Case: Robert F. Kennedy Human Rights v. Department of State

Tammy Bruce

COMPLAINT against DEPARTMENT OF STATE, MARCO RUBIO, in his official capacity as Secretary of State ( Filing fee $ 405 receipt number ADCDC-11738054) filed by ROBERT F. KENNEDY HUMAN RIGHTS, IMMIGRATION EQUALITY, IMMIGRANT DEFENDERS LAW CENTER, NATIONAL ASSOCIATION OF CRIMINAL DEFENSE LAWYERS, CALIFORNIA COLLABORATIVE FOR IMMIGRANT JUSTICE. (Attachments: # 1 Civil Cover Sheet, # 2 Summons, # 3 Summons, # 4 Summons, # 5 Summons)(Morton, Jessica) (Entered: 06/05/2025)

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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NOTICE OF RELATED CASE by CALIFORNIA COLLABORATIVE FOR IMMIGRANT JUSTICE, IMMIGRANT DEFENDERS LAW CENTER, IMMIGRATION EQUALITY, NATIONAL ASSOCIATION OF CRIMINAL DEFENSE LAWYERS, ROBERT F. KENNEDY HUMAN RIGHTS. Case related to Case No. 25-766. (Morton, Jessica) (Entered: 06/05/2025)

NOTICE of Appearance by Kevin E. Friedl on behalf of All Plaintiffs (Friedl, Kevin) (Entered: 06/05/2025)

SUMMONS (2) Issued Electronically as to All Defendants., SUMMONS Issued Electronically as to All Defendants, U.S. Attorney and U.S. Attorney General (Attachments: # 1 Notice and Consent)(zmtm) (Main Document 4 replaced on 6/5/2025) (zmtm). (Entered: 06/05/2025)

NOTICE of Appearance by Robin F. Thurston on behalf of CALIFORNIA COLLABORATIVE FOR IMMIGRANT JUSTICE, IMMIGRANT DEFENDERS LAW CENTER, IMMIGRATION EQUALITY, NATIONAL ASSOCIATION OF CRIMINAL DEFENSE LAWYERS, ROBERT F. KENNEDY HUMAN RIGHTS (Thurston, Robin) (Entered: 06/05/2025)

NOTICE of Appearance by Anthony Enriquez on behalf of ROBERT F. KENNEDY HUMAN RIGHTS (Enriquez, Anthony) (Entered: 06/05/2025)

Case Assigned/Reassigned

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

NOTICE of Appearance by Medha Raman on behalf of ROBERT F. KENNEDY HUMAN RIGHTS (Raman, Medha) (Entered: 06/06/2025)

NOTICE of Appearance by Sarah Telo Gillman on behalf of ROBERT F. KENNEDY HUMAN RIGHTS (Gillman, Sarah) (Entered: 06/07/2025)

NOTICE of Appearance by Sarah Decker on behalf of ROBERT F. KENNEDY HUMAN RIGHTS (Decker, Sarah) (Main Document 9 replaced on 6/9/2025) (znmw). (Entered: 06/08/2025)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed as to the United States Attorney. Date of Service Upon United States Attorney on 6/12/2025. Answer due for ALL FEDERAL DEFENDANTS by 8/11/2025. (Morton, Jessica) (Entered: 06/17/2025)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed on United States Attorney General. Date of Service Upon United States Attorney General 06/12/2025. (Morton, Jessica) (Entered: 06/17/2025)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. DEPARTMENT OF STATE served on 6/12/2025 (Morton, Jessica) (Entered: 06/17/2025)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. MARCO RUBIO served on 6/12/2025 (Morton, Jessica) (Entered: 06/17/2025)

NOTICE of Appearance by Bradley P. Humphreys on behalf of All Defendants (Humphreys, Bradley) (Entered: 07/01/2025)

Joint MOTION for Briefing Schedule by CALIFORNIA COLLABORATIVE FOR IMMIGRANT JUSTICE, IMMIGRANT DEFENDERS LAW CENTER, IMMIGRATION EQUALITY, NATIONAL ASSOCIATION OF CRIMINAL DEFENSE LAWYERS, ROBERT F. KENNEDY HUMAN RIGHTS. (Attachments: # 1 Text of Proposed Order)(Morton, Jessica) (Entered: 07/08/2025)

MINUTE ORDER: The Court ADOPTS the parties' 15 Joint Motion for Briefing Schedule and ORDERS that: 1) Defendants shall produce agreed-upon documents by July 23, 2025; 2) Plaintiffs shall file their Motion for Summary Judgment by August 22, 2025; 3) Defendants shall file their consolidated Opposition, Motion to Dismiss, and Cross-Motion for Summary Judgment by September 22, 2025; 4) Plaintiffs shall file their consolidated Opposition and Reply by October 22, 2025; and 5) Defendants shall file their Reply by November 5, 2025. So ORDERED by Chief Judge James E. Boasberg on 7/9/2025. (lcjeb1)

Order on Motion for Briefing Schedule

Order on Motion for Briefing Schedule AND Set/Reset Deadlines

Order on Motion for Briefing Schedule

Joint MOTION for Protective Order by DEPARTMENT OF STATE, MARCO RUBIO. (Attachments: # 1 Text of Proposed Order)(Humphreys, Bradley) (Entered: 07/23/2025)

1 Text of Proposed Order

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ORDER granting 16 Motion for Protective Order. Signed by Chief Judge James E. Boasberg on July 24, 2025. (lcjeb3) (Entered: 07/24/2025)

SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by CALIFORNIA COLLABORATIVE FOR IMMIGRANT JUSTICE, IMMIGRANT DEFENDERS LAW CENTER, IMMIGRATION EQUALITY, NATIONAL ASSOCIATION OF CRIMINAL DEFENSE LAWYERS, ROBERT F. KENNEDY HUMAN RIGHTS (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Text of Proposed Order for Motion to Seal, # 2 Exhibit Motion for Summary Judgment, # 3 Exhibit Declaration and Exhibits ISO Motion for Summary Judgment, # 4 Text of Proposed Order for Motion for Summary Judgment)(Morton, Jessica) (Entered: 08/22/2025)

MOTION for Summary Judgment REDACTED by CALIFORNIA COLLABORATIVE FOR IMMIGRANT JUSTICE, IMMIGRANT DEFENDERS LAW CENTER, IMMIGRATION EQUALITY, NATIONAL ASSOCIATION OF CRIMINAL DEFENSE LAWYERS, ROBERT F. KENNEDY HUMAN RIGHTS. (Attachments: # 1 Exhibit Declaration and Exhibits, # 2 Text of Proposed Order)(Morton, Jessica) (Entered: 08/22/2025)

1 Exhibit Declaration and Exhibits

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2 Text of Proposed Order

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MOTION to Supplement the Administrative Record by CALIFORNIA COLLABORATIVE FOR IMMIGRANT JUSTICE, IMMIGRANT DEFENDERS LAW CENTER, IMMIGRATION EQUALITY, NATIONAL ASSOCIATION OF CRIMINAL DEFENSE LAWYERS, ROBERT F. KENNEDY HUMAN RIGHTS. (Attachments: # 1 Text of Proposed Order)(Morton, Jessica) (Entered: 08/22/2025)

1 Text of Proposed Order

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SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by CALIFORNIA COLLABORATIVE FOR IMMIGRANT JUSTICE, IMMIGRANT DEFENDERS LAW CENTER, IMMIGRATION EQUALITY, NATIONAL ASSOCIATION OF CRIMINAL DEFENSE LAWYERS, ROBERT F. KENNEDY HUMAN RIGHTS (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Text of Proposed Order for Motion to Seal, # 2 Exhibit Motion for De-Designation, # 3 Exhibit 1, # 4 Exhibit 2, # 5 Exhibit 3, # 6 Text of Proposed Order for Motion for De-Designation)(Morton, Jessica) (Entered: 08/22/2025)

SEALED MOTION for Summary Judgment filed by CALIFORNIA COLLABORATIVE FOR IMMIGRANT JUSTICE, IMMIGRANT DEFENDERS LAW CENTER, IMMIGRATION EQUALITY, NATIONAL ASSOCIATION OF CRIMINAL DEFENSE LAWYERS, ROBERT F. KENNEDY HUMAN RIGHTS. (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Declaration, # 2 Text of Proposed Order)(znmw) (Entered: 08/25/2025)

Order on Sealed Motion for Leave to File Document Under Seal

MINUTE ORDER granting 21 Sealed Motion for Leave to File Document Under Seal. So ORDERED by Chief Judge James E. Boasberg on 8/22/2025. (znbn)

MINUTE ORDER: The Court ORDERS that the Plaintiffs' 18 Motion to File Under Seal is GRANTED. So ORDERED by Chief Judge James E. Boasberg on August 22, 2025. (lcjeb3)

SEALED MOTION for De-Designation filed by CALIFORNIA COLLABORATIVE FOR IMMIGRANT JUSTICE, IMMIGRANT DEFENDERS LAW CENTER, IMMIGRATION EQUALITY, NATIONAL ASSOCIATION OF CRIMINAL DEFENSE LAWYERS, ROBERT F. KENNEDY HUMAN RIGHTS. (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Text of Proposed Order)(znmw) (Entered: 08/25/2025)

MOTION for Extension of Time to File Response/Reply as to 23 SEALED MOTION filed by CALIFORNIA COLLABORATIVE FOR IMMIGRANT JUSTICE, IMMIGRANT DEFENDERS LAW CENTER, IMMIGRATION EQUALITY, NATIONAL ASSOCIATION OF CRIMINAL DEFENSE LAWYERS, ROBERT F. KENNEDY HUMAN RIGHTS. (This document is SEALED and only available t by DEPARTMENT OF STATE, MARCO A. RUBIO. (Attachments: # 1 Text of Proposed Order)(Humphreys, Bradley) (Entered: 08/29/2025)

1 Text of Proposed Order

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SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by DEPARTMENT OF STATE, MARCO A. RUBIO (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Text of Proposed Order, # 2 Exhibit Opposition to Plaintiffs' Motion to De-Designate)(Humphreys, Bradley) (Entered: 09/02/2025)

MINUTE ORDER: The Court ORDERS that: 1) The Defendants' 24 Motion for Extension of Time is GRANTED; and 2) Defendant shall file its Response or otherwise respond to the Plaintiffs' 23 Motion by September 2, 2025. So ORDERED by Chief Judge James E. Boasberg on September 2, 2025. (lcjeb1)

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

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

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

SEALED OPPOSITION filed by DEPARTMENT OF STATE, MARCO A. RUBIO re 23 Sealed Motion, (zjm) (Entered: 09/06/2025)

MINUTE ORDER: The Court ORDERS that Defendants' 25 Sealed Motion to File Under Seal is GRANTED. In the event that the Court, after review, believes that a redacted version of Defendants' Opposition should be filed on the public record, it will so order. So ORDERED by Chief Judge James E. Boasberg on 9/3/2025. (lcjeb1)

Order on Sealed Motion for Leave to File Document Under Seal

SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by CALIFORNIA COLLABORATIVE FOR IMMIGRANT JUSTICE, IMMIGRANT DEFENDERS LAW CENTER, IMMIGRATION EQUALITY, NATIONAL ASSOCIATION OF CRIMINAL DEFENSE LAWYERS, ROBERT F. KENNEDY HUMAN RIGHTS (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Text of Proposed Order, # 2 Exhibit Reply in Support of Motion for De-Designation)(Morton, Jessica) (Entered: 09/04/2025)

NOTICE OF WITHDRAWAL OF APPEARANCE as to ROBERT F. KENNEDY HUMAN RIGHTS. Attorney Medha Raman terminated. (Raman, Medha) (Entered: 09/04/2025)

SEALED REPLY TO OPPOSITION filed by CALIFORNIA COLLABORATIVE FOR IMMIGRANT JUSTICE, IMMIGRANT DEFENDERS LAW CENTER, IMMIGRATION EQUALITY, NATIONAL ASSOCIATION OF CRIMINAL DEFENSE LAWYERS, ROBERT F. KENNEDY HUMAN RIGHTS re 23 Sealed Motion, (This document is SEALED and only available to authorized persons.)(zjm) (Entered: 09/06/2025)

MINUTE ORDER: The Court ORDERS that Plaintiffs' 26 Sealed Motion to File Under Seal is GRANTED. In the event that the Court, after review, believes that a redacted version of Plaintiffs' Reply should be filed on the public record, it will so order. So ORDERED by Chief Judge James E. Boasberg on 9/5/2025. (lcjeb1)

Order on Sealed Motion for Leave to File Document Under Seal

NOTICE OF WITHDRAWAL OF MOTION by CALIFORNIA COLLABORATIVE FOR IMMIGRANT JUSTICE, IMMIGRANT DEFENDERS LAW CENTER, IMMIGRATION EQUALITY, NATIONAL ASSOCIATION OF CRIMINAL DEFENSE LAWYERS, ROBERT F. KENNEDY HUMAN RIGHTS re 23 SEALED MOTION filed by CALIFORNIA COLLABORATIVE FOR IMMIGRANT JUSTICE, IMMIGRANT DEFENDERS LAW CENTER, IMMIGRATION EQUALITY, NATIONAL ASSOCIATION OF CRIMINAL DEFENSE LAWYERS, ROBERT F. KENNEDY HUMAN RIGHTS. (This document is SEALED and only available t (Attachments: # 1 Exhibit 1)(Morton, Jessica) (Entered: 09/08/2025)

1 Exhibit 1

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REDACTED DOCUMENT- Revised Redacted Motion for Summary Judgment to 19 MOTION for Summary Judgment REDACTED, 22 SEALED MOTION filed by CALIFORNIA COLLABORATIVE FOR IMMIGRANT JUSTICE, IMMIGRANT DEFENDERS LAW CENTER, IMMIGRATION EQUALITY, NATIONAL ASSOCIATION OF CRIMINAL DEFENSE LAWYERS, ROBERT F. KENNEDY HUMAN RIGHTS. (This document is SEALED and only available t by CALIFORNIA COLLABORATIVE FOR IMMIGRANT JUSTICE, IMMIGRANT DEFENDERS LAW CENTER, IMMIGRATION EQUALITY, NATIONAL ASSOCIATION OF CRIMINAL DEFENSE LAWYERS, ROBERT F. KENNEDY HUMAN RIGHTS. (Attachments: # 1 Exhibit 22 (Redacted))(Morton, Jessica) (Entered: 09/09/2025)

1 Exhibit 22 (Redacted)

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NOTICE of Appearance by John Stephen Tagert on behalf of All Defendants (Tagert, John) (Entered: 09/22/2025)

MOTION to Dismiss for Lack of Jurisdiction by DEPARTMENT OF STATE, MARCO A. RUBIO. (Attachments: # 1 Memorandum in Support, # 2 Exhibit A, # 3 Text of Proposed Order)(Tagert, John) (Entered: 09/22/2025)

1 Memorandum in Support

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2 Exhibit A

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3 Text of Proposed Order

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NOTICE OF WITHDRAWAL OF APPEARANCE as to DEPARTMENT OF STATE, MARCO A. RUBIO. Attorney Bradley P. Humphreys terminated. (Humphreys, Bradley) (Entered: 09/23/2025)

NOTICE OF FILING REDACTED DOCUMENT to 19 MOTION for Summary Judgment REDACTED by CALIFORNIA COLLABORATIVE FOR IMMIGRANT JUSTICE, IMMIGRANT DEFENDERS LAW CENTER, IMMIGRATION EQUALITY, NATIONAL ASSOCIATION OF CRIMINAL DEFENSE LAWYERS, ROBERT F. KENNEDY HUMAN RIGHTS (Attachments: # 1 Exhibit Second Revised Redacted Motion for Summary Judgment, # 2 Exhibit 12)(Morton, Jessica) (Entered: 09/30/2025)

REPLY to opposition to motion re 22 Sealed Motion, for Summary Judgment filed by CALIFORNIA COLLABORATIVE FOR IMMIGRANT JUSTICE, IMMIGRANT DEFENDERS LAW CENTER, IMMIGRATION EQUALITY, NATIONAL ASSOCIATION OF CRIMINAL DEFENSE LAWYERS, ROBERT F. KENNEDY HUMAN RIGHTS. (Attachments: # 1 Declaration and Exhibits)(Morton, Jessica) (Entered: 10/22/2025)

Memorandum in opposition to re 33 MOTION to Dismiss for Lack of Jurisdiction MOTION for Summary Judgment filed by CALIFORNIA COLLABORATIVE FOR IMMIGRANT JUSTICE, IMMIGRANT DEFENDERS LAW CENTER, IMMIGRATION EQUALITY, NATIONAL ASSOCIATION OF CRIMINAL DEFENSE LAWYERS, ROBERT F. KENNEDY HUMAN RIGHTS. (Attachments: # 1 Declaration and Exhibits)(Morton, Jessica) (Entered: 10/22/2025)

1 Declaration and Exhibits

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MOTION to Lift Stay by CALIFORNIA COLLABORATIVE FOR IMMIGRANT JUSTICE, IMMIGRANT DEFENDERS LAW CENTER, IMMIGRATION EQUALITY, NATIONAL ASSOCIATION OF CRIMINAL DEFENSE LAWYERS, ROBERT F. KENNEDY HUMAN RIGHTS. (Attachments: # 1 Text of Proposed Order)(Morton, Jessica) (Entered: 10/22/2025)

1 Text of Proposed Order

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REPLY to opposition to motion re 22 Sealed Motion, for Summary Judgment, CORRECTED filed by CALIFORNIA COLLABORATIVE FOR IMMIGRANT JUSTICE, IMMIGRANT DEFENDERS LAW CENTER, IMMIGRATION EQUALITY, NATIONAL ASSOCIATION OF CRIMINAL DEFENSE LAWYERS, ROBERT F. KENNEDY HUMAN RIGHTS. (Attachments: # 1 Declaration and Exhibits)(Morton, Jessica) (Entered: 10/22/2025)

Memorandum in opposition to re 33 MOTION to Dismiss for Lack of Jurisdiction MOTION for Summary Judgment CORRECTED filed by CALIFORNIA COLLABORATIVE FOR IMMIGRANT JUSTICE, IMMIGRANT DEFENDERS LAW CENTER, IMMIGRATION EQUALITY, NATIONAL ASSOCIATION OF CRIMINAL DEFENSE LAWYERS, ROBERT F. KENNEDY HUMAN RIGHTS. (Attachments: # 1 Declaration and Exhibits)(Morton, Jessica) (Entered: 10/22/2025)

.Order AND ~Util - Set/Reset Deadlines

MINUTE ORDER: The Court ORDERS that: 1) Plaintiffs' 36 Reply and 37 Opposition are STRICKEN for violating the Court's Local Rule on excessive footnotes; 2) Plaintiffs shall file compliant briefs containing no more than 10 footnotes with no more than 40 aggregate lines of text by October 23, 2025; and 3) Defendants shall respond to Plaintiffs' 38 Motion to Lift Stay by October 24, 2025. So ORDERED by Chief Judge James E. Boasberg on October 22, 2025. (lcjeb1)

Memorandum in opposition to re 38 MOTION to Lift Stay filed by DEPARTMENT OF STATE, MARCO A. RUBIO. (Tagert, John) (Entered: 10/24/2025)

REPLY to opposition to motion re 38 Motion to Lift Stay, filed by CALIFORNIA COLLABORATIVE FOR IMMIGRANT JUSTICE, IMMIGRANT DEFENDERS LAW CENTER, IMMIGRATION EQUALITY, NATIONAL ASSOCIATION OF CRIMINAL DEFENSE LAWYERS, ROBERT F. KENNEDY HUMAN RIGHTS. (Friedl, Kevin) (Entered: 10/27/2025)

.Order AND ~Util - Set/Reset Deadlines

MINUTE ORDER: The Court ORDERS that Plaintiffs shall file any Reply regarding their Motion for Relief by October 29, 2025. So ORDERED by Chief Judge James E. Boasberg on October 27, 2025. (lcjeb1)

Order on Motion to Lift Stay AND Set/Reset Deadlines

MINUTE ORDER: The Court ORDERS that Plaintiffs' 38 Motion to Lift Stay is GRANTED, and Defendants shall file their Reply by November 12, 2025. So ORDERED by Chief Judge James E. Boasberg on October 28, 2025. (lcjeb1)

REPLY to opposition to motion re 33 Motion to Dismiss/Lack of Jurisdiction,, Motion for Summary Judgment, filed by DEPARTMENT OF STATE, MARCO A. RUBIO. (Tagert, John) (Entered: 11/12/2025)

NOTICE of Appearance by Tiberius T Davis on behalf of All Defendants (Davis, Tiberius) (Entered: 11/14/2025)

Unopposed MOTION for Leave to File Surreply by CALIFORNIA COLLABORATIVE FOR IMMIGRANT JUSTICE, IMMIGRANT DEFENDERS LAW CENTER, IMMIGRATION EQUALITY, NATIONAL ASSOCIATION OF CRIMINAL DEFENSE LAWYERS, ROBERT F. KENNEDY HUMAN RIGHTS. (Attachments: # 1 Proposed Surreply, # 2 Text of Proposed Order)(Friedl, Kevin) (Entered: 11/17/2025)

1 Proposed Surreply

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2 Text of Proposed Order

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Order on Motion for Leave to File

MINUTE ORDER: The Court ORDERS that: 1) Plaintiffs' 45 Motion for Leave to File Surreply is GRANTED; and 2) Plaintiffs' Surreply is deemed filed. So ORDERED by Judge James E. Boasberg on November 18, 2025. (lcjeb1)