Case: National Religious Broadcasters v. Werfel

National Religious Boradcasters v. Werfel

National Religious Broadcasters v. Long

National Religious Broadcasters v. Long

National Religious Broadcasters v. Long

COMPLAINT FOR DECLARATORY RELIEF against The Internal Revenue Service, Danny Werfel ( Filing fee $ 405 receipt number ATXEDC-10325031.), filed by National Religious Broadcasters, Intercessors for America, First Baptist Church Waskom, Sand Springs Church. (Attachments: # 1 Civil Cover Sheet)(Stinson, Andrew) (Entered: 08/28/2024)

1 Civil Cover Sheet

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SUMMONS Issued as to The Internal Revenue Service and Danny Werfel. (Attachments: # 1 Summons)(ndc) (Entered: 08/28/2024)

1 Summons

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ORDER REGULATING PRACTICE (gsm) (Entered: 08/29/2024)

Add and Terminate Judges

District Judge J. Campbell Barker added. (gsm)

Fed. R. Civ. P. 7.1(a)(1) Disclosure Statement filed by First Baptist Church Waskom, Intercessors for America, National Religious Broadcasters, Sand Springs Church (Stinson, Andrew) (Entered: 08/30/2024)

FIRST NOTICE of Attorney Appearance by Michael Paul Farris on behalf of All Plaintiffs (Farris, Michael) (Entered: 09/05/2024)

NOTICE of Attorney Appearance - Pro Hac Vice by Rita Peters on behalf of All Plaintiffs. Filing fee $ 100, receipt number ATXEDC-10352041. (Peters, Rita) (Entered: 09/11/2024)

SUMMONS Returned Executed by National Religious Broadcasters, Intercessors for America, First Baptist Church Waskom, Sand Springs Church. The Internal Revenue Service served on 9/9/2024. (Stinson, Andrew) (Entered: 09/23/2024)

UNOPPOSED MOTION for Extension of Time to File Answer by The Internal Revenue Service, Danny Werfel. (Attachments: # 1 Proposed Order)(Blacker, Jonathan) (Entered: 10/21/2024)

ORDER granting 8 Motion for Extension of Time to Answer. The new deadline to answer or otherwise respond to the complaint shall be December 23, 2024. Signed by District Judge J. Campbell Barker on 11/4/2024. (ndc) (Entered: 11/04/2024)

NOTICE of Change of Address by Eduardo Mendoza. (E-filers are reminded that they must also use their PACER account to submit an address change to the NextGen ECF system.) (Mendoza, Eduardo) (Entered: 12/05/2024)

UNOPPOSED MOTION for Leave to File Excess Pages by Danny Werfel, The Internal Revenue Service. (Attachments: # 1 Proposed Order)(Mendoza, Eduardo) (Entered: 12/17/2024)

1 Proposed Order

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ORDER granting 11 Motion for Leave to File Excess Pages. Signed by District Judge J. Campbell Barker on 12/19/2024. (gsm) (Entered: 12/19/2024)

MOTION to Dismiss Pursuant to Federal Rules of Civil Procedure 12(b)(1) and 12(b)(6) by Danny Werfel, The Internal Revenue Service. (Attachments: # 1 Proposed Order)(Mendoza, Eduardo) (Entered: 12/23/2024)

1 Proposed Order

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MOTION for Extension of Time to File Response/Reply as to 13 MOTION to Dismiss Pursuant to Federal Rules of Civil Procedure 12(b)(1) and 12(b)(6) by National Religious Broadcasters, Sand Springs Church, First Baptist Church Waskom, Intercessors for America. (Attachments: # 1 Proposed Order)(Farris, Michael) (Entered: 12/30/2024)

1 Proposed Order

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ORAL ORDER: Plaintiffs' Doc. 14 MOTION for Extension of Time to File Response/Reply to Defendants' Motion to Dismiss Doc. 13 is granted. The new deadline to respond/reply shall be February 21, 2025. Ordered by District Judge J. Campbell Barker on 1/3/2025. (ndc) (Entered: 01/03/2025)

Order on Motion for Extension of Time to File Response/Reply

NOTICE of Attorney Appearance by David A Kallman on behalf of All Plaintiffs (Kallman, David) (Entered: 01/27/2025)

NOTICE of Attorney Appearance by Stephen Kallman on behalf of All Plaintiffs (Kallman, Stephen) (Entered: 01/27/2025)

FIRST MOTION to Amend/Correct 1 Complaint, by All Plaintiffs. (Attachments: # 1 Proposed Order, # 2 Exhibit)(Farris, Michael) (Entered: 02/19/2025)

1 Proposed Order

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2 Exhibit

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ORDER denying 13 Motion to Dismiss; granting 18 Motion to Amend. Plaintiffs are directed to file the amended complaint as a separate docket entry. The court also adopts the parties' agreed schedule for responses and briefing. Signed by District Judge J. Campbell Barker on 2/21/2025. (ndc) (Entered: 02/21/2025)

FIRST AMENDED COMPLAINT against The Internal Revenue Service, Danny Werfel, filed by Intercessors for America, National Religious Broadcasters, First Baptist Church Waskom, Sand Springs Church.(Farris, Michael) (Entered: 02/21/2025)

UNOPPOSED MOTION to Withdraw as Attorney by Danny Werfel, The Internal Revenue Service. (Attachments: # 1 Proposed Order)(Mendoza, Eduardo) (Entered: 03/12/2025)

1 Proposed Order

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ORDER granting 21 Motion to Withdraw Attorney Eduardo Mendoza. Signed by District Judge J. Campbell Barker on 3/19/2025. (ndc) (Entered: 03/19/2025)

FIRST MOTION for Partial Summary Judgment by First Baptist Church Waskom, Intercessors for America, National Religious Broadcasters, Sand Springs Church. (Attachments: # 1 Proposed Order)(Farris, Michael) (Entered: 04/21/2025)

1 Proposed Order

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UNOPPOSED MOTION for Extension of Time to File Response/Reply as to 23 FIRST MOTION for Partial Summary Judgment by The Internal Revenue Service. (Attachments: # 1 Proposed Order)(Blacker, Jonathan) (Entered: 04/22/2025)

UNOPPOSED MOTION for Extension of Time to File Answer re 20 Amended Complaint by The Internal Revenue Service. (Attachments: # 1 Proposed Order)(Blacker, Jonathan) (Entered: 04/22/2025)

ORAL ORDER: Defendants' 24 unopposed motion for an extension of time to respond to plaintiffs' 23 motion for partial summary judgment is granted. Any such response shall be due on June 5, 2025. Ordered by District Judge J. Campbell Barker on 4/23/2025. (ndc) (Entered: 04/23/2025)

Order on Motion for Extension of Time to File Response/Reply

ORDER granting 25 Motion for extension of time and amending briefing schedule. Defendants shall answer or otherwise respond to the amended complaint no later than 5/22/2025. By 5/23/2025, the parties shall inform the court as to whether a hearing on certain motions is desired. Signed by District Judge J. Campbell Barker on 4/25/2025. (ndc) (Entered: 04/25/2025)

FIRST MOTION for Request for Oral Argument by All Plaintiffs. (Farris, Michael) (Entered: 04/29/2025)

RESPONSE to 27 Order on Motion for Extension of Time to Answer, Plaintiffs' Request for Oral Argument filed by First Baptist Church Waskom, Intercessors for America, National Religious Broadcasters, Sand Springs Church. (Stinson, Andrew) (Entered: 05/05/2025)

ANSWER to 20 Amended Complaint by The Internal Revenue Service, Danny Werfel.(Blacker, Jonathan) (Entered: 05/22/2025)

UNOPPOSED MOTION for Extension of Time to File Response/Reply as to 23 FIRST MOTION for Partial Summary Judgment by The Internal Revenue Service, Danny Werfel. (Attachments: # 1 Proposed Order)(Blacker, Jonathan) (Entered: 05/27/2025)

1 Proposed Order

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ORAL ORDER: Defendants' 31 unopposed motion for an extension of time to respond to plaintiffs' 23 motion for partial summary judgment is granted. Any such response shall be due on July 7, 2025. Ordered by District Judge J. Campbell Barker on 6/2/2025. (ndc) (Entered: 06/02/2025)

Order on Motion for Extension of Time to File Response/Reply

UNOPPOSED MOTION for Extension of Time to File Response/Reply as to 23 FIRST MOTION for Partial Summary Judgment by The Internal Revenue Service, Danny Werfel. (Attachments: # 1 Proposed Order)(Blacker, Jonathan) (Entered: 07/06/2025)

JOINT MOTION to Stay All Deadlines and Notice of Settlement by The Internal Revenue Service, Danny Werfel. (Blacker, Jonathan) (Entered: 07/07/2025)

JOINT MOTION Order for Entry of Consent Judgment by The Internal Revenue Service, Danny Werfel. (Attachments: # 1 Proposed Order)(Blacker, Jonathan) (Entered: 07/07/2025)

1 Proposed Order

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ORDER granting 34 joint motion to stay and denying as moot 33 unopposed motion for extension of time to respond. All deadlines in this case are stayed pending this court's review of the proposed consent judgment. Signed by District Judge J. Campbell Barker on 7/8/2025. (ndc) (Entered: 07/08/2025)

OPPOSED MOTION to Intervene as Defendant, or, in the Alternative, Unopposed Motion for Leave to File as Amicus Curiae by Americans United for Separation of Church and State. (Attachments: # 1 Affidavit/Declaration Declaration of Rob Boston in Support of Motion, # 2 Proposed Order)(Woodward, Martin) (Entered: 07/10/2025)

1 Affidavit/Declaration Declaration of Rob Boston in Support of Motion

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2 Proposed Order

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Intervenor-Defendant's ANSWER to 20 Amended Complaint by Americans United for Separation of Church and State.(Woodward, Martin) (Entered: 07/10/2025)

Fed. R. Civ. P. 7.1(a)(1) Disclosure Statement filed by Americans United for Separation of Church and State (Woodward, Martin) (Entered: 07/10/2025)

NOTICE of Attorney Appearance - Pro Hac Vice by Alexandra Zaretsky on behalf of Americans United for Separation of Church and State. Filing fee $ 100, receipt number ATXEDC-10955237. (Zaretsky, Alexandra) (Entered: 07/11/2025)

NOTICE of Attorney Appearance - Pro Hac Vice by Jessica Zalph on behalf of Americans United for Separation of Church and State. Filing fee $ 100, receipt number ATXEDC-10956408. (Zalph, Jessica) (Entered: 07/14/2025)

ORDER granting 37 Motion for leave to file an amicus curiae brief opposing the proposed consent judgment. Signed by District Judge J. Campbell Barker on 7/17/2025. (gsm) (Entered: 07/17/2025)

FIRST RESPONSE in Opposition re 37 OPPOSED MOTION to Intervene as Defendant, or, in the Alternative, Unopposed Motion for Leave to File as Amicus Curiae filed by Americans United for Separation of Church and State, First Baptist Church Waskom, Intercessors for America, National Religious Broadcasters, Sand Springs Church. (Farris, Michael) (Additional attachment(s) added on 7/18/2025: # 1 Proposed Order) (kcv). (Entered: 07/18/2025)

1 Proposed Order

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UNOPPOSED MOTION Consolidate Reply Briefing, UNOPPOSED MOTION for Leave to File Excess Pages by Americans United for Separation of Church and State. (Attachments: # 1 Proposed Order)(Zaretsky, Alexandra) (Entered: 07/21/2025)

1 Proposed Order

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ORAL ORDER: The 44 Unopposed Motion to Consolidate Reply Briefing is granted. The consolidated reply may be up 10 pages long and is due no later than one week after Defendants' forthcoming response to the 37 Opposed Motion to Intervene, if any. Ordered by District Judge J. Campbell Barker on 7/22/2025. (ndc) (Entered: 07/22/2025)

Order on Motion for Leave to File Excess Pages AND Order on Motion for Miscellaneous Relief

RESPONSE in Opposition re 37 OPPOSED MOTION to Intervene as Defendant, or, in the Alternative, Unopposed Motion for Leave to File as Amicus Curiae filed by The Internal Revenue Service, Danny Werfel. (Attachments: # 1 Proposed Order)(Blacker, Jonathan) (Entered: 07/24/2025)

1 Proposed Order

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NOTICE of Attorney Appearance - Pro Hac Vice by Rebecca Markert on behalf of Americans United for Separation of Church and State. Filing fee $ 100, receipt number ATXEDC-10983542. (Markert, Rebecca) (Entered: 07/25/2025)

MOTION Brief of Amicus Curiae Americans United For Separation of Church and State in Opposition to Joint Motion for Entry of Consent Judgment by Americans United for Separation of Church and State. (Zaretsky, Alexandra) (Entered: 07/25/2025)

AGREED MOTION for Leave to File Respond to Amicus Curiae Brief by First Baptist Church Waskom, Intercessors for America, National Religious Broadcasters, Sand Springs Church. (Attachments: # 1 Proposed Order)(Stinson, Andrew) (Entered: 07/31/2025)

FIRST REPLY to Response re 37 OPPOSED MOTION to Intervene as Defendant, or, in the Alternative, Unopposed Motion for Leave to File as Amicus Curiae filed by Americans United for Separation of Church and State. (Zaretsky, Alexandra) (Entered: 07/31/2025)

OPPOSED MOTION for Leave to File Amicus Brief by Campaign Legal Center. (Attachments: # 1 Exhibit Proposed Brief of Amici Curiae Campaign Legal Center, Public Citizen, and Common Cause Opposing the Parties' Joint Motion for Entry of Consent Judgment)(Szilagyi, Heather) (Entered: 07/31/2025)

FIRST RESPONSE in Opposition re 51 OPPOSED MOTION for Leave to File Amicus Brief filed by First Baptist Church Waskom, Intercessors for America, National Religious Broadcasters, Sand Springs Church. (Farris, Michael) (Entered: 08/01/2025)

ORDER granting 51 OPPOSED MOTION for Leave to File Amicus Brief and granting 49 AGREED MOTION for Leave to File Response to Amicus Curiae Brief. Signed by District Judge J. Campbell Barker on 8/1/2025. (ndc) (Entered: 08/01/2025)

BRIEF filed Brief of Amici Curiae Campaign Legal Center, Public Citizen, and Common Cause by Campaign Legal Center. (Szilagyi, Heather) (Entered: 08/04/2025)

UNOPPOSED MOTION for Leave to File Brief as Amicus Curiae by Cornerstone Chapel, First Baptist Church of Dallas. (Attachments: # 1 Proposed Order)(Tucker, Ryan) (Additional attachment(s) added on 8/6/2025: # 2 Corrected Proposed Order) (gsm). (Entered: 08/04/2025)

1 Proposed Order

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NOTICE of Attorney Appearance - Pro Hac Vice by Sejal Jhaveri on behalf of Campaign Legal Center. Filing fee $ 100, receipt number ATXEDC-11004592. (Jhaveri, Sejal) (Entered: 08/05/2025)

NOTICE of Attorney Appearance - Pro Hac Vice by Adav Noti on behalf of Campaign Legal Center. Filing fee $ 100, receipt number ATXEDC-11004628. (Noti, Adav) (Entered: 08/05/2025)

UNOPPOSED MOTION for Leave to File Brief Amicus Curiae by America's Future, Orthodox Church Mission Fund of Texas, Orthodox Church Mission Fund of Houston, Texas, Conservative Legal Defense and Education Fund. (Attachments: # 1 Proposed Order)(Brewer, J. Mark) (Entered: 08/05/2025)

1 Proposed Order

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UNOPPOSED MOTION for Leave to File Brief as amici curiae by Institute for Free Speech and Bradley A. Smith. (Attachments: # 1 Proposed Order Proposed order granting motion leave to file)(Yeates, Owen) (Entered: 08/05/2025)

UNOPPOSED MOTION for Leave to File an Amicus Curiae Brief by Students and Academics for Free Expression, Speech, and Political Action in Campus Education, Inc.. (Attachments: # 1 Proposed Order)(Hooper, Rachel) (Additional attachment(s) added on 8/6/2025: # 2 Corrected Proposed Order) (gsm). (Entered: 08/05/2025)

Amicus Curiae APPEARANCE entered by Hiram Stanley Sasser, III on behalf of First Liberty Insitute. (Sasser, Hiram) (Entered: 08/05/2025)

Amicus Curiae APPEARANCE entered by Jeremiah Grant Dys on behalf of First Liberty Insitute. (Dys, Jeremiah) (Entered: 08/05/2025)

NOTICE of Attorney Appearance - Pro Hac Vice by Allen J Dickerson on behalf of Students and Academics for Free Expression, Speech, and Political Action in Campus Education, Inc.. Filing fee $ 100, receipt number ATXEDC-11006638. (Dickerson, Allen) (Entered: 08/05/2025)

Amicus Curiae APPEARANCE entered by Jeffrey Carl Mateer on behalf of First Liberty Insitute. (Mateer, Jeffrey) (Entered: 08/05/2025)

Amicus Curiae APPEARANCE entered by David Jonathan Hacker on behalf of First Liberty Insitute. (Hacker, David) (Entered: 08/05/2025)

UNOPPOSED MOTION for Leave to File Amicus Brief by First Liberty Insitute. (Dys, Jeremiah) (Additional attachment(s) added on 8/6/2025: # 1 Proposed Order) (gsm). (Entered: 08/05/2025)

Amicus BRIEF filed by First Liberty Insitute. (Attachments: # 1 Exhibit Exhib A Letter-IRS to GSL, # 2 Exhibit Exhib B Letter-IRS to New Way, # 3 Exhibit Exhib C Letter-IRS to CE)(Dys, Jeremiah) Modified on 8/6/2025 (jbe). (Entered: 08/05/2025)

UNOPPOSED MOTION for Leave to File Amicus Brief by Liberty Counsel. (Attachments: # 1 Proposed Order Granting Leave to File Amicus Brief)(Staver, Mat) (Additional attachment(s) added on 8/6/2025: # 2 Corrected Proposed Order) (gsm). (Entered: 08/05/2025)

NOTICE of Attorney Appearance by Owen Dennis Yeates on behalf of Institute for Free Speech and Bradley A. Smith (Yeates, Owen) (Entered: 08/05/2025)

NOTICE of Attorney Appearance by Ryan Nathan Gardner on behalf of First Liberty Insitute (Gardner, Ryan) (Entered: 08/06/2025)

NOTICE of Attorney Appearance - Pro Hac Vice by Kevin P. Hancock on behalf of Campaign Legal Center. Filing fee $ 100, receipt number ATXEDC-11010270. (Hancock, Kevin) (Entered: 08/07/2025)

ORDER granting 66 unopposed motion for leave to file an amicus brief filed by First Liberty Insitute, granting 60 unopposed motion for leave to file an amicus brief filed by Students and Academics for Free Expression, Speech, and Political Action in Campus Education, Inc., granting 55 unopposed motion for leave to file amicus brief filed by First Baptist Church of Dallas, Cornerstone Chapel, granting 58 unopposed motion for leave to file amicus brief filed by Conservative Legal Defense and Education Fund, Orthodox Church Mission Fund of Texas, America's Future, Orthodox Church Mission Fund of Houston, Texas, granting 68 unopposed motion for leave to file amicus brief filed by Liberty Counsel, granting 59 unopposed motion for leave to file amicus brief filed by Institute for Free Speech and Bradley A. Smith. The parties and Americans United for Separation of Church and State, whose motion for intervention is pending 37, may respond to any amicus by August 15, 2025. Signed by District Judge J. Campbell Barker on 8/7/2025. (ndc) (Entered: 08/07/2025)

NOTICE of Attorney Appearance - Pro Hac Vice by Mark Lippelmann on behalf of Cornerstone Chapel, First Baptist Church of Dallas. Filing fee $ 100, receipt number ATXEDC-11011650. (Lippelmann, Mark) (Entered: 08/07/2025)

NOTICE of Attorney Appearance by David Andrew Cortman on behalf of Cornerstone Chapel, First Baptist Church of Dallas (Cortman, David) (Entered: 08/07/2025)

NOTICE of Attorney Appearance by Ryan J Tucker on behalf of Cornerstone Chapel, First Baptist Church of Dallas (Tucker, Ryan) (Entered: 08/07/2025)

BRIEF of Amicus Curiae filed by Liberty Counsel. (Attachments: # 1 Exhibit A - Commission Report)(Staver, Mat) Modified on 8/13/2025 (gsm). (Entered: 08/11/2025)

1 Exhibit A - Commission Report

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BRIEF filed as Amicus Curiae by Cornerstone Chapel, First Baptist Church of Dallas. (Tucker, Ryan) (Entered: 08/11/2025)

BRIEF filed as Amicus Curiae by America's Future, Conservative Legal Defense and Education Fund, Orthodox Church Mission Fund of Houston, Texas, Orthodox Church Mission Fund of Texas. (Brewer, J. Mark) (Entered: 08/11/2025)

BRIEF filed as amici curiae by Institute for Free Speech and Bradley A. Smith. (Yeates, Owen) (Entered: 08/11/2025)

Brief of Amicus Curiae in Support re 35 JOINT MOTION Order for Entry of Consent Judgment by Amicus Curiae SAFE SPACE filed by Students and Academics for Free Expression, Speech, and Political Action in Campus Education, Inc. . (Hooper, Rachel) Modified on 8/13/2025 (gsm). (Entered: 08/11/2025)

ORAL ORDER: The court has received inquiries about page limits. The parties and all amicus curiae may consult E.D. Tex. Local Rule CV-7(a)(1) to determine page limits for briefing on the motion to enter a consent judgment. That rule imposes a 30-page limit. Pages beyond that limit will be disregarded by the court. Any response remains due on August 15, 2025. Ordered by District Judge J. Campbell Barker on 8/14/2025. (ndc) (Entered: 08/14/2025)

Oral Order

RESPONSE in Opposition re 35 JOINT MOTION Order for Entry of Consent Judgment filed by Americans United for Separation of Church and State. (Zaretsky, Alexandra) (Entered: 08/15/2025)

FIRST BRIEF filed in Response to Americans United for Separation of Church and State and Campaign Legal Center by National Religious Broadcasters. (Farris, Michael) (Entered: 08/15/2025)

RESPONSE re 48 MOTION Brief of Amicus Curiae Americans United For Separation of Church and State in Opposition to Joint Motion for Entry of Consent Judgment and RESPONSE re Brief of Amici Curiae Campaign Legal Center, Public Citizen, and Common Cause filed by The Internal Revenue Service, Danny Werfel. (Blacker, Jonathan) (Entered: 08/15/2025)