Case: American Bar Association v. Executive Office of the President

President Donald Trump

President Donald Trump

President Donald Trump

President Donald Trump

COMPLAINT For Declaratory and Injunctive Relief against All Defendants ( Filing fee $ 405 receipt number ADCDC-11757550) filed by American Bar Association. (Attachments: # 1 Civil Cover Sheet, # 2 Summons, # 3 Summons, # 4 Summons, # 5 Summons, # 6 Summons, # 7 Summons, # 8 Summons, # 9 Summons, # 10 Summons, # 11 Summons, # 12 Summons, # 13 Summons, # 14 Summons, # 15 Summons, # 16 Summons, # 17 Summons, # 18 Summons, # 19 Summons, # 20 Summons, # 21 Summons, # 22 Summons, # 23 Summons, # 24 Summons, # 25 Summons, # 26 Summons, # 27 Summons, # 28 Summons, # 29 Summons, # 30 Summons, # 31 Summons, # 32 Summons, # 33 Summons, # 34 Summons, # 35 Summons, # 36 Summons, # 37 Summons, # 38 Summons, # 39 Summons, # 40 Summons, # 41 Summons, # 42 Summons, # 43 Summons, # 44 Summons, # 45 Summons, # 46 Summons, # 47 Summons, # 48 Summons, # 49 Summons, # 50 Summons, # 51 Summons, # 52 Summons, # 53 Summons, # 54 Summons, # 55 Summons, # 56 Summons, # 57 Summons, # 58 Summons, # 59 Summons, # 60 Summons, # 61 Summons, # 62 Summons, # 63 Summons, # 64 Summons, # 65 Summons, # 66 Summons, # 67 Summons, # 68 Summons, # 69 Summons, # 70 Summons, # 71 Summons, # 72 Summons)(Shackelford, Stephen) (Attachment 1 replaced on 6/18/2025) (znmw). (Entered: 06/16/2025)

1 Civil Cover Sheet

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2 Summons

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3 Summons

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NOTICE of Appearance by Stephen Shackelford, Jr on behalf of American Bar Association (Shackelford, Stephen) (Entered: 06/16/2025)

NOTICE of Appearance by Steven M. Seigel on behalf of American Bar Association (Seigel, Steven) (Entered: 06/16/2025)

NOTICE of Appearance by Justin A. Nelson on behalf of American Bar Association (Nelson, Justin) (Entered: 06/16/2025)

SUMMONS (70) Issued Electronically as to PAUL S. ATKINS, SCOTT BESSENT, PAMELA BONDI, DOUG BURGUM, BRENDAN CARR, CENTRAL INTELLIGENCE AGENCY, JUDY W. CHANG, LORI CHAVEZ-DEREMER, MARK C. CHRISTIE, DOUGLAS A. COLLINS, CONSUMER FINANCIAL PROTECTION BUREAU, CAROLINE A. CRENSHAW, DEPARTMENT OF AGRICULTURE, DEPARTMENT OF COMMERCE, DEPARTMENT OF DEFENSE, DEPARTMENT OF ENERGY, DEPARTMENT OF HEALTH AND HUMAN SERVICES, DEPARTMENT OF HOMELAND SECURITY, DEPARTMENT OF LABOR, DEPARTMENT OF STATE, DEPARTMENT OF THE INTERIOR, DEPARTMENT OF THE TREASURY, DEPARTMENT OF TRANSPORTATION, DEPARTMENT OF VETERANS AFFAIRS, SEAN DUFFY, STEPHEN EHEKIAN, ENVIRONMENTAL PROTECTION AGENCY, EQUAL EMPLOYMENT OPPORTUNITY COMMISSION, EXECUTIVE OFFICE OF THE PRESIDENT, CHARLES EZELL, FEDERAL BUREAU OF INVESTIGATION, FEDERAL COMMUNICATIONS COMMISSION, FEDERAL ENERGY REGULATORY COMMISSION, FEDERAL TRADE COMMISSION, ANDREW N. FERGUSON, TULSI GABBARD, GENERAL SERVICES ADMINISTRATION, ANNA M. GOMEZ, PETER B. HEGSETH, MELISSA ANN HOLYOAK, INTERNAL REVENUE SERVICE, ROBERT F. KENNEDY, JR, WILLIAM HOLLIS LONG, II, HOWARD W. LUTNICK, MARK M. MEADOR, KRISTI NOEM, OFFICE OF MANAGEMENT AND BUDGET, OFFICE OF PERSONNEL MANAGEMENT, OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, KASH PATEL, HESTER M. PIERCE, JOHN L. RATCLIFFE, BROOKE L. ROLLINS, DAVID ROSNER, MARCO RUBIO, SECURITIES AND EXCHANGE COMMISSION, LINSAY S. SEE, NATHAN SIMINGTON, GEOFFREY STARKS, COKE MORGAN STEWART, DOUGLAS TULINO, U.S. DEPARTMENT OF JUSTICE, U.S. POST OFFICE, UNITED STATES OF AMERICA, UNITED STATES PATENT AND TRADEMARK OFFICE, MARK T. UYEDA, RUSSELL VOUGHT (2), CHRIS WRIGHT, LEE M. ZELDIN, and U.S. Attorney General (Attachments: # 1 Notice and Consent)(znmw) (Entered: 06/18/2025)

REQUEST FOR SUMMONS TO ISSUE filed by AMERICAN BAR ASSOCIATION. Related document: 1 Complaint,,,,, filed by AMERICAN BAR ASSOCIATION.(Shackelford, Stephen) (Entered: 06/18/2025)

SUMMONS (1) Issued Electronically as to ANDREA R. LUCAS. (mg) (Entered: 06/18/2025)

Case Assigned/Reassigned

Case Assigned to Judge Amir H. Ali. (znmw)

Notice of Error- New Case

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 U.S. Attorney and Andrea R. Lucas (summons formatted poorly) using the event Request for Summons to Issue; do not date summonses. (znmw)

NOTICE of Appearance by Davida Brook on behalf of AMERICAN BAR ASSOCIATION (Brook, Davida) (Entered: 06/24/2025)

MOTION to Intervene by ANDREW DELANEY. (Attachments: # 1 Proposed Motion to Dismiss)(mg) (Entered: 06/27/2025)

ERRATA by ANDREW DELANEY re 11 Motion to Intervene. (mg) (Entered: 06/27/2025)

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Jillian Hewitt, Filing fee $ 100, receipt number BDCDC-11776658. Fee Status: Fee Paid. by AMERICAN BAR ASSOCIATION. (Attachments: # 1 Declaration of Jillian Hewitt, # 2 Text of Proposed Order)(Shackelford, Stephen) (Entered: 06/25/2025)

ERRATA by ANDREW DELANEY re 11 Motion to Intervene. (mg) (Entered: 06/27/2025)

REQUEST FOR SUMMONS TO ISSUE filed by AMERICAN BAR ASSOCIATION. Related document: 1 Complaint,,,,, filed by AMERICAN BAR ASSOCIATION.(Shackelford, Stephen) (Entered: 06/26/2025)

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Katherine M. Peaslee, Filing fee $ 100, receipt number ADCDC-11783138. Fee Status: Fee Paid. by AMERICAN BAR ASSOCIATION. (Attachments: # 1 Declaration of Katherine M. Peaslee, # 2 Text of Proposed Order)(Shackelford, Stephen) (Entered: 06/27/2025)

Order on Motion for Leave to Appear Pro Hac Vice

MINUTE ORDER granting 9 motion for leave to appear pro hac vice. Attorney Jillian Hewitt 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 6/27/2025. (lcaha3)

NOTICE of Appearance by Jillian Shafer Hewitt on behalf of AMERICAN BAR ASSOCIATION (Hewitt, Jillian) (Entered: 06/30/2025)

Order on Motion for Leave to Appear Pro Hac Vice

MINUTE ORDER granting 14 motion for leave to appear pro hac vice. Attorney Katherine M. Peaslee 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 6/30/2025. (lcaha3)

SUMMONS (1) Issued Electronically as to U.S. Attorney (mg) (Entered: 07/01/2025)

Memorandum in opposition to re 11 MOTION to Intervene filed by AMERICAN BAR ASSOCIATION. (Shackelford, Stephen) (Entered: 07/08/2025)

REPLY to opposition to motion re 11 Motion to Intervene filed by ANDREW DELANEY. (mg) (Entered: 07/10/2025)

NOTICE of Appearance by Katherine Marie Peaslee on behalf of AMERICAN BAR ASSOCIATION (Peaslee, Katherine) (Entered: 07/10/2025)

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 7/14/2025. (lcaha3) (Entered: 07/14/2025)

NOTICE of Appearance by James Wen on behalf of All Defendants (Wen, James) (Entered: 08/08/2025)

MOTION to Dismiss for Lack of Jurisdiction by PAUL S. ATKINS, SCOTT BESSENT, PAMELA J. BONDI, DOUG BURGUM, BRENDAN CARR, CENTRAL INTELLIGENCE AGENCY, JUDY W. CHANG, LORI CHAVEZ-DEREMER, MARK C. CHRISTIE, DOUGLAS A. COLLINS, CONSUMER FINANCIAL PROTECTION BUREAU, CAROLINE A. CRENSHAW, DEPARTMENT OF AGRICULTURE, DEPARTMENT OF COMMERCE, DEPARTMENT OF DEFENSE, DEPARTMENT OF ENERGY, DEPARTMENT OF HEALTH AND HUMAN SERVICES, DEPARTMENT OF HOMELAND SECURITY, DEPARTMENT OF LABOR, DEPARTMENT OF STATE, DEPARTMENT OF THE INTERIOR, DEPARTMENT OF THE TREASURY, DEPARTMENT OF TRANSPORTATION, DEPARTMENT OF VETERANS AFFAIRS, SEAN DUFFY, STEPHEN EHEKIAN, ENVIRONMENTAL PROTECTION AGENCY, EQUAL EMPLOYMENT OPPORTUNITY COMMISSION, EXECUTIVE OFFICE OF THE PRESIDENT, CHARLES EZELL, FEDERAL BUREAU OF INVESTIGATION, FEDERAL COMMUNICATIONS COMMISSION, FEDERAL ENERGY REGULATORY COMMISSION, FEDERAL TRADE COMMISSION, ANDREW N. FERGUSON, TULSI GABBARD, GENERAL SERVICES ADMINISTRATION, ANNA M. GOMEZ, PETER B. HEGSETH, MELISSA ANN HOLYOAK, INTERNAL REVENUE SERVICE, ROBERT F. KENNEDY, JR, WILLIAM HOLLIS LONG, II, ANDREA R. LUCAS, HOWARD W. LUTNICK, MARK M. MEADOR, KRISTI NOEM, OFFICE OF MANAGEMENT AND BUDGET, OFFICE OF PERSONNEL MANAGEMENT, OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, KASH PATEL, HESTER M. PIERCE, JOHN L. RATCLIFFE, BROOKE L. ROLLINS, DAVID ROSNER, MARCO A. RUBIO, SECURITIES AND EXCHANGE COMMISSION, LINSAY S. SEE, NATHAN SIMINGTON, GEOFFREY STARKS, COKE MORGAN STEWART, DOUGLAS TULINO, U.S. DEPARTMENT OF JUSTICE, U.S. POST OFFICE, UNITED STATES OF AMERICA, UNITED STATES PATENT AND TRADEMARK OFFICE, MARK T. UYEDA, RUSSELL VOUGHT, CHRIS WRIGHT, LEE M. ZELDIN. (Attachments: # 1 Memorandum in Support, # 2 Text of Proposed Order)(Wen, James) (Entered: 08/08/2025)

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NOTICE of Appearance by Neal Stuart Manne on behalf of AMERICAN BAR ASSOCIATION (Manne, Neal) (Entered: 08/18/2025)

Unopposed MOTION for Extension of Time to File Response/Reply as to 22 MOTION to Dismiss for Lack of Jurisdiction by AMERICAN BAR ASSOCIATION. (Attachments: # 1 Text of Proposed Order)(Hewitt, Jillian) (Entered: 08/19/2025)

MINUTE ORDER. Plaintiff's 24 unopposed motion for an extension of time to file a response to Defendants' motion to dismiss is granted. Plaintiff shall file its response by September 24, 2025. Defendants shall file their reply by October 15, 2025. Signed by Judge Amir H. Ali on 8/20/2025. (lcaha3)

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

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Beatrice Franklin, Filing fee $ 100, receipt number ADCDC-11914790. Fee Status: Fee Paid. by AMERICAN BAR ASSOCIATION. (Attachments: # 1 Declaration, # 2 Text of Proposed Order)(Shackelford, Stephen) (Entered: 08/26/2025)

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Eric R. Olson, Filing fee $ 100, receipt number ADCDC-11975426. Fee Status: Fee Paid. by LAW FIRM PARTNERS UNITED INC.. (Attachments: # 1 Declaration)(Citron, Eric) (Entered: 09/22/2025)

Memorandum in opposition to re 22 MOTION to Dismiss for Lack of Jurisdiction filed by AMERICAN BAR ASSOCIATION. (Shackelford, Stephen) (Entered: 09/24/2025)

Unopposed MOTION for Leave to File Amicus Brief by LAW FIRM PARTNERS UNITED INC.. (Attachments: # 1 Exhibit Amicus Brief, # 2 Text of Proposed Order)(Citron, Eric) (Entered: 09/26/2025)

Unopposed MOTION for Leave to File Amicus Briefin Support of Plaintiff's Opposition to Motion to Dismiss by PAST PRESIDENTS OF THE DC BAR. (Attachments: # 1 Exhibit amicus brief, # 2 Appendix list of amici, # 3 Text of Proposed Order)(Ferster, Andrea) (Entered: 10/02/2025)

NOTICE of Appearance by Andrea C. Ferster on behalf of PAST PRESIDENTS OF THE DC BAR (Ferster, Andrea) (Entered: 10/05/2025)

MINUTE ORDER granting 25 motion for leave to appear pro hac vice. Attorney Beatrice Franklin 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 10/6/2025. (lcaha3)

Order on Motion for Leave to Appear Pro Hac Vice

MINUTE ORDER granting 26 motion for leave to appear pro hac vice. Attorney Eric R. Olson 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 10/6/2025. (lcaha3)

NOTICE of Appearance by Eric R. Olson on behalf of LAW FIRM PARTNERS UNITED INC. (Olson, Eric) (Entered: 10/07/2025)

NOTICE of Appearance by Beatrice Franklin on behalf of AMERICAN BAR ASSOCIATION (Franklin, Beatrice) (Entered: 10/15/2025)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed as to the United States Attorney. Date of Service Upon United States Attorney on 7/15/2025. Answer due for ALL FEDERAL DEFENDANTS by 9/13/2025. (Hewitt, Jillian) (Entered: 10/28/2025)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed on United States Attorney General. Date of Service Upon United States Attorney General 07/15/2025. (Hewitt, Jillian) (Entered: 10/28/2025)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. PAUL S. ATKINS served on 7/15/2025; SCOTT BESSENT served on 7/15/2025; DOUG BURGUM served on 7/17/2025; BRENDAN T. CARR served on 7/15/2025; JUDY W. CHANG served on 7/14/2025; LORI CHAVEZ-DEREMER served on 7/14/2025; DOUGLAS A. COLLINS served on 7/15/2025; CONSUMER FINANCIAL PROTECTION BUREAU served on 7/14/2025; CAROLINE A. CRENSHAW served on 7/14/2025; DEPARTMENT OF AGRICULTURE served on 7/14/2025; DEPARTMENT OF COMMERCE served on 7/15/2025; DEPARTMENT OF DEFENSE served on 7/15/2025; DEPARTMENT OF ENERGY served on 7/22/2025; DEPARTMENT OF HEALTH AND HUMAN SERVICES served on 7/14/2025; DEPARTMENT OF HOMELAND SECURITY served on 7/14/2025; DEPARTMENT OF LABOR served on 7/14/2025; DEPARTMENT OF STATE served on 7/15/2025; DEPARTMENT OF THE INTERIOR served on 7/14/2025; DEPARTMENT OF THE TREASURY served on 7/15/2025; DEPARTMENT OF TRANSPORTATION served on 7/14/2025; DEPARTMENT OF VETERANS AFFAIRS served on 7/15/2025; SEAN P. DUFFY served on 7/14/2025; STEPHEN EHEKIAN served on 7/18/2025; ENVIRONMENTAL PROTECTION AGENCY served on 7/15/2025; EQUAL EMPLOYMENT OPPORTUNITY COMMISSION served on 7/18/2025; EXECUTIVE OFFICE OF THE PRESIDENT served on 7/21/2025; CHARLES EZELL served on 7/14/2025; FEDERAL BUREAU OF INVESTIGATION served on 7/15/2025; FEDERAL COMMUNICATIONS COMMISSION served on 7/15/2025; FEDERAL ENERGY REGULATORY COMMISSION served on 7/18/2025; FEDERAL TRADE COMMISSION served on 7/15/2025; ANDREW N. FERGUSON served on 7/18/2025; GENERAL SERVICES ADMINISTRATION served on 7/14/2025; ANNA M. GOMEZ served on 7/15/2025; PETER B. HEGSETH served on 7/15/2025; MELISSA ANN HOLYOAK served on 7/15/2025; INTERNAL REVENUE SERVICE served on 7/14/2025; ROBERT F. KENNEDY, JR served on 7/14/2025; WILLIAM HOLLIS LONG, II served on 7/29/2025; ANDREA R. LUCAS served on 7/14/2025; HOWARD W. LUTNICK served on 7/15/2025; MARK M. MEADOR served on 7/15/2025; KRISTI NOEM served on 7/14/2025; OFFICE OF MANAGEMENT AND BUDGET served on 7/21/2025; OFFICE OF PERSONNEL MANAGEMENT served on 7/14/2025; KASH PATEL served on 7/15/2025; HESTER M. PIERCE served on 7/14/2025; JOHN L. RATCLIFFE served on 7/15/2025; BROOKE L. ROLLINS served on 7/14/2025; DAVID ROSNER served on 7/14/2025; MARCO A. RUBIO served on 7/15/2025; SECURITIES AND EXCHANGE COMMISSION served on 7/14/2025; LINSAY S. SEE served on 7/14/2025; COKE MORGAN STEWART served on 7/17/2025; DOUGLAS TULINO served on 7/16/2025; U.S. DEPARTMENT OF JUSTICE served on 7/15/2025; U.S. POST OFFICE served on 7/16/2025; UNITED STATES OF AMERICA served on 7/15/2025; UNITED STATES PATENT AND TRADEMARK OFFICE served on 7/14/2025; MARK T. UYEDA served on 7/14/2025; RUSSELL T. VOUGHT served on 7/21/2025; CHRIS WRIGHT served on 7/14/2025; LEE M. ZELDIN served on 7/15/2025 (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C)(Hewitt, Jillian) (Entered: 10/28/2025)

Mail Returned as Undeliverable re Minute Order entered on 8/20/2025; Sent to Andrew Delaney; New Address: Unknown; Unable to Forward. (zalh) (Entered: 11/26/2025)

Mail Returned as Undeliverable re Minute Orders entered on 10/6/2025; Sent to Andrew Delaney; New Address: Unknown; Unable to Forward. (zalh) (Entered: 11/26/2025)