Case: Immigrant Advocates Response Collaborative v. U.S. Department of Justice

Immigrant Advocates Response Collaborative v. United States Department of Justice

COMPLAINT against All Defendants (Fee Status:Filing Fee Waived) filed by M.K., E.C., AMERICAN GATEWAYS, IMMIGRANT ADVOCATES RESPONSE COLLABORATIVE, R.A., D.C., L.H., K.M., M.D., J.L., P.D., M.S., E.M., E.P.. (Attachments: # 1 Civil Cover Sheet, # 2 Summons DOJ, # 3 Summons DHS, # 4 Summons EOIR, # 5 Summons ICE, # 6 Summons Bondi, # 7 Summons Lyons, # 8 Summons Noem, # 9 Summons Owen, # 10 Summons Riley, # 11 Summons Taylor, # 12 Summons USAO-DC)(Zwick, Keren) (Attachment 1 replaced on 7/18/2025) (znmw). (Entered: 07/16/2025)

SEALED MOTION to Proceed Under Pseudonym filed by AMERICAN GATEWAYS, D.C., E.C., E.M., E.P., IMMIGRANT ADVOCATES RESPONSE COLLABORATIVE, J.L., K.M., L.H., M.D., M.K., M.S., P.D., R.A. (Attachments: # 1 Declaration L.H., # 2 Declaration M.S., # 3 Declaration E.P., # 4 Declaration D.C., # 5 Declaration E.C., # 6 Declaration P.D., # 7 Declaration K.M., # 8 Declaration E.M., # 9 Declaration M.K., # 10 Declaration M.D., # 11 Declaration R.A., # 12 Declaration J.L., # 13 Text of Proposed Order Proposed Order)(Zwick, Keren) (Entered: 07/16/2025)

Payment for 1 Complaint,,. ($405; Receipt number ADCDC-11825258). (Zwick, Keren)

Payment of Fee - Complaint/Petition

SUMMONS (11) Issued Electronically as to All Defendants, U.S. Attorney and U.S. Attorney General (Attachments: # 1 Notice and Consent)(znmw) (Entered: 07/18/2025)

MINUTE ORDER: The Court has reviewed Plaintiffs' 2 Motion to Proceed Under Pseudonym and to File Supporting Exhibits Under Seal. Given the imminent nature of this matter, it determines that a full Opinion is not practical at this time. Believing that Plaintiffs have made the required showing on the relevant factors, the Court ORDERS that: 1) The 2 Motion is GRANTED IN PART and DENIED IN PART, subject to any further consideration by the United States District Judge to whom this case is randomly assigned; 2) All parties shall use the pseudonyms listed in the Complaint in all documents filed in this action; 3) All documents containing personally identifying information shall be filed under seal, with a redacted public filing made simultaneously or promptly thereafter. Such redactions should only cover personally identifying information in supporting exhibits and other filings, rather than entire exhibits and filings; and 4) Within fourteen days of this Order, Plaintiffs shall file: i) A pseudonymous version of their 2 Motion and attachments as a Notice to the Court on the public docket; and ii) A sealed declaration containing all Plaintiffs' real names and residential addresses. So ORDERED by Chief Judge James E. Boasberg on July 18, 2025. (lcjeb4)

Order on Sealed Motion to Proceed Under Pseudonym AND Set/Reset Deadlines

Case Assigned to Judge Trevor N. McFadden. (znmw)

Case Assigned/Reassigned

STANDING ORDER Establishing Procedures for Cases Before Judge Trevor N. McFadden. The parties are hereby ORDERED to read and comply with the directives in the attached standing order. Signed by Judge Trevor N. McFadden on 7/21/2025. (lctnm3). (Entered: 07/21/2025)

NOTICE of Appearance by Richard P. Caldarone on behalf of All Plaintiffs (Caldarone, Richard) (Entered: 07/21/2025)

NOTICE of Appearance by Elena Goldstein on behalf of AMERICAN GATEWAYS, D.C., E.C., E.M., E.P., IMMIGRANT ADVOCATES RESPONSE COLLABORATIVE, J.L., K.M., L.H., M.D., M.K., M.S., P.D., R.A. (Goldstein, Elena) (Entered: 07/23/2025)

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Joshua M. Salzman, Filing fee $ 100, receipt number ADCDC-11839110. Fee Status: Fee Paid. by AMERICAN GATEWAYS, D.C., E.C., E.M., E.P., IMMIGRANT ADVOCATES RESPONSE COLLABORATIVE, J.L., K.M., L.H., M.D., M.K., M.S., P.D., R.A.. (Attachments: # 1 Declaration, # 2 Certificate of Good Standing)(Goldstein, Elena) (Entered: 07/23/2025)

MOTION to Expedite Production of the Administrative Record by AMERICAN GATEWAYS, D.C., E.C., E.M., E.P., J.L., K.M., L.H., M.D., M.K., M.S., P.D., R.A.. (Attachments: # 1 Memorandum in Support, # 2 Exhibit Ex. A, Memorandum from Caleb Vitello, Acting Director of ICE on Interim Guidance: Civil Immigration Enforcement Actions in or near Courthouses to All ICE Employees, # 3 Exhibit Ex. B, Memorandum from Sirce E. Owen, Acting Director of EOIR on the Cancellation of Operating Policies and Procedures to All of EOIR And on May 27, 2025, ICE finalized the ICE Interim Guidance., # 4 Exhibit Ex. C, Memorandum from Todd M. Lyons, Acting Director of ICE on Civil Immigration Enforcement Actions In or Near Courthouses to All ICE Employees, # 5 Text of Proposed Order)(Goldstein, Elena) (Entered: 07/24/2025)

Order on Motion for Leave to Appear Pro Hac Vice

MINUTE ORDER granting 7 Motion for Leave to Appear Pro Hac Vice as to Joshua M. Salzman. 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. Signed by Judge Trevor N. McFadden on 7/25/2025. (lctnm1)

NOTICE of Appearance by Joshua M. Salzman on behalf of AMERICAN GATEWAYS, D.C., E.C., E.M., E.P., IMMIGRANT ADVOCATES RESPONSE COLLABORATIVE, J.L., K.M., L.H., M.D., M.K., M.S., P.D., R.A. (Salzman, Joshua) (Entered: 07/28/2025)

RESPONSE TO ORDER OF THE COURT re Order on Sealed Motion to Proceed Under Pseudonym,,,,,, Set/Reset Deadlines,,,,, filed by AMERICAN GATEWAYS, D.C., E.C., E.M., E.P., IMMIGRANT ADVOCATES RESPONSE COLLABORATIVE, J.L., K.M., L.H., M.D., M.K., M.S., P.D., R.A.. (Attachments: # 1 Declaration L.H., # 2 Declaration M.S., # 3 Declaration E.P., # 4 Declaration D.C., # 5 Declaration E.C., # 6 Declaration P.D., # 7 Declaration K.M., # 8 Declaration E.M., # 9 Declaration M.K., # 10 Declaration M.D., # 11 Declaration R.A., # 12 Declaration J.L.)(Zwick, Keren) (Entered: 07/30/2025)

SEALED DOCUMENT filed by AMERICAN GATEWAYS, D.C., E.C., E.M., E.P., IMMIGRANT ADVOCATES RESPONSE COLLABORATIVE, J.L., K.M., L.H., M.D., M.K., M.S., P.D., R.A. re 10 Response to Order of the Court,, Order on Sealed Motion to Proceed Under Pseudonym,,,,,, Set/Reset Deadlines,,,,, (This document is SEALED and only available to authorized persons.)(Zwick, Keren) (Entered: 07/30/2025)

NOTICE of Appearance- Pro Bono by Mary Georgevich on behalf of All Plaintiffs (Georgevich, Mary) (Entered: 08/01/2025)

NOTICE of Appearance by Simon Christopher Brewer on behalf of AMERICAN GATEWAYS, D.C., E.C., E.M., E.P., IMMIGRANT ADVOCATES RESPONSE COLLABORATIVE, J.L., K.M., L.H., M.D., M.K., M.S., P.D., R.A. (Brewer, Simon) (Entered: 08/05/2025)

NOTICE of Appearance by Brian P. Hudak on behalf of All Defendants (Hudak, Brian) (Entered: 08/07/2025)

Memorandum in opposition to re 8 MOTION to Expedite Production of the Administrative Record filed by PAMELA J. BONDI, DEPARTMENT OF HOMELAND SECURITY, EXECUTIVE OFFICE FOR IMMIGRATION REVIEW, TODD M. LYONS, KRISTI NOEM, SIRCE E. OWEN, KEVIN RILEY, PHILIP P. TAYLOR, U.S. DEPARTMENT OF JUSTICE, U.S. IMMIGRATION AND CUSTOM ENFORCEMENT. (Attachments: # 1 Text of Proposed Order)(Hudak, Brian) (Entered: 08/07/2025)

MOTION to Stay Obligation to File a Certified Index of the Administrative Record by PAMELA J. BONDI, DEPARTMENT OF HOMELAND SECURITY, EXECUTIVE OFFICE FOR IMMIGRATION REVIEW, TODD M. LYONS, KRISTI NOEM, SIRCE E. OWEN, KEVIN RILEY, PHILIP P. TAYLOR, U.S. DEPARTMENT OF JUSTICE, U.S. IMMIGRATION AND CUSTOM ENFORCEMENT. (Attachments: # 1 Text of Proposed Order)(Hudak, Brian) (Entered: 08/07/2025)

NOTICE of Appearance by Mark Feldman on behalf of All Plaintiffs (Feldman, Mark) (Main Document 17 replaced on 8/11/2025) (mg). (Entered: 08/08/2025)

NOTICE of Appearance- Pro Bono by Mark Fleming on behalf of All Plaintiffs (Fleming, Mark) (Entered: 08/13/2025)

NOTICE of Appearance- Pro Bono by Colleen Mary Cowgill on behalf of All Plaintiffs (Cowgill, Colleen) (Entered: 08/13/2025)

REPLY to opposition to motion re 8 Motion to Expedite,,, filed by AMERICAN GATEWAYS, D.C., E.C., E.M., E.P., IMMIGRANT ADVOCATES RESPONSE COLLABORATIVE, J.L., K.M., L.H., M.D., M.K., M.S., P.D., R.A.. (Attachments: # 1 Text of Proposed Order)(Brewer, Simon) (Entered: 08/14/2025)

Memorandum in opposition to re 16 MOTION to Stay Obligation to File a Certified Index of the Administrative Record filed by AMERICAN GATEWAYS, D.C., E.C., E.M., E.P., IMMIGRANT ADVOCATES RESPONSE COLLABORATIVE, J.L., K.M., L.H., M.D., M.K., M.S., P.D., R.A.. (Attachments: # 1 Text of Proposed Order)(Brewer, Simon) (Entered: 08/14/2025)

REPLY to opposition to motion re 16 Motion to Stay, filed by PAMELA J. BONDI, DEPARTMENT OF HOMELAND SECURITY, EXECUTIVE OFFICE FOR IMMIGRATION REVIEW, TODD M. LYONS, KRISTI NOEM, SIRCE E. OWEN, KEVIN RILEY, PHILIP P. TAYLOR, U.S. DEPARTMENT OF JUSTICE, U.S. IMMIGRATION AND CUSTOM ENFORCEMENT. (Hudak, Brian) (Entered: 08/21/2025)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed as to the United States Attorney. Date of Service Upon United States Attorney on 7/24/2025. Answer due for ALL FEDERAL DEFENDANTS by 9/22/2025. (Salzman, Joshua) (Entered: 09/18/2025)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. PHILIP P. TAYLOR served on 7/28/2025 (Salzman, Joshua) (Entered: 09/18/2025)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. KEVIN RILEY served on 7/28/2025 (Salzman, Joshua) (Entered: 09/18/2025)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. SIRCE E. OWEN served on 7/28/2025 (Salzman, Joshua) (Entered: 09/18/2025)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. KRISTI NOEM served on 7/28/2025 (Salzman, Joshua) (Entered: 09/18/2025)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. TODD M. LYONS served on 7/30/2025 (Salzman, Joshua) (Entered: 09/18/2025)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. U.S. IMMIGRATION AND CUSTOM ENFORCEMENT served on 7/30/2025 (Salzman, Joshua) (Entered: 09/18/2025)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. EXECUTIVE OFFICE FOR IMMIGRATION REVIEW served on 7/28/2025 (Salzman, Joshua) (Entered: 09/18/2025)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. U.S. DEPARTMENT OF JUSTICE served on 8/6/2025 (Salzman, Joshua) (Entered: 09/18/2025)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. DEPARTMENT OF HOMELAND SECURITY served on 7/30/2025 (Salzman, Joshua) (Entered: 09/18/2025)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed on United States Attorney General. Date of Service Upon United States Attorney General 08/06/2025. (Salzman, Joshua) (Entered: 09/18/2025)

MOTION to Dismiss by PAMELA J. BONDI, DEPARTMENT OF HOMELAND SECURITY, EXECUTIVE OFFICE FOR IMMIGRATION REVIEW, TODD M. LYONS, KRISTI NOEM, SIRCE E. OWEN, KEVIN RILEY, PHILIP P. TAYLOR, U.S. DEPARTMENT OF JUSTICE, U.S. IMMIGRATION AND CUSTOM ENFORCEMENT. (Attachments: # 1 Text of Proposed Order)(Hudak, Brian) (Entered: 09/22/2025)

NOTICE OF SUPPLEMENTAL AUTHORITY by PAMELA J. BONDI, DEPARTMENT OF HOMELAND SECURITY, EXECUTIVE OFFICE FOR IMMIGRATION REVIEW, TODD M. LYONS, KRISTI NOEM, SIRCE E. OWEN, KEVIN RILEY, PHILIP P. TAYLOR, U.S. DEPARTMENT OF JUSTICE, U.S. IMMIGRATION AND CUSTOM ENFORCEMENT (Attachments: # 1 Exhibit EOIR Withdrawal)(Hudak, Brian) (Entered: 09/25/2025)

Consent MOTION for Extension of Time to File Response/Reply as to 34 MOTION to Dismiss by AMERICAN GATEWAYS, D.C., E.C., E.M., E.P., IMMIGRANT ADVOCATES RESPONSE COLLABORATIVE, J.L., K.M., L.H., M.D., M.K., M.S., P.D., R.A.. (Attachments: # 1 Text of Proposed Order)(Brewer, Simon) (Entered: 09/25/2025)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. PAMELA J. BONDI served on 8/6/2025 (Salzman, Joshua) (Entered: 09/26/2025)

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

MINUTE ORDER: The Court GRANTS Plaintiffs' 36 Consent Motion for Extension of Time. Plaintiffs' opposition to Defendants' 34 Motion to Dismiss is now due October 20, 2025. Defendants' reply, if any, is now due November 3, 2025. SO ORDERED. Signed by Judge Trevor N. McFadden on 9/26/2025. (lctnm1)