Case: Los Angeles Press Club v. Kristi Noem

Los Angeles Press Club v. Noem

Los Angeles Press Club v. Noem

Los Angeles Press Club et al. v. Noem et al.

U.S. Court of Appeals for the Ninth Circuit

Los Angeles Press Club et al. v. Noem et al.

U.S. Court of Appeals for the Ninth Circuit

Los Angeles Press Club et al. v. Noem et al.

Los Angeles Press Club et al. v. Noem et al.

COMPLAINT Receipt No: ACACDC-39935670 - Fee: $405, filed by Plaintiff CHARLES XU, Sean Beckner-Carmitchel, Benjamin Adam Climer, NewsGuild-Communications Workers of America, Abigail Olmeda, Los Angeles Press Club, Ryanne Mena, Lexis-Olivier Ray. (Attorney Matthew B Borden added to party Sean Beckner-Carmitchel(pty:pla), Attorney Matthew B Borden added to party Benjamin Adam Climer(pty:pla), Attorney Matthew B Borden added to party Los Angeles Press Club(pty:pla), Attorney Matthew B Borden added to party Ryanne Mena(pty:pla), Attorney Matthew B Borden added to party NewsGuild-Communications Workers of America(pty:pla), Attorney Matthew B Borden added to party Abigail Olmeda(pty:pla), Attorney Matthew B Borden added to party Lexis-Olivier Ray(pty:pla), Attorney Matthew B Borden added to party CHARLES XU(pty:pla))(Borden, Matthew) (Entered: 06/18/2025)

CIVIL COVER SHEET filed by Plaintiffs Sean Beckner-Carmitchel, Benjamin Adam Climer, Los Angeles Press Club, Ryanne Mena, NewsGuild-Communications Workers of America, Abigail Olmeda, Lexis-Olivier Ray, CHARLES XU. (Borden, Matthew) (Entered: 06/18/2025)

Request for Clerk to Issue Summons on Complaint (Attorney Civil Case Opening),,, 1 filed by Plaintiffs Sean Beckner-Carmitchel, Benjamin Adam Climer, Los Angeles Press Club, Ryanne Mena, NewsGuild-Communications Workers of America, Abigail Olmeda, Lexis-Olivier Ray, CHARLES XU. (Borden, Matthew) (Entered: 06/18/2025)

NOTICE of Interested Parties filed by Plaintiffs All Plaintiffs, (Borden, Matthew) (Entered: 06/18/2025)

Notice of Related Cases filed by Plaintiffs Sean Beckner-Carmitchel, Benjamin Adam Climer, Los Angeles Press Club, Ryanne Mena, NewsGuild-Communications Workers of America, Abigail Olmeda, Lexis-Olivier Ray, CHARLES XU. (Borden, Matthew) (Entered: 06/18/2025)

EX PARTE APPLICATION for Temporary Restraining Order and Order to Show Cause Re: Preliminary Injunction filed by Plaintiffs Sean Beckner-Carmitchel, Benjamin Adam Climer, Los Angeles Press Club, Ryanne Mena, NewsGuild-Communications Workers of America, Abigail Olmeda, Lexis-Olivier Ray, CHARLES XU. (Attachments: # 1 MPA in support of TRO, # 2 Declaration of Peter Eliasberg (TRO Notice), # 3 Decl. of Kerlikowske, # 4 Decl. of Olmeda, # 5 Decl. of Rose, # 6 Decl. of Beckner-Carmitchel, # 7 Decl. of Climer, # 8 Decl. of Xu, # 9 Decl. of Carbonati, # 10 Decl. of Bell, # 11 Decl. of Cruz, # 12 Decl. of Dr. Roshini Haar, # 13 Decl. of Egan, # 14 Decl. of Lopez, # 15 Decl. of Alcorn, # 16 Decl. of Schleuss, # 17 Decl. of Ray, # 18 Decl. of Paz, # 19 Decl. of Horowicz, # 20 Decl. of Ochoa, # 21 Decl. of Reyna, # 22 Decl. of Mena, # 23 Decl. of Soqui, # 24 Decl. of Petrosian, # 25 Suppl. Decl. of Beckner-Carmitchel, # 26 Proposed Order) (Borden, Matthew) (Entered: 06/19/2025)

PROOF OF SERVICE filed by Plaintiffs Sean Beckner-Carmitchel, Benjamin Adam Climer, Los Angeles Press Club, Ryanne Mena, NewsGuild-Communications Workers of America, Abigail Olmeda, Lexis-Olivier Ray, CHARLES XU, re EX PARTE APPLICATION for Temporary Restraining Order and Order to Show Cause Re: Preliminary Injunction 6 served on June 19, 2025. (Borden, Matthew) (Entered: 06/19/2025)

EX PARTE APPLICATION for Extension of Time to File Opposition to Plaintiffs' Ex Parte TRO Application filed by Defendants KRISTI NOEM, U.S. DEPARTMENT OF HOMELAND SECURITY. (Attachments: # 1 Exhibit A (email correspondence), # 2 Proposed Order) (Attorney Paul Bartholomew Green added to party KRISTI NOEM(pty:dft), Attorney Paul Bartholomew Green added to party U.S. DEPARTMENT OF HOMELAND SECURITY(pty:dft)) (Green, Paul) (Entered: 06/19/2025)

OBJECTIONS to Notice (Other) 5 of Related Cases filed by Defendants KRISTI NOEM, U.S. DEPARTMENT OF HOMELAND SECURITY. (Green, Paul) (Entered: 06/19/2025)

Opposition to Defendants' Ex Parte Application to Delay TRO re: EX PARTE APPLICATION for Extension of Time to File Opposition to Plaintiffs' Ex Parte TRO Application 8 filed by Plaintiffs Sean Beckner-Carmitchel, Benjamin Adam Climer, Los Angeles Press Club, Ryanne Mena, NewsGuild-Communications Workers of America, Abigail Olmeda, Lexis-Olivier Ray, CHARLES XU. (Borden, Matthew) (Entered: 06/19/2025)

DEFENDANTS' OPPOSITION re: EX PARTE APPLICATION for Temporary Restraining Order and Order to Show Cause Re: Preliminary Injunction 6 filed by Defendants KRISTI NOEM, U.S. DEPARTMENT OF HOMELAND SECURITY. (Attachments: # 1 Declaration of G. Bovino, # 2 Declaration of M. Canton, # 3 Declaration of E. Santacruz)(Green, Paul) (Entered: 06/19/2025)

(Attorney Sean Skedzielewski added to party KRISTI NOEM(pty:dft), Attorney Sean Skedzielewski added to party U.S. DEPARTMENT OF HOMELAND SECURITY(pty:dft))(Skedzielewski, Sean) (Entered: 06/20/2025)

NOTICE OF ASSIGNMENT to District Judge Stephen V. Wilson and Magistrate Judge Maria A. Audero. (et) (Entered: 06/20/2025)

NOTICE TO PARTIES OF COURT-DIRECTED ADR PROGRAM filed. (et) (Entered: 06/20/2025)

Notice to Counsel Re Consent to Proceed Before a United States Magistrate Judge. (et) (Entered: 06/20/2025)

60 DAY Summons Issued re Complaint (Attorney Civil Case Opening) 1 as to Defendants Kristi Noem, U.S. Department of Homeland Security. (et) (Entered: 06/20/2025)

NOTICE OF PRO HAC VICE APPLICATION DUE for Non-Resident Attorney Kevin Opoku-Gyamfi on behalf of Plaintiffs. A document recently filed in this case lists you as an out-of-state attorney of record. However, the Court has not been able to locate any record that you are admitted to the Bar of this Court, and you have not filed an application to appear Pro Hac Vice in this case. Accordingly, within 5 business days of the date of this notice, you must either (1) have your local counsel file an application to appear Pro Hac Vice (Form G-64) and pay the applicable fee, or (2) complete the next section of this form and return it to the court at cacd_attyadm@cacd.uscourts.gov. You have been removed as counsel of record from the docket in this case, and you will not be added back to the docket until your Pro Hac Vice status has been resolved. (et) (Entered: 06/20/2025)

NEW CASE ORDER upon filing of the complaint by Judge Stephen V. Wilson. (pc) (Entered: 06/20/2025)

MINUTES OF ORDER DENYING PLAINTIFF'S EX PARTE APPLICATION FOR A TEMPORARY RESTRAINING ORDER 6 by Judge Stephen V. Wilson. For the foregoing reasons, Plaintiffs' ex parte application for a temporary restraining order is DENIED WITHOUT PREJUDICE to filing a regularly noticed motion for a preliminary injunction.(See document for further details).; denying 6 EX PARTE APPLICATION for Temporary Restraining Order. (aco) (Entered: 06/20/2025)

REPLY in support Notice of Related Cases filed by Plaintiffs Sean Beckner-Carmitchel, Benjamin Adam Climer, Los Angeles Press Club, Ryanne Mena, NewsGuild-Communications Workers of America, Abigail Olmeda, Lexis-Olivier Ray, Charles Xu. (Borden, Matthew) (Entered: 06/22/2025)

NOTICE of Appearance filed by attorney Mohammad K. Tajsar on behalf of Plaintiffs Sean Beckner-Carmitchel, Benjamin Adam Climer, Los Angeles Press Club, Ryanne Mena, NewsGuild-Communications Workers of America, Abigail Olmeda, Lexis-Olivier Ray, Charles Xu (Attorney Mohammad K. Tajsar added to party Sean Beckner-Carmitchel(pty:pla), Attorney Mohammad K. Tajsar added to party Benjamin Adam Climer(pty:pla), Attorney Mohammad K. Tajsar added to party Los Angeles Press Club(pty:pla), Attorney Mohammad K. Tajsar added to party Ryanne Mena(pty:pla), Attorney Mohammad K. Tajsar added to party NewsGuild-Communications Workers of America(pty:pla), Attorney Mohammad K. Tajsar added to party Abigail Olmeda(pty:pla), Attorney Mohammad K. Tajsar added to party Lexis-Olivier Ray(pty:pla), Attorney Mohammad K. Tajsar added to party Charles Xu (pty:pla))(Tajsar, Mohammad) (Entered: 06/23/2025)

APPLICATION of Non-Resident Attorney Kevin Opoku-Gyamfi to Appear Pro Hac Vice on behalf of Plaintiffs Sean Beckner-Carmitchel, Benjamin Adam Climer, Los Angeles Press Club, Ryanne Mena, NewsGuild-Communications Workers of America, Abigail Olmeda, Lexis-Olivier Ray, Charles Xu (Pro Hac Vice Fee - $500 Fee Paid, Receipt No. ACACDC-39957249) filed by Plaintiffs Sean Beckner-Carmitchel, Benjamin Adam Climer, Los Angeles Press Club, Ryanne Mena, NewsGuild-Communications Workers of America, Abigail Olmeda, Lexis-Olivier Ray, Charles Xu. (Attachments: # 1 Proposed Order) (Eliasberg, Peter) (Entered: 06/23/2025)

APPLICATION for Refund of Fees Paid filed by Plaintiffs Sean Beckner-Carmitchel, Benjamin Adam Climer, Los Angeles Press Club, Ryanne Mena, NewsGuild-Communications Workers of America, Abigail Olmeda, Lexis-Olivier Ray, Charles Xu. (Eliasberg, Peter) (Entered: 06/24/2025)

ORDER by Judge Stephen V. Wilson: granting 22 Non-Resident Attorney Kevin Opoku-Gyamfi APPLICATION to Appear Pro Hac Vice on behalf of Plaintiffs Sean Beckner-Carmitchel, Benjamin Adam Climer, Los Angeles Press Club, Ryanne Mena, NewsGuild-Communications Workers of America, Abigail Olmeda, Lexis-Olivier Ray, Charles Xu, designating Peter Eliasberg as local counsel. THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY (sbou) (Entered: 06/24/2025)

OBJECTIONS to Reply (Motion related), 20 -- Defendants' Objection to Plaintiffs' Unauthorized Filing filed by Defendants Kristi Noem, U.S. Department of Homeland Security. (Green, Paul) (Entered: 06/24/2025)

Appear Pro Hac Vice

NOTICE OF MOTION AND MOTION to Expedite Discovery filed by Plaintiffs Sean Beckner-Carmitchel, Benjamin Adam Climer, Los Angeles Press Club, Ryanne Mena, NewsGuild-Communications Workers of America, Abigail Olmeda, Lexis-Olivier Ray, Charles Xu. Motion set for hearing on 7/28/2025 at 01:30 PM before Judge Stephen V. Wilson. (Attachments: # 1 Declaration of Matthew Borden, # 2 Exhibit A, # 3 Exhibit B, # 4 Proposed Order) (Borden, Matthew) (Entered: 06/25/2025)

1 Declaration of Matthew Borden

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2 Exhibit A

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3 Exhibit B

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4 Proposed Order

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PROOF OF SERVICE Executed by Plaintiff Charles Xu, Sean Beckner-Carmitchel, Benjamin Adam Climer, NewsGuild-Communications Workers of America, Abigail Olmeda, Los Angeles Press Club, Ryanne Mena, Lexis-Olivier Ray, upon Defendant All Defendants. Service of the Summons and Complaint were executed upon the United States Attorneys Office by delivering a copy to Estrella Garcia. Executed upon the Attorney Generals Office of the United States by delivering a copy to Evie Sassok. Service was executed in compliance with Federal Rules of Civil Procedure. Due diligence declaration NOT attached. Registered or certified mail return receipt NOT attached. (Attachments: # 1 Proof of Service on Attorney General of the United States and Department of Homeland Security)(Borden, Matthew) (Entered: 07/03/2025)

MEMORANDUM in Opposition to NOTICE OF MOTION AND MOTION to Expedite Discovery 26 filed by Defendants Kristi Noem, U.S. Department of Homeland Security. (Attachments: # 1 Declaration of Paul (Bart) Green)(Green, Paul) (Entered: 07/07/2025)

1 Declaration of Paul (Bart) Green

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ORDER RE TRANSFER PURSUANT to this Court's General Order in the Matter of Assignment of Cases and Duties to the District Judges. Related Case- filed. Related Case No: 2:25-cv-05423 HDV (Ex). Case transferred from Magistrate Judge Maria A. Audero and Judge Stephen V. Wilson to Judge Hernan D. Vera and Magistrate Judge Charles F. Eick for all further proceedings. The case number will now reflect the initials of the transferee Judge 2:25-cv-05563 HDV (Ex). Signed by Judge Hernan D. Vera (lh) (Entered: 07/09/2025)

CIVIL STANDING ORDER by Judge Hernan D. Vera. (wm) (Entered: 07/12/2025)

TEXT ONLY ENTRY (IN CHAMBERS) ORDER by Judge Hernan D. Vera: The Court resets Plaintiffs' Motion for Expedited Discovery 26 to 08/14/25 at 10AM. THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY. (wm) TEXT ONLY ENTRY (Entered: 07/12/2025)

Text Only Scheduling Notice

Notice of Withdrawal of Motion to Expedite, 26 filed by Plaintiffs Sean Beckner-Carmitchel, Benjamin Adam Climer, Los Angeles Press Club, Ryanne Mena, NewsGuild-Communications Workers of America, Abigail Olmeda, Lexis-Olivier Ray, Charles Xu. (Borden, Matthew) (Entered: 07/14/2025)

TEXT ONLY ENTRY (IN CHAMBERS) ORDER by Judge Hernan D. Vera: On June 19, 2025, Defendants filed an ex parte application for an extension of time to file an opposition. Dkt. No. 8 . The Court ruled on Plaintiff's TRO request on June 20, 2025, rendering Defendants' ex parte as MOOT. THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY. (wm) TEXT ONLY ENTRY (Entered: 07/14/2025)

Text Only Scheduling Notice

NOTICE OF MOTION AND MOTION for Preliminary Injunction filed by Plaintiffs Sean Beckner-Carmitchel, Benjamin Adam Climer, Los Angeles Press Club, Ryanne Mena, NewsGuild-Communications Workers of America, Abigail Olmeda, Lexis-Olivier Ray, Charles Xu. Motion set for hearing on 8/21/2025 at 10:00 AM before Judge Hernan D. Vera. (Attachments: # 1 Memorandum ISO Motion for Preliminary Injunction, # 2 Declaration of A.R., # 3 Declaration of Blanc, # 4 Declaration of Nadolishny, # 5 Declaration of Dransfeldt, # 6 Declaration of Barbadillo, # 7 Declaration of Riva, # 8 Declaration of Teran, # 9 Declaration of Coven, # 10 Declaration of Marquez, # 11 Declaration of Marantos, # 12 Declaration of Fisher, # 13 Declaration of Ellison, # 14 Declaration of Guardado, # 15 Declaration of Aguiluz, # 16 Declaration of Solrzano, # 17 Declaration of Taha, # 18 Declaration of R.R., # 19 Declaration of Shapiro, # 20 Declaration of Wilczewski, # 21 Declaration of Anderson, # 22 Declaration of Berg, # 23 Declaration of Miranda, # 24 Declaration of Lubka, # 25 Supplemental Declaration of Rose, # 26 Supplemental Declaration of Kerlikowske, # 27 Supplemental Declaration of Mena, # 28 Proposed Order) (Borden, Matthew) (Entered: 07/18/2025)

1 Memorandum ISO Motion for Preliminary Injunction

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2 Declaration of A.R.

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3 Declaration of Blanc

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4 Declaration of Nadolishny

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5 Declaration of Dransfeldt

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6 Declaration of Barbadillo

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7 Declaration of Riva

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8 Declaration of Teran

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9 Declaration of Coven

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10 Declaration of Marquez

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11 Declaration of Marantos

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12 Declaration of Fisher

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13 Declaration of Ellison

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14 Declaration of Guardado

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15 Declaration of Aguiluz

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16 Declaration of Solrzano

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17 Declaration of Taha

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18 Declaration of R.R.

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19 Declaration of Shapiro

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20 Declaration of Wilczewski

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21 Declaration of Anderson

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22 Declaration of Berg

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23 Declaration of Miranda

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24 Declaration of Lubka

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25 Supplemental Declaration of Rose

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26 Supplemental Declaration of Kerlikowske

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27 Supplemental Declaration of Mena

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28 Proposed Order

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EX PARTE APPLICATION to Shorten Time for Hearing on re NOTICE OF MOTION AND MOTION for Preliminary Injunction 34 to August 7, 2025 filed by Plaintiffs Sean Beckner-Carmitchel, Benjamin Adam Climer, Los Angeles Press Club, Ryanne Mena, NewsGuild-Communications Workers of America, Abigail Olmeda, Lexis-Olivier Ray, Charles Xu. (Attachments: # 1 Memorandum, # 2 Declaration of Matthew Borden, # 3 Proposed Order) (Borden, Matthew) (Entered: 07/21/2025)

PROOF OF SERVICE filed by Plaintiffs Sean Beckner-Carmitchel, Benjamin Adam Climer, Los Angeles Press Club, Ryanne Mena, NewsGuild-Communications Workers of America, Abigail Olmeda, Lexis-Olivier Ray, Charles Xu, re EX PARTE APPLICATION to Shorten Time for Hearing on re NOTICE OF MOTION AND MOTION for Preliminary Injunction 34 to August 7, 2025 35 served on July 21, 2025. (Borden, Matthew) (Entered: 07/21/2025)

OPPOSITION to EX PARTE APPLICATION to Shorten Time for Hearing on re NOTICE OF MOTION AND MOTION for Preliminary Injunction 34 to August 7, 2025 35 filed by Defendants Kristi Noem, U.S. Department of Homeland Security. (Attachments: # 1 Declaration of Paul (Bart) Green)(Green, Paul) (Entered: 07/22/2025)

1 Declaration of Paul (Bart) Green

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REPLY in support of EX PARTE APPLICATION to Shorten Time for Hearing on re NOTICE OF MOTION AND MOTION for Preliminary Injunction 34 to August 7, 2025 35 filed by Plaintiffs Sean Beckner-Carmitchel, Benjamin Adam Climer, Los Angeles Press Club, Ryanne Mena, NewsGuild-Communications Workers of America, Abigail Olmeda, Lexis-Olivier Ray, Charles Xu. (Borden, Matthew) (Entered: 07/22/2025)

OBJECTIONS to Reply (Motion related), 38 -- Defendants' Objection to Plaintiffs' Unauthorized Filing -- filed by Defendants Kristi Noem, U.S. Department of Homeland Security. (Green, Paul) (Entered: 07/23/2025)

MINUTES (IN CHAMBERS) ORDER GRANTING PLAINTIFFS' EX PARTE APPLICATION TO SHORTEN TIME FOR HEARING by Judge Hernan D. Vera. Having reviewed Plaintiffs' Ex Parte Application to expedite the briefing schedule for their motion for a preliminary injunction, ("Application") [Dkt. No. 35], and Defendants' Opposition, [Dkt. No. 37], the Court grants Plaintiffs' Application.1 Accordingly, the Court sets the following briefing schedule: A preliminary injunction hearing is set for August 11, 2025 at 10:00 a.m. Defendants shall file their opposition no later than August 4, 2025. Plaintiffs shall file their reply by August 5, 2025. (lom) (Entered: 07/23/2025)

REFUND OF $500.00 made payable on 07/28/2025 to Michelle Castaneda for payment made on 06/23/2025 Re: APPLICATION for Refund of Fees Paid 23 . (rdj) (Entered: 07/28/2025)

(IN CHAMBERS) SCHEDULING NOTICE by Judge Hernan D. Vera The Court continues the hearing on Plaintiffs' Motion for a Preliminary Injunction 34 to August 25, 2025 at 10:00 a.m. Defendants shall file their opposition by August 18, 2025. Plaintiffs shall file their reply by August 21, 2025. THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY. (lca) TEXT ONLY ENTRY (Entered: 08/04/2025)

Text Only Scheduling Notice

NOTICE of Appearance filed by attorney Kathleen Carr Jacobs on behalf of Defendants Kristi Noem, U.S. Department of Homeland Security (Attorney Kathleen Carr Jacobs added to party Kristi Noem(pty:dft), Attorney Kathleen Carr Jacobs added to party U.S. Department of Homeland Security(pty:dft))(Jacobs, Kathleen) (Entered: 08/07/2025)

Joint STIPULATION for Extension of Time to File Answer to 10 days following the Court's Order on Plaintiffs' Motion for Preliminary Injunction; and to Exceed Page Limit on Opposition to Plaintiffs' Motion for Preliminary Injunction. re NOTICE OF MOTION AND MOTION for Preliminary Injunction 34, Complaint (Attorney Civil Case Opening),,, 1 filed by Defendants Kristi Noem, U.S. Department of Homeland Security. (Attachments: # 1 Declaration, # 2 Proposed Order)(Jacobs, Kathleen) (Entered: 08/11/2025)

ORDER GRANTING STIPULATION TO EXTEND DEADLINE FOR PLAINTIFFS' COMPLAINT, AND FOR PAGE LIMIT 44 by Judge Hernan D. Vera. IT IS HEREBY ORDERED THAT Defendants response to the Complaint, ECF No. 1, shall be filed no more than ten (10) days after this Court issues an order on Plaintiffs' Motion for Preliminary Injunction. FURTHER the Court grants the Parties' stipulated request to exceed the page limit by five (5) pages for Defendants' Response due on August 18, 2025 and Plaintiffs' Reply due on August 21, 2025 to Plaintiffs Motion for Preliminary Injunction. (lom) (Entered: 08/13/2025)

NOTICE of Change of address by Matthew B Borden attorney for Plaintiffs Sean Beckner-Carmitchel, Benjamin Adam Climer, Los Angeles Press Club, Ryanne Mena, NewsGuild-Communications Workers of America, Abigail Olmeda, Lexis-Olivier Ray, Charles Xu. Changing attorneys address to 200 Madison Avenue, 23rd Floor, New York, NY 10016. Filed by Plaintiffs Sean Beckner-Carmitchel, Benjamin Adam Climer, Los Angeles Press Club, Ryanne Mena, NewsGuild-Communications Workers of America, Abigail Olmeda, Lexis-Olivier Ray, Charles Xu. (Borden, Matthew) (Entered: 08/18/2025)

MEMORANDUM in Opposition to NOTICE OF MOTION AND MOTION for Preliminary Injunction 34 filed by Defendants Kristi Noem, U.S. Department of Homeland Security. (Attachments: # 1 Declaration of Eddy Wang, # 2 Declaration of Brian Szemes, # 3 Declaration of Roger Scharmen, # 4 Declaration of Paul Green, # 5 Declaration of Matthew Harvey, # 6 Declaration of Daniel Parra, # 7 Declaration of Kevin Green)(Skedzielewski, Sean) (Entered: 08/18/2025)

NOTICE OF ERRATA filed by Defendants Kristi Noem, U.S. Department of Homeland Security. correcting MEMORANDUM in Opposition to Motion, 47 AND FILING OF DECLARATION OF KYLE HARVICK IN OPPOSITION TO PLAINTIFFS MOTION FOR PRELIMINARY INJUNCTION (Attachments: # 1 Declaration of Kyle C. Harvick)(Green, Paul) (Entered: 08/20/2025)

1 Declaration of Kyle C. Harvick

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REPLY in Support of NOTICE OF MOTION AND MOTION for Preliminary Injunction 34 filed by Plaintiffs Sean Beckner-Carmitchel, Benjamin Adam Climer, Los Angeles Press Club, Ryanne Mena, NewsGuild-Communications Workers of America, Abigail Olmeda, Lexis-Olivier Ray, Charles Xu. (Attachments: # 1 Kerlikowske Reply Declaration, # 2 Declaration of Alec Bertrand, # 3 Declaration of Catherine Saillant, # 4 Declaration of Diane Alvarez, # 5 Declaration of Dolores Ortiz, # 6 Declaration of F.F., # 7 Declaration of Lynn Griffin, # 8 Declaration Nathan Tran, # 9 Supplemental Declaration of A.R., # 10 Supplemental Declaration of Monica Solorzano, # 11 Proposed Order)(Borden, Matthew) (Entered: 08/21/2025)

MINUTES OF HEARING ON OSC ON ISSUANCE OF A PRELIMINARY INJUNCTION; REQUEST FOR SANCTIONS FILED IN CV25-5423-HDV; PLAINTIFFS' MOTION FOR PRELIMINARY INJUNCTION 34 FILED IN CV 25-5563-HDV held before Judge Hernan D. Vera. The Court, having heard oral argument, takes the matters under submission. Court Reporter: Maria Bustillos. (lom) (Entered: 08/26/2025)

TRANSCRIPT ORDER as to Plaintiff Sean Beckner-Carmitchel, Benjamin Adam Climer, Los Angeles Press Club, Ryanne Mena, NewsGuild-Communications Workers of America, Abigail Olmeda, Lexis-Olivier Ray, Charles Xu for Court Reporter. Court will contact Winni Yan at yan@braunhagey.com with further instructions regarding this order. Transcript preparation will not begin until payment has been satisfied with the court reporter. (Borden, Matthew) (Entered: 08/28/2025)

NOTICE of Change of address by Peter Bibring attorney for Plaintiffs Sean Beckner-Carmitchel, Benjamin Adam Climer, Los Angeles Press Club, Ryanne Mena, NewsGuild-Communications Workers of America, Abigail Olmeda, Lexis-Olivier Ray, Charles Xu. Changing attorneys address to 2210 W. Sunset Blvd., #203, Los Angeles, CA 90026. Filed by Plaintiffs Sean Beckner-Carmitchel, Benjamin Adam Climer, Los Angeles Press Club, Ryanne Mena, NewsGuild-Communications Workers of America, Abigail Olmeda, Lexis-Olivier Ray, Charles Xu. (Bibring, Peter) (Entered: 09/03/2025)

Notice of Supplemental Authority filed by Defendants Kristi Noem, U.S. Department of Homeland Security. (Jacobs, Kathleen) (Entered: 09/10/2025)

Notice of Errata filed by Defendants Kristi Noem, U.S. Department of Homeland Security. (Attachments: # 1 Exhibit)(Jacobs, Kathleen) (Entered: 09/10/2025)

1 Exhibit

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ORDER GRANTING PLAINTIFFS'MOTION FOR PRELIMINARYINJUNCTION 34 by Judge Hernan D. Vera. It is hereby ORDERED that Defendants, their officers, agents, assigns, and all persons acting in concert with them, are ENJOINED, pending final resolution of this matter. Within the next 72 hours, DHS is also hereby ORDERED to summarize this Order and disseminate its contents to all DHS officers responding to a protest in the Counties referred to above. The parties shall meet and confer and provide a joint status report within 30 days setting forth proposals for ensuring that DHS officers present in the Central District of California while this action is pending remain aware of the limitations imposed by this Order. [See order for details] (lom) (Entered: 09/10/2025)

Joint STIPULATION for Order on the Parties Stipulated Scheduling Order for Plaintiffs' First Amended Complaint and Defendants' Response filed by Defendants Kristi Noem, U.S. Department of Homeland Security. (Attachments: # 1 Declaration, # 2 Proposed Order)(Jacobs, Kathleen) (Entered: 09/18/2025)

1 Declaration

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2 Proposed Order

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NOTICE OF APPEAL to the 9th Circuit Court of Appeals filed by Defendants Kristi Noem, U.S. Department of Homeland Security. Appeal of Order on Motion for Preliminary Injunction,,, 55 . (Appeal Fee - Not Required for US Goverment.) (Attachments: # 1 Exhibit)(Jacobs, Kathleen) (Entered: 09/19/2025)

EX PARTE APPLICATION to Stay pending Disposition of Appeal Order on Motion for Preliminary Injunction,,, 55 filed by Defendants Kristi Noem, U.S. Department of Homeland Security. (Attachments: # 1 Declaration, # 2 Declaration, # 3 Declaration, # 4 Declaration, # 5 Proposed Order) (Jacobs, Kathleen) (Entered: 09/19/2025)

1 Declaration

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Opposition to re: EX PARTE APPLICATION to Stay pending Disposition of Appeal Order on Motion for Preliminary Injunction,,, 55 58 filed by Plaintiffs Sean Beckner-Carmitchel, Benjamin Adam Climer, Los Angeles Press Club, Ryanne Mena, NewsGuild-Communications Workers of America, Abigail Olmeda, Lexis-Olivier Ray, Charles Xu. (Attachments: # 1 Declaration of Matthew Borden, # 2 Exhibit 1)(Borden, Matthew) (Entered: 09/22/2025)

MINUTES (IN CHAMBERS) ORDER DENYING DEFENDANTS' EX PARTE APPLICATION 58 by Judge Hernan D. Vera. Defendants have not shown that their cause will be irreparably prejudiced unless their Application is heard on an ex parte basis. Defendants waited nine days after the Court issued its injunction to file its Application, during which time the Court presumes Defendants complied with the Court's order to disseminate the injunction. Though Defendants expound at length about their concerns with the injunction's workability, Application at 12-16, they identify no instance (postdating the Court's injunction) where Defendants have suffered any harm as a resultof the injunction. Defendants have not shown their entitlement to such extraordinary relief. However, in light of the parties' pending appeal, the Court sets the following expedited briefing schedule. Plaintiffs will file their opposition by Monday, September 29, 2025. Defendants will file their reply by Thursday, October 2, 2025. [See order for details] (lom) (Entered: 09/22/2025)

NOTIFICATION from Ninth Circuit Court of Appeals of case number assigned and briefing schedule. Appeal Docket No. 25-5975 assigned to Notice of Appeal to 9th Circuit Court of Appeals, 57 as to defandants Kristi Noem, U.S. Department of Homeland Security. (mat) (Entered: 09/26/2025)

ORDER GRANTING STIPULATION FOR SCHEDULING 56 by Judge Hernan D. Vera. IT IS HEREBY ORDERED THAT: 1. Plaintiffs will provide Defendants with a draft First Amended Complaint on October 3, 2025. 2. If Defendants still believe that there are grounds for a Rule 12 motion, the parties. will meet and confer about Defendants' intended motion by October 9, 2025. 3. Plaintiffs will file the First Amended Complaint on October 16, 2025. 4. Defendants will file their response to the First Amended Complaint on October 30, 2025. 5. Plaintiffs will file their opposition (assuming the response is a motion to dismiss) on November 13, 2025. 6. Defendants will file their reply on November 20, 2025. 7. The hearing will be on December 4, 2025 AT 10:00 a.m. (lom) Modified on 9/24/2025 (lom). (Entered: 09/24/2025)

TRANSCRIPT ORDER as to defendant Kristi Noem, U.S. Department of Homeland Security DCN number: R25CACA1157 for Court Reporter. (Green, Paul) (Entered: 09/29/2025)

Opposition re: EX PARTE APPLICATION to Stay pending Disposition of Appeal Order on Motion for Preliminary Injunction,,, 55 58 filed by Plaintiffs Sean Beckner-Carmitchel, Benjamin Adam Climer, Los Angeles Press Club, Ryanne Mena, NewsGuild-Communications Workers of America, Abigail Olmeda, Lexis-Olivier Ray, Charles Xu. (Attachments: # 1 Declaration of Beckner-Carmitchel, # 2 Declaration of Jill Connelly, # 3 Declaration of Matthew Borden, # 4 Exhibit 1, # 5 Exhibit 2)(Borden, Matthew) (Entered: 09/29/2025)

1 Declaration of Beckner-Carmitchel

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2 Declaration of Jill Connelly

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3 Declaration of Matthew Borden

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4 Exhibit 1

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5 Exhibit 2

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REPLY in support of EX PARTE APPLICATION to Stay pending Disposition of Appeal Order on Motion for Preliminary Injunction,,, 55 58 filed by Defendants Kristi Noem, U.S. Department of Homeland Security. (Attachments: # 1 Exhibit Declaration of Roger Scharmen)(Jacobs, Kathleen) (Entered: 10/02/2025)

STATUS REPORT -- Joint Status Report Pursuant to Court Order [ECF 55] filed by Defendants Kristi Noem, U.S. Department of Homeland Security. (Green, Paul) (Entered: 10/10/2025)

First AMENDED COMPLAINT against Defendants All Defendants amending Complaint (Attorney Civil Case Opening),,, 1, filed by Plaintiffs Charles Xu, Sean Beckner-Carmitchel, Benjamin Adam Climer, NewsGuild-Communications Workers of America, Abigail Olmeda, Los Angeles Press Club, Ryanne Mena, Lexis-Olivier Ray, Maria Alejandra-Paz(Attorney Matthew B Borden added to party Maria Alejandra-Paz(pty:pla))(Borden, Matthew) (Entered: 10/16/2025)

Request for Clerk to Issue Summons on Amended Complaint/Petition, 67 filed by Plaintiffs Maria Alejandra-Paz, Sean Beckner-Carmitchel, Benjamin Adam Climer, Los Angeles Press Club, Ryanne Mena, NewsGuild-Communications Workers of America, Abigail Olmeda, Lexis-Olivier Ray, Charles Xu. (Borden, Matthew) (Entered: 10/20/2025)

Request for Clerk to Issue Summons on Amended Complaint/Petition, 67 filed by Plaintiffs Maria Alejandra-Paz, Sean Beckner-Carmitchel, Benjamin Adam Climer, Los Angeles Press Club, Ryanne Mena, NewsGuild-Communications Workers of America, Abigail Olmeda, Lexis-Olivier Ray, Charles Xu. (Borden, Matthew) (Entered: 10/20/2025)

Request for Clerk to Issue Summons on Amended Complaint/Petition, 67 filed by Plaintiffs Maria Alejandra-Paz, Sean Beckner-Carmitchel, Benjamin Adam Climer, Los Angeles Press Club, Ryanne Mena, NewsGuild-Communications Workers of America, Abigail Olmeda, Lexis-Olivier Ray, Charles Xu. (Borden, Matthew) (Entered: 10/20/2025)

Request for Clerk to Issue Summons on Amended Complaint/Petition, 67 filed by Plaintiffs Maria Alejandra-Paz, Sean Beckner-Carmitchel, Benjamin Adam Climer, Los Angeles Press Club, Ryanne Mena, NewsGuild-Communications Workers of America, Abigail Olmeda, Lexis-Olivier Ray, Charles Xu. (Borden, Matthew) (Entered: 10/20/2025)

Request for Clerk to Issue Summons on Amended Complaint/Petition, 67 filed by Plaintiffs Maria Alejandra-Paz, Sean Beckner-Carmitchel, Benjamin Adam Climer, Los Angeles Press Club, Ryanne Mena, NewsGuild-Communications Workers of America, Abigail Olmeda, Lexis-Olivier Ray, Charles Xu. (Borden, Matthew) (Entered: 10/20/2025)

Request for Clerk to Issue Summons on Amended Complaint/Petition, 67 filed by Plaintiffs Maria Alejandra-Paz, Sean Beckner-Carmitchel, Benjamin Adam Climer, Los Angeles Press Club, Ryanne Mena, NewsGuild-Communications Workers of America, Abigail Olmeda, Lexis-Olivier Ray, Charles Xu. (Borden, Matthew) (Entered: 10/20/2025)

ORDER DENYING DEFENDANTS' EX PARTE APPLICATION TO STAY PRELIMINARY INJUNCTION PENDING APPEAL 58 by Judge Hernan D. Vera, re EX PARTE APPLICATION to Stay pending Disposition of Appeal Order on Motion for Preliminary Injunction 55 58 : Defendants' Application to stay the Court's PI Order is therefore denied. All prior orders remain in full force and effect. (see document for further details) (bm) (Entered: 10/21/2025)

60 DAY Summons Issued re First Amended Complaint 67 as to Defendant Gregory Bovino. (lom) (Entered: 10/22/2025)

60 DAY Summons Issued re First Amended Complaint 67 as to Defendant Mario Canton. (lom) (Entered: 10/22/2025)

60 DAY Summons Issued re First Amended Complaint 67 as to Defendant Kevin Green. (lom) (Entered: 10/22/2025)

60 DAY Summons Issued re First Amended Complaint 67 as to Defendant Todd Lyons. (lom) (Entered: 10/22/2025)

60 DAY Summons Issued re First Amended Complaint 67 as to Defendant Eddy Wang. (lom) (Entered: 10/22/2025)

60 DAY Summons Issued re First Amended Complaint 67 as to Defendant Ernesto Santacruz Jr. (lom) (Entered: 10/22/2025)

NOTICE OF MOTION AND MOTION to Dismiss Case filed by Defendants Gregory Bovino, Mario Canton, Kevin Green, Todd Lyons, Kristi Noem, Ernesto Santacruz Jr., U.S. Department of Homeland Security, Eddy Wang. Motion set for hearing on 12/4/2025 at 10:00 AM before Judge Hernan D. Vera. (Attachments: # 1 Proposed Order) (Attorney Paul Bartholomew Green added to party Gregory Bovino(pty:dft), Attorney Paul Bartholomew Green added to party Mario Canton(pty:dft), Attorney Paul Bartholomew Green added to party Kevin Green(pty:dft), Attorney Paul Bartholomew Green added to party Todd Lyons(pty:dft), Attorney Paul Bartholomew Green added to party Ernesto Santacruz Jr. (pty:dft), Attorney Paul Bartholomew Green added to party Eddy Wang(pty:dft)) (Green, Paul) (Entered: 10/30/2025)

1 Proposed Order

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OPPOSITION re: NOTICE OF MOTION AND MOTION to Dismiss Case 81 filed by Plaintiffs Maria Alejandra-Paz, Sean Beckner-Carmitchel, Benjamin Adam Climer, Los Angeles Press Club, Ryanne Mena, NewsGuild-Communications Workers of America, Abigail Olmeda, Lexis-Olivier Ray, Charles Xu. (Borden, Matthew) (Entered: 11/13/2025)

REPLY in support of NOTICE OF MOTION AND MOTION to Dismiss Case 81 filed by Defendants Gregory Bovino, Mario Canton, Kevin Green, Todd Lyons, Kristi Noem, Ernesto Santacruz Jr., U.S. Department of Homeland Security, Eddy Wang. (Attachments: # 1 Exhibit A [Chicago Headline Club v. Noem, No. 25-3023 (7th Cir. Nov. 19, 2025)])(Green, Paul) (Entered: 11/20/2025)

1 Exhibit A [Chicago Headline Club v. Noem, No. 25-3023 (7th Cir. Nov. 19, 2025)]

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MINUTES OF DEFENDANTS' MOTION TO DISMISS FIRST AMENDED COMPLAINT 81 held before Judge Hernan D. Vera: Having heard oral argument on the motion, the Court takes the motion under submission. Time in court: 44 min(s). Attorney for Plaintiff(s): Adrienna Wong/Matt Borden. Attorney for Defendant(s): Sean Skedzielewski/AUSA Paul Green. Court Reporter: CourtSmart. CRD: Wendy Hernandez. THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY. (wm) (Entered: 12/04/2025)

Dismiss Case AND Motion Hearing

TRANSCRIPT ORDER as to Plaintiffs Maria Alejandra-Paz, Sean Beckner-Carmitchel, Benjamin Adam Climer, Los Angeles Press Club, Ryanne Mena, NewsGuild-Communications Workers of America, Abigail Olmeda, Lexis-Olivier Ray, Charles Xu for Court Smart (CS). Court will contact Tristyn Thomas at tthomas@braunhagey.com with further instructions regarding this order. Transcript preparation will not begin until payment has been satisfied with the transcription company. (Borden, Matthew) (Entered: 12/10/2025)

TRANSCRIPT for proceedings held on 12/4/25 10:32 a.m. to 11:16 a.m.. Court Reporter/Electronic Court Recorder: ECHO REPORTING, INC., phone number (858) 453-7590. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Electronic Court Recorder before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Notice of Intent to Redact due within 7 days of this date. Redaction Request due 1/8/2026. Redacted Transcript Deadline set for 1/20/2026. Release of Transcript Restriction set for 3/18/2026. (apr) (Entered: 12/18/2025)

NOTICE OF FILING TRANSCRIPT filed for proceedings 12/4/25 10:32 a.m. to 11:16 a.m. re Transcript 86 THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY. (apr) TEXT ONLY ENTRY (Entered: 12/18/2025)

Notice of Filing Transcript

Notice of Appearance or Withdrawal of Counsel: for attorney Kevin Opoku-Gyamfi counsel for Plaintiffs Sean Beckner-Carmitchel, Benjamin Adam Climer, Los Angeles Press Club, Ryanne Mena, NewsGuild-Communications Workers of America, Abigail Olmeda, Lexis-Olivier Ray, Charles Xu. Kevin Opoku-Gyamfi is no longer counsel of record for the aforementioned party in this case for the reason indicated in the G-123 Notice. Filed by Plaintiffs Los Angeles Press Club, NewsGuild-Communications Workers of America, Abigail Olmeda, individually; and Sean Beckner-Carmitchel, Ryanne Mena, Lexis-Oliver Ray, Charles Xu, Benjamin Adam Climer, and Maria Alejandra-Paz, individually and on behalf of others similarly situated. (Opoku-Gyamfi, Kevin) (Entered: 12/30/2025)

ORDER DENYING DEFENDANTS' MOTION TO DISMISS 81 by Judge Hernan D. Vera. Defendants' Motion to dismiss the FAC is therefore denied. [See order for details] (lom) (Entered: 01/08/2026)

Notice of Appearance or Withdrawal of Counsel (G-123)