Case: United States v. International Union, United Automobile, Aerospace, and Agricultural Implement Workers of America

COMPLAINT filed by United States of America against International Union, United Automobile, Aerospace, and Agricultural Implement Workers of America. Plaintiff requests summons issued. No Fee Required - US Government. County of 1st Plaintiff: USA - County Where Action Arose: Wayne - County of 1st Defendant: Wayne. [Previously dismissed case: No] [Possible companion case(s): U.S. District Court, EDMI, 17-cr-20406, Judge Paul D. Borman] (Gardey, David) Modified on 12/15/2020 (TTho). [COMPANION CASES: 18-CV-51223 JUDGE PAUL D. BORMAN, 19-CR-20146 JUDGE PAUL D. BORMAN, 19-CR-20726 JUDGE PAUL D. BORMAN, 19-CV-13429 JUDGE PAUL D. BORMAN, 20-CR-20382 JUDGE PAUL D. BORMAN, 19-CR-20738 JUDGE BERNARD A. FRIEDMAN] (Entered: 12/14/2020)

NOTICE of Appearance by Steven P. Cares on behalf of United States of America. (Cares, Steven) (Entered: 12/14/2020)

Joint MOTION for entry of Consent Order by United States of America. (Attachments: # 1 Exhibit 1 - Proposed Consent Order) (Cares, Steven)[PROPOSED ORDER STRICKEN PURSUANT TO 12/17/20 ORDER] Modified on 12/18/2020 (DPer). (Entered: 12/14/2020)

1 Exhibit 1 - Proposed Consent Order

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SUMMONS Issued for *International Union, United Automobile, Aerospace, and Agricultural Implement Workers of America* (LGra) (Entered: 12/14/2020)

A United States Magistrate Judge of this Court is available to conduct all proceedings in this civil action in accordance with 28 U.S.C. 636c and FRCP 73. The Notice, Consent, and Reference of a Civil Action to a Magistrate Judge form is available for download at http://www.mied.uscourts.gov (LGra)

Notice to Parties of Consent of a Civil Action before a Magistrate Judge Option

NOTICE of Appearance by Terence H. Campbell on behalf of International Union, United Automobile, Aerospace, and Agricultural Implement Workers of America. (Campbell, Terence) (Entered: 12/15/2020)

ORDER striking improper filing. Signed by District Judge David M. Lawson. (DPer) (Entered: 12/18/2020)

Joint MOTION for entry of Consent Order by United States of America. (Cares, Steven) (Entered: 01/05/2021)

NOTICE of Appearance by Barbara M. Harvey on behalf of Unite All Workers for Democracy Movement (UAWD). (Harvey, Barbara) (Entered: 01/07/2021)

ORDER Granting Joint Motion 3 and 7 for Entry of Consent Decree. Signed by District Judge David M. Lawson. (SPin) (Entered: 01/29/2021)

CONSENT DECREE. Signed by District Judge David M. Lawson. (SPin) (Entered: 01/29/2021)

NOTICE of Appearance by Eric Shawn Pruitt on behalf of International Union, United Automobile, Aerospace, and Agricultural Implement Workers of America. (Pruitt, Eric) (Entered: 02/11/2021)

MOTION to Intervene by Unite All Workers for Democracy Movement (UAWD). (Attachments: # 1 Exh.-Parker Declaration) (Harvey, Barbara) (Entered: 02/22/2021)

MOTION Intervention re 12 MOTION to Intervene Declaration of Scott Houldieson by Unite All Workers for Democracy Movement (UAWD). (Attachments: # 1 Exhibits List, # 2 Exhibit, # 3 Exhibit, # 4 Exhibit, # 5 Exhibit, # 6 Exhibit, # 7 Exhibit, # 8 Exhibit) (Harvey, Barbara) (Entered: 02/22/2021)

1 Exhibits List

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2 Exhibit

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3 Exhibit

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4 Exhibit

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5 Exhibit

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6 Exhibit

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7 Exhibit

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8 Exhibit

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NOTICE OF HEARING on 12, 13 MOTION to Intervene. Motion Hearing set for 4/22/2021 at 1:00 PM before District Judge David M. Lawson. (SPin) (Entered: 03/03/2021)

RESPONSE to 12 MOTION to Intervene filed by United States of America. (Cares, Steven) (Entered: 03/08/2021)

RESPONSE to 12 MOTION to Intervene filed by International Union, United Automobile, Aerospace, and Agricultural Implement Workers of America. (Attachments: # 1 Exhibit Ex. A, # 2 Exhibit Ex. B, # 3 Exhibit Ex. C, # 4 Exhibit Ex. D) (Campbell, Terence) (Entered: 03/08/2021)

1 Exhibit Ex. A

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2 Exhibit Ex. B

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3 Exhibit Ex. C

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4 Exhibit Ex. D

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MOTION to file Amended Response to Motion to Intervene by United States of America. (Cares, Steven) (Entered: 03/12/2021)

RESPONSE to 17 MOTION to file Amended Response to Motion to Intervene --Non-Opposition Statement filed by Unite All Workers for Democracy Movement (UAWD). (Harvey, Barbara) (Entered: 03/13/2021)

MOTION for Extension of Time to File Response/Reply as to 15 Response to Motion, 16 Response to Motion, by Unite All Workers for Democracy Movement (UAWD). (Harvey, Barbara) (Entered: 03/15/2021)

ORDER Granting 19 Motion for Extension of Time to File Reply to 12, 13 MOTION for Intervention. Reply due by 3/19/2019. . Signed by District Judge David M. Lawson. (SPin) (Entered: 03/18/2021)

REPLY to Response re 12 MOTION to Intervene filed by Unite All Workers for Democracy Movement (UAWD). (Harvey, Barbara) (Entered: 03/20/2021)

ORDER Denying 17 Motion for Leave to File Amended Response. Signed by District Judge David M. Lawson. (SPin) (Entered: 03/22/2021)

MOTION re 21 Reply to Response to Motion to Intervene-Exhibit Supporting Intervention by Unite All Workers for Democracy Movement (UAWD). (Attachments: # 1 Exhibit DOJ Monitor Selection Guidelines in Civil Cases) (Harvey, Barbara) (Entered: 03/23/2021)

ORDER Granting 23 Motion for Leave to File Exhibits. Signed by District Judge David M. Lawson. (SPin) (Entered: 03/24/2021)

MOTION for Leave to File a Brief as Amicus Curiae In Support of the UAWD's Motion for Leave to Intervene by Association for Union Democracy. (Attachments: # 1 Exhibit) (Hermann, John) (Entered: 03/24/2021)

MOTION for Leave to File to File Exhibit (Unopposed Motion) by International Union, United Automobile, Aerospace, and Agricultural Implement Workers of America. (Attachments: # 1 Exhibit A (Tom Krisher, UAW Agrees to Monitor, Voting Changes after Corruption Probe, Associated Press, Dec. 14. 2020)) (Pruitt, Eric) (Entered: 03/30/2021)

1 Exhibit A (Tom Krisher, UAW Agrees to Monitor, Voting Changes after Corruption P

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ORDER Granting 26 Motion for Leave to File Exhibit. Signed by District Judge David M. Lawson. (SPin) (Entered: 04/02/2021)

MOTION for appointment of Monitor by United States of America. (Cares, Steven) (Entered: 04/12/2021)

NOTICE OF HEARING BY VIDEO CONFERENCE on 12 MOTION to Intervene, and 13 Declaration of Scott Houldieson in Support of Motion to Intervene. Motion Hearing set for 4/22/2021 at 1:00 PM before District Judge David M. Lawson. |Zoom Webinar Information: https://www.zoomgov.com/j/1605855002?pwd=NVA3NkVSbWV3a3plcDJ3Z1Y2cUFmQT09 Passcode: 844153 Or iPhone one-tap : US: +16692545252,,1605855002# or +16468287666,,1605855002#| (SPin) (Entered: 04/13/2021)

ORDER Granting 25 Motion for Leave to File Brief. Signed by District Judge David M. Lawson. (SPin) (Entered: 04/15/2021)

RESPONSE to 28 MOTION for appointment of Monitor Neil M. Barofsky filed by International Union, United Automobile, Aerospace, and Agricultural Implement Workers of America. (Attachments: # 1 Exhibit Ex. A - Barofsky C.V.) (Campbell, Terence) (Entered: 04/20/2021)

1 Exhibit Ex. A - Barofsky C.V.

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Minute Entry for proceedings before District Judge David M. Lawson: Motion Hearing held on 4/22/2021 re 13 MOTION Intervention re 12 MOTION to Intervene Declaration of Scott Houldieson filed by Unite All Workers for Democracy Movement (UAWD), 12 MOTION to Intervene filed by Unite All Workers for Democracy Movement (UAWD). Disposition: Motions taken under advisement. (Court Reporter: Rene Twedt) (SPin)

Motion Hearing

OPINION AND ORDER Denying 12, 13 Motion to Intervene. Signed by District Judge David M. Lawson. (See image for amicus filing deadline.) (SPin) (Entered: 04/27/2021)

Letter from UAWD re Monitor. (SPin) (Entered: 05/11/2021)

ORDER Granting Unopposed 28 Motion to Appoint Monitor. Signed by District Judge David M. Lawson. (SPin) (Entered: 05/12/2021)

MOTION for Disclosure of Grand Jury Materials by United States of America. (Cares, Steven) (Entered: 06/02/2021)

ORDER Granting in Part Government's Unopposed 35 Motion to Authorize Disclosure of Grand Jury Materials. Signed by District Judge David M. Lawson. (SPin) (Entered: 06/07/2021)

MOTION for Order Governing Disclosure of Privileged Information to the Monitor (Unopposed) by International Union, United Automobile, Aerospace, and Agricultural Implement Workers of America. (Pruitt, Eric) (Entered: 07/01/2021)

NOTICE OF HEARING BY VIDEO CONFERENCE on 37 MOTION for Order Governing Disclosure of Privileged Information to the Monitor. Motion Hearing set for 7/29/2021 at 10:30 AM before District Judge David M. Lawson. |Zoom Webinar Information: https://www.zoomgov.com/j/1614805319?pwd=MnVOLzBxS0lkdk1VQ1ZSZG9VKzFDUT09 Passcode: 095480 Or One tap mobile : US: +16692545252,,1614805319# or +16468287666,,1614805319#| (SPin) (Entered: 07/09/2021)

NOTICE OF HEARING BY VIDEO CONFERENCE on 37 MOTION for Order Governing Disclosure of Privileged Information to the Monitor (Unopposed). Motion Hearing RESET for 7/29/2021 09:30 AM before District Judge David M. Lawson (TIME CHANGE ONLY) |Zoom Webinar Information: https://www.zoomgov.com/j/1614805319?pwd=MnVOLzBxS0lkdk1VQ1ZSZG9VKzFDUT09 Passcode: 095480 Or One tap mobile : US: +16692545252,,1614805319# or +16468287666,,1614805319#| (KSan) (Entered: 07/26/2021)

Minute Entry for proceedings before District Judge David M. Lawson: Motion Hearing held on 7/29/2021 re 37 MOTION for Order Governing Disclosure of Privileged Information to the Monitor (Unopposed) filed by International Union, United Automobile, Aerospace, and Agricultural Implement Workers of America. Disposition: Motion taken under advisement; awaiting further briefing due by 8//15/2021. (Court Reporter: Rene Twedt) (SPin)

Motion Hearing

ORDER Granting 37 Motion for Order Governing Disclosure of Privileged Materials. Signed by District Judge David M. Lawson. (SPin) (Entered: 08/11/2021)

NOTICE of Appearance by Michael W. Ross on behalf of Neil M. Barofsky (Monitor). (Ross, Michael) (Entered: 08/19/2021)

NOTICE of Appearance by Lori B. Day on behalf of Neil M. Barofsky (Monitor). (Day, Lori) (Entered: 08/19/2021)

Joint MOTION to amend Consent Decree to move date for Concluding Referendum by United States of America. (Cares, Steven) (Entered: 09/07/2021)

MOTION for Appointment of Adjudications Officer by United States of America. (Gardey, David) (Entered: 09/08/2021)

ORDER Granting 43 Motion to Amend Consent Decree to Extend Deadline for Completing Referendum. Signed by District Judge David M. Lawson. (SPin) (Entered: 09/10/2021)

ORDER Granting 44 Motion to Appoint Adjudications Officer. Signed by District Judge David M. Lawson. (SPin) (Entered: 09/10/2021)

Joint MOTION for Modification of Consent Order by United States of America. (Cares, Steven) (Entered: 10/08/2021)

ORDER signed by District Judge David M. Lawson Denying 47 Joint Motion to Modify Consent Decree. (KGri) (Entered: 10/12/2021)

Monitor's Initial Status REPORT by Neil M. Barofsky (Monitor) (Ross, Michael) (Entered: 11/11/2021)

CERTIFICATE OF SERVICE re 49 Report (Free) by Neil M. Barofsky (Monitor) /Certificate of Service of Monitor's Initial Status Report (Ross, Michael) (Entered: 11/11/2021)

STATEMENT of UAW Statement in Connection With the Monitor's First Report by International Union, United Automobile, Aerospace, and Agricultural Implement Workers of America (Campbell, Terence) (Entered: 11/11/2021)

MOTION for Approval of Referendum Results (UNOPPOSED) by Neil M. Barofsky (Monitor). (Attachments: # 1 Index of Exhibits, # 2 Exhibit A - Monitor's Referendum Report, # 3 Exhibit B - OLMS Endorsement, # 4 Certificate of Service) (Ross, Michael) (Entered: 01/24/2022)

ORDER Granting 52 Joint Motion to Approve Referendum Results. Signed by District Judge David M. Lawson. (SPin) (Entered: 01/31/2022)

STIPULATION Regarding Date of UAW Constitutional Convention and Date for Adoption of New Election Rules by International Union, United Automobile, Aerospace, and Agricultural Implement Workers of America (Campbell, Terence) (Entered: 03/10/2022)

TRANSCRIPT of Motion Hearing held on 07/29/2021. (Court Reporter/Transcriber: Rene L Twedt) (Number of Pages: 14) The parties have 21 days to file with the court and Court Reporter/Transcriber a Redaction Request of this transcript. If no request is filed, the transcript may be made remotely electronically available to the public without redaction after 90 days. Redaction Request due 4/6/2022. Redacted Transcript Deadline set for 4/18/2022. Release of Transcript Restriction set for 6/14/2022. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber at WWW.TRANSCRIPTORDERS.COM before the deadline for Release of Transcript Restriction. After that date, the transcript is publicly available. (Twedt, R) (Entered: 03/16/2022)

ORDER Amending Deadlines for Completion of Change in Election Method and Amendment of UAW Constitution. Signed by District Judge David M. Lawson. (SPin) (Entered: 03/16/2022)

Non-Party James Coakley's MOTION for Interpretation of the Union Constitution. (SPin) (Entered: 05/10/2022)

ORDER Requiring Response to 57 Motion. Response due by 5/24/2022. Signed by District Judge David M. Lawson. (SPin) (Entered: 05/10/2022)

Certificate of Service

TEXT-ONLY CERTIFICATE OF SERVICE re 58 Order Requiring Responsive Pleading on Non-Party James Coakley, 16954 Heather Lane, Clinton Twp, MI 48038. (SPin)

Monitor's Second Status REPORT by Neil M. Barofsky (Monitor) (Attachments: # 1 Exhibit A, # 2 Certificate of Service) (Ross, Michael) (Entered: 05/11/2022)

1 Exhibit A

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2 Certificate of Service

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MOTION for Leave to File an Amicus Brief in Support of James Coakley's Motion for relief pursuant to Paragraph 48 of the Consent Decree filed by Sharon Bell and Roberta Gainer. [Submitted through Pro se Portal 5/17/22] (SSch) (Entered: 05/18/2022)

ORDER Denying 60 Motion for Leave to File Amicus Brief. Signed by District Judge David M. Lawson. (SPin) (Entered: 05/19/2022)

Certificate of Service

TEXT-ONLY CERTIFICATE OF SERVICE re 61 Order on Motion for Leave to File on the non-filers (Roberta Granger and Sharon Bell) via email. (SPin)

RESPONSE to 57 MOTION for Interpretation of the Union Constitution filed by Neil M. Barofsky (Monitor). (Attachments: # 1 Index of Exhibits, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D) (Ross, Michael) (Entered: 05/24/2022)

RESPONSE to 57 MOTION for Interpretation of the Union Constitution filed by United States of America. (Attachments: # 1 Index of Exhibits, # 2 Exhibit 1 - Monitor's Letter to Adjudications Officer, # 3 Exhibit 2 - Adjudications Officer's Decision) (Cares, Steven) (Entered: 05/24/2022)

NOTICE of Appearance by Abigail V. Carter on behalf of International Union, United Automobile, Aerospace, and Agricultural Implement Workers of America. (Carter, Abigail) (Entered: 05/24/2022)

CERTIFICATE OF SERVICE re 62 Response to Motion by Neil M. Barofsky (Monitor) (Amended) (Ross, Michael) (Entered: 05/24/2022)

RESPONSE to 57 MOTION for Interpretation of the Union Constitution filed by International Union, United Automobile, Aerospace, and Agricultural Implement Workers of America. (Attachments: # 1 Index of Exhibits, # 2 Exhibit 1 Decl. of Allen Wilson, # 3 Exhibit 2 Excerpts of 2006 Constitution, # 4 Exhibit 3 Curry Memorandum, # 5 Exhibit 4 Excerpts of 2018 Constitution, # 6 Exhibit 5 Decision of Adj. Officer, # 7 Exhibit 6 PRB Case 1283, # 8 Exhibit 7 PRB Case 1499, # 9 Exhibit 8 PRB Case 1746) (Carter, Abigail) (Entered: 05/24/2022)

REPLY to Response to 57 MOTION for Clarification by James R. Coakley. (SPin) (Entered: 06/01/2022)

OPINION AND ORDER Granting in Part and Denying in Part 57 Motion for Appeal of an Interpretive Ruling of the Defendant's Constitution. Signed by District Judge David M. Lawson. (SPin) (Entered: 07/01/2022)

Certificate of Service

TEXT-ONLY CERTIFICATE OF SERVICE of 68 Order to James Coakley at his email address of jamesrcoakley@yahoo.com. (SPin)

NOTICE of Appearance by Ellis Boal on behalf of James R Coakley. (Boal, Ellis) (Entered: 07/05/2022)

MOTION for Certificate of Appealability and Accelerated Consideration by James R Coakley. (Boal, Ellis) (Entered: 07/05/2022)

ORDER Denying 70 Motion for Certificate of Appealability. Signed by District Judge David M. Lawson. (SPin) (Entered: 07/06/2022)

Second MOTION for Certificate of Appealability and Accelerated Consideration - re-filed by James R Coakley. (Boal, Ellis) (Entered: 07/06/2022)

ORDER Requiring Response to 72 Motion for Certificate of Appealability. Response due by close of business on 7/11/2022. Signed by District Judge David M. Lawson. (SPin) (Entered: 07/07/2022)

RESPONSE to 72 Second MOTION for Certificate of Appealability and Accelerated Consideration - re-filed filed by United States of America. (Cares, Steven) (Entered: 07/11/2022)

RESPONSE to 72 Second MOTION for Certificate of Appealability and Accelerated Consideration - re-filed filed by International Union, United Automobile, Aerospace, and Agricultural Implement Workers of America. (Carter, Abigail) (Entered: 07/11/2022)

MOTION for Reconsideration re 68 Order on Motion - Free by James R Coakley. (Boal, Ellis) (Entered: 07/12/2022)

Monitor's Third Status REPORT by Neil M. Barofsky (Monitor) (Ross, Michael) (Entered: 07/19/2022)

ORDER Dismissing 72 Second Motion for Certificate of Appealability and Denying 76 Motion for Reconsideration. Signed by District Judge David M. Lawson. (SPin) (Entered: 07/20/2022)

MOTION for Appeal of an Interpretive Ruling of the Defendant's Constitution by Sharon Bell. (SPin) (Entered: 10/05/2022)

ORDER Requiring Parties and Monitor to Respond to 79 Motion. Response due by 10/20/2022; Reply due by 10/27/2022. Signed by District Judge David M. Lawson. (SPin) (Entered: 10/07/2022)

TEXT-ONLY CERTIFICATE OF SERVICE re 80 Order Requiring Responsive Pleading on Sharon Bell, 1214 St. Clair, Unit 56, Detroit, MI 48214. (SPin)

Certificate of Service

RESPONSE to 79 MOTION for Appeal of an Interpretive Ruling of the Defendant's Constitution filed by Neil M. Barofsky (Monitor). (Attachments: # 1 Index of Exhibits, # 2 Exhibit 1, # 3 Exhibit 2, # 4 Exhibit 3, # 5 Exhibit 4, # 6 Exhibit 5) (Ross, Michael) (Entered: 10/20/2022)

RESPONSE to 79 MOTION for Appeal of an Interpretive Ruling of the Defendant's Constitution filed by International Union, United Automobile, Aerospace, and Agricultural Implement Workers of America. (Attachments: # 1 Exhibit Ex. A) (Campbell, Terence) (Entered: 10/20/2022)

RESPONSE to 79 MOTION for Appeal of an Interpretive Ruling of the Defendant's Constitution filed by United States of America. (Cares, Steven) (Entered: 10/20/2022)

MOTION to extend time to respond to ECF Nos. 81, 82 and 83 by Sharon Bell. (TTho) (Entered: 10/27/2022)

ORDER Granting in Part 84 Motion for Extension of Time to File Reply as to 81, 82, and 83 Responses to Motion. Reply due by 11/2/2022. Signed by District Judge David M. Lawson. (SPin) (Entered: 10/28/2022)

Certificate of Service