Case: Air Alliance Houston v. Trump

Legal Defense Fund

Donald Trump

COMPLAINT against All Defendants ( Filing fee $ 405 receipt number ADCDC-11752866) filed by DOWNWINDERS AT RISK, CITIZENS FOR PENNSYLVANIAS FUTURE, ENVIRONMENTAL DEFENSE FUND, ENVIRONMENTAL LAW & POLICY CENTER, CENTER FOR BIOLOGICAL DIVERSITY, ENVIRONMENTAL INTEGRITY PROJECT, AIR ALLIANCE HOUSTON, CLEAN AIR COUNCIL, MONTANA ENVIRONMENTAL INFORMATION CENTER, DAKOTA RESOURCE COUNCIL. (Attachments: # 1 Civil Cover Sheet, # 2 Exhibit 1, # 3 Exhibit 2, # 4 Exhibit 3, # 5 Exhibit 4, # 6 Exhibit 5, # 7 Exhibit 6, # 8 Exhibit 7, # 9 Summons Attorney General Pam Bondi, # 10 Summons Donald Trump, # 11 Summons U.S. Attorney for the District of Columbia, # 12 Summons Lee Zeldin)(Morales, Nicholas) (Entered: 06/12/2025)

1 Civil Cover Sheet

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2 Exhibit 1

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3 Exhibit 2

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4 Exhibit 3

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5 Exhibit 4

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6 Exhibit 5

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7 Exhibit 6

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8 Exhibit 7

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9 Summons Attorney General Pam Bondi

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10 Summons Donald Trump

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11 Summons U.S. Attorney for the District of Columbia

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12 Summons Lee Zeldin

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LCvR 26.1 CERTIFICATE OF DISCLOSURE of Corporate Affiliations and Financial Interests by AIR ALLIANCE HOUSTON, CENTER FOR BIOLOGICAL DIVERSITY, CITIZENS FOR PENNSYLVANIAS FUTURE, CLEAN AIR COUNCIL, DAKOTA RESOURCE COUNCIL, DOWNWINDERS AT RISK, ENVIRONMENTAL DEFENSE FUND, ENVIRONMENTAL INTEGRITY PROJECT, ENVIRONMENTAL LAW & POLICY CENTER, MONTANA ENVIRONMENTAL INFORMATION CENTER, NATURAL RESOURCES DEFENSE COUNCIL, SIERRA CLUB (Attachments: # 1 Rule 26.1 Certificate of Disclosure, # 2 Rule 26.1 Certificate of Disclosure, # 3 Rule 26.1 Certificate of Disclosure, # 4 Rule 26.1 Certificate of Disclosure, # 5 Rule 26.1 Certificate of Disclosure, # 6 Rule 26.1 Certificate of Disclosure, # 7 Rule 26.1 Certificate of Disclosure, # 8 Rule 26.1 Certificate of Disclosure, # 9 Rule 26.1 Certificate of Disclosure, # 10 Rule 26.1 Certificate of Disclosure, # 11 Rule 26.1 Certificate of Disclosure)(Morales, Nicholas) (Entered: 06/12/2025)

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Sarah Buckley, Filing fee $ 100, receipt number ADCDC-11753437. Fee Status: Fee Paid. by NATURAL RESOURCES DEFENSE COUNCIL. (Attachments: # 1 Declaration, # 2 Certificate of Good Standing, # 3 Text of Proposed Order)(Morales, Nicholas) (Entered: 06/12/2025)

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Brian H. Lynk, Filing fee $ 100, receipt number ADCDC-11753484. Fee Status: Fee Paid. by DAKOTA RESOURCE COUNCIL, ENVIRONMENTAL LAW & POLICY CENTER. (Attachments: # 1 Declaration, # 2 Certificate of Good Standing, # 3 Text of Proposed Order)(Morales, Nicholas) (Entered: 06/12/2025)

SUMMONS (4) Issued Electronically as to DONALD TRUMP, LEE ZELDIN, U.S. Attorney and U.S. Attorney General (Attachments: # 1 Notice and Consent)(znmw) (Entered: 06/16/2025)

Notice of Error- New Case

Case Assigned/Reassigned

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

ENTERED IN ERROR....NOTICE OF NEW CASE ERROR regarding 1 Complaint,,. The following error(s) need correction: Missing summonses- U.S. government. When naming a U.S. government agent or agency as a defendant, you must supply a summons for each defendant & two additional summonses for the U.S. Attorney & U.S. Attorney General. Please submit summons for EPA using the event Request for Summons to Issue. (znmw) Modified on 6/17/2025; Plaintiff has submitted Summons (zdp).

REQUEST FOR SUMMONS TO ISSUE to U.S. Environmental Protection Agency filed by NATURAL RESOURCES DEFENSE COUNCIL, DOWNWINDERS AT RISK, CITIZENS FOR PENNSYLVANIAS FUTURE, ENVIRONMENTAL DEFENSE FUND, SIERRA CLUB, ENVIRONMENTAL LAW & POLICY CENTER, CENTER FOR BIOLOGICAL DIVERSITY, ENVIRONMENTAL INTEGRITY PROJECT, AIR ALLIANCE HOUSTON, CLEAN AIR COUNCIL, MONTANA ENVIRONMENTAL INFORMATION CENTER, DAKOTA RESOURCE COUNCIL. Related document: 1 Complaint,, filed by ENVIRONMENTAL INTEGRITY PROJECT, DOWNWINDERS AT RISK, AIR ALLIANCE HOUSTON, CITIZENS FOR PENNSYLVANIAS FUTURE, DAKOTA RESOURCE COUNCIL, ENVIRONMENTAL LAW & POLICY CENTER, CLEAN AIR COUNCIL, CENTER FOR BIOLOGICAL DIVERSITY, ENVIRONMENTAL DEFENSE FUND, MONTANA ENVIRONMENTAL INFORMATION CENTER.(Morales, Nicholas) (Entered: 06/17/2025)

NOTICE of Appearance by Katherine K. Desormeau on behalf of NATURAL RESOURCES DEFENSE COUNCIL (Desormeau, Katherine) (Entered: 06/17/2025)

Order on Motion for Leave to Appear Pro Hac Vice

MINUTE ORDER granting 4 Motion for Leave to Appear Pro Hac Vice 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 Paul L. Friedman on June 17, 2025. (lcjd) Modified on 6/20/2025 to correct docket text(zjm).

NOTICE of Appearance by Brian Hamilton Lynk on behalf of DAKOTA RESOURCE COUNCIL, ENVIRONMENTAL LAW & POLICY CENTER (Lynk, Brian) (Entered: 06/18/2025)

NOTICE of Appearance by Shaun A Goho on behalf of CITIZENS FOR PENNSYLVANIAS FUTURE (Goho, Shaun) (Entered: 06/20/2025)

SUMMONS (1) Issued Electronically as to U.S. ENVIRONMENTAL PROTECTION AGENCY. (Attachments: # 1 Notice and Consent)(zjm) (Entered: 06/20/2025)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed as to the United States Attorney. Date of Service Upon United States Attorney on 6/17/2025. Answer due for ALL FEDERAL DEFENDANTS by 8/16/2025. (Morales, Nicholas) (Entered: 06/23/2025)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed on United States Attorney General. Date of Service Upon United States Attorney General 6/20/25. (Morales, Nicholas) (Entered: 06/23/2025)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. LEE M. ZELDIN served on 6/18/2025 (Morales, Nicholas) (Entered: 06/23/2025)

ERRATA by AIR ALLIANCE HOUSTON, CLEAN AIR COUNCIL, DOWNWINDERS AT RISK, MONTANA ENVIRONMENTAL INFORMATION CENTER, SIERRA CLUB re 3 Motion for Leave to Appear Pro Hac Vice,. (Attachments: # 1 Declaration)(Morales, Nicholas) (Entered: 06/23/2025)

Order on Motion for Leave to Appear Pro Hac Vice

MINUTE ORDER granting 3 Motion for Leave to Appear Pro Hac Vice 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 Paul L. Friedman on June 25, 2025. (lcjd)

NOTICE of Appearance by Ryan Maher on behalf of CENTER FOR BIOLOGICAL DIVERSITY (Maher, Ryan) (Main Document 15 replaced on 6/30/2025) (zjm). (Entered: 06/26/2025)

NOTICE of Appearance by Sarah A. Buckley on behalf of NATURAL RESOURCES DEFENSE COUNCIL (Buckley, Sarah) (Entered: 06/26/2025)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. DONALD TRUMP served on 7/1/2025 (Morales, Nicholas) (Entered: 07/01/2025)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. U.S. ENVIRONMENTAL PROTECTION AGENCY served on 6/23/2025 (Morales, Nicholas) (Entered: 07/02/2025)

ENTERED IN ERROR.....NOTICE of Appearance by Richard Yates, III on behalf of ENVIRONMENTAL DEFENSE FUND (Yates, Richard) Modified on 7/15/2025 (zjm). (Entered: 07/14/2025)

NOTICE of Appearance by Surbhi Sarang on behalf of ENVIRONMENTAL DEFENSE FUND (Sarang, Surbhi) (Entered: 07/15/2025)

NOTICE of Appearance by Richard Yates, III on behalf of ENVIRONMENTAL DEFENSE FUND (Yates, Richard) (Entered: 07/15/2025)

Notice of Error

NOTICE OF ERROR regarding 19 Notice of Appearance. The following error(s) need correction: Missing attorney signature- signature on document must match PACER login. Also, form filed as fillable PDF. Please file form in a non-fillable PDF format. Please refile. (zjm)

NOTICE of Appearance by Laura Jane Brown on behalf of All Defendants (Brown, Laura) (Entered: 07/23/2025)

NOTICE of Appearance by Zoe Palenik on behalf of All Defendants (Palenik, Zoe) (Entered: 07/23/2025)

Consent MOTION for Extension of Time to File Answer or Responsive Pleading by DONALD TRUMP, U.S. ENVIRONMENTAL PROTECTION AGENCY, LEE M. ZELDIN. (Attachments: # 1 Text of Proposed Order)(Brown, Laura) (Entered: 07/25/2025)

1 Text of Proposed Order

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Order on Motion for Extension of Time to Answer

MINUTE ORDER: Upon consideration of defendants' 24 Consent Motion to Extend Time to File a Responsive Pleading, defendants' motion is GRANTED. Defendants shall respond to the complaint on or before September 5, 2025. Signed by Judge Paul L. Friedman on July 28, 2025. (lcjd)

NOTICE of Appearance by Sean H. Donahue on behalf of ENVIRONMENTAL DEFENSE FUND (Donahue, Sean) (Entered: 07/29/2025)

MOTION to Hold in Abeyance or alternatively, MOTION for Extension of Time to File Answer by DONALD TRUMP, U.S. ENVIRONMENTAL PROTECTION AGENCY, LEE M. ZELDIN. (Attachments: # 1 Text of Proposed Order)(Brown, Laura) (Entered: 08/05/2025)

ENTERED IN ERROR.....NOTICE of Appearance by Abel J. Russ on behalf of ENVIRONMENTAL INTEGRITY PROJECT (Russ, Abel) Modified on 8/6/2025; refiled as docket entry 28 (znmw). (Entered: 08/06/2025)

NOTICE of Appearance by Abel J. Russ on behalf of ENVIRONMENTAL INTEGRITY PROJECT (Russ, Abel) (Entered: 08/06/2025)

Unopposed MOTION to Intervene and to Defer Filing Pleading by TALEN MONTANA, LLC. (Attachments: # 1 Memorandum in Support, # 2 Exhibit 1, # 3 Exhibit 2, # 4 Text of Proposed Order, # 5 Rule 26.1 Certificate of Disclosure)(Frank, Joshua) (Entered: 08/08/2025)

1 Memorandum in Support

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2 Exhibit 1

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3 Exhibit 2

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4 Text of Proposed Order

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5 Rule 26.1 Certificate of Disclosure

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NOTICE of Appearance by Joshua B. Frank on behalf of TALEN MONTANA, LLC (Frank, Joshua) (Entered: 08/08/2025)

MOTION for Leave to File Supplemental Complaint by AIR ALLIANCE HOUSTON, CENTER FOR BIOLOGICAL DIVERSITY, CITIZENS FOR PENNSYLVANIAS FUTURE, CLEAN AIR COUNCIL, DAKOTA RESOURCE COUNCIL, DOWNWINDERS AT RISK, ENVIRONMENTAL DEFENSE FUND, ENVIRONMENTAL INTEGRITY PROJECT, ENVIRONMENTAL LAW & POLICY CENTER, MONTANA ENVIRONMENTAL INFORMATION CENTER, NATURAL RESOURCES DEFENSE COUNCIL, SIERRA CLUB. (Attachments: # 1 Exhibit A, # 2 Exhibit 1, # 3 Exhibit 1A, # 4 Exhibit 2, # 5 Exhibit 3, # 6 Exhibit 4, # 7 Exhibit 5, # 8 Exhibit 6, # 9 Exhibit 7, # 10 Text of Proposed Order)(Morales, Nicholas) (Entered: 08/08/2025)

RESPONSE re 31 MOTION for Leave to File Supplemental Complaint filed by DONALD TRUMP, U.S. ENVIRONMENTAL PROTECTION AGENCY, LEE M. ZELDIN. (Brown, Laura) (Entered: 08/08/2025)

ORDER granting plaintiffs' 31 Motion for Leave to File Supplemental Complaint. See Order for details. Signed by Judge Paul L. Friedman on August 12, 2025. (lcjd) (Entered: 08/12/2025)

Memorandum in opposition to re 26 MOTION to Hold in Abeyance or alternatively MOTION for Extension of Time to File Answer filed by AIR ALLIANCE HOUSTON, CENTER FOR BIOLOGICAL DIVERSITY, CITIZENS FOR PENNSYLVANIAS FUTURE, CLEAN AIR COUNCIL, DAKOTA RESOURCE COUNCIL, DOWNWINDERS AT RISK, ENVIRONMENTAL DEFENSE FUND, ENVIRONMENTAL INTEGRITY PROJECT, ENVIRONMENTAL LAW & POLICY CENTER, MONTANA ENVIRONMENTAL INFORMATION CENTER, NATURAL RESOURCES DEFENSE COUNCIL, SIERRA CLUB. (Attachments: # 1 Exhibit Ex. 1-9)(Buckley, Sarah) (Entered: 08/19/2025)