Case: Cabrera v. Department of Labor

Cabrera v. C.D.

COMPLAINT against All Defendants ( Filing fee $ 405 receipt number ADCDC-11763355) filed by ABIGAIL SHAUGER, MADDEX DAVIS-NEWMAN, C.D., DEONDRE BURKES, ANARIA CABRERA, ATHENA SASSER, LOGAN CHRISTENSEN. (Attachments: # 1 Civil Cover Sheet, # 2 Summons U.S. Department of Labor, # 3 Summons Chavez-DeRemer, # 4 Summons Attorney General, # 5 Summons USAO)(Pulver, Adam) (Entered: 06/18/2025)

Case Assigned/Reassigned

Status Report Order

NOTICE of Appearance by Michael T. Kirkpatrick on behalf of All Plaintiffs (Kirkpatrick, Michael) (Entered: 06/18/2025)

MOTION for Preliminary Injunction, MOTION to Stay by DEONDRE BURKES, C.D., ANARIA CABRERA, LOGAN CHRISTENSEN, MADDEX DAVIS-NEWMAN, ATHENA SASSER, ABIGAIL SHAUGER. (Attachments: # 1 Memorandum in Support, # 2 Declaration of Adam R. Pulver, # 3 Declaration of Anaria Cabrera, # 4 Declaration of Deondre Burkes, # 5 Declaration of Maddex Davis-Newman, # 6 Declaration of Athena Sasser, # 7 Declaration of Logan Christensen, # 8 Declaration of Abigail Shauger, # 9 Declaration of Tiffany Davis, # 10 Text of Proposed Order)(Pulver, Adam) (Entered: 06/18/2025)

MOTION to Certify Class by DEONDRE BURKES, C.D., ANARIA CABRERA, LOGAN CHRISTENSEN, MADDEX DAVIS-NEWMAN, ATHENA SASSER, ABIGAIL SHAUGER. (Attachments: # 1 Memorandum in Support of Class Certification, # 2 Declaration of Adam Pulver, # 3 Declaration of Scott McCoy, # 4 Text of Proposed Order)(Kirkpatrick, Michael) (Entered: 06/18/2025)

Case Assigned to Judge Dabney L. Friedrich. (znmw)

SUMMONS (4) Issued Electronically as to All Defendants, U.S. Attorney and U.S. Attorney General (Attachments: # 1 Notice and Consent)(znmw) (Entered: 06/18/2025)

NOTICE of Appearance by Arthur Ago on behalf of All Plaintiffs (Ago, Arthur) (Entered: 06/18/2025)

MINUTE ORDER directing the parties to confer and jointly propose a briefing and hearing schedule regarding the plaintiffs' 3 Motion for Preliminary Injunction and 4 Motion to Certify Class on or before June 20, 2025. So ordered by Judge Dabney L. Friedrich on June 18, 2025 (lcdlf3)

NOTICE of Appearance by Zareen Iqbal on behalf of All Defendants (Iqbal, Zareen) (Entered: 06/19/2025)

Notice of Provisional/Government Not Certified Status

Scheduling Order

RESOLVED.....NOTICE of Provisional/Government Not Certified Status re 6 NOTICE of Appearance by Arthur Ago on behalf of All Plaintiffs (Ago, Arthur).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 6/27/2025. (zapb) Modified on 6/20/2025 (zapb).

PROPOSED BRIEFING SCHEDULE re 3 MOTION for Preliminary Injunction MOTION to Stay, 4 MOTION to Certify Class by DEONDRE BURKES, C.D., ANARIA CABRERA, LOGAN CHRISTENSEN, MADDEX DAVIS-NEWMAN, ATHENA SASSER, ABIGAIL SHAUGER. (Attachments: # 1 Text of Proposed Order)(Pulver, Adam) (Entered: 06/20/2025)

MINUTE ORDER. Upon consideration of the parties' proposal in their 8 Joint Proposed Briefing and Schedule, and in light of the fact that another court has entered a temporary restraining order (TRO) prohibiting the Department of Labor from taking steps to effectuate the elimination of the Job Corps program, Natl Job Corps Assn v. DOL, No. 25-cv-04641, 2025 WL 1577843, at *1 (S.D.N.Y. June 4, 2025), has extended that order through June 25, 2025, see Minute Order, NJCA, Dkt. 54 (S.D.N.Y. June 17, 2025), and may extend it further, see Joint Proposed Briefing and Schedule, Dkt. 8, at 2, the Court adopts the following schedule: The defendants shall file their opposition to the plaintiffs' 3 Motion for Preliminary Injunction on or before June 27, 2025, and the plaintiffs shall file their reply on or before July 2, 2025. It is further ORDERED that the defendants shall file their opposition to the plaintiffs' 4 Motion to Certify Class on or before July 7, 2025, and the plaintiffs shall file their reply on or before July 14, 2025.Finally, the Court will hold a hearing on the plaintiffs' 3 Motion for a Preliminary Injunction on July 9, 2025 at 1:00 p.m. in Courtroom 24A. If the existing injunction is not extended before the defendants' deadline to close Job Corps centers at the end of June 2025, the plaintiffs may file a motion for temporary restraining order. See Minute Order, NJCA, ECF 54 (S.D.N.Y. June 17, 2025). So ordered by Judge Dabney L. Friedrich on June 20, 2025 (lcdlf3)

STANDARD ORDER in Civil Cases. See text for details. Signed by Judge Dabney L. Friedrich on June 20, 2025 (lcdlf3) (Entered: 06/20/2025)

NOTICE TO THE COURT by LORI CHAVEZ-DEREMER, U.S. DEPARTMENT OF LABOR (Iqbal, Zareen) (Entered: 06/21/2025)

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Carli Raben, Filing fee $ 100, receipt number ADCDC-11778503. Fee Status: Fee Paid. by DEONDRE BURKES, C.D., ANARIA CABRERA, LOGAN CHRISTENSEN, MADDEX DAVIS-NEWMAN, ATHENA SASSER, ABIGAIL SHAUGER. (Attachments: # 1 Declaration of Carli Raben, # 2 Exhibit Certificate of Good Standing for Carli Raben, # 3 Text of Proposed Order Proposed Order - Carli Raben)(Ago, Arthur) (Entered: 06/26/2025)

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

MINUTE ORDER granting 11 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. So Ordered by Judge Dabney L. Friedrich on June 26, 2025. (lcdlf2)

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Scott McCoy, Filing fee $ 100, receipt number ADCDC-11779315. Fee Status: Fee Paid. by DEONDRE BURKES, C.D., ANARIA CABRERA, LOGAN CHRISTENSEN, MADDEX DAVIS-NEWMAN, ATHENA SASSER, ABIGAIL SHAUGER. (Attachments: # 1 Declaration of Scott McCoy, # 2 Exhibit Certificate of Good Standing for Scott McCoy, # 3 Text of Proposed Order Proposed Order - Scott McCoy)(Ago, Arthur) (Entered: 06/26/2025)

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Samuel Boyd, Filing fee $ 100, receipt number ADCDC-11779654. Fee Status: Fee Paid. by DEONDRE BURKES, C.D., ANARIA CABRERA, LOGAN CHRISTENSEN, MADDEX DAVIS-NEWMAN, ATHENA SASSER, ABIGAIL SHAUGER. (Attachments: # 1 Declaration of Samuel Boyd, # 2 Exhibit Certificate of Good Standing for Samuel Boyd, # 3 Text of Proposed Order Proposed Order - Samuel Boyd)(Ago, Arthur) (Entered: 06/26/2025)

MINUTE ORDER granting [12, 13] Motions 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. (lcdlf2) Modified on 6/27/2025 (zsmc).

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Diego Soto, Filing fee $ 100, receipt number ADCDC-11779795. Fee Status: Fee Paid. by DEONDRE BURKES, C.D., ANARIA CABRERA, LOGAN CHRISTENSEN, MADDEX DAVIS-NEWMAN, ATHENA SASSER, ABIGAIL SHAUGER. (Attachments: # 1 Declaration of Diego Soto, # 2 Exhibit Certificate of Good Standing - Diego Soto, # 3 Text of Proposed Order Proposed Order - Diego Soto)(Ago, Arthur) (Entered: 06/26/2025)

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Michael Tafelski, Filing fee $ 100, receipt number ADCDC-11779947. Fee Status: Fee Paid. by DEONDRE BURKES, C.D., ANARIA CABRERA, LOGAN CHRISTENSEN, MADDEX DAVIS-NEWMAN, ATHENA SASSER, ABIGAIL SHAUGER. (Attachments: # 1 Declaration of Michael Tafelski, # 2 Exhibit Certificate of Good Standing for Michael Tafelski, # 3 Text of Proposed Order Proposed Order - Michael Tafelski)(Ago, Arthur) (Entered: 06/26/2025)

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Aaron Fleisher, Filing fee $ 100, receipt number ADCDC-11780076. Fee Status: Fee Paid. by DEONDRE BURKES, C.D., ANARIA CABRERA, LOGAN CHRISTENSEN, MADDEX DAVIS-NEWMAN, ATHENA SASSER, ABIGAIL SHAUGER. (Attachments: # 1 Declaration of Aaron Fleisher, # 2 Exhibit Certificate of Good Standing for Aaron Fleisher, # 3 Text of Proposed Order Proposed Order - Aaron Fleisher)(Ago, Arthur) (Entered: 06/26/2025)

NOTICE of Appearance by Samuel T.S. Boyd on behalf of All Plaintiffs (Boyd, Samuel) (Main Document 17 replaced on 7/1/2025) (zdp). (Entered: 06/27/2025)

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

MINUTE ORDER granting the 14, 15, 16 Motions 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. So Ordered by Judge Dabney L. Friedrich on June 27, 2025. (lcdlf2)

NOTICE of Appearance by Carli Sean Raben on behalf of All Plaintiffs (Raben, Carli) (Main Document 18 replaced on 7/1/2025) (zdp). (Entered: 06/27/2025)

NOTICE of Appearance by Michael Joseph Tafelski on behalf of All Plaintiffs (Tafelski, Michael) (Main Document 19 replaced on 7/1/2025) (zdp). (Entered: 06/27/2025)

Memorandum in opposition to re 3 MOTION for Preliminary Injunction MOTION to Stay filed by LORI CHAVEZ-DEREMER, U.S. DEPARTMENT OF LABOR. (Attachments: # 1 Affidavit, # 2 Affidavit, # 3 Affidavit)(Iqbal, Zareen) (Entered: 06/28/2025)

1 Affidavit

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2 Affidavit

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3 Affidavit

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NOTICE of Proposed Order by LORI CHAVEZ-DEREMER, U.S. DEPARTMENT OF LABOR re 20 Memorandum in Opposition, (Iqbal, Zareen) (Entered: 06/28/2025)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed as to the United States Attorney. Date of Service Upon United States Attorney on 6/18/2025. Answer due for ALL FEDERAL DEFENDANTS by 8/17/2025. (Pulver, Adam) (Entered: 06/29/2025)

NOTICE by LORI CHAVEZ-DEREMER, U.S. DEPARTMENT OF LABOR re 20 Memorandum in Opposition, (Attachments: # 1 Exhibit Exhibit 6 Doc. No. 20-1)(Iqbal, Zareen) (Entered: 07/01/2025)

1 Exhibit Exhibit 6 Doc. No. 20-1

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RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. U.S. DEPARTMENT OF LABOR served on 7/1/2025 (Attachments: # 1 Exhibit Delivery Confirmation)(Kirkpatrick, Michael) (Entered: 07/02/2025)

1 Exhibit Delivery Confirmation

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RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. LORI CHAVEZ-DEREMER served on 7/1/2025 (Attachments: # 1 Exhibit Delivery Confirmation)(Kirkpatrick, Michael) (Entered: 07/02/2025)

1 Exhibit Delivery Confirmation

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NOTICE of Appearance by Zane Muller on behalf of STATE OF WASHINGTON (Muller, Zane) (Entered: 07/02/2025)

AMICUS BRIEF in support of Plaintiff's Motion for Preliminary Injunction by STATE OF WASHINGTON. (Muller, Zane) (Entered: 07/02/2025)

REPLY to opposition to motion re 3 Motion for Preliminary Injunction,,, Motion to Stay,, filed by DEONDRE BURKES, C.D., ANARIA CABRERA, LOGAN CHRISTENSEN, MADDEX DAVIS-NEWMAN, ATHENA SASSER, ABIGAIL SHAUGER. (Pulver, Adam) (Entered: 07/02/2025)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed on United States Attorney General. Date of Service Upon United States Attorney General 07/03/2025. (Attachments: # 1 Exhibit Delivery Confirmation)(Kirkpatrick, Michael) (Entered: 07/03/2025)

Notice of Appearance

Notice of Appearance