Case: African Communities Together v. Lyons

COMPLAINT against Pamela Bondi, Todd M. Lyons, Kristi Noem, Sirce E. Owen. (Filing Fee $ 405.00, Receipt Number ANYSDC-31471917)Document filed by African Communities Together, The Door..(Wanger, Emily) (Entered: 08/01/2025)

CIVIL COVER SHEET filed..(Wanger, Emily) (Entered: 08/01/2025)

REQUEST FOR ISSUANCE OF SUMMONS as to Todd M. Lyons, Kristi Noem, Sirce E. Owen, and Pamela Bondi, in their official capacities, re: 1 Complaint. Document filed by African Communities Together, The Door..(Wanger, Emily) (Entered: 08/01/2025)

RULE 7.1 CORPORATE DISCLOSURE STATEMENT. No Corporate Parent. Document filed by African Communities Together..(Wanger, Emily) (Entered: 08/01/2025)

RULE 7.1 CORPORATE DISCLOSURE STATEMENT. No Corporate Parent. Document filed by The Door..(Wanger, Emily) (Entered: 08/01/2025)

NOTICE OF APPEARANCE by Katherine R. Rosenfeld on behalf of African Communities Together, The Door..(Rosenfeld, Katherine) (Entered: 08/04/2025)

NOTICE OF APPEARANCE by Samuel Shapiro on behalf of African Communities Together, The Door..(Shapiro, Samuel) (Entered: 08/04/2025)

NOTICE OF APPEARANCE by Wafa Junaid on behalf of African Communities Together, The Door..(Junaid, Wafa) (Entered: 08/04/2025)

NOTICE OF APPEARANCE OF PRO BONO COUNSEL by Paige Austin on behalf of African Communities Together, The Door.(Austin, Paige) (Entered: 08/04/2025)

NOTICE OF APPEARANCE by Robert Andrew Hodgson on behalf of African Communities Together, The Door..(Hodgson, Robert) (Entered: 08/04/2025)

NOTICE OF APPEARANCE by Elizabeth Hui Gyori on behalf of African Communities Together, The Door..(Gyori, Elizabeth) (Entered: 08/04/2025)

ELECTRONIC SUMMONS ISSUED as to Pamela Bondi, Todd M. Lyons, Kristi Noem, Sirce E. Owen..(pc) (Entered: 08/04/2025)

Case Opening Initial Assignment Notice

CASE OPENING INITIAL ASSIGNMENT NOTICE: The above-entitled action is assigned to Judge P. Kevin Castel. Please download and review the Individual Practices of the assigned District Judge, located at https://nysd.uscourts.gov/judges/district-judges. Attorneys are responsible for providing courtesy copies to judges where their Individual Practices require such. Please download and review the ECF Rules and Instructions, located at https://nysd.uscourts.gov/rules/ecf-related-instructions..(pc)

Magistrate Judge Robyn F. Tarnofsky is designated to handle matters that may be referred in this case. Pursuant to 28 U.S.C. Section 636(c) and Fed. R. Civ. P. 73(b)(1) parties are notified that they may consent to proceed before a United States Magistrate Judge. Parties who wish to consent may access the necessary form at the following link: https://nysd.uscourts.gov/sites/default/files/2018-06/AO-3.pdf. (pc)

Case Designated ECF. (pc)

NOTICE OF APPEARANCE by Harold A. Solis on behalf of African Communities Together, The Door..(Solis, Harold) (Entered: 08/05/2025)

NOTICE OF APPEARANCE by Thomas Willoughby Munson on behalf of African Communities Together, The Door..(Munson, Thomas) (Entered: 08/05/2025)

NOTICE OF APPEARANCE by Noor Zafar on behalf of African Communities Together, The Door..(Zafar, Noor) (Entered: 08/05/2025)

NOTICE OF APPEARANCE by Michael Thomas Tan on behalf of African Communities Together, The Door..(Tan, Michael) (Entered: 08/05/2025)

NOTICE OF APPEARANCE by Jeffrey Stuart Oestericher on behalf of Pamela Bondi, Todd M. Lyons, Kristi Noem, Sirce E. Owen..(Oestericher, Jeffrey) (Entered: 08/06/2025)

NOTICE OF APPEARANCE by Tomoko Onozawa on behalf of Pamela Bondi, Todd M. Lyons, Kristi Noem, Sirce E. Owen..(Onozawa, Tomoko) (Entered: 08/07/2025)

LETTER addressed to Judge P. Kevin Castel from Elizabeth Gyori dated August 7, 2025 re: Pre-Motion Letter and Joint Proposed Briefing Schedule. Document filed by African Communities Together, The Door..(Gyori, Elizabeth) (Entered: 08/07/2025)

ORDER INITIAL PRETRIAL CONFERENCE: COUNSEL FOR PLAINTIFF (OR THE REMOVING DEFENDANT) SHALL IMMEDIATELY SEND A COPY OF THIS ORDER TO ALL PARTIES. 1. Counsel for all parties shall appear for an Initial Pretrial Conference, held pursuant to Rule 16 of the Federal Rules of Civil Procedure, October 10, 2025 at 10:30 a.m. Principal trial counsel shall appear at this and all subsequent conferences. 2. The parties shall submit a joint letter five business days prior to the Conference addressing the following in separate paragraphs: (1) a brief description of the case, including the factual and legal bases for the claim(s) and defense(s); (2) any contemplated motions; and (3) the prospect for settlement. The parties shall set forth the date and time of the Conference in the opening paragraph of the joint letter. 3. The parties are directed to confer on a Case Management Plan (the "Plan") in accordance with Rule 26(f) of the Federal Rules of Civil Procedure. The outline of a Plan may be found on the Court's website: https://nysd.uscourts.gov/hon-p-kevin-castel. The jointly proposed Plan shall be submitted in writing to the Deputy Clerk immediately prior to the Conference. 4. The parties shall consult the undersigned's Individual Practices available on the Court's website. Requests for adjournment of the Conference will be considered only if made in writing and in accordance with the undersigned's Individual Practices. 5. Prior to the Conference, counsel for all parties shall file a Notice of Appearance in accordance with the Rules and Instructions for Electronic Case Filing. 6. For initial pretrial conferences, plaintiff(s)' counsel shall, no later than 5 business days before the conference, email a copy of the agreed upon (or disputed) Civil Case Management Plan & Scheduling Order to: castelnysdchambers@nysd.uscourts.gov. The call-in information for all teleconferences is: Dial-in: 1-855-244-8681 Access Code: 2305 810 3970 # Attention is called to Local Rule 1.8 that prohibits the recording or transmission of any proceeding. SO ORDERED. (Signed by Judge P. Kevin Castel on 8/8/2025) Initial Conference set for 10/10/2025 at 10:30 AM before Judge P. Kevin Castel. (ar) (Entered: 08/08/2025)

MEMO ENDORSEMENT on re: 19 Letter filed by The Door, African Communities Together. ENDORSEMENT: Application GRANTED. The proposed briefing schedule is adopted. Plaintiffs may file their motion by August 11, defendants may file their opposition by August 20, and plaintiffs may reply by August 25. ( Motions due by 8/11/2025., Responses due by 8/20/2025, Replies due by 8/25/2025.) (Signed by Judge P. Kevin Castel on 8/8/2025) (rro) (Entered: 08/08/2025)

MOTION to Stay under 5 U.S.C. § 705. Document filed by African Communities Together, The Door. (Attachments: # 1 Exhibit Proposed Order).(Wanger, Emily) (Entered: 08/11/2025)

1 Exhibit Proposed Order

View on PACER

MEMORANDUM OF LAW in Support re: 22 MOTION to Stay under 5 U.S.C. § 705. . Document filed by African Communities Together, The Door. (Attachments: # 1 Exhibit Declaration of Beth Baltimore, # 2 Exhibit Declaration of Sarah M. Burr, # 3 Exhibit Declaration of Andres Santamaria Cortes, # 4 Exhibit Declaration of Jennifer A. Durkin, # 5 Exhibit Declaration of Rosanna Eugenio, # 6 Exhibit Declaration of Deborah Fleischaker, # 7 Exhibit Declaration of Audrey Gilliam, # 8 Exhibit Declaration of Diana Konate, # 9 Exhibit Declaration of Brad Lander, # 10 Exhibit Declaration of Rachel Levenson, # 11 Exhibit Declaration of Gillian Rowland-Kain, # 12 Exhibit Declaration of Siomara M. Umana).(Wanger, Emily) (Entered: 08/11/2025)

1 Exhibit Declaration of Beth Baltimore

View on PACER

2 Exhibit Declaration of Sarah M. Burr

View on PACER

3 Exhibit Declaration of Andres Santamaria Cortes

View on PACER

4 Exhibit Declaration of Jennifer A. Durkin

View on RECAP

5 Exhibit Declaration of Rosanna Eugenio

View on PACER

6 Exhibit Declaration of Deborah Fleischaker

View on PACER

7 Exhibit Declaration of Audrey Gilliam

View on PACER

8 Exhibit Declaration of Diana Konate

View on PACER

9 Exhibit Declaration of Brad Lander

View on PACER

10 Exhibit Declaration of Rachel Levenson

View on PACER

11 Exhibit Declaration of Gillian Rowland-Kain

View on PACER

12 Exhibit Declaration of Siomara M. Umana

View on PACER

DECLARATION of Amy Belsher in Support re: 22 MOTION to Stay under 5 U.S.C. § 705.. Document filed by African Communities Together, The Door. (Attachments: # 1 Exhibit 1 - April 27, 2021 ICE Memo, # 2 Exhibit 2 - Practice Alert: EOIR Guidance to IJs, # 3 Exhibit 3 - January 21, 2025 ICE Memo, # 4 Exhibit 4 - May 27, 2025 ICE Courthouse Arrest Memo, # 5 Exhibit 5 - EOIR Court Practice Manual Ch. 3, # 6 Exhibit 6 - NYTimes Article, # 7 Exhibit 7 - Washington Post Article, # 8 Exhibit 8 - N.P.R. Article, # 9 Exhibit 9 - Fox News Article, # 10 Exhibit 10 - Axios Article, # 11 Exhibit 11 - The City Article, # 12 Exhibit 12 - May 30, 2025 EOIR Dismissal Memo, # 13 Exhibit 13 - Policy Brief, # 14 Exhibit 14 - CBS Article, # 15 Exhibit 15 - X Post, # 16 Exhibit 16 - NY Times Article).(Wanger, Emily) (Entered: 08/11/2025)

MOTION for Megan Porter to Appear Pro Hac Vice . Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by African Communities Together, The Door. (Attachments: # 1 Exhibit Affidavit in Support of Motion for Pro Hac Vice Admission, # 2 Exhibit Certificate of Good Standing (Illinois), # 3 Exhibit Certificate of Good Standing (Ohio), # 4 Exhibit Proposed Order).(Porter, Megan) (Entered: 08/12/2025)

Notice Regarding Pro Hac Vice Motion

>>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. 25 MOTION for Megan Porter to Appear Pro Hac Vice . Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (rju)

MOTION for Oscar Sarabia Roman to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-31534960. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by African Communities Together, The Door. (Attachments: # 1 Affidavit Affidavit in Support of Motion for Pro Hac Vice Admission, # 2 Exhibit Certificate of Good Standing, # 3 Proposed Order Proposed Order).(Sarabia Roman, Oscar) (Entered: 08/13/2025)

AFFIDAVIT OF SERVICE. Service was made by Certified Mail. Document filed by African Communities Together, The Door..(Wanger, Emily) (Entered: 08/14/2025)

CERTIFICATE OF SERVICE. Pamela Bondi served on 8/5/2025, answer due 10/6/2025; Todd M. Lyons served on 8/5/2025, answer due 10/6/2025; Kristi Noem served on 8/5/2025, answer due 10/6/2025; Sirce E. Owen served on 8/5/2025, answer due 10/6/2025. Service was accepted by United States Attorney, SDNY. Document filed by African Communities Together; The Door..(Wanger, Emily) (Entered: 08/14/2025)

Notice Regarding Pro Hac Vice Motion

>>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. 26 MOTION for Oscar Sarabia Roman to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-31534960. Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (bc)

Amicus Curiae Appearance

File Amicus Brief

Order on Motion to Appear Pro Hac Vice

CONSENT LETTER MOTION for Leave to File Excess Pages addressed to Judge P. Kevin Castel from AUSA Jeffrey Oestericher dated 08/20/2025. Document filed by Pamela Bondi, Todd M. Lyons, Kristi Noem, Sirce E. Owen..(Oestericher, Jeffrey) (Entered: 08/20/2025)

CONSENT LETTER MOTION for Leave to File Excess Pages addressed to Judge P. Kevin Castel from Emily Wanger dated 08/20/2025. Document filed by African Communities Together, The Door..(Wanger, Emily) (Entered: 08/20/2025)

MOTION for Hannah Schoen Steinberg to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-31591121. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by African Communities Together, The Door. (Attachments: # 1 Affidavit in Support of Motion for Pro Hac Vice Admission, # 2 Exhibit Certificate of Good Standing, # 3 Proposed Order Proposed Order).(Steinberg, Hannah) (Entered: 08/20/2025)

ORDER granting 33 Letter Motion for Leave to File Excess Pages. Application GRANTED. SO ORDERED. (Signed by Judge P. Kevin Castel on 8/20/2025) (vfr) (Entered: 08/20/2025)

ORDER granting 34 Letter Motion for Leave to File Excess Pages. Application GRANTED. SO ORDERED. (Signed by Judge P. Kevin Castel on 8/20/2025) (vfr) (Entered: 08/20/2025)

NOTICE OF APPEARANCE by Amy Belsher on behalf of African Communities Together, The Door..(Belsher, Amy) (Entered: 08/20/2025)

MEMORANDUM OF LAW in Opposition re: 22 MOTION to Stay under 5 U.S.C. § 705. . Document filed by Pamela Bondi, Todd M. Lyons, Kristi Noem, Sirce E. Owen..(Oestericher, Jeffrey) (Entered: 08/20/2025)

DECLARATION of Sirce Owen in Opposition re: 22 MOTION to Stay under 5 U.S.C. § 705.. Document filed by Pamela Bondi, Todd M. Lyons, Kristi Noem, Sirce E. Owen..(Oestericher, Jeffrey) (Entered: 08/20/2025)

DECLARATION of AUSA Jeffrey Oestericher in Opposition re: 22 MOTION to Stay under 5 U.S.C. § 705.. Document filed by Pamela Bondi, Todd M. Lyons, Kristi Noem, Sirce E. Owen. (Attachments: # 1 Exhibit A- 3/19/14 Email from Philip T. Miller, # 2 Exhibit B- 1/26/15 Email from Philip T. Miller).(Oestericher, Jeffrey) (Entered: 08/20/2025)

1 Exhibit A- 3/19/14 Email from Philip T. Miller

View on PACER

2 Exhibit B- 1/26/15 Email from Philip T. Miller

View on PACER

Notice Regarding Pro Hac Vice Motion

>>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. 35 MOTION for Hannah Schoen Steinberg to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-31591121. Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (rju)

Order on Motion to Appear Pro Hac Vice