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1
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COMPLAINT against Adrienne E. Adams, Eric L. Adams, City of New York, Juanita N. Holmes, Lynelle Maginley-Liddie, New York City Council, New York City Department of Correction, New York City Department of Probation, New York City Police Department, Jessica S Tisch Was the Disclosure Statement on Civil Cover Sheet completed -NO,, filed by United States of America. (Attachments: # 1 Civil Cover Sheet, # 2 Proposed Summons, # 3 Exhibit Exhibit A: Letter from David M. Carr, Council Member, et al., to Attorney General Pamela Bondi (May 7, 2025), # 4 Exhibit Exhibit B: Statistics and Compliance, ICE Reports, NYC Dept. of Correction, # 5 Exhibit Exhibit C: Stats, Civil Immigration Detainers, NYPD, # 6 Exhibit Exhibit D: ICE Administrative Arrest Statistics, # 7 Exhibit Exhibit E: Rep. of the Governmental Affairs Div., Comm. on Immigration, Nov. 2, 2011, # 8 Exhibit Exhibit F: Report of the Governmental Affairs Div., Comm. on Immigration, Feb. 26, 2013, # 9 Exhibit Exhibit G: Report of the Governmental Affairs Div., Comm. on Immigration, Oct. 20, 2014, # 10 Exhibit Exhibit H: NYPD Operations Order 4) (Reno, Catherine) (Entered: 07/24/2025)
1 Civil Cover Sheet
View on PACER
2 Proposed Summons
View on PACER
3 Exhibit Exhibit A: Letter from David M. Carr, Council Member, et al., to Attorne
View on RECAP
4 Exhibit Exhibit B: Statistics and Compliance, ICE Reports, NYC Dept. of Correcti
View on PACER
5 Exhibit Exhibit C: Stats, Civil Immigration Detainers, NYPD
View on RECAP
6 Exhibit Exhibit D: ICE Administrative Arrest Statistics
View on PACER
7 Exhibit Exhibit E: Rep. of the Governmental Affairs Div., Comm. on Immigration,
View on PACER
8 Exhibit Exhibit F: Report of the Governmental Affairs Div., Comm. on Immigration
View on PACER
9 Exhibit Exhibit G: Report of the Governmental Affairs Div., Comm. on Immigration
View on PACER
10 Exhibit Exhibit H: NYPD Operations Order 4
View on RECAP
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July 24, 2025
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July 24, 2025
Clearinghouse
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2
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Proposed Summons. by United States of America (Reno, Catherine) (Entered: 07/24/2025)
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July 24, 2025
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July 24, 2025
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3
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Clerk's Notice Re: Consent. A United States Magistrate Judge has been assigned to this case and is available to conduct all proceedings. In accordance with Rule 73 of the Federal Rules of Civil Procedure, Local Rule 73.1, the parties are notified that if all parties consent, the assigned Magistrate Judge is available to conduct all proceedings in this action including a (jury or nonjury) trial and to order the entry of a final judgment. Attached to this Notice is a blank copy of the consent form that should be filled out, signed and filed electronically only if all parties wish to consent. Any party may withhold its consent without adverse substantive consequences. Do NOT return or file the consent unless all parties have signed the consent.The form may also be accessed at the following link: https://img.nyed.uscourts.gov/files/forms/MJConsentForm.pdf (CV) (Entered: 07/24/2025)
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July 24, 2025
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July 24, 2025
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4
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Summons Issued as to Adrienne E. Adams, Eric L. Adams, City of New York, Juanita N. Holmes, Lynelle Maginley-Liddie, New York City Council, New York City Department of Correction, New York City Department of Probation, New York City Police Department, Jessica S Tisch. (CV) (Main Document 4 replaced on 7/24/2025) (CV). (Entered: 07/24/2025)
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July 24, 2025
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July 24, 2025
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5
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This attorney case opening filing has been checked for quality control. See the attachment for corrections that were made, if any. (CV) (Entered: 07/24/2025)
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July 24, 2025
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July 24, 2025
RECAP
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6
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NOTICE of Appearance by Elianis N Perez on behalf of All Plaintiffs (aty to be noticed) (Perez, Elianis) (Entered: 07/24/2025)
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July 24, 2025
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July 24, 2025
RECAP
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NOTICE: INCOMPLETE INITIAL CASE OPENING DOCUMENT SUBMISSION. Please file the Complaint, Civil Cover Sheet, Proposed Summons and pay the Civil Filing Fee for the following case so that it may be processed. Initial Case Opening Documents Should be Filed at The Time a Case Number is generated! (CV)
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July 24, 2025
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July 24, 2025
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Notice: Re: Incomplete Civil Cover Sheet
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July 24, 2025
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July 24, 2025
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Case Assigned/Reassigned
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July 24, 2025
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July 24, 2025
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Case Assigned to Judge Ramon E. Reyes, Jr and Magistrate Judge Peggy Kuo. Please download and review the Individual Practices of the assigned Judges, located on our website. Attorneys are responsible for providing courtesy copies to judges where their Individual Practices require such. (CV)
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July 24, 2025
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July 24, 2025
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7
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SCHEDULING ORDER: An Initial Conference will be held in this case on November 13, 2025 at 10:00 a.m. before Peggy Kuo, United States Magistrate Judge in Courtroom 11C South of the United States Courthouse, 225 Cadman Plaza East, Brooklyn, New York. Counsel are directed to the annexed Initial Conference Order for instructions. By November 7, 2025, the parties must file a joint and completed copy of the Proposed Discovery Plan. Any request for adjournment of this or any other conference must be made in writing on notice to opposing parties, and must disclose whether or not all parties consent. No request for adjournment will be considered unless made at least two (2) business days before the scheduled conference, except in the event of an emergency. Counsel with knowledge and authority must be present. Per diem counsel may not appear without prior permission of the Court. Plaintiff's counsel is directed to ensure that Defendants are aware of this conference. Ordered by Magistrate Judge Peggy Kuo on 7/25/2025. (RO) (Entered: 07/25/2025)
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July 25, 2025
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July 25, 2025
RECAP
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8
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NOTICE of Appearance by Karen B. Selvin on behalf of All Defendants (aty to be noticed) (Selvin, Karen) (Entered: 08/07/2025)
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Aug. 7, 2025
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Aug. 7, 2025
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9
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SUMMONS Returned Executed by United States of America. Adrienne E. Adams served on 8/4/2025, answer due 8/25/2025; Eric L. Adams served on 8/4/2025, answer due 8/25/2025; City of New York served on 8/4/2025, answer due 8/25/2025; Juanita N. Holmes served on 8/5/2025, answer due 8/26/2025; Lynelle Maginley-Liddie served on 7/31/2025, answer due 8/21/2025; New York City Council served on 8/4/2025, answer due 8/25/2025; New York City Department of Correction served on 7/31/2025, answer due 8/21/2025; New York City Department of Probation served on 8/5/2025, answer due 8/26/2025; New York City Police Department served on 8/1/2025, answer due 8/22/2025; Jessica S Tisch served on 8/1/2025, answer due 8/22/2025. (Reno, Catherine) (Entered: 08/08/2025)
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Aug. 8, 2025
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Aug. 8, 2025
RECAP
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10
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MOTION for Extension of Time to File Answer by Adrienne E. Adams, Eric L. Adams, City of New York, Juanita N. Holmes, Lynelle Maginley-Liddie, New York City Council, New York City Department of Correction, New York City Department of Probation, New York City Police Department, Jessica S Tisch. (Selvin, Karen) (Entered: 08/14/2025)
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Aug. 14, 2025
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Aug. 14, 2025
RECAP
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ORDER granting 10 Motion for Extension of Time to Answer: Defendants are directed to answer or otherwise respond to the Complaint by September 10, 2025. Ordered by Magistrate Judge Peggy Kuo on 8/15/2025. (VRM)
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Aug. 15, 2025
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Aug. 15, 2025
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Order on Motion for Extension of Time to Answer
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Aug. 15, 2025
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Aug. 15, 2025
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11
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NOTICE of Appearance by Andrew Steffan on behalf of All Defendants (aty to be noticed) (Steffan, Andrew) (Entered: 08/22/2025)
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Aug. 22, 2025
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Aug. 22, 2025
RECAP
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12
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Letter MOTION for pre motion conference by Adrienne E. Adams, Eric L. Adams, City of New York, Juanita N. Holmes, Lynelle Maginley-Liddie, New York City Council, New York City Department of Correction, New York City Department of Probation, New York City Police Department, Jessica S Tisch. (Steffan, Andrew) (Entered: 09/10/2025)
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Sept. 10, 2025
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Sept. 10, 2025
RECAP
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13
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RESPONSE in Opposition re 12 Letter MOTION for pre motion conference filed by United States of America. (Reno, Catherine) (Entered: 09/17/2025)
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Sept. 17, 2025
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Sept. 17, 2025
RECAP
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Order on Motion for Pre Motion Conference
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Sept. 25, 2025
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Sept. 25, 2025
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ORDER denying 12 Motion for Pre Motion Conference. A premotion conference is unnecessary. Defendants are granted leave to file their motion to dismiss according to the following schedule: Defendants serve their motion on plaintiff on October 15, 2025; plaintiff serves its opposition papers on defendants on November 5, 2025; defendants serve their reply on plaintiff, and file the fully briefed motion on December 5, 2025. The parties are directed to provide the court with 2 courtesy copies of all motion papers by December 9, 2025. Ordered by Judge Ramon E. Reyes, Jr on 9/25/2025. (Reyes, Ramon)
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Sept. 25, 2025
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Sept. 25, 2025
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14
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MOTION to Stay the entire case by United States of America. (Reno, Catherine) (Entered: 10/01/2025)
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Oct. 1, 2025
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Oct. 1, 2025
RECAP
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~Util - Set Deadlines
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Oct. 3, 2025
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Oct. 3, 2025
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ORDER: Defendants to respond to Plaintiff's 14 motion to stay the entire case by 10/7/2025. Ordered by Judge Ramon E. Reyes, Jr. on 10/3/2025. (RL)
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Oct. 3, 2025
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Oct. 3, 2025
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15
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RESPONSE to Motion re 14 MOTION to Stay the entire case filed by All Defendants. (Selvin, Karen) (Entered: 10/07/2025)
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Oct. 7, 2025
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Oct. 7, 2025
RECAP
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ORDER granting 14 Motion to Stay entire case pursuant to the terms of Administrative Order 2025-15. Ordered by Judge Ramon E. Reyes, Jr on 10/8/2025. (MV)
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Oct. 8, 2025
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Oct. 8, 2025
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Order on Motion to Stay
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Oct. 8, 2025
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Oct. 8, 2025
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1 - Terminate Deadlines and Hearings
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Oct. 22, 2025
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Oct. 22, 2025
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SCHEDULING ORDER: In light of this matter being stayed pursuant to the terms of Administrative Order 2025-15, the initial conference scheduled for November 13, 2025 is adjourned sine die. Ordered by Magistrate Judge Peggy Kuo on 10/22/2025. (RO)
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Oct. 22, 2025
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Oct. 22, 2025
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16
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NOTICE by United States of America re Order on Motion to Stay (Reno, Catherine) (Entered: 11/14/2025)
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Nov. 14, 2025
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Nov. 14, 2025
RECAP
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17
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NOTICE by United States of America re Terminate Deadlines and Hearings, (Reno, Catherine) (Entered: 11/14/2025)
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Nov. 14, 2025
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Nov. 14, 2025
RECAP
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18
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NOTICE by Adrienne E. Adams, Eric L. Adams, City of New York, Juanita N. Holmes, Lynelle Maginley-Liddie, New York City Council, New York City Department of Correction, New York City Department of Probation, New York City Police Department, Jessica S Tisch re Page Extension Request (Steffan, Andrew) (Entered: 11/17/2025)
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Nov. 17, 2025
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Nov. 17, 2025
RECAP
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19
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Letter MOTION for Leave to File Excess Pages by Adrienne E. Adams, Eric L. Adams, City of New York, Juanita N. Holmes, Lynelle Maginley-Liddie, New York City Council, New York City Department of Correction, New York City Department of Probation, New York City Police Department, Jessica S Tisch. (Steffan, Andrew) (Entered: 11/17/2025)
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Nov. 17, 2025
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Nov. 17, 2025
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Order(Other)
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Nov. 17, 2025
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Nov. 17, 2025
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ORDER re 16 Notice(Other) filed by United States of America. The parties' proposed briefing schedule is granted. Defendants' motion to dismiss is due December 2, 2025; Plaintiff's response is due December 23, 2025; Defendants' reply is due January 23, 2026. Ordered by Judge Ramon E. Reyes, Jr. on 11/17/2025. (RL)
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Nov. 17, 2025
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Nov. 17, 2025
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Incorrect Case-Document Information
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Nov. 18, 2025
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Nov. 18, 2025
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Incorrect Filing: Please Disregard 18 as it was correctly filed at 19 . (IH)
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Nov. 18, 2025
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Nov. 18, 2025
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Order on Motion for Leave to File Excess Pages
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Nov. 18, 2025
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Nov. 18, 2025
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ORDER granting 19 Motion for Leave to File Excess Pages. The parties are permitted to file excess pages per their request in Motion 19 . Ordered by Judge Ramon E. Reyes, Jr. on 11/18/2025. (RL)
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Nov. 18, 2025
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Nov. 18, 2025
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20
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NOTICE of Appearance by Emeline Kong on behalf of All Defendants (aty to be noticed) (Kong, Emeline) (Entered: 11/24/2025)
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Nov. 24, 2025
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Nov. 24, 2025
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21
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Letter Regarding Service of Motion to Dismiss by Adrienne E. Adams, Eric L. Adams, City of New York, Juanita N. Holmes, Lynelle Maginley-Liddie, New York City Council, New York City Department of Correction, New York City Department of Probation, New York City Police Department, Jessica S Tisch (Selvin, Karen) (Entered: 12/02/2025)
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Dec. 2, 2025
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Dec. 2, 2025
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22
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NOTICE of Appearance by Philip Levitz on behalf of State of New York (aty to be noticed) (Levitz, Philip) (Entered: 12/09/2025)
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Dec. 9, 2025
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Dec. 9, 2025
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23
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NOTICE of Appearance by Ames Grawert on behalf of Former Law Enforcement Officials (aty to be noticed) (Grawert, Ames) (Entered: 12/09/2025)
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Dec. 9, 2025
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Dec. 9, 2025
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24
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Letter regarding guidance on the Court's Individual Practice Rules by Former Law Enforcement Officials (Grawert, Ames) (Entered: 12/09/2025)
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Dec. 9, 2025
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Dec. 9, 2025
RECAP
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25
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Letter Regarding Service of Amicus Motion and Proposed Brief by State of New York (Levitz, Philip) (Entered: 12/09/2025)
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Dec. 9, 2025
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Dec. 9, 2025
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26
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NOTICE of Appearance by Meghna Philip on behalf of Legal Aid Society, Make the Road New York, Immigrant Defense Project (aty to be noticed) (Philip, Meghna) (Entered: 12/09/2025)
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Dec. 9, 2025
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Dec. 9, 2025
RECAP
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27
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Letter Regarding Service of Motion and Proposed Amicus Brief by Immigrant Defense Project, Legal Aid Society, Make the Road New York, Bronx Defenders, New York Legal Assistance Group, UnLocal, LatinoJustice PRLDEF, New York County Defender Services, Brooklyn Defender Services, Neighborhood Defender Service of Harlem (Philip, Meghna) (Entered: 12/09/2025)
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Dec. 9, 2025
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Dec. 9, 2025
RECAP
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28
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NOTICE of Appearance by Ifeyinwa Chikezie on behalf of New York Civil Liberties Union, New York Immigration Coalition (aty to be noticed) (Chikezie, Ifeyinwa) (Entered: 12/09/2025)
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Dec. 9, 2025
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Dec. 9, 2025
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29
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Letter Regarding Service of Motion and Proposed Amicus Brief by New York Civil Liberties Union, New York Immigration Coalition (Chikezie, Ifeyinwa) (Entered: 12/09/2025)
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Dec. 9, 2025
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Dec. 9, 2025
RECAP
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30
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NOTICE of Appearance by Evan Henley on behalf of Immigrant Defense Project, Legal Aid Society, Make the Road New York (aty to be noticed) (Henley, Evan) (Entered: 12/09/2025)
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Dec. 9, 2025
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Dec. 9, 2025
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31
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NOTICE of Appearance by Erin Monju on behalf of 75 Cities, Counties, and Elected Officials (aty to be noticed) (Monju, Erin) (Entered: 12/09/2025)
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Dec. 9, 2025
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Dec. 9, 2025
RECAP
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32
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Letter Regarding Service of Motion and Proposed Amicus Brief by 75 Cities, Counties, and Elected Officials (Monju, Erin) (Entered: 12/09/2025)
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Dec. 9, 2025
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Dec. 9, 2025
RECAP
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33
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Letter regarding service of motion for leave to file a brief of amicus curiae by Former Law Enforcement Officials (Grawert, Ames) (Entered: 12/09/2025)
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Dec. 9, 2025
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Dec. 9, 2025
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Order(Other)
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Dec. 9, 2025
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Dec. 9, 2025
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Order re: process for filing amicus curiae motions and briefs. The process for filing amicus curiae motions and briefs suggested in 24 is acceptable to the Court. Ordered by Judge Ramon E. Reyes, Jr. on 12/9/2025. (RL)
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Dec. 9, 2025
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Dec. 9, 2025
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34
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NOTICE of Appearance by Brian Perbix on behalf of Immigrant Defense Project, Legal Aid Society, Make the Road New York (aty to be noticed) (Perbix, Brian) (Entered: 12/10/2025)
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Dec. 10, 2025
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Dec. 10, 2025
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35
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NOTICE of Appearance by Paula Garcia Salazar on behalf of Immigrant Defense Project, Legal Aid Society, Make the Road New York (aty to be noticed) (Garcia Salazar, Paula) (Entered: 12/10/2025)
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Dec. 10, 2025
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Dec. 10, 2025
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36
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NOTICE of Appearance by Gabriella Larios on behalf of New York Civil Liberties Union, New York Immigration Coalition (aty to be noticed) (Larios, Gabriella) (Entered: 12/10/2025)
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Dec. 10, 2025
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Dec. 10, 2025
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37
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NOTICE of Appearance by Hasan Shafiqullah on behalf of Immigrant Defense Project, Legal Aid Society, Make the Road New York (aty to be noticed) (Shafiqullah, Hasan) (Entered: 12/10/2025)
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Dec. 10, 2025
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Dec. 10, 2025
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38
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NOTICE of Appearance by Rosa Cohen-Cruz on behalf of Bronx Defenders (aty to be noticed) (Cohen-Cruz, Rosa) (Entered: 12/10/2025)
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Dec. 10, 2025
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Dec. 10, 2025
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39
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Consent MOTION for Extension of Time to File Response/Reply as to 21 Letter, by United States of America. (Reno, Catherine) (Entered: 12/11/2025)
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Dec. 11, 2025
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Dec. 11, 2025
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ORDER granting 39 Motion for Extension of Time to File Response/Reply. Plaintiff's responses due by 1/21/2026. Defendants' replies due by 2/23/2026. Ordered by Judge Ramon E. Reyes, Jr. on 12/12/2025. (RL)
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Dec. 12, 2025
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Dec. 12, 2025
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Order on Motion for Extension of Time to File Response/Reply
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Dec. 12, 2025
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Dec. 12, 2025
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40
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Amicus Curiae APPEARANCE entered by Kendal Nystedt on behalf of UnLocal (Nystedt, Kendal) (Entered: 12/15/2025)
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Dec. 15, 2025
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Dec. 15, 2025
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41
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NOTICE of Appearance by Stanislao A. German on behalf of New York County Defender Services (aty to be noticed) (German, Stanislao) (Entered: 12/19/2025)
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Dec. 19, 2025
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Dec. 19, 2025
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42
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NOTICE of Appearance by Rex J. Chen on behalf of LatinoJustice PRLDEF (aty to be noticed) (Chen, Rex) (Entered: 12/22/2025)
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Dec. 22, 2025
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Dec. 22, 2025
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43
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NOTICE of Appearance by Lucas S. Marquez on behalf of Brooklyn Defender Services (aty to be noticed) (Marquez, Lucas) (Entered: 01/21/2026)
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Jan. 21, 2026
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Jan. 21, 2026
RECAP
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44
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Letter Regarding Service of Opposition to Motion to Dismiss by United States of America (Reno, Catherine) (Entered: 01/21/2026)
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Jan. 21, 2026
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Jan. 21, 2026
RECAP
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45
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NOTICE of Appearance by Jodi Ziesemer on behalf of New York Legal Assistance Group (aty to be noticed) (Ziesemer, Jodi) (Entered: 01/22/2026)
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Jan. 22, 2026
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Jan. 22, 2026
RECAP
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46
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Notice of Appearance
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Jan. 27, 2026
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Jan. 27, 2026
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