Case: Elev8 Baltimore, Inc. v. Corporation for National and Community Service

Elev8 Baltimore v. Corporation for National and Community Service

COMPLAINT against Corporation for National and Community Service, Jennifer Bastress Tahmasebi, Nate Cavanaugh ( Filing fee $ 405 receipt number AMDDC-11954417.), filed by THE SERVICE COLLABORATIVE OF WNY, INC., NORTH CAROLINA HOUSING COALITION, RED CLOUD INDIAN SCHOOL, INC./MAPYA LTA, J. DOE 2, ELEV8 BALTIMORE, INC., J. DOE 3, SEED COALITION, J. DOE 1, MICHIGAN COLLEGE ACCESS NETWORK, BUR OAK LAND TRUST, HANDSON SUBURBAN CHICAGO, RAINBOW LABS, ASPIRE AFTERSCHOOL LEARNING, AmeriCorps Employees Union, Local 2027, AMERICAN FEDERATION OF STATE, COUNTY & MUNICIPAL EMPLOYEES, AFL-CIO, HOUSING & COMMUNITY DEVELOPMENT NETWORK OF NEW JERSEY, PARTNERS FOR CAMPUS-COMMUNITY ENGAGEMENT, DEMOCRACY MAINE, NATIONAL COLLEGE ATTAINMENT NETWORK. (Attachments: # 1 Civil Cover Sheet, # 2 Summons)(Eisen, Norman) (Entered: 05/05/2025)

1 Civil Cover Sheet

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2 Summons

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Summons Issued 60 days as to Nate Cavanaugh, Corporation for National and Community Service, Jennifer Bastress Tahmasebi, U.S. Attorney and U.S. Attorney General(kb3s, Deputy Clerk) (Entered: 05/07/2025)

MOTION for Other Relief by Americorps Employees Union, Local 2027, American Federation of State, County & Municipal Employees, Aflcio, Aspire Afterschool Learning, Bur Oak Land Trust, Democracy Maine, J. Doe 1, J. Doe 2, J. Doe 3, Elev8 Baltimore, Inc., Handson Suburban Chicago, Housing & Community Development Network of New Jersey, Michigan College Access Network, National College Attainment Network, North Carolina Housing Coalition, Partners for Campus-Community Engagement, Rainbow Labs, Red Cloud Indian School, Inc./Mahpiya Luta, Seed Coalition, The Service Collaborative of WNY, Inc. (Attachments: # 1 Memorandum in Support Memo in Support, # 2 Text of Proposed Order Proposed Order)(Eisen, Norman) (Entered: 05/07/2025)

1 Memorandum in Support Memo in Support

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2 Text of Proposed Order Proposed Order

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NOTICE of Appearance by Abbe D Lowell on behalf of All Plaintiffs (Lowell, Abbe) (Entered: 05/09/2025)

MOTION to Appear Pro Hac Vice for Elena Goldstein (Filing fee $100, receipt number AMDDC-11965396.) by Elev8 Baltimore, Inc.(Lowell, Abbe) (Entered: 05/09/2025)

***FILED IN ERROR BY COUNSEL*** MOTION to Appear Pro Hac Vice for Brenna L. Frey (Filing fee $100, receipt number AMDDC-11965515.) by Elev8 Baltimore, Inc.(Lowell, Abbe) Modified on 5/9/2025 (av4s). (Entered: 05/09/2025)

PAPERLESS ORDER granting 5 Motion to Appear Pro Hac Vice on behalf of Elena Goldstein. Directing attorney Elena Goldstein to register for pro hac vice filing in the District of Maryland through PACER at https://pacer.uscourts.gov/ if attorney has not already done so. The Pro Hac Vice option must be selected when registering. Signed by Clerk on 5/9/2025. (mh4s, Deputy Clerk) (Entered: 05/09/2025)

CORRECTED MOTION to Appear Pro Hac Vice for Brenna L. Frey by Elev8 Baltimore, Inc.. The fee has already been paid.(Lowell, Abbe) (Entered: 05/09/2025)

MOTION to Appear Pro Hac Vice for Isabella M. Oishi (Filing fee $100, receipt number CMDDC-11966271.) by Elev8 Baltimore, Inc.(Lowell, Abbe) (Entered: 05/09/2025)

QC NOTICE: 8 Corrected Motion to Appear Pro Hac Vice filed by Elev8 Baltimore, Inc. needs to be modified. See attachment for details and corrective actions needed regarding the signature(s) on the motion. (mh4s, Deputy Clerk) (Entered: 05/13/2025)

QC NOTICE: 9 Motion to Appear Pro Hac Vice filed by Elev8 Baltimore, Inc. needs to be modified. See attachment for details and corrective actions needed regarding the signature(s) on the motion. (mh4s, Deputy Clerk) (Entered: 05/13/2025)

Second CORRECTED MOTION to Appear Pro Hac Vice for Brenna L. Frey by Elev8 Baltimore, Inc.. The fee has already been paid.(Lowell, Abbe) (Entered: 05/13/2025)

CORRECTED MOTION to Appear Pro Hac Vice for Isabella M. Oishi by Elev8 Baltimore, Inc.. The fee has already been paid.(Lowell, Abbe) (Entered: 05/13/2025)

PAPERLESS ORDER granting 12 Corrected Motion to Appear Pro Hac Vice on behalf of Brenna L. Frey. Directing attorney Brenna L. Frey to register for pro hac vice filing in the District of Maryland through PACER at https://pacer.uscourts.gov/ if attorney has not already done so. The Pro Hac Vice option must be selected when registering. Signed by Clerk on 5/14/2025. (mh4s, Deputy Clerk) (Entered: 05/14/2025)

PAPERLESS ORDER granting 13 Corrected Motion to Appear Pro Hac Vice on behalf of Isabella M. Oishi. Directing attorney Isabella M. Oishi to register for pro hac vice filing in the District of Maryland through PACER at https://pacer.uscourts.gov/ if attorney has not already done so. The Pro Hac Vice option must be selected when registering. Signed by Clerk on 5/14/2025. (mh4s, Deputy Clerk) (Entered: 05/14/2025)

AFFIDAVIT of Service for Complaint, Summons and Civil Cover Sheet served on Kelly O. Hayes, U.S. Attorney for the District of Maryland on 5/9/2025, filed by Elev8 Baltimore, Inc..(Lowell, Abbe) (Entered: 05/15/2025)

MOTION for Leave to File Excess Pages by Elev8 Baltimore, Inc. (Attachments: # 1 Text of Proposed Order)(Lowell, Abbe) (Entered: 05/16/2025)

1 Text of Proposed Order

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MOTION to Appear Pro Hac Vice for Pooja Chaudhuri (Filing fee $100, receipt number AMDDC-11984380.) by Americorps Employees Union, Local 2027, American Federation of State, County & Municipal Employees, Aflcio, Aspire Afterschool Learning, Bur Oak Land Trust, Democracy Maine, J. Doe 1, J. Doe 2, J. Doe 3, Elev8 Baltimore, Inc., Handson Suburban Chicago, Housing & Community Development Network of New Jersey, Michigan College Access Network, National College Attainment Network, North Carolina Housing Coalition, Partners for Campus-Community Engagement, Rainbow Labs, Red Cloud Indian School, Inc./Mahpiya Luta, Seed Coalition, The Service Collaborative of WNY, Inc.(Eisen, Norman) (Entered: 05/16/2025)

MOTION to Appear Pro Hac Vice for Sofia Fernandez Gold (Filing fee $100, receipt number AMDDC-11984384.) by Americorps Employees Union, Local 2027, American Federation of State, County & Municipal Employees, Aflcio, Aspire Afterschool Learning, Bur Oak Land Trust, Democracy Maine, J. Doe 1, J. Doe 2, J. Doe 3, Elev8 Baltimore, Inc., Handson Suburban Chicago, Housing & Community Development Network of New Jersey, Michigan College Access Network, National College Attainment Network, North Carolina Housing Coalition, Partners for Campus-Community Engagement, Rainbow Labs, Red Cloud Indian School, Inc./Mahpiya Luta, Seed Coalition, The Service Collaborative of WNY, Inc.(Eisen, Norman) (Entered: 05/16/2025)

MOTION to Appear Pro Hac Vice for Joshua Kolb (Filing fee $100, receipt number AMDDC-11984399.) by Americorps Employees Union, Local 2027, American Federation of State, County & Municipal Employees, Aflcio, Aspire Afterschool Learning, Bur Oak Land Trust, Democracy Maine, J. Doe 1, J. Doe 2, J. Doe 3, Elev8 Baltimore, Inc., Handson Suburban Chicago, Housing & Community Development Network of New Jersey, Michigan College Access Network, National College Attainment Network, North Carolina Housing Coalition, Partners for Campus-Community Engagement, Rainbow Labs, Red Cloud Indian School, Inc./Mahpiya Luta, Seed Coalition, The Service Collaborative of WNY, Inc.(Eisen, Norman) (Entered: 05/16/2025)

PAPERLESS ORDER granting 18 Motion to Appear Pro Hac Vice on behalf of Pooja Chaudhuri. Directing attorney Pooja Chaudhuri to register for pro hac vice filing in the District of Maryland through PACER at https://pacer.uscourts.gov/ if attorney has not already done so. The Pro Hac Vice option must be selected when registering. Signed by Clerk on 5/19/2025. (mh4s, Deputy Clerk) (Entered: 05/19/2025)

PAPERLESS ORDER granting 19 Motion to Appear Pro Hac Vice on behalf of Sofia Fernandez Gold. Directing attorney Sofia Fernandez Gold to register for pro hac vice filing in the District of Maryland through PACER at https://pacer.uscourts.gov/ if attorney has not already done so. The Pro Hac Vice option must be selected when registering. Signed by Clerk on 5/19/2025. (mh4s, Deputy Clerk) (Entered: 05/19/2025)

PAPERLESS ORDER granting 20 Motion to Appear Pro Hac Vice on behalf of Joshua Gabriel Kolb. Directing attorney Joshua Gabriel Kolb to register for pro hac vice filing in the District of Maryland through PACER at https://pacer.uscourts.gov/ if attorney has not already done so. The Pro Hac Vice option must be selected when registering. Signed by Clerk on 5/19/2025. (mh4s, Deputy Clerk) (Entered: 05/19/2025)

AFFIDAVIT of Service for Complaint, Summons and Civil Cover Sheet served on Pam Bondi, U.S. Attorney General on 5/19/2025, filed by Elev8 Baltimore, Inc..(Lowell, Abbe) (Entered: 05/19/2025)

MOTION for Preliminary Injunction by Elev8 Baltimore, Inc. (Attachments: # 1 Memorandum in Support, # 2 Text of Proposed Order, # 3 Exhibit, # 4 Exhibit, # 5 Exhibit, # 6 Exhibit, # 7 Exhibit, # 8 Exhibit, # 9 Exhibit, # 10 Exhibit, # 11 Exhibit, # 12 Exhibit, # 13 Exhibit, # 14 Exhibit, # 15 Exhibit, # 16 Exhibit, # 17 Exhibit, # 18 Exhibit, # 19 Exhibit, # 20 Exhibit, # 21 Exhibit, # 22 Exhibit)(Lowell, Abbe) (Entered: 05/20/2025)

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NOTICE by Elev8 Baltimore, Inc. re 25 MOTION for Preliminary Injunction (Lowell, Abbe) (Entered: 05/20/2025)

ORDER granting 17 Motion for Leave to File Excess Pages. Signed by Judge Matthew J. Maddox on 5/21/2025. (kb3s, Deputy Clerk) (Entered: 05/21/2025)

NOTICE of Appearance by Ryan Underwood on behalf of All Defendants (Underwood, Ryan) (Entered: 05/22/2025)

MOTION to Expedite Briefing Schedule by Elev8 Baltimore, Inc. (Attachments: # 1 Text of Proposed Order)(Lowell, Abbe) (Entered: 05/22/2025)

1 Text of Proposed Order

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ORDER granting 29 MOTION to Expedite Briefing Schedule. Signed by Judge Matthew J. Maddox on 5/27/2025. (kb3s, Deputy Clerk) (Entered: 05/27/2025)

Consent MOTION to Expedite Hearing on Plaintiffs Motion for Preliminary Injunction by Elev8 Baltimore, Inc. (Attachments: # 1 Text of Proposed Order)(Lowell, Abbe) (Entered: 05/29/2025)

ORDER Granting 31 Consent Motion for Scheduling of a Hearing. Signed by Judge Matthew J. Maddox on 5/29/2025. (bas, Deputy Clerk) (Entered: 05/29/2025)

RESPONSE in Opposition re 25 MOTION for Preliminary Injunction filed by Nate Cavanaugh, Corporation for National and Community Service. (Attachments: # 1 Exhibit Exhibit 1, # 2 Exhibit Exhibit 2, # 3 Exhibit Exhibit 3, # 4 Exhibit Exhibit 4, # 5 Exhibit Exhibit 5)(Underwood, Ryan) (Entered: 05/30/2025)

1 Exhibit Exhibit 1

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2 Exhibit Exhibit 2

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3 Exhibit Exhibit 3

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4 Exhibit Exhibit 4

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5 Exhibit Exhibit 5

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AFFIDAVIT of Service for Complaint, Summons and Civil Cover Sheet served on Nate Cavanaugh, DOGE Team Lead for AmeriCorps on 5/29/2025, filed by Elev8 Baltimore, Inc..(Lowell, Abbe) (Entered: 06/03/2025)

MOTION for Leave to File Excess Pages by Americorps Employees Union, Local 2027, American Federation of State, County & Municipal Employees, Aflcio, Aspire Afterschool Learning, Bur Oak Land Trust, Democracy Maine, J. Doe 1, J. Doe 2, J. Doe 3, Elev8 Baltimore, Inc., Handson Suburban Chicago, Housing & Community Development Network of New Jersey, Michigan College Access Network, National College Attainment Network, North Carolina Housing Coalition, Partners for Campus-Community Engagement, Rainbow Labs, Red Cloud Indian School, Inc./Mahpiya Luta, Seed Coalition, The Service Collaborative of WNY, Inc. (Attachments: # 1 Text of Proposed Order Proposed Order)(Eisen, Norman) (Entered: 06/04/2025)

ORDER granting 35 Motion for Leave to File Excess Pages. Signed by Judge Matthew J. Maddox on 6/5/2025. (kb3s, Deputy Clerk) (Entered: 06/05/2025)

REPLY to Response to Motion re 25 MOTION for Preliminary Injunction filed by Elev8 Baltimore, Inc..(Lowell, Abbe) (Entered: 06/06/2025)

-[FILED IN ERROR]- AFFIDAVIT of Service for Complaint, Summons and Civil Cover Sheet served on Jennifer Bastress Tahmasebi, Interim Agency Head of AmeriCorps on 6/12/2025, filed by Elev8 Baltimore, Inc..(Lowell, Abbe) Modified on 6/16/2025 (bas). (Entered: 06/13/2025)

QC NOTICE: 38 Affidavit of Service filed by Elev8 Baltimore, Inc. was filed incorrectly. **Please re-file documents by selecting Service of Process > Summons Returned Executed. It has been noted as FILED IN ERROR, and the document link has been disabled. (bas, Deputy Clerk) (Entered: 06/16/2025)

SUMMONS Returned Executed by Elev8 Baltimore, Inc.. Jennifer Bastress Tahmasebi served on 6/12/2025, answer due 7/3/2025.(Lowell, Abbe) (Entered: 06/16/2025)

MOTION for Leave to File by Americorps Employees Union, Local 2027, American Federation of State, County & Municipal Employees, Aflcio, Aspire Afterschool Learning, Bur Oak Land Trust, Democracy Maine, J. Doe 1, J. Doe 2, J. Doe 3, Elev8 Baltimore, Inc., Handson Suburban Chicago, Housing & Community Development Network of New Jersey, Michigan College Access Network, National College Attainment Network, North Carolina Housing Coalition, Partners for Campus-Community Engagement, Rainbow Labs, Red Cloud Indian School, Inc./Mahpiya Luta, Seed Coalition, The Service Collaborative of WNY, Inc. (Attachments: # 1 Text of Proposed Order Proposed Order, # 2 Supplement Supplemental Declaration, # 3 Supplement Supplemental Declaration)(Mays, Tianna) (Entered: 06/16/2025)

1 Text of Proposed Order Proposed Order

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2 Supplement Supplemental Declaration

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3 Supplement Supplemental Declaration

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Preliminary Injunction Hearing held on 6/18/2025 before Judge Matthew J. Maddox.(Court Reporter: Amanda Longmore) (jh2s, Deputy Clerk) (Entered: 06/18/2025)

SUMMONS Returned Executed by Elev8 Baltimore, Inc.. Corporation for National and Community Service served on 6/17/2025, answer due 7/8/2025.(Lowell, Abbe) (Entered: 06/26/2025)

NOTICE by Elev8 Baltimore, Inc. of Supplemental Authority (Attachments: # 1 Attachment, # 2 Attachment)(Lowell, Abbe) (Entered: 07/03/2025)

MEMORANDUM OPINION. Signed by Judge Matthew J. Maddox on 7/7/2025. (kb3s, Deputy Clerk)

ORDER granting in part and denying in part 25 Motion for Preliminary Injunction; granting 41 Motion for Leave to File. Signed by Judge Matthew J. Maddox on 7/7/2025. (kb3s, Deputy Clerk) (Entered: 07/07/2025)

ORDER granting 3 MOTION for Other Relief. Signed by Judge Matthew J. Maddox on 7/7/2025. (kb3s, Deputy Clerk) (Entered: 07/07/2025)

RESPONSE re 49 Status Report Supplement filed by Elev8 Baltimore, Inc..(Lowell, Abbe) (Entered: 07/16/2025)

STATUS REPORT by Nate Cavanaugh, Corporation for National and Community Service, Jennifer Bastress Tahmasebi (Attachments: # 1 Exhibit 1, # 2 Exhibit 2)(Underwood, Ryan) (Entered: 07/22/2025)

STATUS REPORT by Nate Cavanaugh, Corporation for National and Community Service, Jennifer Bastress Tahmasebi(Underwood, Ryan) (Entered: 08/01/2025)