2025)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. LINDA MCMAHON served on 5/21/2025 (McLaurin, Charles) (Entered: 05/21/2025)

MOTION for Preliminary Injunction by MID-ATLANTIC EQUITY CONSORTIUM, INC., NAACP TENNESSEE STATE CONFERENCE, NATIONAL ASSOCIATION FOR THE ADVANCEMENT OF COLORED PEOPLE, SOMERVILLE-FAYETTE NAACP. (Attachments: # 1 Memorandum in Support, # 2 Index of Exhibits, # 3 Exhibit 1 - Shaffer Declaration (with Appendix), # 4 Exhibit 2 - Rouland Declaration, # 5 Exhibit 3 - Williams Declaration, # 6 Exhibit 4 - Training and Advisory Services Equity Assistance Centers Home, U.S. Dept of Educ., # 7 Exhibit 5 - MAEC-CEE, Mid Atlantic Equity Consortium Application - S004D22002, # 8 Exhibit 6 - Lewis Declaration, # 9 Exhibit 7 - Holmes Declaration, # 10 Exhibit 8 - Simelton Declaration (AL NAACP Declaration), # 11 Exhibit 9 - Hearings and Appeals _ U.S. Department of Education, # 12 Exhibit 10 - Administrative Appeals Process for Department Grants _ U.S. Department of Education, # 13 Exhibit 11 - Press Release, U.S. Dept of Educ. Release Secretary McMahons Supplemental Grant Priorities, U.S. Dept of Educ. (May 20, 2025), # 14 Text of Proposed Order)(McLaurin, Charles) (Entered: 05/22/2025)

.Order

Notice of Error

MINUTE ORDER: In light of Plaintiffs' motion for a preliminary injunction, Dkt. 14, it is hereby ORDERED that the parties shall appear for a scheduling conference on May 27, 2025, at 11:30 a.m. Judge Friedman is currently unavailable, and so the parties shall appear for the conference before Judge Moss in Courtroom 8. Signed by Judge Randolph D. Moss on 5/22/2025. (lcao)

NOTICE OF ERROR regarding 14 MOTION for Preliminary Injunction . The following error(s) need correction: Incorrect court case number listed on main document. Please refile using Errata. (zjm)

ERRATA Motion for Preliminary Injunction by MID-ATLANTIC EQUITY CONSORTIUM, INC., NAACP TENNESSEE STATE CONFERENCE, NATIONAL ASSOCIATION FOR THE ADVANCEMENT OF COLORED PEOPLE, SOMERVILLE-FAYETTE NAACP re 14 Motion for Preliminary Injunction,,,,. (Attachments: # 1 Memorandum in Support, # 2 Index of Exhibits, # 3 Exhibit 1 - Susan Shaffer Declaration (with Appendix), # 4 Exhibit 2 - Karmen Rouland Declaration, # 5 Exhibit 3 - Daryl Williams Declaration, # 6 Exhibit 4 - Training and Advisory Services Equity Assistance Centers Home, U.S. Dept of Educ., # 7 Exhibit 5 - Region_I_Project_Narrative-MAEC_S004D22002 - Mid Atlantic Equity Consortium Application, # 8 Exhibit 6 - Lewis Declaration, # 9 Exhibit 7 - Holmes Declaration, # 10 Exhibit 8 - Simelton Declaration (AL NAACP Declaration), # 11 Exhibit 9 - Hearings and Appeals _ U.S. Department of Education, # 12 Exhibit 10 - Administrative Appeals Process for Department Grants _ U.S. Department of Education, # 13 Exhibit 11 - U.S. Department of Education Releases Secretary McMahons Supplemental Grant Priorities _ U.S. Department of Education, # 14 Text of Proposed Order)(McLaurin, Charles) (Entered: 05/23/2025)

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Maia Cole, Filing fee $ 100, receipt number ADCDC-11712153. Fee Status: Fee Paid. by MID-ATLANTIC EQUITY CONSORTIUM, INC., NAACP TENNESSEE STATE CONFERENCE, NATIONAL ASSOCIATION FOR THE ADVANCEMENT OF COLORED PEOPLE, SOMERVILLE-FAYETTE NAACP. (Attachments: # 1 Declaration of Maia Cole, # 2 Certificate of Good Standing, # 3 Text of Proposed Order)(McLaurin, Charles) (Entered: 05/23/2025)

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Victor Genecin, Filing fee $ 100, receipt number ADCDC-11712300. Fee Status: Fee Paid. by MID-ATLANTIC EQUITY CONSORTIUM, INC., NAACP TENNESSEE STATE CONFERENCE, NATIONAL ASSOCIATION FOR THE ADVANCEMENT OF COLORED PEOPLE, SOMERVILLE-FAYETTE NAACP. (Attachments: # 1 Declaration of Victor Genecin, # 2 Certificate of Good Standing, # 3 Text of Proposed Order)(McLaurin, Charles) (Entered: 05/23/2025)

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Katrina Feldkamp, Filing fee $ 100, receipt number ADCDC-11712356. Fee Status: Fee Paid. by MID-ATLANTIC EQUITY CONSORTIUM, INC., NAACP TENNESSEE STATE CONFERENCE, NATIONAL ASSOCIATION FOR THE ADVANCEMENT OF COLORED PEOPLE, SOMERVILLE-FAYETTE NAACP. (Attachments: # 1 Declaration of Katrina Feldkamp, # 2 Certificate of Good Standing, # 3 Text of Proposed Order)(McLaurin, Charles) (Entered: 05/23/2025)

Summons Returned Executed as to DC Attorney General

Status Conference AND ~Util - Set/Reset Deadlines

Minute Entry for proceedings held before Judge Randolph D. Moss: Status Conference held on 5/27/2025. For the reasons stated on the record the Government is directed to file a Response to 14 Motion for Preliminary Injunction on or before 6/4/2025 and the plaintiff shall file a Reply on or before 6/13/2025). (Court Reporter Sherry Lindsay.) (zglw)

Notice of Error

Summons Returned Executed as to US Attorney

Notice of Appearance

Order on Motion for Leave to Appear Pro Hac Vice

Extension of Time to File Response/Reply

Notice of Appearance

Notice of Appearance

Notice of Appearance

Memorandum in opposition to motion

Order on Motion for Extension of Time to File Response/Reply

Notice of Appearance