Case: Community Economic Development Center of Southeastern Massachusetts v. Scott Bessent

Community Economic Development Center of Southeastern Massachusetts v. Bessent

COMPLAINT 25-12822 against All Defendants Filing fee: $ 405, receipt number AMADC-11269541 (Fee Status: Filing Fee paid), filed by Scott Bessent, Social Security Administration, U.S. Immigration and Customs Enforcement, Kristi L NOEM, Internal Revenue Service, Todd M Lyons, Frank Bisignano, Department of Homeland Security. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, # 4 Exhibit, # 5 Category Form, # 6 Civil Cover Sheet)(Arevalo, Luz) (Entered: 09/30/2025)

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2 Exhibit

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5 Category Form

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6 Civil Cover Sheet

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ELECTRONIC NOTICE of Case Assignment. Judge Indira Talwani assigned to case. If the trial Judge issues an Order of Reference of any matter in this case to a Magistrate Judge, the matter will be transmitted to Magistrate Judge Donald L. Cabell. (JKK) (Entered: 09/30/2025)

Summons Issued as to Scott Bessent, Frank Bisignano, Department of Homeland Security, Internal Revenue Service, Todd M Lyons, Kristi L. Noem, Social Security Administration, U.S. Immigration and Customs Enforcement. Counsel receiving this notice electronically should download this summons, complete one for each defendant and serve it in accordance with Fed.R.Civ.P. 4 and LR 4.1. Summons will be mailed to plaintiff(s) not receiving notice electronically for completion of service. (EZG) (Entered: 09/30/2025)

First MOTION for Leave to Appear Pro Hac Vice for admission of Angela Divaris Filing fee: $ 125, receipt number AMADC-11270819 by Community Economic Development Center of Southeastern Massachusetts. (Attachments: # 1 Declaration in support)(Arevalo, Luz) (Entered: 09/30/2025)

NOTICE by Community Economic Development Center of Southeastern Massachusetts Notice of Related Civil Cases (Arevalo, Luz) (Entered: 09/30/2025)

First MOTION for Leave to Appear Pro Hac Vice for admission of Laure Carr Mims Filing fee: $ 125, receipt number AMADC-11270953 by Community Economic Development Center of Southeastern Massachusetts. (Attachments: # 1 Declaration in support)(Arevalo, Luz) (Entered: 09/30/2025)

First MOTION for Leave to Appear Pro Hac Vice for admission of Dorothy Chang Filing fee: $ 125, receipt number AMADC-11270984 by Community Economic Development Center of Southeastern Massachusetts. (Attachments: # 1 Declaration in support)(Arevalo, Luz) (Entered: 09/30/2025)

First MOTION for Leave to Appear Pro Hac Vice for admission of Kelly M. Hernandez Filing fee: $ 125, receipt number AMADC-11270997 by Community Economic Development Center of Southeastern Massachusetts. (Attachments: # 1 Declaration in support)(Arevalo, Luz) (Entered: 09/30/2025)

First MOTION for Leave to Appear Pro Hac Vice for admission of Sarah Salomon Filing fee: $ 125, receipt number AMADC-11271010 by Community Economic Development Center of Southeastern Massachusetts. (Attachments: # 1 Declaration in support)(Arevalo, Luz) (Entered: 09/30/2025)

First MOTION for Leave to Appear Pro Hac Vice for admission of Leo Lam Filing fee: $ 125, receipt number AMADC-11271029 by Community Economic Development Center of Southeastern Massachusetts. (Attachments: # 1 Declaration in Support)(Arevalo, Luz) (Entered: 09/30/2025)

First MOTION for Leave to Appear Pro Hac Vice for admission of Charlotte J. Kamai Filing fee: $ 125, receipt number AMADC-11271056 by Community Economic Development Center of Southeastern Massachusetts. (Attachments: # 1 Declaration in support)(Arevalo, Luz) (Entered: 09/30/2025)

Notice of Case Assignment

Judge Indira Talwani: ELECTRONIC ORDER entered granting 4 Motion for Leave to Appear Pro Hac Vice; granting 6 Motion for Leave to Appear Pro Hac Vice; granting 7 Motion for Leave to Appear Pro Hac Vice; granting 8 Motion for Leave to Appear Pro Hac Vice Added; granting 9 Motion for Leave to Appear Pro Hac Vice; granting 10 Motion for Leave to Appear Pro Hac Vice; granting 11 Motion for Leave to Appear Pro Hac Vice. Added Angela Divaris, Laurie Carr Mims, Dorothy Chang, Kelly M. Hernandez, Sarah Salomon, Leo Lam, and Charlotte J. Kamai,. Attorneys admitted Pro Hac Vice must have an individual PACER account, not a shared firm account, to electronically file in the District of Massachusetts. To register for a PACER account, go the Pacer website at https://pacer.uscourts.gov/register-account. You must put the docket number under ADDITIONAL FILER INFORMATION on your form when registering or it will be rejected.Pro Hac Vice Admission Request Instructions https://www.mad.uscourts.gov/caseinfo/nextgen-pro-hac-vice.htm.A Notice of Appearance must be entered on the docket by each of the newly admitted attorneys. (SEC) (Entered: 10/01/2025)

First MOTION for Leave to Appear Pro Hac Vice for admission of Joshua Rosenthal Filing fee: $ 125, receipt number AMADC-11273023 by Community Economic Development Center of Southeastern Massachusetts. (Attachments: # 1 Declaration in support)(Arevalo, Luz) (Entered: 10/01/2025)

NOTICE of Appearance by Charlotte Kamai on behalf of Community Economic Development Center of Southeastern Massachusetts, National Korean American Service and Education Consortium, National Parents Union, UndocuBlack Network Inc. (Kamai, Charlotte) (Entered: 10/01/2025)

NOTICE of Appearance by Sarah Salomon on behalf of Community Economic Development Center of Southeastern Massachusetts, National Korean American Service and Education Consortium, National Parents Union, UndocuBlack Network Inc. (Salomon, Sarah) (Entered: 10/01/2025)

Order on Motion for Leave to Appear AND Order on Motion for Leave to Appear AND Order on Motion for Leave to Appear AND Order on Motion for Leave to Appear AND Order on Motion for Leave to Appear AND Order on Motion for Leave to Appear AND Order on Motion for Leave to Appear

Judge Indira Talwani: ELECTRONIC ORDER entered granting 13 Motion for Leave to Appear Pro Hac Vice. Added Joshua Rosenthal. Attorneys admitted Pro Hac Vice must have an individual upgraded PACER account, not a shared firm account, to electronically file in the District of Massachusetts. Counsel may need to link their CM/ECF account to their upgraded individual pacer account. Instructions on how to link CM/ECF accounts to upgraded pacer account can be found at https://www.mad.uscourts.gov/caseinfo/nextgen-current-pacer-accounts.htm#link-account. (SEC) (Entered: 10/02/2025)

CERTIFICATE OF SERVICE pursuant to LR 5.2 by Community Economic Development Center of Southeastern Massachusetts, National Korean American Service and Education Consortium, National Parents Union, UndocuBlack Network Inc. re 2 Notice of Case Assignment, 3 Summons Issued,, 1 Complaint, . (Kamai, Charlotte) (Entered: 10/02/2025)

Order on Motion for Leave to Appear

NOTICE of Appearance by Leo L. Lam on behalf of Community Economic Development Center of Southeastern Massachusetts, National Korean American Service and Education Consortium, National Parents Union, UndocuBlack Network Inc. (Lam, Leo) (Entered: 10/08/2025)

NOTICE of Appearance by Laurie Carr Mims on behalf of Community Economic Development Center of Southeastern Massachusetts, National Korean American Service and Education Consortium, National Parents Union, UndocuBlack Network Inc. (Mims, Laurie) (Entered: 10/08/2025)

NOTICE of Appearance by Joshua A. Rosenthal on behalf of Community Economic Development Center of Southeastern Massachusetts, National Korean American Service and Education Consortium, National Parents Union, UndocuBlack Network Inc. (Rosenthal, Joshua) (Entered: 10/08/2025)

MOTION to Stay by Scott Bessent, Frank Bisignano, Department of Homeland Security, Internal Revenue Service, Todd M Lyons.(Yen, Shawna) (Entered: 10/08/2025)

NOTICE of Appearance by Dorothy Ann Chang on behalf of Community Economic Development Center of Southeastern Massachusetts, National Korean American Service and Education Consortium, National Parents Union, UndocuBlack Network Inc. (Chang, Dorothy) (Entered: 10/10/2025)

NOTICE of Appearance by Kelly Hernandez on behalf of Community Economic Development Center of Southeastern Massachusetts, National Korean American Service and Education Consortium, National Parents Union, UndocuBlack Network Inc. (Hernandez, Kelly) (Entered: 10/16/2025)

AFFIDAVIT of Joshua Rosenthal in Support of Plaintiffs' Opposition to Defendants' Motion to Stay in Opposition re 21 MOTION to Stay filed by Community Economic Development Center of Southeastern Massachusetts, National Korean American Service and Education Consortium, National Parents Union, UndocuBlack Network Inc.. (Attachments: # 1 Exhibit 1 - October 8, 2025 Yen Email to Rosenthal, # 2 Exhibit 2 - CTR v. IRS, DDC Case No. 25-cv-457 Docket Excerpt, # 3 Exhibit 3 - CTR v. IRS, Doc No. 43 Order Denying Stay)(Lam, Leo) (Entered: 10/22/2025)

Opposition re 21 MOTION to Stay filed by Community Economic Development Center of Southeastern Massachusetts, National Korean American Service and Education Consortium, National Parents Union, UndocuBlack Network Inc.. (Lam, Leo) (Entered: 10/22/2025)

Errata by Community Economic Development Center of Southeastern Massachusetts, National Korean American Service and Education Consortium, National Parents Union to 25 Opposition to Motion,. (CM) (Entered: 10/30/2025)

MOTION for Preliminary Injunction for Relief Under 5 U.S.C. §§ 705, 706 by Community Economic Development Center of Southeastern Massachusetts, National Korean American Service and Education Consortium, National Parents Union, UndocuBlack Network Inc..(Lam, Leo) (Entered: 11/03/2025)

AFFIDAVIT of Leo L. Lam in Support re 27 MOTION for Preliminary Injunction for Relief Under 5 U.S.C. §§ 705, 706 filed by Community Economic Development Center of Southeastern Massachusetts, National Korean American Service and Education Consortium, National Parents Union, UndocuBlack Network Inc.. (Attachments: # 1 Exhibit 1; Administrative Record Excerpts from CTR, # 2 Exhibit 2; News Article, # 3 Exhibit 3; News Article, # 4 Exhibit 4; News Article, # 5 Exhibit 5; News Article, # 6 Exhibit 6; News Article, # 7 Exhibit 7; News Article)(Lam, Leo) (Entered: 11/03/2025)

1 Exhibit 1; Administrative Record Excerpts from CTR

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2 Exhibit 2; News Article

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3 Exhibit 3; News Article

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4 Exhibit 4; News Article

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5 Exhibit 5; News Article

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6 Exhibit 6; News Article

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7 Exhibit 7; News Article

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AFFIDAVIT in Support re 27 MOTION for Preliminary Injunction for Relief Under 5 U.S.C. §§ 705, 706 filed by Community Economic Development Center of Southeastern Massachusetts, National Korean American Service and Education Consortium, National Parents Union, UndocuBlack Network Inc.. (Attachments: # 1 Exhibit 1; Redacted Case)(Lam, Leo) (Entered: 11/03/2025)

1 Exhibit 1; Redacted Case

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AFFIDAVIT in Support re 27 MOTION for Preliminary Injunction for Relief Under 5 U.S.C. §§ 705, 706 filed by Community Economic Development Center of Southeastern Massachusetts, National Korean American Service and Education Consortium, National Parents Union, UndocuBlack Network Inc.. (Lam, Leo) (Entered: 11/03/2025)

AFFIDAVIT in Support re 27 MOTION for Preliminary Injunction for Relief Under 5 U.S.C. §§ 705, 706 filed by Community Economic Development Center of Southeastern Massachusetts, National Korean American Service and Education Consortium, National Parents Union, UndocuBlack Network Inc.. (Attachments: # 1 Exhibit 1; Community Investment Plan)(Lam, Leo) (Entered: 11/03/2025)

AFFIDAVIT in Support re 27 MOTION for Preliminary Injunction for Relief Under 5 U.S.C. §§ 705, 706 filed by Community Economic Development Center of Southeastern Massachusetts, National Korean American Service and Education Consortium, National Parents Union, UndocuBlack Network Inc.. (Lam, Leo) (Entered: 11/03/2025)

AFFIDAVIT in Support re 27 MOTION for Preliminary Injunction for Relief Under 5 U.S.C. §§ 705, 706 filed by Community Economic Development Center of Southeastern Massachusetts, National Korean American Service and Education Consortium, National Parents Union, UndocuBlack Network Inc.. (Lam, Leo) (Entered: 11/03/2025)

AFFIDAVIT in Support re 27 MOTION for Preliminary Injunction for Relief Under 5 U.S.C. §§ 705, 706 filed by Community Economic Development Center of Southeastern Massachusetts, National Korean American Service and Education Consortium, National Parents Union, UndocuBlack Network Inc.. (Lam, Leo) (Entered: 11/03/2025)

MEMORANDUM in Support re 27 MOTION for Preliminary Injunction for Relief Under 5 U.S.C. §§ 705, 706 filed by Community Economic Development Center of Southeastern Massachusetts, National Korean American Service and Education Consortium, National Parents Union, UndocuBlack Network Inc.. (Attachments: # 1 Text of Proposed Order Proposed Order)(Lam, Leo) (Entered: 11/03/2025)

1 Text of Proposed Order Proposed Order

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NOTICE of Appearance by Cesar Azrak on behalf of Scott Bessent, Frank Bisignano, Department of Homeland Security, Internal Revenue Service, Todd M Lyons, Kristi L. Noem, Social Security Administration, U.S. Immigration and Customs Enforcement (Azrak, Cesar) (Entered: 11/04/2025)

Notice of Errata by Community Economic Development Center of Southeastern Massachusetts, National Korean American Service and Education Consortium, National Parents Union, UndocuBlack Network Inc. to 32 Affidavit in Support of Motion, . (Lam, Leo) (Entered: 11/04/2025)

Judge Indira Talwani: MEMORANDUM AND ORDER entered. See attached.Plaintiffs' interest in proceeding in this case outweighs Defendants' interest in a stay where counsel for Defendants may continue litigating during the lapse in funding pursuant to a court order. Accordingly, Defendants' Motion [Doc. No. 21 ] is DENIED.IT IS SO ORDERED. (SEC)

MEMORANDUM in Opposition re 27 MOTION for Preliminary Injunction for Relief Under 5 U.S.C. §§ 705, 706 filed by Scott Bessent, Frank Bisignano, Department of Homeland Security, Internal Revenue Service, Todd M Lyons, Kristi L. Noem, Social Security Administration, U.S. Immigration and Customs Enforcement. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C)(Azrak, Cesar) (Entered: 11/17/2025)

1 Exhibit A

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2 Exhibit B

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3 Exhibit C

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NOTICE of Appearance by Gary E. Klein on behalf of Community Economic Development Center of Southeastern Massachusetts, National Korean American Service and Education Consortium, National Parents Union, UndocuBlack Network Inc. (Klein, Gary) (Entered: 11/18/2025)

MOTION for Leave to File Reply Brief re 27 PLAINTIFFS MOTION FOR RELIEF UNDER 5 U.S.C. §§ 705, 706 OR, IN THE ALTERNATIVE, FOR PRELIMINARY INJUNCTION by Community Economic Development Center of Southeastern Massachusetts, National Korean American Service and Education Consortium, National Parents Union, UndocuBlack Network Inc.. (Attachments: # 1 Exhibit A - Proposed Reply Brief)(Lam, Leo) (Entered: 11/24/2025)

Judge Indira Talwani: ELECTRONIC ORDER allowing [ 41 ] MOTION for Leave to File Reply Brief re 27 PLAINTIFFS MOTION FOR RELIEF UNDER 5 U.S.C. §§ 705, 706 OR, IN THE ALTERNATIVE, FOR PRELIMINARY INJUNCTION. Counsel using the Electronic Case Filing System should now file the document for which leave to file has been granted in accordance with the CM/ECF Administrative Procedures. Counsel must include - Leave to file granted on (date of order)- in the caption of the document. (SEC) (Entered: 11/25/2025)

REPLY to Response to 27 MOTION for Preliminary Injunction for Relief Under 5 U.S.C. §§ 705, 706 filed by Community Economic Development Center of Southeastern Massachusetts, National Korean American Service and Education Consortium, National Parents Union, UndocuBlack Network Inc.. (Lam, Leo) (Entered: 11/25/2025)

Notice of Supplemental Authorities re 27 MOTION for Preliminary Injunction for Relief Under 5 U.S.C. §§ 705, 706 (Attachments: # 1 Exhibit A)(Azrak, Cesar) (Entered: 11/25/2025)

Order on Motion for Leave to File Document

Notice of Supplemental Authorities re 27 MOTION for Preliminary Injunction for Relief Under 5 U.S.C. §§ 705, 706 PLTFS RESPONSE TO DEFS NOTICE OF SUPPLEMENTAL AUTHORITY, DKT 44 filed by Community Economic Development Center of Southeastern Massachusetts, National Korean American Service and Education Consortium, National Parents Union, UndocuBlack Network Inc.. (Lam, Leo) (Entered: 11/26/2025)

MOTION for Extension of Time to January 9, 2026 to Respond to Complaint by Scott Bessent, Frank Bisignano, Department of Homeland Security, Internal Revenue Service, Todd M Lyons, Kristi L. Noem, Social Security Administration, U.S. Immigration and Customs Enforcement.(Azrak, Cesar) (Entered: 12/01/2025)

Judge Indira Talwani: ELECTRONIC ORDER allowing 46 MOTION for Extension of Time to January 9, 2026 to Respond to Complaint. (SEC) (Entered: 12/01/2025)

Order on Motion for Extension of Time

ELECTRONIC NOTICE Setting Hearing on Motion 27 MOTION for Preliminary Injunction for Relief Under 5 U.S.C. §§ 705, 706: Motion Hearing set for 12/19/2025 02:45 PM in Courtroom 9 (In person only) before Judge Indira Talwani. (GAM) (Entered: 12/10/2025)

Notice Setting or Resetting Hearing on Motion

Electronic Clerk's Notes for proceedings held before Judge Indira Talwani: Motion Hearing held on 12/19/2025 re 27 MOTION for Preliminary Injunction for Relief Under 5 U.S.C. §§ 705, 706 filed by UndocuBlack Network Inc., Community Economic Development Center of Southeastern Massachusetts, National Korean American Service and Education Consortium, National Parents Union. Case called. Court heard argument from counsel. Counsel shall confer re addresses being used for criminal purposes. Further briefing is due 12/22/2025. Motion remains under advisement. (Court Reporter: Robert Paschal at rwp.reporter@gmail.com.)(Attorneys present: Charlotte Kamai, Gary E. Klein, Joshua A. Rosenthal, Sarah Salomon, Cesar Azrak) (GAM) (Entered: 12/23/2025)

Transcript of Motion Hearing held on December 19, 2025, before Judge Indira Talwani. The Transcript may be purchased through the Court Reporter, viewed at the public terminal, or viewed through PACER after it is released. Court Reporter Name and Contact Information: Robert Paschal at rwp.reporter@gmail.com. Redaction Request due 1/12/2026. Redacted Transcript Deadline set for 1/22/2026. Release of Transcript Restriction set for 3/23/2026. (DRK) (Entered: 12/22/2025)

NOTICE is hereby given that an official transcript of a proceeding has been filed by the court reporter in the above-captioned matter. Counsel are referred to the Court's Transcript Redaction Policy, available on the court website at https://www.mad.uscourts.gov/caseinfo/transcripts.htm (DRK) (Entered: 12/22/2025)

NOTICE by Scott Bessent, Frank Bisignano, Department of Homeland Security, Internal Revenue Service, Todd M Lyons, Kristi L. Noem, Social Security Administration, U.S. Immigration and Customs Enforcement re 27 MOTION for Preliminary Injunction for Relief Under 5 U.S.C. §§ 705, 706 (Attachments: # 1 Exhibit A, # 2 Exhibit B)(Azrak, Cesar) (Entered: 12/22/2025)

1 Exhibit A

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2 Exhibit B

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Notice of Filing of Official Transcript

First MOTION for Leave to Appear Pro Hac Vice for admission of Leia Walker Filing fee: $ 125, receipt number AMADC-11438099 by Community Economic Development Center of Southeastern Massachusetts. (Attachments: # 1 Affidavit)(Arevalo, Luz) (Entered: 12/23/2025)

First MOTION for Leave to Appear Pro Hac Vice for admission of Angela Divaris Filing fee: $ 125, receipt number AMADC-11438433 by Community Economic Development Center of Southeastern Massachusetts. (Attachments: # 1 Affidavit)(Arevalo, Luz) (Entered: 12/23/2025)

MOTION for Leave to File a Response to Defendants Supplemental Declarations by Community Economic Development Center of Southeastern Massachusetts, National Korean American Service and Education Consortium, National Parents Union, UndocuBlack Network Inc.. (Attachments: # 1 Exhibit A - [Proposed] Response to Defendants Supplemental Declarations)(Hernandez, Kelly) (Entered: 12/23/2025)

Motion Hearing

Judge Indira Talwani: ELECTRONIC ORDER entered granting 52 Motion for Leave to Appear Pro Hac Vice; granting 53 Motion for Leave to Appear Pro Hac Vice. Added Leia Walker and Angela Divaris. Attorneys admitted Pro Hac Vice must have an individual PACER account, not a shared firm account, to electronically file in the District of Massachusetts. To register for a PACER account, go the Pacer website at https://pacer.uscourts.gov/register-account. You must put the docket number under ADDITIONAL FILER INFORMATION on your form when registering or it will be rejected.Pro Hac Vice Admission Request Instructions https://www.mad.uscourts.gov/caseinfo/nextgen-pro-hac-vice.htm.A Notice of Appearance must be entered on the docket by each of the newly admitted attorneys. (SEC) (Entered: 12/24/2025)

Judge Indira Talwani: ELECTRONIC ORDER allowing 55 MOTION for Leave to File a Response to Defendants' Supplemental Declarations. Counsel using the Electronic Case Filing System should now file the document for which leave to file has been granted in accordance with the CM/ECF Administrative Procedures. Counsel must include - Leave to file granted on (date of order)- in the caption of the document. (SEC) (Entered: 12/24/2025)

NOTICE of Appearance by Leia R. Walker on behalf of Community Economic Development Center of Southeastern Massachusetts, National Korean American Service and Education Consortium, National Parents Union, UndocuBlack Network Inc. (Walker, Leia) (Entered: 12/24/2025)

First REPLY to Response to 55 MOTION for Leave to File a Response to Defendants Supplemental Declarations filed by Community Economic Development Center of Southeastern Massachusetts. (Arevalo, Luz) (Entered: 12/24/2025)

Order on Motion for Leave to Appear AND Order on Motion for Leave to Appear

Order on Motion for Leave to File Document

SUMMONS Returned Executed (Mims, Laurie) (Entered: 01/05/2026)

SUMMONS Returned Executed (Mims, Laurie) (Entered: 01/05/2026)

SUMMONS Returned Executed (Mims, Laurie) (Entered: 01/05/2026)

SUMMONS Returned Executed (Mims, Laurie) (Entered: 01/05/2026)

SUMMONS Returned Executed (Mims, Laurie) (Entered: 01/05/2026)

SUMMONS Returned Executed (Mims, Laurie) (Entered: 01/05/2026)

SUMMONS Returned Executed (Mims, Laurie) (Entered: 01/05/2026)

SUMMONS Returned Executed as to US Attorney by National Korean American Service and Education Consortium, National Parents Union, Community Economic Development Center of Southeastern Massachusetts, UndocuBlack Network Inc.. Scott Bessent served on 10/1/2025, answer due 11/30/2025; Frank Bisignano served on 10/1/2025, answer due 11/30/2025; Department of Homeland Security served on 10/1/2025, answer due 11/30/2025; Department of the Treasury served on 10/1/2025, answer due 11/30/2025; Internal Revenue Service served on 10/1/2025, answer due 11/30/2025; Todd M Lyons served on 10/1/2025, answer due 11/30/2025; Kristi L. Noem served on 10/1/2025, answer due 11/30/2025; Social Security Administration served on 10/1/2025, answer due 11/30/2025; U.S. Immigration and Customs Enforcement served on 10/1/2025, answer due 11/30/2025. (Mims, Laurie) (Entered: 01/06/2026)

Notice of Supplemental Authorities re 27 MOTION for Preliminary Injunction for Relief Under 5 U.S.C. §§ 705, 706 (Attachments: # 1 Exhibit A)(Salomon, Sarah) (Entered: 01/08/2026)

1 Exhibit A

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MOTION to Dismiss by Scott Bessent, Frank Bisignano, Department of Homeland Security, Department of the Treasury, Internal Revenue Service, Todd M Lyons, Kristi L. Noem, Social Security Administration, U.S. Immigration and Customs Enforcement.(Azrak, Cesar) (Entered: 01/09/2026)

MEMORANDUM in Support re 69 MOTION to Dismiss filed by Scott Bessent, Frank Bisignano, Department of Homeland Security, Department of the Treasury, Internal Revenue Service, Todd M Lyons, Kristi L. Noem, Social Security Administration, U.S. Immigration and Customs Enforcement. (Azrak, Cesar) (Entered: 01/09/2026)

NOTICE by Community Economic Development Center of Southeastern Massachusetts, National Korean American Service and Education Consortium, National Parents Union, UndocuBlack Network Inc. of Intent to File a First Amended Complaint (Mims, Laurie) (Entered: 01/23/2026)

Judge Indira Talwani: ELECTRONIC ORDER: Pending before the court is Plaintiffs’ Motion for Relief under 5 U.S.C. §§ 705, 706 or, in the alternative, for Preliminary Injunction [ 27 ], which Defendants oppose, see Defs’ Opp’n [ 39 ]. In a supplemental filing, Defendants assert that this court’s “entry of preliminary relief [is] unnecessary” because, on November 21, 2025, “the United States District Court for the District of Columbia entered a preliminary injunction against the Internal Revenue Service (“IRS”); the Department of the Treasury; and [Treasury Secretary] Scott Bessent[.]” Defs.’ Notice of Supp. Auth. 1–2 [ 44 ]. Pursuant to the D.C. District Court’s Order, the IRS is now preliminarily enjoined “from disclosing any return information, including taxpayer return information, to the Department of Homeland Security (“DHS”) or any of its component agencies pursuant to [26 U.S.C.] Section 6103(i)(2), except in strict compliance with the requirements of that Section, including that the recipients of the information be “officers and employees of [the receiving] agency who are personally and directly engaged in” a relevant nontax criminal investigation or proceeding and that the recipients will use the information “solely for” that criminal investigation or proceeding.” Ctr. for Taxpayer Rights v. Internal Revenue Serv., 2025 WL 3257096 *1 (D.D.C. Nov. 21, 2025) (footnotes omitted).The court takes judicial notice that, although those defendants have appealed the D.C. District Court’s preliminary injunction to the United States Court of Appeals for the D.C. Circuit, seeCtr. for Taxpayer Rights v. Internal Revenue Serv., No. 26-05006 (D.C. Cir. Jan. 13, 2026), the injunction remains in effect pending the outcome of the D.C. Circuit’s decision. See Ctr. for Taxpayer Rights v. Internal Revenue Serv., No. 1:25-cv-00457-CKK, ECF No. 65 (Jan. 21, 2026). Therefore, regarding Plaintiffs’ request for preliminary relief as to Defendants IRS, the Department of the Treasury, and Secretary Bessent, Plaintiffs have not demonstrated the likelihood of irreparable harm required for a preliminary injunction while the litigation is pending. See Esso Standard Oil Co. v. Monroig-Zayas, 445 F.3d 13, 17–18 (1st Cir. 2006). As to these Defendants, the Motion [ 27 ] is DENIED without prejudice.Plaintiffs argue that injunctive relief is still necessary in this case because the remaining Defendants here are not parties to the D.C. District Court proceeding and are not bound by that court’s injunction. See Pls.’ Reply at 13 [ 43 ].As to Plaintiffs’ allegations regarding impermissible sharing of confidential tax information by Defendant Social Security Administration (“SSA”) with Defendant U.S. Immigration and Customs Enforcement (“ICE”), the court finds that Plaintiffs have not demonstrated a substantial likelihood of success on the merits where the record is not sufficient to make a finding that sharing of tax information between SSA and ICE has or is likely to occur. Plaintiffs rely on a newspaper article that describes a February 2025 data transfer by SSA to ICE, see Compl. ¶ 98 [ 1 ], but the record is insufficient to support Plaintiffs’ claim that the transferred information was confidential tax information (as opposed to other non-tax information held by SSA). Further, Defendants have submitted a declaration from an SSA official, attesting that no sharing of tax information has yet taken place, despite the data-sharing agreement laid out in the August 2025 letter sent by SSA to ICE. See Compl., Ex. D [[1-4]]; Defs.’ Opp’n, Myers Decl., Ex. B ¶ 4 [[39-2]]. Accordingly, Plaintiffs’ Motion [ 27 ] is also DENIED without prejudice as to Defendants SSA and SSA Commissioner Frank Bisignano.Regarding ICE’s alleged use and threatened use of confidential tax information in contravention of 26 U.S.C. § 6103’s requirements, Plaintiffs’ Motion [ 27 ] seeking to enjoin Defendants ICE, DHS, Secretary of DHS Kristi Noem, and Acting Director of ICE Todd M. Lyons remains under advisement.(SEC) (Entered: 01/27/2026)

Order

AMENDED COMPLAINT against All Defendants, filed by Community Economic Development Center of Southeastern Massachusetts, National Korean American Service and Education Consortium, National Parents Union, UndocuBlack Network Inc.. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E)(Salomon, Sarah) (Entered: 01/30/2026)

1 Exhibit A

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2 Exhibit B

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3 Exhibit C

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4 Exhibit D

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5 Exhibit E

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Judge Indira Talwani: ELECTRONIC ORDER denying without prejudice Defendants' Motion to Dismiss [ 69 ] Plaintiffs' Complaint [ 1 ] where Plaintiffs have filed a superseding Amended Complaint [ 73 ]. (SEC) (Entered: 02/02/2026)

Order on Motion to Dismiss

Memorandum & Order