Case: State of Washington v. Trump

Legal Defense Fund

President Donald Trump

COMPLAINT against All Defendants (Receipt # AWAWDC-8969909) Attorney Kelly Thomas Wood added to party Commonwealth of Massachusetts(pty:pla), Attorney Kelly Thomas Wood added to party People of the State of Michigan(pty:pla), Attorney Kelly Thomas Wood added to party State of Arizona(pty:pla), Attorney Kelly Thomas Wood added to party State of California(pty:pla), Attorney Kelly Thomas Wood added to party State of Connecticut(pty:pla), Attorney Kelly Thomas Wood added to party State of Illinois(pty:pla), Attorney Kelly Thomas Wood added to party State of Maine(pty:pla), Attorney Kelly Thomas Wood added to party State of Maryland(pty:pla), Attorney Kelly Thomas Wood added to party State of Minnesota (pty:pla), Attorney Kelly Thomas Wood added to party State of New Jersey(pty:pla), Attorney Kelly Thomas Wood added to party State of Oregon(pty:pla), Attorney Kelly Thomas Wood added to party State of Rhode Island (pty:pla), Attorney Kelly Thomas Wood added to party State of Vermont(pty:pla), Attorney Kelly Thomas Wood added to party State of Washington(pty:pla), Attorney Kelly Thomas Wood added to party State of Wisconsin (pty:pla) filed by State of New Jersey, State of Maryland, State of California, State of Washington, State of Rhode Island, State of Maine, State of Arizona, People of the State of Michigan, State of Oregon, State of Vermont, State of Wisconsin, Commonwealth of Massachusetts, State of Connecticut, State of Minnesota, State of Illinois. (Attachments: # 1 Civil Cover Sheet, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E, # 7 Exhibit F, # 8 Exhibit G, # 9 Exhibit H, # 10 Exhibit I, # 11 Exhibit J, # 12 Exhibit K, # 13 Exhibit L, # 14 Exhibit M, # 15 Summons, # 16 Summons, # 17 Summons, # 18 Summons, # 19 Summons, # 20 Summons)(Wood, Kelly) (Entered: 05/09/2025)

1 Civil Cover Sheet

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2 Exhibit A

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3 Exhibit B

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4 Exhibit C

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5 Exhibit D

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6 Exhibit E

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7 Exhibit F

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8 Exhibit G

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9 Exhibit H

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10 Exhibit I

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11 Exhibit J

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12 Exhibit K

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13 Exhibit L

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14 Exhibit M

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15 Summons

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16 Summons

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17 Summons

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18 Summons

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19 Summons

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20 Summons

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NOTICE of Appearance by attorney Kelly Thomas Wood on behalf of Plaintiff State of Washington. (Wood, Kelly) (Entered: 05/09/2025)

NOTICE of Appearance by attorney Janell Marie Middleton on behalf of Plaintiff State of Washington. (Middleton, Janell) (Entered: 05/09/2025)

NOTICE of Appearance by attorney Dylan Stonecipher on behalf of Plaintiff State of Washington. (Stonecipher, Dylan) (Entered: 05/09/2025)

NOTICE of Appearance by attorney Caitlin Soden on behalf of Plaintiff State of Washington. (Soden, Caitlin) (Entered: 05/09/2025)

Summons(es) Electronically Issued as to defendant(s) Advisory Council on Historic Preservation, Daniel Driscoll, William H Graham, Jr, Donald Trump, United States Army Corps of Engineers, Travis Voyles. (Attachments: # 1 Summons, # 2 Summons, # 3 Summons, # 4 Summons, # 5 Summons) (RE) (Entered: 05/09/2025)

Add and Terminate Judges

Judge Jamal N Whitehead added. (RE)

APPLICATION OF ATTORNEY Nell Hryshko FOR LEAVE TO APPEAR PRO HAC VICE for Plaintiff State of New Jersey (Fee Paid) Receipt No. AWAWDC-8974221 (Wood, Kelly) (Entered: 05/12/2025)

APPLICATION OF ATTORNEY Laura B. Murphy FOR LEAVE TO APPEAR PRO HAC VICE for Plaintiff State of Vermont (Fee Paid) Receipt No. AWAWDC-8974397 (Wood, Kelly) (Entered: 05/12/2025)

APPLICATION OF ATTORNEY Keari A. Platt FOR LEAVE TO APPEAR PRO HAC VICE for Plaintiff State of California (Fee Paid) Receipt No. AWAWDC-8973828 (Wood, Kelly) (Entered: 05/12/2025)

APPLICATION OF ATTORNEY Catherine M. Wieman FOR LEAVE TO APPEAR PRO HAC VICE for Plaintiff State of California (Fee Paid) Receipt No. AWAWDC-8973944 (Wood, Kelly) (Entered: 05/12/2025)

APPLICATION OF ATTORNEY Tatiana K. Gaur FOR LEAVE TO APPEAR PRO HAC VICE for Plaintiff State of California (Fee Paid) Receipt No. AWAWDC-8974170 (Wood, Kelly) (Entered: 05/12/2025)

APPLICATION OF ATTORNEY Joseph Branco FOR LEAVE TO APPEAR PRO HAC VICE for Plaintiff State of Arizona (Fee Paid) Receipt No. AWAWDC-8976193 (Wood, Kelly) (Entered: 05/13/2025)

NOTICE of Appearance by attorney Kelly Thomas Wood on behalf of Plaintiffs Commonwealth of Massachusetts, People of the State of Michigan, State of Arizona, State of California, State of Connecticut, State of Illinois, State of Maine, State of Maryland, State of Minnesota, State of New Jersey, State of Oregon, State of Rhode Island, State of Vermont, State of Wisconsin. (Wood, Kelly) (Entered: 05/13/2025)

APPLICATION OF ATTORNEY Jason E. James FOR LEAVE TO APPEAR PRO HAC VICE for Plaintiff State of Illinois (Fee Paid) Receipt No. AWAWDC-8977010 (Wood, Kelly) (Entered: 05/14/2025)

APPLICATION OF ATTORNEY Alyssa Bixby-Lawson FOR LEAVE TO APPEAR PRO HAC VICE for Plaintiff State of Minnesota (Fee Paid) Receipt No. AWAWDC-8977371 (Wood, Kelly) (Entered: 05/14/2025)

ORDER re 9 Application for Leave to Appear Pro Hac Vice, 11 Application for Leave to Appear Pro Hac Vice, 7 Application for Leave to Appear Pro Hac Vice, 12 Application for Leave to Appear Pro Hac Vice, 10 Application for Leave to Appear Pro Hac Vice, 8 Application for Leave to Appear Pro Hac Vice. The Court ADMITS Attorneys Joseph James Branco for State of Arizona,Keari Amanda Platt, Catherine Mitchell Wieman, Tatiana Gaur for State of California, Nell Maria Miano Hryshko for State of New Jersey, Laura B. Murphy for State of Vermont, by Clerk Ravi Subramanian. No document associated with this docket entry, text only.NOTE TO COUNSEL: Local counsel agrees to sign all filings and to be prepared to handle the matter, including the trial thereof, in the event the applicant is unable to be present on any date scheduled by the court, pursuant to LCR 83.1(d).(HH) (Entered: 05/14/2025)

Order on Application for Leave to Appear Pro Hac Vice

NOTICE of Appearance by attorney Jeffrey Hughes on behalf of Defendants Advisory Council on Historic Preservation, Daniel Driscoll, William H Graham, Jr, Donald Trump, United States Army Corps of Engineers, Travis Voyles. (Hughes, Jeffrey) (Entered: 05/16/2025)

APPLICATION OF ATTORNEY Diane Lloyd FOR LEAVE TO APPEAR PRO HAC VICE for Plaintiff State of Oregon (Fee Paid) Receipt No. AWAWDC-8982957 (Wood, Kelly) (Entered: 05/16/2025)

ORDER re 14 Application for Leave to Appear Pro Hac Vice, 15 Application for Leave to Appear Pro Hac Vice. The Court ADMITS Attorney Jason Elliott James for State of Illinois,Alyssa Bixby-Lawson for State of Minnesota, by Clerk Ravi Subramanian. No document associated with this docket entry, text only.NOTE TO COUNSEL: Local counsel agrees to sign all filings and to be prepared to handle the matter, including the trial thereof, in the event the applicant is unable to be present on any date scheduled by the court, pursuant to LCR 83.1(d).(CDA) (Entered: 05/19/2025)

NOTICE of Appearance by attorney Jason Elliott James on behalf of Plaintiff State of Illinois. (James, Jason) (Entered: 05/19/2025)

Order on Application for Leave to Appear Pro Hac Vice

Notice to PHV and Local Counsel Unable to Process Application

Application for Leave to Appear Pro Hac Vice 18 by attorney Diane Lloyd will not be processed at this time. The Pro Hac attorney must submit a Pro Hac Vice access request via Manage My Account on PACER, under the Maintenance tab. See page 2 of the Pro Hac Vice Application Guide for detailed instructions. Please contact the Attorney Admissions Clerk at 206-370-8400 or WAWD_Admissions@wawd.uscourts.gov with additional questions. (Ad hoc Attorney Diane Lloyd) (CDA)

ORDER re 18 Application for Leave to Appear Pro Hac Vice. The Court ADMITS Attorney Diane Lloyd for Plaintiff State of Oregon, by Clerk Ravi Subramanian. No document associated with this docket entry, text only.NOTE TO COUNSEL: Local counsel agrees to sign all filings and to be prepared to handle the matter, including the trial thereof, in the event the applicant is unable to be present on any date scheduled by the court, pursuant to LCR 83.1(d).(CDA) (Entered: 05/21/2025)

Order on Application for Leave to Appear Pro Hac Vice

APPLICATION OF ATTORNEY Jack Dafoe FOR LEAVE TO APPEAR PRO HAC VICE for Plaintiff State of Maine (Fee Paid) Receipt No. AWAWDC-8994181 (Wood, Kelly) (Entered: 05/23/2025)

APPLICATION OF ATTORNEY Alison H. Carney FOR LEAVE TO APPEAR PRO HAC VICE for Plaintiff State of Rhode Island (Fee Paid) Receipt No. AWAWDC-8994197 (Wood, Kelly) (Entered: 05/23/2025)

APPLICATION OF ATTORNEY Nicholas M. Vaz FOR LEAVE TO APPEAR PRO HAC VICE for Plaintiff State of Rhode Island (Fee Paid) Receipt No. AWAWDC-8994213 (Wood, Kelly) (Entered: 05/23/2025)

APPLICATION OF ATTORNEY Jill Lacedonia FOR LEAVE TO APPEAR PRO HAC VICE for Plaintiff State of Connecticut (Fee Paid) Receipt No. AWAWDC-8994276 (Wood, Kelly) (Entered: 05/23/2025)

ORDER re 25 Application for Leave to Appear Pro Hac Vice. The Court ADMITS Attorney Jill Lacedonia for Plaintiff State of Connecticut, by Clerk Ravi Subramanian. No document associated with this docket entry, text only.NOTE TO COUNSEL: Local counsel agrees to sign all filings and to be prepared to handle the matter, including the trial thereof, in the event the applicant is unable to be present on any date scheduled by the court, pursuant to LCR 83.1(d).(KB) (Entered: 05/23/2025)

ORDER re 24 Application for Leave to Appear Pro Hac Vice. The Court ADMITS Attorney Nicholas M. Vaz for Plaintiff State of Rhode Island, by Clerk Ravi Subramanian. No document associated with this docket entry, text only.NOTE TO COUNSEL: Local counsel agrees to sign all filings and to be prepared to handle the matter, including the trial thereof, in the event the applicant is unable to be present on any date scheduled by the court, pursuant to LCR 83.1(d).(KB) (Entered: 05/23/2025)

ORDER re 22 Application for Leave to Appear Pro Hac Vice. The Court ADMITS Attorney Jack Dafoe for Plaintiff State of Maine, by Clerk Ravi Subramanian. No document associated with this docket entry, text only.NOTE TO COUNSEL: Local counsel agrees to sign all filings and to be prepared to handle the matter, including the trial thereof, in the event the applicant is unable to be present on any date scheduled by the court, pursuant to LCR 83.1(d).(KB) (Entered: 05/23/2025)

Order on Application for Leave to Appear Pro Hac Vice

Notice to PHV and Local Counsel Unable to Process Application

Application for Leave to Appear Pro Hac Vice 23, Application for Leave to Appear Pro Hac Vice 22 by attorneys Alison Carney and Jack Dafoe will not be processed at this time. The Pro Hac attorneys must each submit a Pro Hac Vice access request via Manage My Account on PACER, under the Maintenance tab. See page 2 of the Pro Hac Vice Application Guide for detailed instructions. Please contact the Attorney Admissions Clerk at 206-370-8400 or WAWD_Admissions@wawd.uscourts.gov with additional questions. (Ad hoc Attorney Alison Carney and Jack Dafoe) (KB)

ORDER re 23 Application for Leave to Appear Pro Hac Vice. The Court ADMITS Attorney Alison Hoffman Carney for Plaintiff State of Rhode Island, by Clerk Ravi Subramanian. No document associated with this docket entry, text only.NOTE TO COUNSEL: Local counsel agrees to sign all filings and to be prepared to handle the matter, including the trial thereof, in the event the applicant is unable to be present on any date scheduled by the court, pursuant to LCR 83.1(d).(KB) (Entered: 05/28/2025)

Order on Application for Leave to Appear Pro Hac Vice

APPLICATION OF ATTORNEY Gabe Johnson-Karp FOR LEAVE TO APPEAR PRO HAC VICE for Plaintiff State of Wisconsin (Fee Paid) Receipt No. AWAWDC-9010772 (Wood, Kelly) (Entered: 06/03/2025)

AFFIDAVIT of Service of Summons and Complaint on United States Attorney's Office on 5/12/2025, filed by Plaintiff State of Washington. (Wood, Kelly) (Entered: 06/03/2025)

AFFIDAVIT of Mailing of Summons and Complaint to Advisory Council on Historic Preservation; Daniel Driscoll, in his official capacity as Secretary of the Army; Lieutenant General William H. Graham, Jr., in his official capacity as Commanding General of the U.S. Army Corps of Engineers; Donald Trump, in his official capacity as President of the United States; United States Army Corps of Engineers; Travis Voyles, in his official capacity as Vice Chairman of the Advisory Council on Historic Preservation; Attorney General of the United States of America; and Civil Process Clerk, United States Attorney's Office, Western District of Washington on 5/12/2025, filed by Plaintiff State of Washington. (Wood, Kelly) (Entered: 06/03/2025)

ORDER re 30 Application for Leave to Appear Pro Hac Vice. The Court ADMITS Attorney Gabe Johnson-Karp for Plaintiff State of Wisconsin, by Clerk Ravi Subramanian. No document associated with this docket entry, text only.NOTE TO COUNSEL: Local counsel agrees to sign all filings and to be prepared to handle the matter, including the trial thereof, in the event the applicant is unable to be present on any date scheduled by the court, pursuant to LCR 83.1(d).(KB) (Entered: 06/04/2025)

Order on Application for Leave to Appear Pro Hac Vice

APPLICATION OF ATTORNEY Steven J. Goldstein FOR LEAVE TO APPEAR PRO HAC VICE for Plaintiff State of Maryland (Fee Paid) Receipt No. AWAWDC-9022717 (Wood, Kelly) (Entered: 06/11/2025)

APPLICATION OF ATTORNEY Benjamin C. Houston FOR LEAVE TO APPEAR PRO HAC VICE for Plaintiff People of the State of Michigan (Fee Paid) Receipt No. AWAWDC-9022719 (Wood, Kelly) (Entered: 06/11/2025)

APPLICATION OF ATTORNEY Zeus H. Smith FOR LEAVE TO APPEAR PRO HAC VICE for Plaintiff Commonwealth of Massachusetts (Fee Paid) Receipt No. AWAWDC-9022720 (Wood, Kelly) (Entered: 06/11/2025)

ORDER re 34 Application for Leave to Appear Pro Hac Vice. The Court ADMITS Attorney Steven J. Goldstein for State of Maryland, by Clerk Ravi Subramanian. No document associated with this docket entry, text only.NOTE TO COUNSEL: Local counsel agrees to sign all filings and to be prepared to handle the matter, including the trial thereof, in the event the applicant is unable to be present on any date scheduled by the court, pursuant to LCR 83.1(d).(CDA) (Entered: 06/11/2025)

ORDER re 35 Application for Leave to Appear Pro Hac Vice. The Court ADMITS Attorney Benjamin Charles Houston for People of the State of Michigan, by Clerk Ravi Subramanian. No document associated with this docket entry, text only.NOTE TO COUNSEL: Local counsel agrees to sign all filings and to be prepared to handle the matter, including the trial thereof, in the event the applicant is unable to be present on any date scheduled by the court, pursuant to LCR 83.1(d).(CDA) (Entered: 06/11/2025)

ORDER re 36 Application for Leave to Appear Pro Hac Vice. The Court ADMITS Attorney Zeus Smith for Commonwealth of Massachusetts, by Clerk Ravi Subramanian. No document associated with this docket entry, text only.NOTE TO COUNSEL: Local counsel agrees to sign all filings and to be prepared to handle the matter, including the trial thereof, in the event the applicant is unable to be present on any date scheduled by the court, pursuant to LCR 83.1(d).(CDA) (Entered: 06/11/2025)

Order on Application for Leave to Appear Pro Hac Vice

ORDER REGARDING INITIAL DISCLOSURES AND JOINT STATUS REPORT FRCP 26(f) Conference Deadline is 8/19/2025, Initial Disclosure Deadline is 9/2/2025, Joint Status Report due by 9/9/2025, signed by Judge Jamal N Whitehead. (GC) (Entered: 07/29/2025)

NOTICE of Appearance by attorney Sanya Shahrasbi on behalf of Defendants Advisory Council on Historic Preservation, Daniel Driscoll, William H Graham, Jr, Donald Trump, United States Army Corps of Engineers, Travis Voyles. (Shahrasbi, Sanya) (Entered: 08/01/2025)

Joint Status Report Order Form for District Judges

Notice of Appearance