Case: National Association of the Deaf v. Trump

COMPLAINT against EXECUTIVE OFFICE OF THE PRESIDENT, KAROLINE LEAVITT, OFFICE OF THE VICE PRESIDENT, THE WHITE HOUSE OFFICE, DONALD J. TRUMP, SUSAN WILES ( Filing fee $ 405 receipt number ADCDC-11719783) filed by MATTHEW BONN, DERRICK FORD, NATIONAL ASSOCIATION OF THE DEAF. (Attachments: # 1 Exhibit - A ASL Policy, # 2 Exhibit - B January 31, 2025 Letter, # 3 Exhibit - C April 12, 2025 Letter, # 4 Civil Cover Sheet, # 5 Summons - Pam Bondi, # 6 Summons - Civil Process Clerk, # 7 Summons - Executive Office of the President, # 8 Summons - Karoline Leavitt, # 9 Summons - Office of the Vice President, # 10 Summons - President Donald J. Trump, # 11 Summons - Susan Wiles, # 12 Summons - The White House Office)(Hoffman, Ian) (Entered: 05/28/2025)

1 Exhibit - A ASL Policy

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2 Exhibit - B January 31, 2025 Letter

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3 Exhibit - C April 12, 2025 Letter

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4 Civil Cover Sheet

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5 Summons - Pam Bondi

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6 Summons - Civil Process Clerk

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7 Summons - Executive Office of the President

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8 Summons - Karoline Leavitt

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9 Summons - Office of the Vice President

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10 Summons - President Donald J. Trump

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11 Summons - Susan Wiles

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12 Summons - The White House Office

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MOTION for Preliminary Injunction and Request for an Expedited Hearing by MATTHEW BONN, DERRICK FORD, NATIONAL ASSOCIATION OF THE DEAF. (Attachments: # 1 Text of Proposed Order, # 2 Declaration of Derrick Ford, # 3 Declaration of Matthew Bonn, # 4 Declaration of Dr. Judy Shepard-Kegl and Dr. Amy June Rowley, # 5 Declaration of Kelby N. Brick, # 6 Exhibit - A - January 31, 2025 Letter, # 7 Exhibit - B - ASL Policy, # 8 Exhibit - C - April 12, 2025 Letter)(Hoffman, Ian). Added MOTION to Expedite on 5/29/2025 (znmw). (Entered: 05/28/2025)

1 Text of Proposed Order

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2 Declaration of Derrick Ford

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3 Declaration of Matthew Bonn

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4 Declaration of Dr. Judy Shepard-Kegl and Dr. Amy June Rowley

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5 Declaration of Kelby N. Brick

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6 Exhibit - A - January 31, 2025 Letter

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7 Exhibit - B - ASL Policy

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8 Exhibit - C - April 12, 2025 Letter

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MOTION for Preliminary Injunction and Request for an Expedited Hearing by MATTHEW BONN, DERRICK FORD, NATIONAL ASSOCIATION OF THE DEAF. (Attachments: # 1 Text of Proposed Order, # 2 Declaration of Derrick Ford, # 3 Declaration of Matthew Bonn, # 4 Declaration of Dr. Judy Shepard-Kegl and Dr. Amy June Rowley, # 5 Declaration of Kelby N. Brick, # 6 Exhibit - A - January 31, 2025 Letter, # 7 Exhibit - B - ASL Policy, # 8 Exhibit - C - April 12, 2025 Letter)(Hoffman, Ian). Added MOTION to Expedite on 5/29/2025 (znmw). (Entered: 05/28/2025)

1 Text of Proposed Order

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2 Declaration of Derrick Ford

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3 Declaration of Matthew Bonn

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4 Declaration of Dr. Judy Shepard-Kegl and Dr. Amy June Rowley

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5 Declaration of Kelby N. Brick

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6 Exhibit - A - January 31, 2025 Letter

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7 Exhibit - B - ASL Policy

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8 Exhibit - C - April 12, 2025 Letter

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NOTICE OF RELATED CASE by MATTHEW BONN, DERRICK FORD, NATIONAL ASSOCIATION OF THE DEAF. Case related to Case No. 20-cv-2107. (Hoffman, Ian) (Entered: 05/28/2025)

LCvR 26.1 CERTIFICATE OF DISCLOSURE of Corporate Affiliations and Financial Interests by NATIONAL ASSOCIATION OF THE DEAF (Hoffman, Ian) (Entered: 05/29/2025)

SUMMONS (8) Issued Electronically as to All Defendants, U.S. Attorney and U.S. Attorney General (Attachments: # 1 Notice and Consent)(znmw) (Entered: 05/29/2025)

1 Notice and Consent

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Case Assigned/Reassigned

Case Assigned to Chief Judge James E. Boasberg. (znmw)

NOTICE of Appearance by Elizabeth Themins Hedges on behalf of All Defendants (Hedges, Elizabeth) (Entered: 06/02/2025)

RESPONSE re 3 Notice of Related Case Objection to Designation as Related Case filed by EXECUTIVE OFFICE OF THE PRESIDENT, KAROLINE LEAVITT, OFFICE OF THE VICE PRESIDENT, DONALD J. TRUMP, WHITE HOUSE OFFICE, SUSAN WILES. (Hedges, Elizabeth) (Entered: 06/02/2025)

.Order AND ~Util - Set/Reset Deadlines

.Order AND ~Util - Set/Reset Deadlines/Hearings

Order

MINUTE ORDER: The Court ORDERS that: 1) Defendants shall file their Opposition to Plaintiffs' 2 Motion for a Preliminary Injunction by June 11, 2025; 2) Plaintiffs shall file their Reply by June 18, 2025; and 3) The parties shall appear for a hearing on the Motion via Zoom on June 26, 2025, at 2:00 p.m. So ORDERED by Chief Judge James E. Boasberg on June 2, 2025. (lcjeb3)

MINUTE ORDER: The Court ORDERS that Plaintiffs shall file any response to Defendants' 7 Response by June 5, 2025. So ORDERED by Chief Judge Boasberg on June 2, 2025. (lcjeb3)

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Brittany Shrader, Filing fee $ 100, receipt number ADCDC-11732900. Fee Status: Fee Paid. by MATTHEW BONN, DERRICK FORD, NATIONAL ASSOCIATION OF THE DEAF. (Attachments: # 1 Declaration, # 2 Exhibit Certificate of Good Standing, # 3 Text of Proposed Order)(Hoffman, Ian) (Attachment 1 replaced on 6/4/2025) (znmw). (Entered: 06/03/2025)

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Drake W. Darrah, Filing fee $ 100, receipt number ADCDC-11735675. Fee Status: Fee Paid. by MATTHEW BONN, DERRICK FORD, NATIONAL ASSOCIATION OF THE DEAF. (Attachments: # 1 Declaration, # 2 Exhibit Certificate of Good Standing, # 3 Text of Proposed Order)(Hoffman, Ian) (Entered: 06/04/2025)

Amended MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Drake W. Darrah, Filing fee $ 100, receipt number ADCDC-11735675. Fee Status: Fee Paid. Fee Status: No Fee Paid. by MATTHEW BONN, DERRICK FORD, NATIONAL ASSOCIATION OF THE DEAF. (Attachments: # 1 Declaration, # 2 Exhibit Certificate of Good Standing, # 3 Text of Proposed Order)(Hoffman, Ian) (Entered: 06/04/2025)

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Alexander S. Van Hook, Fee Status: No Fee Paid. by MATTHEW BONN, DERRICK FORD, NATIONAL ASSOCIATION OF THE DEAF. (Attachments: # 1 Declaration, # 2 Exhibit Certificate of Good Standing, # 3 Text of Proposed Order)(Hoffman, Ian) (Entered: 06/04/2025)

NOTICE of Appearance by Alexander E. Sirio on behalf of MATTHEW BONN, DERRICK FORD, NATIONAL ASSOCIATION OF THE DEAF (Sirio, Alexander) (Entered: 06/04/2025)

DECLARATION (CORRECTED ATTACHMENT 1) by MATTHEW BONN, DERRICK FORD, NATIONAL ASSOCIATION OF THE DEAF re 8 MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Brittany Shrader, Filing fee $ 100, receipt number ADCDC-11732900. Fee Status: Fee Paid.. (Hoffman, Ian) (Entered: 06/04/2025)

Notice of Error

Order on Motion for Leave to Appear Pro Hac Vice

Order on Motion for Leave to Appear Pro Hac Vice AND Order on Motion for Leave to Appear Pro Hac Vice

NOTICE OF ERROR regarding 8 MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Brittany Shrader, Filing fee $ 100, receipt number ADCDC-11732900. Fee Status: Fee Paid.. The following error(s) need correction: Declaration must have an original, ink signature. Please refile using the event Declaration. (znmw)

MINUTE ORDER: The Court ORDERS that the 8 Motion for Leave to Appear Pro Hac Vice of Brittany Shrader is GRANTED. Counsel should register for e-filing via PACER and file a notice of appearance pursuant to LCvR 83.6(a). Click for instructions. So ORDERED by Chief Judge James E. Boasberg on June 4, 2025. (lcjeb3)

MINUTE ORDER: The Court ORDERS that the 11 Motion for Leave to Appear Pro Hac Vice of Drake W. Darrah is GRANTED. Counsel should register for e-filing via PACER and file a notice of appearance pursuant to LCvR 83.6(a). Click for instructions. So ORDERED by Chief Judge James E. Boasberg on June 4, 2025. (lcjeb3)

MINUTE ORDER: The Court ORDERS that the 12 Motion for Leave to Appear Pro Hac Vice of Alexander S. Van Hook is GRANTED. Counsel should register for e-filing via PACER and file a notice of appearance pursuant to LCvR 83.6(a). Click for instructions. So ORDERED by Chief Judge James E. Boasberg on June 4, 2025. (lcjeb3)

REPLY re 3 Notice of Related Case Plaintiffs' Response to Defendants' Objection to Notice of Relatedness under LCvR 40.5 filed by MATTHEW BONN, DERRICK FORD, NATIONAL ASSOCIATION OF THE DEAF. (Attachments: # 1 Exhibit A)(Hoffman, Ian) Modified event title on 6/6/2025 (znmw). (Entered: 06/05/2025)

1 Exhibit A

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NOTICE of Appearance by Alexander Sklaroff Van Hook on behalf of All Plaintiffs (Van Hook, Alexander) (Entered: 06/06/2025)

.Order AND Order Reassigning Case

MINUTE ORDER: Although it is quite a close question, the Court ultimately believes that this case does not fall within our related-case rule. The relief sought is considerably broader here; there has been a break in administrations; and, given the Court's limited involvement in the prior case, the judicial economy to be gained is slight. The Court, accordingly, ORDERS that the Calendar Committee shall randomly reassign this matter. So ORDERED by Chief Judge James E. Boasberg on June 6, 2025. (lcjeb3)

Order

Case Assigned/Reassigned

Case randomly reassigned to Judge Amir H. Ali pursuant to the Minute Order dated 6/6/2025. Chief Judge James E. Boasberg is no longer assigned to the case. (ztnr)

NOTICE of Appearance by Tyler J. Becker on behalf of All Defendants (Becker, Tyler) (Entered: 06/09/2025)

NOTICE of Appearance by Drake Darrah on behalf of All Plaintiffs (Darrah, Drake) (Entered: 06/09/2025)

Memorandum in opposition to re 2 MOTION for Preliminary Injunction and Request for an Expedited Hearing MOTION to Expedite Memorandum in Opposition filed by EXECUTIVE OFFICE OF THE PRESIDENT, KAROLINE LEAVITT, OFFICE OF THE VICE PRESIDENT, DONALD J. TRUMP, WHITE HOUSE OFFICE, SUSAN WILES. (Attachments: # 1 Exhibit Proposed Order)(Hedges, Elizabeth) (Entered: 06/11/2025)

1 Exhibit Proposed Order

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NOTICE of Appearance by Brittany Shrader on behalf of All Plaintiffs (Shrader, Brittany) (Entered: 06/17/2025)

.Order AND ~Util - Set/Reset Hearings

MINUTE ORDER. The Court will hold a motion hearing on Plaintiffs' 2 motion for preliminary injunction on June 25, 2025, at 10:00 am in Courtroom 19. The motion hearing scheduled for June 26, 2025, is vacated. Signed by Judge Amir H. Ali on 6/17/2025. (lcaha1)

Order

REPLY to opposition to motion re 2 Motion for Preliminary Injunction,,, Motion to Expedite,, filed by MATTHEW BONN, DERRICK FORD, NATIONAL ASSOCIATION OF THE DEAF. (Hoffman, Ian) (Entered: 06/18/2025)

MINUTE ORDER. The Court will hold a motion hearing on Plaintiffs' 2 motion for preliminary injunction on July 2, 2025, at 10:30 am in Courtroom 19. The motion hearing scheduled for June 25, 2025, is vacated. Signed by Judge Amir H. Ali on 6/20/2025. (lcaha1)

.Order AND ~Util - Set/Reset Hearings

Order

NOTICE of Appearance by Samuel Kleinman on behalf of MATTHEW BONN, DERRICK FORD, NATIONAL ASSOCIATION OF THE DEAF (Kleinman, Samuel) (Entered: 06/23/2025)

NOTICE of Appearance by Robert J. Katerberg on behalf of MATTHEW BONN, DERRICK FORD, NATIONAL ASSOCIATION OF THE DEAF (Katerberg, Robert) (Entered: 07/01/2025)

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Caitlyn Lewis Kellerman, Filing fee $ 100, receipt number ADCDC-11790649. Fee Status: Fee Paid. by MATTHEW BONN, DERRICK FORD, NATIONAL ASSOCIATION OF THE DEAF. (Attachments: # 1 Declaration, # 2 Certificate of Good Standing, # 3 Text of Proposed Order)(Sirio, Alexander) (Entered: 07/01/2025)

NOTICE of Appearance by Caitlyn R. Lewis on behalf of MATTHEW BONN, NATIONAL ASSOCIATION OF THE DEAF (Lewis, Caitlyn) (Entered: 07/02/2025)

NOTICE of Provisional/Government Not Certified Status re 22 NOTICE of Appearance by Robert J. Katerberg on behalf of MATTHEW BONN, DERRICK FORD, NATIONAL ASSOCIATION OF THE DEAF (Katerberg, Robert).Your attorney renewal/government certification has not been received. As a result, your membership with the U.S. District & Bankruptcy Courts for the District of Columbia is not in good standing, and you are not permitted to file. Pursuant to Local Civil Rule 83.9, you must immediately correct your membership status by following the appropriate instructions on this page of our website: https://www.dcd.uscourts.gov/attorney-renewal. Please be advised that the presiding judge in this case has been notified that you are currently not in good standing to file in this court. Renewal Due by 7/9/2025. (zapb)

Order on Motion for Leave to Appear Pro Hac Vice

Notice of Provisional/Government Not Certified Status

Motion Hearing

RESOLVED.....NOTICE of Provisional/Government Not Certified Status re 22 NOTICE of Appearance by Robert J. Katerberg on behalf of MATTHEW BONN, DERRICK FORD, NATIONAL ASSOCIATION OF THE DEAF (Katerberg, Robert).Your attorney renewal/government certification has not been received. As a result, your membership with the U.S. District & Bankruptcy Courts for the District of Columbia is not in good standing, and you are not permitted to file. Pursuant to Local Civil Rule 83.9, you must immediately correct your membership status by following the appropriate instructions on this page of our website: https://www.dcd.uscourts.gov/attorney-renewal. Please be advised that the presiding judge in this case has been notified that you are currently not in good standing to file in this court. Renewal Due by 7/9/2025. (zapb) Modified on 7/3/2025 (zhcn).

MINUTE ORDER granting 23 motion for leave to appear pro hac vice. Attorney Caitlyn Lewis Kellerman 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 7/2/2025. (lcaha1)

Minute Entry for proceedings held before Judge Amir H. Ali: Motion Hearing held on 7/2/2025 re 2 Motion for Preliminary Injunction. Oral arguments heard. The Court takes the motion under advisement. Written ruling forthcoming via Chambers. (Court Reporter: Sonja Reeves) (ASL Interpreters: Joseph Lucas and Sarah Blattbert) (Certified Deaf Interpreters: Nancylynn Ward, and Neisha Washington-Shepherd) (zalh)

TRANSCRIPT OF MOTION HEARING before Judge Amir H. Ali held on July 2, 2025; Page Numbers: 1-79. Date of Issuance: July 6, 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 7/27/2025. Redacted Transcript Deadline set for 8/6/2025. Release of Transcript Restriction set for 10/4/2025.(Reeves, Sonja) (Entered: 07/06/2025)

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 7/15/2025. (lcaha1) (Entered: 07/15/2025)

Joint MOTION to Vacate Answer Deadline and Set JSR Deadline by EXECUTIVE OFFICE OF THE PRESIDENT, KAROLINE LEAVITT, OFFICE OF THE VICE PRESIDENT, DONALD J. TRUMP, WHITE HOUSE OFFICE, SUSAN WILES. (Attachments: # 1 Text of Proposed Order)(Becker, Tyler) (Entered: 07/22/2025)

1 Text of Proposed Order

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Order on Motion to Vacate AND Set/Reset Deadlines

Order on Motion to Vacate

MINUTE ORDER. The parties' 27 joint motion to vacate answer deadline and set deadline for joint status report is granted. The July 28, 2025, deadline to file an answer is vacated. The parties shall file a joint status report within ten days of the Court's ruling on Plaintiffs' 2 motion for a preliminary injunction. Signed by Judge Amir H. Ali on 7/22/2025. (lcaha1) Modified on 7/28/2025. (zalh)

NOTICE [PLAINTIFF MATTTHEW BONN'S NOTICE OF VOLUNTARY DISMISSAL OF HIS CLAIMS AGAINST DEFENDANTS] by MATTHEW BONN, DERRICK FORD, NATIONAL ASSOCIATION OF THE DEAF (Hoffman, Ian) (Entered: 07/25/2025)