Case: International Partners For Ethical Care Inc v. Inslee

COMPLAINT for Declaratory and Injunctive Relief against All Defendants (Receipt # AWAWDC-8127152) Attorney Joel B Ard added to party Parent 1A(pty:pla), Attorney Joel B Ard added to party Parent 1B(pty:pla), Attorney Joel B Ard added to party Parent 2A(pty:pla), Attorney Joel B Ard added to party Parent 2B(pty:pla), Attorney Joel B Ard added to party Parent 3A(pty:pla), Attorney Joel B Ard added to party Parent 3B(pty:pla), Attorney Joel B Ard added to party Parent 4A(pty:pla), Attorney Joel B Ard added to party Parent 4B(pty:pla), Attorney Joel B Ard added to party Advocates Protecting Children(pty:pla), Attorney Joel B Ard added to party International Partners For Ethical Care, Inc.(pty:pla) filed by Parent 2B, Parent 1A, Parent 3A, Parent 4A, Advocates Protecting Children, Parent 3B, International Partners For Ethical Care, Inc., Parent 1B, Parent 4B, Parent 2A. (Attachments: # 1 Civil Cover Sheet)(Ard, Joel) (Entered: 08/16/2023)

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CORPORATE DISCLOSURE STATEMENT indicating no Corporate Parents and/or Affiliates. Filed pursuant to Fed.R.Civ.P 7.1(a)(1). Filed by International Partners For Ethical Care, Inc.. (Ard, Joel) (Entered: 08/16/2023)

CORPORATE DISCLOSURE STATEMENT indicating no Corporate Parents and/or Affiliates. Filed pursuant to Fed.R.Civ.P 7.1(a)(1). Filed by Advocates Protecting Children. (Ard, Joel) (Entered: 08/16/2023)

PRAECIPE TO ISSUE SUMMONS to all Defendants by All Plaintiffs (Ard, Joel) (Entered: 08/16/2023)

APPLICATION OF ATTORNEY Gene Schaerr FOR LEAVE TO APPEAR PRO HAC VICE for All Plaintiffs (Fee Paid) Receipt No. AWAWDC-8127194 (Ard, Joel) (Entered: 08/16/2023)

Summons(es) Electronically Issued as to defendant(s) Robert Ferguson, Ross Hunter, Jay Inslee. (AMD) (Main Document 6 replaced on 8/16/2023 with correct doc) (AMD). Modified on 8/16/2023 (AMD). (Entered: 08/16/2023)

Add and Terminate Judges

U.S. District Judge David G Estudillo added. (AMD)

ORDER re 5 Application for Leave to Appear Pro Hac Vice. The Court ADMITS Attorney Gene Schaerr for PLAINTIFFS Parent 1A,Gene Schaerr for Parent 1B,Gene Schaerr for Parent 2A,Gene Schaerr for Parent 2B,Gene Schaerr for Parent 3A,Gene Schaerr for Parent 3B,Gene Schaerr for Parent 4A,Gene Schaerr for Parent 4B,Gene Schaerr for Advocates Protecting Children,Gene Schaerr for International Partners For Ethical Care Inc, by Clerk Ravi Subramanian. No document associated with this docket entry, text only.NOTE TO COUNSEL: Local counsel agrees to sign all filings and to be prepared to handle the matter, including the trial thereof, in the event the applicant is unable to be present on any date scheduled by the court, pursuant to LCR 83.1(d).(MG) (Entered: 08/18/2023)

Order on Application for Leave to Appear Pro Hac Vice

NOTICE of Appearance by attorney Cristina Sepe on behalf of Defendants Robert Ferguson, Ross Hunter, Jay Inslee. (Sepe, Cristina) (Entered: 08/22/2023)

NOTICE of Appearance by attorney Andrew R W Hughes on behalf of Defendants Robert Ferguson, Ross Hunter, Jay Inslee. (Hughes, Andrew) (Entered: 08/23/2023)

Add and Terminate Attorneys

Attorney Marsha J. Chien added for Robert Ferguson, Ross Hunter, Jay Inslee; per 8 Notice of Appearance. (MW)

Add and Terminate Attorneys

Attorney Lauryn K. Fraas added for Robert Ferguson, Ross Hunter, Jay Inslee; per 9 Notice of Appearance. (MW)

APPLICATION OF ATTORNEY Edward Trent FOR LEAVE TO APPEAR PRO HAC VICE for All Plaintiffs (Fee Paid) Receipt No. AWAWDC-8139758 (Ard, Joel) (Entered: 08/25/2023)

ORDER re 10 Application for Leave to Appear Pro Hac Vice. The Court ADMITS Attorney Edward H Trent for Plaintiffs Parent 1A, Parent 1B, Parent 2A, Parent 2B, Parent 3A, Parent 3B, Parent 4A, Parent 4B, Advocates Protecting Children, and International Partners For Ethical Care Inc by Clerk Ravi Subramanian. No document associated with this docket entry, text only.NOTE TO COUNSEL: Local counsel agrees to sign all filings and to be prepared to handle the matter, including the trial thereof, in the event the applicant is unable to be present on any date scheduled by the court, pursuant to LCR 83.1(d). (JWC) (Entered: 08/25/2023)

Order on Application for Leave to Appear Pro Hac Vice

ORDER REGARDING INITIAL DISCLOSURES, JOINT STATUS REPORT, DISCOVERY, DEPOSITIONS AND EARLY SETTLEMENT: FRCP 26(f) Conference Deadline is 11/13/2023, Initial Disclosure Deadline is 11/20/2023, Joint Status Report due by 11/27/2023, Scheduling Conference set for 12/8/2023 at 2:30 PM in Courtroom B before U.S. District Judge David G. Estudillo. Signed by U.S. District Judge David G. Estudillo. (MGC) (Entered: 08/28/2023)

NOTICE of Appearance by attorney Jonathan F Mitchell on behalf of Plaintiffs Parent 1A, Parent 1B, Parent 2A, Parent 2B, Parent 3A, Parent 3B, Parent 4A, Parent 4B, Advocates Protecting Children, International Partners For Ethical Care Inc. (Mitchell, Jonathan) (Entered: 09/05/2023)

NOTICE OF WITHDRAWAL OF COUNSEL: Attorney Joel B Ard for All Plaintiffs. (Ard, Joel) (Entered: 09/05/2023)

Stipulated MOTION and Proposed Order Re: Briefing Schedule and Word Limits and to Extend Initial Case Schedule Order Dates, filed by Defendants Robert Ferguson, Ross Hunter, Jay Inslee. Noting Date 9/6/2023, (Sepe, Cristina) (Entered: 09/06/2023)

MOTION Leave to Proceed Under Pseudonyms, filed by Plaintiffs Parent 1A, Parent 1B, Parent 2A, Parent 2B, Parent 3A, Parent 3B, Parent 4A, Parent 4B. (Attachments: # 1 Proposed Order) Noting Date 9/29/2023, (Mitchell, Jonathan) (Entered: 09/08/2023)

ORDER re Parties' 15 Stipulated MOTION and Proposed Order Re: Briefing Schedule and Word Limits and to Extend Initial Case Schedule Order Dates. The following briefing schedule shall govern the resolution of Plaintiffs' Motion f or Preliminary Injunction and Defendants' Motion to Dismiss in this case: Plaintiffs' Motion for Preliminary Injunction due 9/15/2023; Defendants' Motion to Dismiss and Opposition to Plaintiffs' Motion for Preliminary Injunction due 10/16/2023; Plaintiffs' Reply to Motion for Preliminary Injunction and Opposition to Defendants Motion to Dismiss due 11/15/2023; Defendants' Reply to Motion to Dismiss due 11/29/2023. The initial case deadlines (see Dkt. No. 12 ) shall be stayed. The Court will issue a new order regarding the initial case deadlines, as necessary, after it decides the Defendants' motion to dismiss. Signed by U.S. District Judge David G Estudillo.(MW)

APPLICATION OF ATTORNEY Ian Pryor FOR LEAVE TO APPEAR PRO HAC VICE for All Plaintiffs (Fee Paid) Receipt No. AWAWDC-8166224 (Mitchell, Jonathan) (Entered: 09/15/2023)

APPLICATION OF ATTORNEY Nicholas R. Barry FOR LEAVE TO APPEAR PRO HAC VICE for All Plaintiffs (Fee Paid) Receipt No. AWAWDC-8166242 (Mitchell, Jonathan) (Entered: 09/15/2023)

NOTICE to the Court of Plaintiffs' Decision Not to Move for Preliminary Injunction ; filed by All Plaintiffs. (Mitchell, Jonathan) (Entered: 09/15/2023)

MOTION Waive Local-Counsel Signature Requirement in Rule 83.1(d)(2), filed by All Plaintiffs. (Attachments: # 1 Proposed Order) Noting Date 10/6/2023, (Mitchell, Jonathan) (Entered: 09/17/2023)

ORDER re 19 Application for Leave to Appear Pro Hac Vice. The Court ADMITS Attorney Nicholas Barry for PLAINTIFFS Parent 1A, Parent 1B, Parent 2A, Parent 2B, Parent 3A, Parent 3B, Parent 4A, Parent 4B and Advocates Protecting Children by Clerk Ravi Subramanian. No document associated with this docket entry, text only.NOTE TO COUNSEL: Local counsel agrees to sign all filings and to be prepared to handle the matter, including the trial thereof, in the event the applicant is unable to be present on any date scheduled by the court, pursuant to LCR 83.1(d).(MG) (Entered: 09/18/2023)

Order on Application for Leave to Appear Pro Hac Vice

ORDER re 18 Application for Leave to Appear Pro Hac Vice. The Court ADMITS Attorney Ian Prior for Parent PLAINTIFFS Parent 1A, Parent 2A, Parent 2B, Parent 3A, Parent 3B, Parent 4A, Parent 4B, Advocates Protecting Children and International Partners Ethical Care Inc by Clerk Ravi Subramanian. No document associated with this docket entry, text only.NOTE TO COUNSEL: Local counsel agrees to sign all filings and to be prepared to handle the matter, including the trial thereof, in the event the applicant is unable to be present on any date scheduled by the court, pursuant to LCR 83.1(d).(MG) (Entered: 09/19/2023)

RESPONSE, by Defendants Robert Ferguson, Ross Hunter, Jay Inslee, to 16 MOTION Leave to Proceed Under Pseudonyms . (Hughes, Andrew) (Entered: 09/19/2023)

RESPONSE, by Defendants Robert Ferguson, Ross Hunter, Jay Inslee, to 21 MOTION Waive Local-Counsel Signature Requirement in Rule 83.1(d)(2) . (Hughes, Andrew) (Entered: 09/19/2023)

Order on Application for Leave to Appear Pro Hac Vice

APPLICATION OF ATTORNEY James Rogers FOR LEAVE TO APPEAR PRO HAC VICE for All Plaintiffs (Fee Paid) Receipt No. AWAWDC-8175493 (Mitchell, Jonathan) (Entered: 09/22/2023)

ORDER re 26 Application for Leave to Appear Pro Hac Vice. The Court ADMITS Attorney James K Rogers for Plaintiffs Parent 1A, Parent 1B, Parent 2A, Parent 2B, Parent 3A, Parent 3B, Parent 4A, Parent 4B, Advocates Protecting Children, and International Partners For Ethical Care Inc by Clerk Ravi Subramanian. No document associated with this docket entry, text only.NOTE TO COUNSEL: Local counsel agrees to sign all filings and to be prepared to handle the matter, including the trial thereof, in the event the applicant is unable to be present on any date scheduled by the court, pursuant to LCR 83.1(d). (JWC) (Entered: 09/22/2023)

Order on Application for Leave to Appear Pro Hac Vice

REPLY, filed by All Plaintiffs, TO RESPONSE to 16 MOTION Leave to Proceed Under Pseudonyms (Mitchell, Jonathan) (Entered: 09/28/2023)

REPLY, filed by All Plaintiffs, TO RESPONSE to 21 MOTION Waive Local-Counsel Signature Requirement in Rule 83.1(d)(2) (Mitchell, Jonathan) (Entered: 10/06/2023)

MOTION to Dismiss, filed by Defendants Robert Ferguson, Ross Hunter, Jay Inslee. (Attachments: # 1 Proposed Order) Noting Date 11/29/2023, (Sepe, Cristina) (Entered: 10/16/2023)

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DECLARATION of Cristina Sepe in Support of Defendants' Motion to Dismiss filed by Defendants Robert Ferguson, Ross Hunter, Jay Inslee re 30 MOTION to Dismiss (Attachments: # 1 Exhibit A-E)(Sepe, Cristina) (Entered: 10/16/2023)

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ORDER granting Plaintiffs' 16 MOTION to Proceed Under Pseudonyms. Signed by U.S. District Judge David G Estudillo.(MW)

ORDER denying Plaintiff's 21 Motion to Waive Local Counsel Signature Requirement. Signed by U.S. District Judge David G Estudillo.(MW)

AMENDED COMPLAINT against defendant(s) Jay Inslee, Robert Ferguson, Ross Hunter filed by Parent 2B, Parent 1A, Parent 3A, Parent 4A, Advocates Protecting Children, Parent 3B, International Partners For Ethical Care Inc, Parent 1B, Parent 4B, Parent 2A. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, # 4 Exhibit, # 5 Exhibit, # 6 Exhibit, # 7 Exhibit, # 8 Exhibit, # 9 Exhibit)(Mitchell, Jonathan) (Entered: 11/06/2023)

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Joint Stipulated MOTION and [Proposed] Order to Set Briefing Schedule and Word Limits, filed by Defendants Robert Ferguson, Ross Hunter, Jay Inslee. Noting Date 11/13/2023, (Sepe, Cristina) (Entered: 11/13/2023)

ORDER granting Parties' 35 Joint Stipulated MOTION to Set Briefing Schedule and Word Limits. Signed by U.S. District Judge David G Estudillo.(MW)

MOTION to Dismiss First Amended Complaint, filed by All Defendants. (Attachments: # 1 Appendix - Statutes, # 2 Proposed Order) Noting Date 2/2/2024, (Sepe, Cristina) (Entered: 12/15/2023)

1 Appendix - Statutes

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DECLARATION of Cristina Sepe in Support of Defendants' Motion to Dismiss First Amended Complaint filed by All Defendants re 37 MOTION to Dismiss First Amended Complaint (Attachments: # 1 Exhibit A-H)(Sepe, Cristina) (Entered: 12/15/2023)

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NOTICE of Appearance by attorney Isaac Ruiz on behalf of Amicus Legal Counsel for Youth and Children. (Ruiz, Isaac) (Entered: 01/18/2024)

NOTICE of Appearance by attorney McKean J Evans on behalf of Amicus Legal Counsel for Youth and Children. (Evans, McKean) (Entered: 01/18/2024)

MOTION for Leave of Legal Counsel for Youth and Children to Appear as Amicus Curiae, filed by Amicus Legal Counsel for Youth and Children. (Attachments: # 1 Proposed Order) Noting Date 2/2/2024, (Evans, McKean) (Entered: 01/18/2024)

DECLARATION of Erin L. Lovell filed by Amicus Legal Counsel for Youth and Children re 41 MOTION for Leave of Legal Counsel for Youth and Children to Appear as Amicus Curiae (Attachments: # 1 Exhibit A, # 2 Complaint B)(Evans, McKean) (Entered: 01/18/2024)

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RESPONSE, by All Plaintiffs, to 37 MOTION to Dismiss First Amended Complaint. (Attachments: # 1 Proposed Order)(Mitchell, Jonathan) (Entered: 01/19/2024)

REPLY, filed by Amicus Legal Counsel for Youth and Children, TO RESPONSE to 41 MOTION for Leave of Legal Counsel for Youth and Children to Appear as Amicus Curiae (Evans, McKean) (Entered: 02/02/2024)

REPLY, filed by Defendants Robert Ferguson, Ross Hunter, Jay Inslee, TO RESPONSE to 37 MOTION to Dismiss First Amended Complaint (Sepe, Cristina) (Entered: 02/02/2024)

MINUTE ORDER entered at the direction of U.S. District Judge David G. Estudillo: Plaintiffs' Amended Complaint (Dkt. 34 ) renders the original complaint (Dkt. 1 ) in this case without legal effect. Thus, the Court STRIKES Defendants' 30 MOTION to Dismiss as MOOT. (MGC) (Entered: 02/05/2024)

ORDER granting Legal Counsel for Youth and Children's 41 Motion for Leave to Appear as Amicus Curiae. LCYC SHALL be permitted to proceed as Amicus Curiae and may file its amicus brief. Signed by U.S. District Judge David G Estudillo.(MW)

BRIEF re 47 Order on Motion for Leave, 37 MOTION to Dismiss First Amended Complaint of Amicus Curiae Legal Counsel for Youth and Children in Support of Defendants' Motion to Dismiss First Amended Complaint by Amicus Legal Counsel for Youth and Children (Evans, McKean) (Entered: 02/05/2024)

2 - Minute Order AND ~Util - Terminate Motions

MINUTE ORDER. This case is reassigned to United States Judge Robert J. Bryan for the purposes of considering all pending motions. Authorized by U.S. District Judge David G Estudillo. (MW)

ORDER granting 37 Motion to Dismiss First Amended Complaint. Signed by Judge Robert J. Bryan. (JL)

JUDGMENT BY COURT. Defendants' Motion to Dismiss Plaintiffs' First Amended Complaint is GRANTED. This case is hereby DISMISSED WITH PREJUDICE (CJS) (Entered: 05/15/2024)

NOTICE OF APPEAL (24-3661) to Ninth Circuit re 51 Judgment by Court, 50 Order on Motion to Dismiss by Plaintiffs Parent 1A, Parent 1B, Parent 2A, Parent 2B, Parent 3A, Parent 3B, Parent 4A, Parent 4B, Advocates Protecting Children, International Partners For Ethical Care Inc, Parent 5A, Parent 5B. $605, receipt number AWAWDC-8499203 (cc: USCA) (Attachments: # 1 Exhibit)(Mitchell, Jonathan) Modified to add CCA # on 6/13/2024 (MW). (Entered: 06/08/2024)

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EXHIBIT (Notice of Representation) re 52 Notice of Appeal, by All Plaintiffs (Mitchell, Jonathan) Modified on 6/11/2024 - Regenerated NEF to USCA 9th Circuit (CJS). (Entered: 06/10/2024)

MINUTE ORDER TERMINATING REASSIGNMENT OF PENDING MOTIONS. The reassignment of pending motions in this case to Judge Robert J. Bryan is terminated. Authorized by U.S. District Judge David G Estudillo. (CJS) (Entered: 06/10/2024)

TIME SCHEDULE ORDER/USCA CASE NUMBER 24-3661 as to 52 Notice of Appeal, filed by Parent 4B, Parent 4A, Parent 3A, Parent 3B, Parent 2B, Parent 2A, Parent 1B, Parent 1A, Parent 5A, Parent 5B, International Partners For Ethical Care Inc, Advocates Protecting Children. (MW) (Entered: 06/13/2024)

TRANSCRIPT DESIGNATION (#24-3661) by All Plaintiffs. Requesting Attorney: Jonathan F Mitchell. (Mitchell, Jonathan) (Entered: 06/17/2024)

OPINION FROM USCA (24-3661) (NOT THE MANDATE) as to 52 Notice of Appeal, filed by Parent 4B, Parent 4A, Parent 3A, Parent 3B, Parent 2B, Parent 2A, Parent 1B, Parent 1A, Parent 5A, Parent 5B, International Partners For Ethical Care Inc, Advocates Protecting Children. AFFIRMED. (RE) (Entered: 07/25/2025)

ORDER OF USCA (24-3661) as to 52 Notice of Appeal, filed by Parent 4B, Parent 4A, Parent 3A, Parent 3B, Parent 2B, Parent 2A, Parent 1B, Parent 1A, Parent 5A, Parent 5B, International Partners For Ethical Care Inc, Advocates Protecting Children. Defendants-Appellees are directed to file a response to Plaintiffs-Appellants' petition for panel rehearing or rehearing en banc filed with this court on August 8, 2025. The response shall be filed within 21 days of the date of this order and shall not exceed 15 pages in length unless it complies with the alternative length limitation of 4,200 words. (MW) (Entered: 09/09/2025)

ORDER OF USCA (24-3661) as to 52 Notice of Appeal. The petition for panel rehearing and the petition for rehearing en banc are DENIED. (MW) (Entered: 12/05/2025)

Transmittal Letter from USCA