Case: Ethical Society of Police v. Pamela J. Bondi

Ethical Society of Police et al. v. Pamela J. Bondi et al.

Ethical Society of Police v. Bondi

Ethical Society of Police et al. v. Bondi et al.

Ethical Society of Police v. Bondi et al.

Ethical Society of Police et al. v. Bondi et al.

Ethical Society of Police et al. v. Bondi et al.

Ethical Society of Police et al. v. Bondi et al.

COMPLAINT against Pamela J. Bondi Filing fee: $ 405, receipt number AMADC-11318881 (Fee Status: Filing Fee paid), filed by Berkshire Resources for Integration of Diverse Groups and Education dba Multicultural Bridge, Ethical Society of Police, Haitian Community Help & Support Center dba Haitian Support Center, Missouri Baptist Convention, NAACP CO-MT-WY, NAACP County of St. Louis, Out Accountability Project, Peacemakers Lodge, Pikes Peak Southern Christian Leadership Conference, Two Wrasslin' Cats, Wellspring Health Access. (Attachments: # 1 Civil Cover Sheet, # 2 Category Form)(Munoz, Ana) (Entered: 10/24/2025)

1 Civil Cover Sheet

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2 Category Form

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MOTION for Temporary Restraining Order by Berkshire Resources for Integration of Diverse Groups and Education dba Multicultural Bridge, Ethical Society of Police, Haitian Community Help & Support Center dba Haitian Support Center, Missouri Baptist Convention, NAACP CO-MT-WY, NAACP County of St. Louis, Out Accountability Project, Peacemakers Lodge, Pikes Peak Southern Christian Leadership Conference, Two Wrasslin' Cats, Wellspring Health Access. (Attachments: # 1 Memorandum in Support of Motion for Temporary Restraining Order, # 2 Text of Proposed Order, # 3 Affidavit Julius Nam, # 4 Affidavit Kyle Freeney, # 5 Affidavit Donnell Walters for Ethical Society of Police, # 6 Affidavit John Bowman for NAACP Stl County, # 7 Affidavit Linden Bowie for Missionary Baptist State Convention, # 8 Affidavit Mark Thied for Two Wrasslin Cats, # 9 Affidavit Melissa Combs for Out Accountability, # 10 Affidavit Gwendolyn VanSant for BRIDGE, # 11 Affidavit Thomas Mayes for NAACP Tri-State, # 12 Affidavit Paul Nelson for Pikes Peak Southern Christian Leadership Conference, # 13 Affidavit L'Dawn Olsen for Peacemakers Lodge, # 14 Affidavit Julie Burkhart for Wellspring Health Access, # 15 Affidavit Viles Dorsainvil for Haitian Support Center)(Munoz, Ana) (Entered: 10/24/2025)

1 Memorandum in Support of Motion for Temporary Restraining Order

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2 Text of Proposed Order

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3 Affidavit Julius Nam

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4 Affidavit Kyle Freeney

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5 Affidavit Donnell Walters for Ethical Society of Police

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6 Affidavit John Bowman for NAACP Stl County

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7 Affidavit Linden Bowie for Missionary Baptist State Convention

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8 Affidavit Mark Thied for Two Wrasslin Cats

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9 Affidavit Melissa Combs for Out Accountability

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10 Affidavit Gwendolyn VanSant for BRIDGE

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11 Affidavit Thomas Mayes for NAACP Tri-State

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12 Affidavit Paul Nelson for Pikes Peak Southern Christian Leadership Conference

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13 Affidavit L'Dawn Olsen for Peacemakers Lodge

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14 Affidavit Julie Burkhart for Wellspring Health Access

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15 Affidavit Viles Dorsainvil for Haitian Support Center

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MOTION for Leave to File Excess Pages for TRO Memo of Law by Berkshire Resources for Integration of Diverse Groups and Education dba Multicultural Bridge, Ethical Society of Police, Haitian Community Help & Support Center dba Haitian Support Center, Missouri Baptist Convention, NAACP CO-MT-WY, NAACP County of St. Louis, Out Accountability Project, Peacemakers Lodge, Pikes Peak Southern Christian Leadership Conference, Two Wrasslin' Cats, Wellspring Health Access.(Munoz, Ana) (Entered: 10/24/2025)

MOTION for Leave to Appear Pro Hac Vice for admission of Kyle Freeney Filing fee: $ 125, receipt number AMADC-11319103 by Berkshire Resources for Integration of Diverse Groups and Education dba Multicultural Bridge, Ethical Society of Police, Haitian Community Help & Support Center dba Haitian Support Center, Missouri Baptist Convention, NAACP CO-MT-WY, NAACP County of St. Louis, Out Accountability Project, Peacemakers Lodge, Pikes Peak Southern Christian Leadership Conference, Two Wrasslin' Cats, Wellspring Health Access.(Munoz, Ana) (Entered: 10/24/2025)

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 Paul G. Levenson. (SP) (Entered: 10/24/2025)

Summons Issued as to Pamela J. Bondi, U.S. Department of Justice. 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. (SEC) (Entered: 10/24/2025)

ELECTRONIC NOTICE Setting Hearing on 2 MOTION for Temporary Restraining Order : Motion Hearing set for 10/29/2025 10:00 AM in Courtroom 9 (In person only) before Judge Indira Talwani. (SEC) (Entered: 10/24/2025)

Notice of Case Assignment

Notice Setting or Resetting Hearing on Motion

Judge Indira Talwani: ELECTRONIC ORDER: Plaintiffs shall promptly serve a copy of the court's notice setting hearing on Plaintiffs' Motion for Temporary Restraining Order [ 2 ] on Defendants and/or their counsel and file a certificate of such service. (SEC) (Entered: 10/28/2025)

Judge Indira Talwani: ELECTRONIC ORDER allowing 3 MOTION for Leave to File Excess Pages for TRO Memo of Law (SEC) (Entered: 10/28/2025)

Judge Indira Talwani: ELECTRONIC ORDER allowing 4 Motion for Leave to Appear Pro Hac Vice. Added Kyle R. Freeny. 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 the newly admitted attorney. (SEC) (Entered: 10/28/2025)

NOTICE of Appearance by Abigail Stout on behalf of Pamela J. Bondi, U.S. Department of Justice (Stout, Abigail) (Entered: 10/28/2025)

NOTICE by Berkshire Resources for Integration of Diverse Groups and Education, Ethical Society of Police, Haitian Community Help & Support Center dba Haitian Support Center, Missouri Baptist Convention, NAACP St. Louis County, NAACP State Conference Colorado-Montana-Wyoming, Out Accountability Project, Peacemakers Lodge, Pikes Peak Southern Christian Leadership Conference, Two Wrasslin Cats Accord, Wellspring Health Access of Hearing Setting (Munoz, Ana) (Entered: 10/28/2025)

MOTION for Leave to Appear Pro Hac Vice for admission of Nathaniel Zelinsky Filing fee: $ 125, receipt number AMADC-11324066 by Berkshire Resources for Integration of Diverse Groups and Education, Ethical Society of Police, Haitian Community Help & Support Center dba Haitian Support Center, Missouri Baptist Convention, NAACP St. Louis County, NAACP State Conference Colorado-Montana-Wyoming, Out Accountability Project, Peacemakers Lodge, Pikes Peak Southern Christian Leadership Conference, Two Wrasslin Cats Accord, Wellspring Health Access.(Munoz, Ana) (Entered: 10/28/2025)

Judge Indira Talwani: ELECTRONIC ORDER: Plaintiffs shall file a table of contents and table of authorities for Plaintiffs' Memorandum of Law in Support of Plaintiffs' Motion for a Temporary Restraining Order [ 2 -1]. See this session's Standing Order Regarding Motion Practice.(SEC) (Entered: 10/28/2025)

MEMORANDUM in Opposition re 2 MOTION for Temporary Restraining Order filed by Pamela J. Bondi, U.S. Department of Justice. (Attachments: # 1 Affidavit Lauria Declaration, # 2 Exhibit Exhibit A - Consolidated Spend Plan)(Stout, Abigail) (Entered: 10/28/2025)

1 Affidavit Lauria Declaration

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2 Exhibit Exhibit A - Consolidated Spend Plan

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Order on Motion for Leave to Appear

Order on Motion for Leave to File Excess Pages

Order

Consent MOTION for Leave to File Excess Pages by Pamela J. Bondi, U.S. Department of Justice.(Stout, Abigail) (Entered: 10/29/2025)

Amended MEMORANDUM in Support re 2 MOTION for Temporary Restraining Order (Revised with Tables of Contents and Authorities) filed by Berkshire Resources for Integration of Diverse Groups and Education, Ethical Society of Police, Haitian Community Help & Support Center dba Haitian Support Center, Missouri Baptist Convention, NAACP St. Louis County, NAACP State Conference Colorado-Montana-Wyoming, Out Accountability Project, Peacemakers Lodge, Pikes Peak Southern Christian Leadership Conference, Two Wrasslin Cats Accord, Wellspring Health Access. (Munoz, Ana) (Entered: 10/29/2025)

Amended MEMORANDUM in Opposition re 2 MOTION for Temporary Restraining Order (with Table of Authorities) filed by Pamela J. Bondi, U.S. Department of Justice. (Stout, Abigail) (Entered: 10/29/2025)

Electronic Clerk's Notes for proceedings held before Judge Indira Talwani: Motion Hearing held on 10/29/2025 re 2 MOTION for Temporary Restraining Order. Case called. Court heard argument from counsel. Plaintiffs may supplement the record. Counsel to confer re setting a hearing on the PI or the consolidation of the PI w/an evidentiary hearing and will contact the clerk for scheduling. TRO motion remains under advisement.(Court Reporter: Robert Paschal at rwp.reporter@gmail.com.)(Attorneys present: Ana I. Munoz, Kyle Freeney, Nathaniel Zelinsky, Abigail Stout - Attys admited Pro Hac must file appearances to receive CM/ECF Notices) (GAM) (Entered: 10/29/2025)

Judge Indira Talwani: ELECTRONIC ORDER granting nunc pro tunc Defendants' Unopposed Motion for Leave to File Extra Pages 16 . (SEC) (Entered: 10/29/2025)

NOTICE of Appearance by Kyle R Freeny on behalf of Berkshire Resources for Integration of Diverse Groups and Education, Ethical Society of Police, Haitian Community Help & Support Center dba Haitian Support Center, Missouri Baptist Convention, NAACP St. Louis County, NAACP State Conference Colorado-Montana-Wyoming, Out Accountability Project, Peacemakers Lodge, Pikes Peak Southern Christian Leadership Conference, Two Wrasslin Cats Accord, Wellspring Health Access (Freeny, Kyle) (Entered: 10/29/2025)

Motion Hearing

Order on Motion for Leave to File Excess Pages

Judge Indira Talwani: For the reasons set forth in the attached MEMORANDUM AND ORDER, Plaintiffs' Motion for Temporary Restraining Order [Doc. No. 2] is DENIED. This order is without prejudice to Plaintiffs filing a motion for preliminary relief demonstrating the likelihood that they will suffer irreparable harm before this matter may be resolved on the merits. (GAM)

MOTION for Order to Set Evidentiary Hearing on Merits by Berkshire Resources for Integration of Diverse Groups and Education, Ethical Society of Police, Haitian Community Help & Support Center dba Haitian Support Center, Missouri Baptist Convention, NAACP St. Louis County, NAACP State Conference Colorado-Montana-Wyoming, Out Accountability Project, Peacemakers Lodge, Pikes Peak Southern Christian Leadership Conference, Two Wrasslin Cats Accord, Wellspring Health Access.(Freeny, Kyle) (Entered: 10/31/2025)

RESPONSE to Motion re 23 MOTION for Order to Set Evidentiary Hearing on Merits filed by Pamela J. Bondi, U.S. Department of Justice. (Stout, Abigail) (Entered: 11/03/2025)

Consent MOTION for Leave to File Reply on Plaintiffs' Motion for Order Setting Merits Hearing by Berkshire Resources for Integration of Diverse Groups and Education, Ethical Society of Police, Haitian Community Help & Support Center dba Haitian Support Center, Missouri Baptist Convention, NAACP St. Louis County, NAACP State Conference Colorado-Montana-Wyoming, Out Accountability Project, Peacemakers Lodge, Pikes Peak Southern Christian Leadership Conference, Two Wrasslin Cats Accord, Wellspring Health Access. (Attachments: # 1 Exhibit A - Proposed Reply Memorandum)(Freeny, Kyle) (Entered: 11/04/2025)

Judge Indira Talwani: ELECTRONIC ORDER allowing 25 Consent MOTION for Leave to File Reply on Plaintiffs' Motion for Order Setting Merits Hearing. 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: 11/05/2025)

REPLY to Response to 23 MOTION for Order to Set Evidentiary Hearing on Merits filed by Berkshire Resources for Integration of Diverse Groups and Education, Ethical Society of Police, Haitian Community Help & Support Center dba Haitian Support Center, Missouri Baptist Convention, NAACP St. Louis County, NAACP State Conference Colorado-Montana-Wyoming, Out Accountability Project, Peacemakers Lodge, Pikes Peak Southern Christian Leadership Conference, Two Wrasslin Cats Accord, Wellspring Health Access. (Freeny, Kyle) (Entered: 11/05/2025)

Order on Motion for Leave to File Document

Judge Indira Talwani: ELECTRONIC ORDER entered granting 13 Motion for Leave to Appear Pro Hac Vice. Added Nathaniel A.G. Zelinsky. 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 the newly admitted attorney. (SEC) (Entered: 11/06/2025)

Order on Motion for Leave to Appear

Judge Indira Talwani: ELECTRONIC ORDER denying without prejudice Plaintiffs' Motion for Order Setting Merits Hearing [ 23 ], where the requested hearing is unconnected to a pending motion for preliminary relief and the court has not yet set a case schedule for resolving the matter on the merits. Plaintiffs may request an evidentiary hearing in connection with a renewed motion for a preliminary injunction. Defendants correctly assert that Plaintiffs "are free to move for a preliminary injunction" but incorrectly state that "their lack of irreparable harm would doom that effort for the same reasons it doomed their TRO[.]" Defs.' Resp. 1 [ 24 ]. In denying Plaintiffs' motion for a temporary restraining order in advance of the October 31, 2025 RIFs, the court "focuse[d] on the potential harm that Plaintiffs state[d] would occur if the RIFs proceed[ed] as scheduled." Mem. & Order 6 [ 22 ]. The court did not find a lack of irreparable harm due to the alleged closing of the Community Relations Service altogether, and the order contemplated the possibility of "a renewed motion for a preliminary injunction supported by an immediate need for CRS's services after the government shutdown ends[.]" Id. at 7. Plaintiffs may also request an expedited case schedule for resolving the merits of this dispute. (SEC) (Entered: 11/07/2025)

SEE attached NOTICE of Scheduling Conference, with attached PROPOSED ORDER TEMPLATE. When filing the Joint Statement, which is due 7 days before the scheduling conference, counsel must attach a separate, proposed scheduling order using the template attached to this Notice. A Word version of the proposed scheduling order should be emailed to gail_macdonald@mad.uscourts.gov Scheduling Conference set for 11/20/2025 02:15 PM in Courtroom 9 (Remote only) before Judge Indira Talwani. This proceeding will be conducted by video conference. Counsel of record will receive a video conference invite at the email registered in CM/ECF. If you have technical or compatibility issues with the technology, please notify the courtroom deputy of the session as soon as possible.Audio access to the hearing may be available to the media and public. Please check the Court schedule. In order to gain access to the hearing, you must sign up at the following address: https://forms.mad.uscourts.gov/courtlist.html.For questions regarding access to hearings, you may refer to the general orders and public notices of the Court available on www.mad.uscourts.gov or contact media@mad.uscourts.gov. (Attachments: # 1 Proposed Order Template)(GAM) (Entered: 11/07/2025)

1 Proposed Order Template

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Order on Motion for Order

JOINT STATEMENT re scheduling conference . (Attachments: # 1 Text of Proposed Order)(Freeny, Kyle) (Entered: 11/13/2025)

1 Text of Proposed Order

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Electronic Clerk's Notes for proceedings held before Judge Indira Talwani: Scheduling Conference held on 11/20/2025. Case called. Court had colloquy with counsel. Initial Disclosures/Admin Record due 12/5/2025. Plaintiff shall file either a motion to supplement the administrative record, a motion for discovery, or a notice of satisfaction by 12/22/2025; response due 1/12/2026. No expert discovery deadlines set. Scheduling Order to follow. (Court Reporter: Robert Paschal at rwp.reporter@gmail.com.)(Attorneys present: Ana I. Munoz, Kyle R Freeny, Abigail Stout) (GAM) (Entered: 12/02/2025)

MOTION for Preliminary Injunction by Berkshire Resources for Integration of Diverse Groups and Education, Ethical Society of Police, Haitian Community Help & Support Center dba Haitian Support Center, Missouri Baptist Convention, NAACP St. Louis County, NAACP State Conference Colorado-Montana-Wyoming, Out Accountability Project, Peacemakers Lodge, Pikes Peak Southern Christian Leadership Conference, Two Wrasslin Cats Accord, Wellspring Health Access. (Attachments: # 1 Text of Proposed Order Proposed Preliminary Injunction)(Freeny, Kyle) (Entered: 11/25/2025)

1 Text of Proposed Order Proposed Preliminary Injunction

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AFFIDAVIT in Support re 32 MOTION for Preliminary Injunction . (Attachments: # 1 1- OMB Technical Supplement to the Presidents FY2026 Budget Excerpt, # 2 2- DOJ FY 2026 Budget and Performance Summary, # 3 3 - Bloomberg Law New article, # 4 4 - CRS "About Us", # 5 5- 2019 CRS Report to Congress, # 6 6- 2020 CRS Report to Congress, # 7 7- 2021 CRS Report to Congress, # 8 8- 2022 CRS Report to Congress, # 9 9- North Plains Independent Article, # 10 10- Declaration of Julius J. Nam, # 11 11- Supplemental Declaration of Julius J. Nam, # 12 12- Declaration of Sgt. Donnell Walters,, # 13 13- Declaration of John Bowman, Sr., # 14 14- Declaration of Pastor Linden Bowie, # 15 15- Declaration of Mark Thiede, # 16 16- Declaration of Melissa Combs, # 17 17- Declaration of Gwendolyn VanSant, # 18 18- Declaration of Pastor Thomas Mayes, # 19 19- Pastor Paul P. Nelson, # 20 20- Declaration of LDawn Olsen, # 21 21- Declaration of Julie Burkhart, # 22 22- Declaration of Viles Dorsainvil, # 23 23- Supplemental Declaration of Gwendolyn VanSant, # 24 24- Declaration of Reverend Philip Duvall)(Freeny, Kyle) (Entered: 11/25/2025)

1 1- OMB Technical Supplement to the Presidents FY2026 Budget Excerpt

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2 2- DOJ FY 2026 Budget and Performance Summary

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3 3 - Bloomberg Law New article

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4 4 - CRS "About Us"

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5 5- 2019 CRS Report to Congress

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6 6- 2020 CRS Report to Congress

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7 7- 2021 CRS Report to Congress

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8 8- 2022 CRS Report to Congress

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9 9- North Plains Independent Article

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10 10- Declaration of Julius J. Nam

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11 11- Supplemental Declaration of Julius J. Nam

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12 12- Declaration of Sgt. Donnell Walters,

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13 13- Declaration of John Bowman, Sr.

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14 14- Declaration of Pastor Linden Bowie

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15 15- Declaration of Mark Thiede

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16 16- Declaration of Melissa Combs

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17 17- Declaration of Gwendolyn VanSant

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18 18- Declaration of Pastor Thomas Mayes

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19 19- Pastor Paul P. Nelson

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20 20- Declaration of LDawn Olsen

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21 21- Declaration of Julie Burkhart

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22 22- Declaration of Viles Dorsainvil

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23 23- Supplemental Declaration of Gwendolyn VanSant

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24 24- Declaration of Reverend Philip Duvall

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Consent MOTION for Leave to File Excess Pages by Berkshire Resources for Integration of Diverse Groups and Education, Ethical Society of Police, Haitian Community Help & Support Center dba Haitian Support Center, Missouri Baptist Convention, NAACP St. Louis County, NAACP State Conference Colorado-Montana-Wyoming, Out Accountability Project, Peacemakers Lodge, Pikes Peak Southern Christian Leadership Conference, Two Wrasslin Cats Accord, Wellspring Health Access.(Freeny, Kyle) (Entered: 11/25/2025)

MEMORANDUM in Support re 32 MOTION for Preliminary Injunction filed by Berkshire Resources for Integration of Diverse Groups and Education, Ethical Society of Police, Haitian Community Help & Support Center dba Haitian Support Center, Missouri Baptist Convention, NAACP St. Louis County, NAACP State Conference Colorado-Montana-Wyoming, Out Accountability Project, Peacemakers Lodge, Pikes Peak Southern Christian Leadership Conference, Two Wrasslin Cats Accord, Wellspring Health Access. (Freeny, Kyle) (Entered: 11/25/2025)

Judge Indira Talwani: ELECTRONIC ORDER granting nunc pro tunc Motion for Leave to File Excess Pages 34 . (SEC) (Entered: 11/25/2025)

Judge Indira Talwani: SCHEDULING ORDER entered. See attached. (SEC) (Entered: 11/25/2025)

Order on Motion for Leave to File Excess Pages

Scheduling Conference

Amicus Curiae APPEARANCE entered by Shoba Pillay on behalf of Members of Congress. (Pillay, Shoba) (Entered: 12/05/2025)

MOTION for Leave to Appear Pro Hac Vice for admission of Matthew B. Klapper Filing fee: $ 125, receipt number AMADC-11400114 by Members of Congress.(Pillay, Shoba) (Entered: 12/05/2025)

MOTION for Leave to Appear Pro Hac Vice for admission of Elizabeth Henthorne Filing fee: $ 125, receipt number AMADC-11400160 by Members of Congress.(Pillay, Shoba) (Entered: 12/05/2025)

MOTION for Leave to Appear Pro Hac Vice for admission of Gavan W. Duffy Gideon Filing fee: $ 125, receipt number AMADC-11400177 by Members of Congress.(Pillay, Shoba) (Entered: 12/05/2025)

MOTION for Leave to File Amici Curiae Brief in Support of Plaintiffs' Motion for Preliminary Injunction by Members of Congress. (Attachments: # 1 Brief of Members of Congress as Amici Curiae in Support of Plaintiffs' Motion for Preliminary Injunction)(Pillay, Shoba) (Entered: 12/05/2025)

1 Brief of Members of Congress as Amici Curiae in Support of Plaintiffs' Mot

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NOTICE of Appearance by Steven M. Stimell on behalf of The Leadership Conference on Civil and Human Rights, 101 Civil Rights and Community Organizations (Stimell, Steven) (Entered: 12/05/2025)

MOTION for Leave to File Brief of Amici Curiae The Leadership Conference on Civil and Human Rights, and 101 Civil Rights and Community Organizations in support of Plaintiff's Motion for Preliminary Injunction by 101 Civil Rights and Community Organizations, The Leadership Conference on Civil and Human Rights. (Attachments: # 1 Amicus Brief, # 2 Appendix 1, # 3 Appendix 2)(Stimell, Steven) (Entered: 12/05/2025)

1 Amicus Brief

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2 Appendix 1

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3 Appendix 2

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MOTION for Leave to Appear Pro Hac Vice for admission of Saurish Appleby-Bhattacharjee Filing fee: $ 125, receipt number AMADC-11400920 by 101 Civil Rights and Community Organizations, The Leadership Conference on Civil and Human Rights. (Attachments: # 1 Certification of Saurish Appleby-Bhattacharjee)(Stimell, Steven) (Entered: 12/05/2025)

NOTICE by Pamela J. Bondi, U.S. Department of Justice Filing of Administrative Record and Certified Index to the Administrative Record (Attachments: # 1 Administrative Record)(Stout, Abigail) (Entered: 12/05/2025)

1 Administrative Record

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Consent MOTION for Leave to File Excess Pages by Pamela J. Bondi, U.S. Department of Justice.(Stout, Abigail) (Entered: 12/08/2025)

Judge Indira Talwani: ELECTRONIC ORDER allowing 48 Consent MOTION for Leave to File Excess Pages. 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: 12/09/2025)

Judge Indira Talwani: ELECTRONIC ORDER granting Unopposed Motion of Members of Congress for Leave to File Amici Curiae Brief in Support of Plaintiffs' Motion for Preliminary Injunction [ 43 ]. 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: 12/09/2025)

RESPONSE to Motion re 32 MOTION for Preliminary Injunction filed by Pamela J. Bondi, U.S. Department of Justice. (Attachments: # 1 Affidavit, # 2 Exhibit Exhibit A to Declaration)(Stout, Abigail) (Entered: 12/09/2025)

1 Affidavit

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2 Exhibit Exhibit A to Declaration

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Order on Motion for Leave to File Document

Order on Motion for Leave to File Excess Pages

Judge Indira Talwani: ELECTRONIC ORDER granting unopposed Motion for Leave to File Brief of Amici Curiae The Leadership Conference on Civil and Human Rights and 101 Civil Rights and Community Organizations in Support of Plaintiffs' Motion for Preliminary Injunction [ 45 ]. 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: 12/10/2025)

Judge Indira Talwani: ELECTRONIC ORDER entered granting 40 Motion for Leave to Appear Pro Hac Vice; granting 41 Motion for Leave to Appear Pro Hac Vice; granting 42 Motion for Leave to Appear Pro Hac Vice; granting 46 Motion for Leave to Appear Pro Hac Vice. Added Matthew B. Klapper, Elizabeth Henthorne, Gavan W. Duffy Gideon, and Saurish Appleby-Bhattacharjee. 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: 12/10/2025)

NOTICE of Appearance by Saurish Appleby-Bhattacharjee on behalf of 101 Civil Rights and Community Organizations, The Leadership Conference on Civil and Human Rights (Appleby-Bhattacharjee, Saurish) (Entered: 12/10/2025)

AMICUS BRIEF filed by Members of Congress in Support of Plaintiffs' Motion for Preliminary Injunction. (Pillay, Shoba) (Entered: 12/10/2025)

AMICUS BRIEF filed by 101 Civil Rights and Community Organizations, The Leadership Conference on Civil and Human Rights . (Attachments: # 1 Appendix 1, # 2 Appendix 2)(Appleby-Bhattacharjee, Saurish) (Entered: 12/10/2025)

CERTIFICATE OF SERVICE pursuant to LR 5.2 by 101 Civil Rights and Community Organizations, The Leadership Conference on Civil and Human Rights re 56 Amicus brief filed . (Appleby-Bhattacharjee, Saurish) (Entered: 12/10/2025)

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

Order on Motion for Leave to File Document

Amicus Curiae APPEARANCE entered by Elizabeth Henthorne on behalf of Members of Congress. (Henthorne, Elizabeth) (Entered: 12/11/2025)

MOTION for Leave to File Reply Memorandum on Plaintiffs' Motion for Preliminary Injunction by Berkshire Resources for Integration of Diverse Groups and Education, Ethical Society of Police, Haitian Community Help & Support Center dba Haitian Support Center, Missouri Baptist Convention, NAACP St. Louis County, NAACP State Conference Colorado-Montana-Wyoming, Out Accountability Project, Peacemakers Lodge, Pikes Peak Southern Christian Leadership Conference, Two Wrasslin Cats Accord, Wellspring Health Access. (Attachments: # 1 Exhibit A - Proposed Reply Memorandum)(Freeny, Kyle) (Entered: 12/15/2025)

Amicus Curiae APPEARANCE entered by Matthew Bennett Klapper on behalf of Members of Congress. (Klapper, Matthew) (Entered: 12/15/2025)

Amicus Curiae APPEARANCE entered by Gavan William Duffy Gideon on behalf of Members of Congress. (Duffy Gideon, Gavan) (Entered: 12/15/2025)

Judge Indira Talwani: ELECTRONIC ORDER allowing [ 59 ] MOTION for Leave to File Reply Memorandum on Plaintiffs' Motion 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: 12/15/2025)

REPLY to Response to 32 MOTION for Preliminary Injunction filed by Berkshire Resources for Integration of Diverse Groups and Education, Ethical Society of Police, Haitian Community Help & Support Center dba Haitian Support Center, Missouri Baptist Convention, NAACP St. Louis County, NAACP State Conference Colorado-Montana-Wyoming, Out Accountability Project, Peacemakers Lodge, Pikes Peak Southern Christian Leadership Conference, Two Wrasslin Cats Accord, Wellspring Health Access. (Freeny, Kyle) (Entered: 12/15/2025)

Order on Motion for Leave to File Document

Notice of Supplemental Authorities re 32 MOTION for Preliminary Injunction (Attachments: # 1 Exhibit A - AFGE v. OMB Slip Opinion)(Freeny, Kyle) (Entered: 12/18/2025)

1 Exhibit A - AFGE v. OMB Slip Opinion

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MOTION to Compel Completion of Administrative Record, Production of Privilege Log, and for Limited Discovery by Berkshire Resources for Integration of Diverse Groups and Education, Ethical Society of Police, Haitian Community Help & Support Center dba Haitian Support Center, Missouri Baptist Convention, NAACP St. Louis County, NAACP State Conference Colorado-Montana-Wyoming, Out Accountability Project, Peacemakers Lodge, Pikes Peak Southern Christian Leadership Conference, Two Wrasslin Cats Accord, Wellspring Health Access. (Attachments: # 1 Text of Proposed Order)(Freeny, Kyle) (Entered: 12/22/2025)

AFFIDAVIT in Support re 65 MOTION to Compel Completion of Administrative Record, Production of Privilege Log, and for Limited Discovery . (Attachments: # 1 Ex. 1 - Third Declaration of Julius J. Nam, # 2 Ex. 2 - Defs' Initial Disclosures)(Freeny, Kyle) (Entered: 12/22/2025)

MEMORANDUM in Support re 65 MOTION to Compel Completion of Administrative Record, Production of Privilege Log, and for Limited Discovery filed by Berkshire Resources for Integration of Diverse Groups and Education, Ethical Society of Police, Haitian Community Help & Support Center dba Haitian Support Center, Missouri Baptist Convention, NAACP St. Louis County, NAACP State Conference Colorado-Montana-Wyoming, Out Accountability Project, Peacemakers Lodge, Pikes Peak Southern Christian Leadership Conference, Two Wrasslin Cats Accord, Wellspring Health Access. (Freeny, Kyle) (Entered: 12/22/2025)

Notice of Supplemental Authorities re 32 MOTION for Preliminary Injunction (Freeny, Kyle) (Entered: 01/06/2026)

Judge Indira Talwani: ORDER Granting Plaintiff's Motion Regarding the Administrative Record and Discovery. See attached. (SEC) (Entered: 01/08/2026)

Judge Indira Talwani: Judge Indira Talwani: ELECTRONIC ORDER: vacating Order [ 69 ] granting Plaintiffs' Motion Regarding the Administrative Record and Discovery [ 65 ] in light of the Scheduling Order [ 37 ] setting a January 12, 2026 date for any opposition to Plaintiffs' Motion. (GAM) (Entered: 01/08/2026)

Order AND ~Util - Set Motion and R&R Deadlines/Hearings

RESPONSE to Motion re 65 MOTION to Compel Completion of Administrative Record, Production of Privilege Log, and for Limited Discovery filed by Pamela J. Bondi, U.S. Department of Justice. (Stout, Abigail) (Entered: 01/12/2026)

MOTION for Status Conference by Berkshire Resources for Integration of Diverse Groups and Education, Ethical Society of Police, Haitian Community Help & Support Center dba Haitian Support Center, Missouri Baptist Convention, NAACP St. Louis County, NAACP State Conference Colorado-Montana-Wyoming, Out Accountability Project, Peacemakers Lodge, Pikes Peak Southern Christian Leadership Conference, Two Wrasslin Cats Accord, Wellspring Health Access.(Freeny, Kyle) (Entered: 01/13/2026)

RESPONSE to Motion re 72 MOTION for Status Conference and Notice Regarding RIF Rescission filed by Pamela J. Bondi, U.S. Department of Justice. (Attachments: # 1 Exhibit A)(Stout, Abigail) (Entered: 01/13/2026)

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Judge Indira Talwani: ELECTRONIC ORDER: allowing [ 72 ] MOTION for Status Conference. The clerk shall set a status conference by videoconference for 1/22/2026 at 03:30 p.m.. The parties shall confer and file a joint status report no later than 1/21/2026. Status Conference set for 1/22/2026 03:30 PM in Courtroom 9 (Remote only) before Judge Indira Talwani. (SEC) (Entered: 01/16/2026)

Order AND ~Util - Set Hearings AND ~Util - Terminate Motions

STATUS REPORT (Joint) by Pamela J. Bondi, U.S. Department of Justice. (Attachments: # 1 Exhibit Exhibit A - Lauria Declaration)(Stout, Abigail) (Entered: 01/21/2026)

NOTICE of Appearance by Steven Chasin on behalf of Pamela J. Bondi, U.S. Department of Justice (Chasin, Steven) (Entered: 01/22/2026)

MOTION to Withdraw as Attorney Abigail Stout by Pamela J. Bondi, U.S. Department of Justice.(Stout, Abigail) (Entered: 01/22/2026)

Electronic Clerk's Notes for proceedings held before Judge Indira Talwani: Status Conference held on 1/22/2026. Case called. Court had colloquy with counsel. Status Conference to be continued to February and will be set by the clerk. (Court Reporter: Robert Paschal at rwp.reporter@gmail.com.)(Attorneys present: Kyle Freeny, Ana Munoz, Steven Chasin, Abigail Stout) (LC/GAM) (Entered: 01/23/2026)

Judge Indira Talwani: ELECTRONIC ORDER entered. ELECTRONIC ORDER: The clerk has set a Status Conference for 2/13/2026 at 02:45 PM in Courtroom 9 (Remote only) After conferring, and no later than 2/11/2026, the parties shall file a joint status report regarding the status and plans for resumption of operations of CRS. Defendants shall also refile the Administrative Record [[47-1]], including a certification attesting that the Administrative Record, and the documents contained therein, are complete. (GAM) (Entered: 01/23/2026)

Judge Indira Talwani: ELECTRONIC ORDER allowing 77 MOTION to Withdraw as Attorney Abigail Stout. Attorney Abigail Stout terminated. (SEC) (Entered: 01/23/2026)

Order AND ~Util - Set Deadlines/Hearings