Case: Urban Sustainability Directors Network v. U.S. Department of Agriculture

Urban Sustainability Directors Network v. United States Department of Agriculture

President Donald Trump

President Donald Trump

President Donald Trump

COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF against AUBREY J.D. BETTENCOURT, JAYE L. HAMBY, NATIONAL INSTITUTE OF FOOD AND AGRICULTURE, NATURAL RESOURCES CONSERVATION SERVICE, BROOKE ROLLINS, TOM SCHULTZ, UNITED STATES DEPARTMENT OF AGRICULTURE, UNITED STATES FOREST SERVICE ( Filing fee $ 405 receipt number ADCDC-11738210) filed by AGROECOLOGY COMMONS, OAKVILLE BLUEGRASS COOPERATIVE, URBAN SUSTAINABILITY DIRECTORS NETWORK. (Attachments: # 1 Civil Cover Sheet, # 2 Summons)(Muraskin, David) (Entered: 06/05/2025)

1 Civil Cover Sheet

View on PACER

2 Summons

View on PACER

Case Assigned/Reassigned

Case Assigned to Judge Beryl A. Howell. (zmtm)

SUMMONS (10) Issued Electronically as to All Defendants, U.S. Attorney and U.S. Attorney General (Attachments: # 1 Notice and Consent)(zmtm) (Entered: 06/05/2025)

LCvR 26.1 CERTIFICATE OF DISCLOSURE of Corporate Affiliations and Financial Interests by AGROECOLOGY COMMONS, OAKVILLE BLUEGRASS COOPERATIVE, URBAN SUSTAINABILITY DIRECTORS NETWORK (Muraskin, David) (Entered: 06/05/2025)

STANDING ORDER. Signed by Judge Beryl A. Howell on June 5, 2025. (lcbah4) (Entered: 06/05/2025)

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Holly Bainbridge, Filing fee $ 100, receipt number ADCDC-11739586. Fee Status: Fee Paid. by AGROECOLOGY COMMONS, OAKVILLE BLUEGRASS COOPERATIVE, URBAN SUSTAINABILITY DIRECTORS NETWORK. (Attachments: # 1 Declaration, # 2 Exhibit Certificate of Good Standing)(Muraskin, David) (Entered: 06/05/2025)

Order on Motion for Leave to Appear Pro Hac Vice

MINUTE ORDER (paperless) GRANTING plaintiff's 5 Motion to Appear Pro Hac Vice. Ms. Holly Bainbridge may enter an appearance pro hac vice for the purpose of representing plaintiff in this action. 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 Beryl A. Howell on June 9, 2025. (lcbah4)

NOTICE of Appearance by Holly Bainbridge on behalf of AGROECOLOGY COMMONS, OAKVILLE BLUEGRASS COOPERATIVE, URBAN SUSTAINABILITY DIRECTORS NETWORK (Bainbridge, Holly) (Entered: 06/09/2025)

NOTICE of Appearance by Carrie F. Apfel on behalf of AGROECOLOGY COMMONS, OAKVILLE BLUEGRASS COOPERATIVE, URBAN SUSTAINABILITY DIRECTORS NETWORK (Apfel, Carrie) (Entered: 06/11/2025)

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Benjamin E. Apple, Filing fee $ 100, receipt number ADCDC-11772841. Fee Status: Fee Paid. by AGROECOLOGY COMMONS, OAKVILLE BLUEGRASS COOPERATIVE, URBAN SUSTAINABILITY DIRECTORS NETWORK. (Attachments: # 1 Declaration, # 2 Exhibit Certificate of Good Standing)(Muraskin, David) (Entered: 06/23/2025)

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Scott W. Carlson, Filing fee $ 100, receipt number ADCDC-11772847. Fee Status: Fee Paid. by AGROECOLOGY COMMONS, OAKVILLE BLUEGRASS COOPERATIVE, URBAN SUSTAINABILITY DIRECTORS NETWORK. (Attachments: # 1 Declaration, # 2 Exhibit Certificate of Good Standing)(Muraskin, David) (Entered: 06/23/2025)

Order on Motion for Leave to Appear Pro Hac Vice

MINUTE ORDER (paperless) GRANTING plaintiffs' 8 Motion for Leave to Appear Pro Hac Vice. Mr. Benjamin Apple may enter an appearance pro hac vice for the purpose of representing plaintiffs in this action. 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 Beryl A. Howell on June 24, 2025. (lcbah4)

MINUTE ORDER (paperless) GRANTING plaintiffs' 9 Motion for Leave to Appear Pro Hac Vice. Mr. Scott Carlson may enter an appearance pro hac vice for the purpose of representing plaintiffs in this action. 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 Beryl A. Howell on June 24, 2025. (lcbah4)

AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF against AUBREY J.D. BETTENCOURT, JAYE L. HAMBY, NATIONAL INSTITUTE OF FOOD AND AGRICULTURE, NATURAL RESOURCES CONSERVATION SERVICE, BROOKE ROLLINS, TOM SCHULTZ, UNITED STATES DEPARTMENT OF AGRICULTURE, UNITED STATES FOREST SERVICE, DEPARTMENT OF GOVERNMENT EFFICIENCY, AMY GLEASON, FARM SERVICE AGENCY, WILLIAM BEAM, AGRICULTURAL MARKETING SERVICE, ERIN MORRIS filed by AGROECOLOGY COMMONS, OAKVILLE BLUEGRASS COOPERATIVE, URBAN SUSTAINABILITY DIRECTORS NETWORK, PROVIDENCE FARM COLLECTIVE CORP., INSTITUTE FOR AGRICULTURE AND TRADE POLICY. (Attachments: # 1 Redline Comparison, # 2 Exhibit Index of Exhibits, # 3 Exhibit A, # 4 Exhibit B, # 5 Exhibit C, # 6 Exhibit D, # 7 Exhibit E, # 8 Summons)(Bainbridge, Holly) (Entered: 06/24/2025)

1 Redline Comparison

View on RECAP

2 Exhibit Index of Exhibits

View on RECAP

3 Exhibit A

View on RECAP

4 Exhibit B

View on RECAP

5 Exhibit C

View on RECAP

6 Exhibit D

View on RECAP

7 Exhibit E

View on RECAP

8 Summons

View on RECAP

LCvR 26.1 CERTIFICATE OF DISCLOSURE of Corporate Affiliations and Financial Interests by INSTITUTE FOR AGRICULTURE AND TRADE POLICY (Bainbridge, Holly) (Entered: 06/24/2025)

LCvR 26.1 CERTIFICATE OF DISCLOSURE of Corporate Affiliations and Financial Interests by PROVIDENCE FARM COLLECTIVE CORP. (Bainbridge, Holly) (Entered: 06/24/2025)

NOTICE of Appearance by Benjamin Apple on behalf of All Plaintiffs (Apple, Benjamin) (Entered: 06/25/2025)

MOTION for Preliminary Injunction by AGROECOLOGY COMMONS, INSTITUTE FOR AGRICULTURE AND TRADE POLICY, OAKVILLE BLUEGRASS COOPERATIVE, PROVIDENCE FARM COLLECTIVE CORP., URBAN SUSTAINABILITY DIRECTORS NETWORK. (Attachments: # 1 Memorandum in Support OF MOTION FOR A PRELIMINARY INJUNCTION, # 2 Declaration OF JAMAL BROWN, # 3 Declaration OF JEFF THIEL, # 4 Declaration LEAH ATWOOD, # 5 Declaration KRISTIN HELTMAN-WEISS, # 6 Declaration ERIN MCKEE VANSLOOTEN, # 7 [PROPOSED] ORDER GRANTING PRELIMINARY INJUCTION)(Bainbridge, Holly) (Entered: 06/26/2025)

1 Memorandum in Support OF MOTION FOR A PRELIMINARY INJUNCTION

View on RECAP

2 Declaration OF JAMAL BROWN

View on PACER

3 Declaration OF JEFF THIEL

View on PACER

4 Declaration LEAH ATWOOD

View on PACER

5 Declaration KRISTIN HELTMAN-WEISS

View on PACER

6 Declaration ERIN MCKEE VANSLOOTEN

View on PACER

7 [PROPOSED] ORDER GRANTING PRELIMINARY INJUCTION

View on PACER

.Order

MINUTE ORDER (paperless), upon consideration of plaintiffs' 14 Motion for Preliminary Injunction, DIRECTING the parties to confer and jointly propose by June 30, 2025 at 5:00 PM a briefing schedule on plaintiffs' pending motion. Signed by Judge Beryl A. Howell on June 26, 2025. (lcbah4)

MOTION to Expedite DISCOVERY by AGROECOLOGY COMMONS, INSTITUTE FOR AGRICULTURE AND TRADE POLICY, OAKVILLE BLUEGRASS COOPERATIVE, PROVIDENCE FARM COLLECTIVE CORP., URBAN SUSTAINABILITY DIRECTORS NETWORK. (Attachments: # 1 Exhibit Index, # 2 Exhibit A, # 3 Exhibit B, # 4 Text of Proposed Order)(Bainbridge, Holly) (Entered: 06/26/2025)

Set/Reset Deadlines

Set/Reset Deadlines: Joint Proposed Briefing Schedule due no later than 5:00PM on 6/30/2025. (mac)

SUMMONS (6) Issued Electronically as to AGRICULTURAL MARKETING SERVICE, WILLIAM BEAM, DEPARTMENT OF GOVERNMENT EFFICIENCY, FARM SERVICE AGENCY, AMY GLEASON, ERIN MORRIS. (mg) (Entered: 06/27/2025)

CERTIFICATE OF SERVICE by AGROECOLOGY COMMONS, INSTITUTE FOR AGRICULTURE AND TRADE POLICY, OAKVILLE BLUEGRASS COOPERATIVE, PROVIDENCE FARM COLLECTIVE CORP., URBAN SUSTAINABILITY DIRECTORS NETWORK re 15 MOTION to Expedite DISCOVERY, 14 MOTION for Preliminary Injunction . (Bainbridge, Holly) (Entered: 06/27/2025)

NOTICE of Appearance by Scott Carlson on behalf of All Plaintiffs (Carlson, Scott) (Entered: 06/30/2025)

.Order

NOTICE of Appearance by John Bardo on behalf of All Defendants (Bardo, John) (Entered: 06/30/2025)

Joint STATUS REPORT by AGROECOLOGY COMMONS, INSTITUTE FOR AGRICULTURE AND TRADE POLICY, OAKVILLE BLUEGRASS COOPERATIVE, PROVIDENCE FARM COLLECTIVE CORP., URBAN SUSTAINABILITY DIRECTORS NETWORK. (Bainbridge, Holly) (Entered: 06/30/2025)

MINUTE ORDER (paperless), upon consideration of the parties' 20 Joint Status Report, which puzzlingly proposes a synchronous schedule for briefing both plaintiffs' 14 Motion for Preliminary Injunction and 15 Motion for Expedited Discovery, despite plaintiffs explicitly anticipating that the discovery, if granted, will be used to supplement the pending preliminary injunction motion, potentially necessitating additional rounds of briefing, since plaintiffs at least seem to anticipate discovery may be necessary to its resolution, but nonetheless ISSUING the following scheduling order in accord with the parties' agreed-upon proposal: 1. Defendants shall file responses to plaintiffs' 14 Motion for Preliminary Injunction and their 15 Motion to Expedite Discovery by July 10, 2025;2. Plaintiffs shall file any replies by July 15, 2025;3. Hearings, as necessary, on one or both of the motions will be scheduled after July 15, 2025. Signed by Judge Beryl A. Howell on June 30, 2025. (lcbah4)

Set/Reset Deadlines

Set/Reset Deadlines: Defendants Responses To Plaintiffs' 14 Motion for Preliminary Injunction and 15 Motion To Expedite Discovery due by 7/10/2025. Plaintiffs Replies due by 7/15/2025. (mac)

MOTION for Leave to File Amicus BriefIn Support of Plaintiffs' Motion For A Preliminary Injunction by CHESAPEAKE BAY FOUNDATION, INC.,. (Attachments: # 1 Memorandum in Support Proposed Amicus Curiae Brief of Chesapeake Bay Foundation, # 2 Text of Proposed Order Proposed Order Granting Leave to File Amicus)(Lilley, Taylor) (Entered: 07/07/2025)

Order on Motion for Leave to File Amicus Brief

MINUTE ORDER (paperless) GRANTING Chesapeake Bay Foundation's 21 Motion for Leave to File Amicus Curiae Brief in Support of Plaintiffs' Motion for a Preliminary Injunction. Signed by Judge Beryl A. Howell on July 8, 2025. (lcbah4)

AMICUS BRIEF by CHESAPEAKE BAY FOUNDATION, INC. (mg) (Entered: 07/11/2025)

Memorandum in opposition to re 15 MOTION to Expedite DISCOVERY, 14 MOTION for Preliminary Injunction filed by AGRICULTURAL MARKETING SERVICE, WILLIAM BEAM, AUBREY J.D. BETTENCOURT, DEPARTMENT OF GOVERNMENT EFFICIENCY, FARM SERVICE AGENCY, AMY GLEASON, JAYE L. HAMBY, ERIN MORRIS, NATIONAL INSTITUTE OF FOOD AND AGRICULTURE, NATURAL RESOURCES CONSERVATION SERVICE, BROOKE ROLLINS, TOM SCHULTZ, UNITED STATES DEPARTMENT OF AGRICULTURE, UNITED STATES FOREST SERVICE. (Attachments: # 1 Text of Proposed Order)(Bardo, John) (Entered: 07/10/2025)

1 Text of Proposed Order

View on PACER

REPLY to opposition to motion re 15 Motion to Expedite, 14 Motion for Preliminary Injunction,, filed by AGROECOLOGY COMMONS, INSTITUTE FOR AGRICULTURE AND TRADE POLICY, OAKVILLE BLUEGRASS COOPERATIVE, PROVIDENCE FARM COLLECTIVE CORP., URBAN SUSTAINABILITY DIRECTORS NETWORK. (Apfel, Carrie) (Entered: 07/15/2025)

.Order

MINUTE ORDER (paperless) DIRECTING the parties to appear in-person for a hearing on July 30, 2025, at 10:00 AM in Courtroom 26A regarding plaintiffs' pending 14 Motion for Preliminary Injunction and 15 Motion for Expedited Discovery. Signed by Judge Beryl A. Howell on July 18, 2025. (lcbah4)

Set/Reset Hearings

Set/Reset Hearings: Motion Hearing set for 7/30/2025 at 10:00 AM in Courtroom 26A- In Person before Judge Beryl A. Howell. (mac)

MOTION for Extension of Time to Hold Hearing on Plaintiffs' Motions for Preliminary Injunction and Discovery by AGRICULTURAL MARKETING SERVICE, WILLIAM BEAM, AUBREY J.D. BETTENCOURT, DEPARTMENT OF GOVERNMENT EFFICIENCY, FARM SERVICE AGENCY, AMY GLEASON, JAYE L. HAMBY, ERIN MORRIS, NATIONAL INSTITUTE OF FOOD AND AGRICULTURE, NATURAL RESOURCES CONSERVATION SERVICE, BROOKE ROLLINS, TOM SCHULTZ, UNITED STATES DEPARTMENT OF AGRICULTURE, UNITED STATES FOREST SERVICE. (Attachments: # 1 Text of Proposed Order)(Bardo, John) (Entered: 07/22/2025)

Order on Motion for Extension of Time to

Set/Reset Hearings

MINUTE ORDER (paperless) GRANTING, over plaintiffs' objection, defendants' 25 Motion to Reschedule the Hearing on Plaintiffs' Motion for Preliminary Injunction, and RESCHEDULING the July 30, 2025 hearing for August 6, 2025 at 10:00 AM in-person in Courtroom 26A. Signed by Judge Beryl A. Howell on July 23, 2025. (lcbah4)

Set/Reset Hearings: Motion Hearing set for 8/6/2025 at 10:00 AM in Courtroom 26A- In Person before Judge Beryl A. Howell. (mac)

NOTICE OF FACTUAL DEVELOPMENT by AGROECOLOGY COMMONS, INSTITUTE FOR AGRICULTURE AND TRADE POLICY, OAKVILLE BLUEGRASS COOPERATIVE, PROVIDENCE FARM COLLECTIVE CORP., URBAN SUSTAINABILITY DIRECTORS NETWORK (Attachments: # 1 Exhibit A)(Bainbridge, Holly) (Entered: 07/24/2025)

1 Exhibit A

View on RECAP

Notice (Other)

NOTICE: Members of the public or media who wish to listen to live audio of the hearing scheduled for August 6, 2025 at 10:00AM ET, without physically attending the proceeding, may do so by dialing the Toll Free Number: 833-990-9400, Meeting ID: 491822013. Any use of the public access telephone line requires adherence to the general prohibition against photographing, recording, livestreaming, and rebroadcasting of court proceedings (including those held by telephone or videoconference), as set out in Standing Order No. 24-31 (JEB). Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or other sanctions deemed necessary by the Court. (mac)

Motion Hearing

Minute Entry for proceedings held before Judge Beryl A. Howell: Motion Hearing held on 8/6/2025 re 14 Motion for Preliminary Injunction. The Court Heard Oral Arguments From The Parties And Will Reserve Judgment. (Court Reporter ELIZABETH DAVILA.) (mac)

.Order

MINUTE ORDER (paperless) DIRECTING defendants to file a supplemental notice by August 7, 2025 at 5:00 PM, indicating which of plaintiffs' grants were funded pursuant to either programs or appropriated funds that have since been eliminated, per counsel's representation at today's motions hearing, with citation to the specific statutory provision effecting such elimination. Signed by Judge Beryl A. Howell on August 6, 2025. (lcbah4)

Set/Reset Deadlines

Set/Reset Deadlines: Plaintiff's Supplemental Notice due no later than 5:00PM on 8/7/2025. (mac)

NOTICE by AGRICULTURAL MARKETING SERVICE, WILLIAM BEAM, AUBREY J.D. BETTENCOURT, DEPARTMENT OF GOVERNMENT EFFICIENCY, FARM SERVICE AGENCY, AMY GLEASON, JAYE L. HAMBY, ERIN MORRIS, NATIONAL INSTITUTE OF FOOD AND AGRICULTURE, NATURAL RESOURCES CONSERVATION SERVICE, BROOKE ROLLINS, TOM SCHULTZ, UNITED STATES DEPARTMENT OF AGRICULTURE, UNITED STATES FOREST SERVICE (Bardo, John) (Entered: 08/07/2025)

RESPONSE re 27 Notice (Other), filed by AGROECOLOGY COMMONS, INSTITUTE FOR AGRICULTURE AND TRADE POLICY, OAKVILLE BLUEGRASS COOPERATIVE, PROVIDENCE FARM COLLECTIVE CORP., URBAN SUSTAINABILITY DIRECTORS NETWORK. (Attachments: # 1 Exhibit A (U.S. Forest Service Handbook))(Muraskin, David) (Entered: 08/07/2025)

1 Exhibit A (U.S. Forest Service Handbook)

View on PACER

ORDER GRANTING IN PART and DENYING IN PART plaintiffs' 14 Motion for Preliminary Injunction and DENYING plaintiffs' 15 Motion for Expedited Discovery. See Order for further details. Signed by Judge Beryl A. Howell on August 14, 2025. (lcbah4) (Entered: 08/14/2025)

MEMORANDUM OPINION regarding plaintiffs' 14 Motion for Preliminary Injunction and plaintiffs' 15 Motion for Expedited Discovery. Signed by Judge Beryl A. Howell on August 14, 2025. (lcbah4)

Extension of Time to

Response to motion

Order on Motion for Extension of Time to

Set/Reset Deadlines