Case: Moreno Gonzalez v. Noem

COMPLAINT (Class Action) filed by Felipe Agustin Zamacona, Pablo Moreno Gonzalez; Filing fee $ 405, receipt number AILNDC-24281878.(Van Brunt, Alexa) (Entered: 10/30/2025)

ATTORNEY Appearance for Plaintiffs Felipe Agustin Zamacona, Pablo Moreno Gonzalez by Michelle Teresa Garcia (Garcia, Michelle) (Entered: 10/30/2025)

ATTORNEY Appearance for Plaintiffs Felipe Agustin Zamacona, Pablo Moreno Gonzalez by Rebecca Kim Glenberg (Glenberg, Rebecca) (Entered: 10/30/2025)

ATTORNEY Appearance for Plaintiffs Felipe Agustin Zamacona, Pablo Moreno Gonzalez by Samuel B. Cole (Cole, Samuel) (Entered: 10/30/2025)

ATTORNEY Appearance for Plaintiffs Felipe Agustin Zamacona, Pablo Moreno Gonzalez by Danielle Berkowsky (Berkowsky, Danielle) (Entered: 10/30/2025)

ATTORNEY Appearance for Plaintiffs Felipe Agustin Zamacona, Pablo Moreno Gonzalez by Nathan P. Eimer (Eimer, Nathan) (Entered: 10/30/2025)

MOTION by Plaintiffs Felipe Agustin Zamacona, Pablo Moreno Gonzalez to expedite discovery (Attachments: # 1 Exhibit A - Plaintiffs' Requests for Expedited Discovery)(Eimer, Nathan) (Entered: 10/30/2025)

1 Exhibit A - Plaintiffs' Requests for Expedited Discovery

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ATTORNEY Appearance for Plaintiffs Felipe Agustin Zamacona, Pablo Moreno Gonzalez by Scott C. Solberg (Solberg, Scott) (Entered: 10/30/2025)

MOTION by Plaintiffs Felipe Agustin Zamacona, Pablo Moreno Gonzalez for temporary restraining order (Attachments: # 1 EXHIBIT A)(Fee, Kevin) (Entered: 10/30/2025)

1 EXHIBIT A

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ATTORNEY Appearance for Plaintiffs Felipe Agustin Zamacona, Pablo Moreno Gonzalez by Michael L. McCluggage (McCluggage, Michael) (Entered: 10/30/2025)

ATTORNEY Appearance for Plaintiffs Felipe Agustin Zamacona, Pablo Moreno Gonzalez by Lisa S. Meyer (Meyer, Lisa) (Entered: 10/30/2025)

Exhibit List and Exhibits to Complaint by Felipe Agustin Zamacona, Pablo Moreno Gonzalez (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Exhibit 7, # 8 Exhibit 8, # 9 Exhibit 9, # 10 Exhibit 10, # 11 Exhibit 11, # 12 Exhibit 12, # 13 Exhibit 13, # 14 Exhibit 14, # 15 Exhibit 15, # 16 Exhibit 16, # 17 Exhibit 17, # 18 Exhibit 18, # 19 Exhibit 19, # 20 Exhibit 20, # 21 Exhibit 21, # 22 Exhibit 22, # 23 Exhibit 23, # 24 Exhibit 24, # 25 Exhibit 25, # 26 Exhibit 26, # 27 Exhibit 27, # 28 Exhibit 28, # 29 Exhibit 29, # 30 Exhibit 30, # 31 Exhibit 31, # 32 Exhibit 32, # 33 Exhibit 33, # 34 Exhibit 34, # 35 Exhibit 35, # 36 Exhibit 36, # 37 Exhibit 37, # 38 Exhibit 38, # 39 Exhibit 39, # 40 Exhibit 40)(Van Brunt, Alexa) (Entered: 10/30/2025)

1 Exhibit 1

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2 Exhibit 2

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3 Exhibit 3

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4 Exhibit 4

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5 Exhibit 5

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6 Exhibit 6

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7 Exhibit 7

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8 Exhibit 8

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9 Exhibit 9

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10 Exhibit 10

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11 Exhibit 11

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12 Exhibit 12

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13 Exhibit 13

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14 Exhibit 14

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15 Exhibit 15

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16 Exhibit 16

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17 Exhibit 17

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18 Exhibit 18

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19 Exhibit 19

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20 Exhibit 20

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21 Exhibit 21

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22 Exhibit 22

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23 Exhibit 23

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24 Exhibit 24

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25 Exhibit 25

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26 Exhibit 26

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27 Exhibit 27

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28 Exhibit 28

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29 Exhibit 29

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30 Exhibit 30

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31 Exhibit 31

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32 Exhibit 32

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33 Exhibit 33

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34 Exhibit 34

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35 Exhibit 35

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36 Exhibit 36

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37 Exhibit 37

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38 Exhibit 38

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39 Exhibit 39

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40 Exhibit 40

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Motion for Leave to File Excess Pages by Felipe Agustin Zamacona, Pablo Moreno Gonzalez (Attachments: # 1 EXHIBIT A)(Fee, Kevin) (Entered: 10/31/2025)

1 EXHIBIT A

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CIVIL Cover Sheet (Van Brunt, Alexa) (Entered: 10/30/2025)

ATTORNEY Appearance for Plaintiffs Felipe Agustin Zamacona, Pablo Moreno Gonzalez by Alexa Van Brunt (and on behalf of the putative class) (Van Brunt, Alexa) (Entered: 10/30/2025)

Motion for Class Certification by Felipe Agustin Zamacona, Pablo Moreno Gonzalez (Fee, Kevin) (Entered: 10/30/2025)

MOTION by Plaintiffs Felipe Agustin Zamacona, Pablo Moreno Gonzalez for leave to file excess pages (Attachments: # 1 EXHIBIT A)(Fee, Kevin) (Entered: 10/30/2025)

1 EXHIBIT A

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ATTORNEY Appearance for Plaintiffs Felipe Agustin Zamacona, Pablo Moreno Gonzalez by Kevin M. Fee, Jr (Fee, Kevin) (Entered: 10/30/2025)

ATTORNEY Appearance for Plaintiffs Felipe Agustin Zamacona, Pablo Moreno Gonzalez by Jennifer L. Stark (Stark, Jennifer) (Entered: 10/30/2025)

ATTORNEY Appearance for Plaintiffs Felipe Agustin Zamacona, Pablo Moreno Gonzalez by Kathleen W. Hickey (Hickey, Kathleen) (Entered: 10/30/2025)

ATTORNEY Appearance for Plaintiffs Felipe Agustin Zamacona, Pablo Moreno Gonzalez by Brent R. Austin (Austin, Brent) (Entered: 10/31/2025)

ATTORNEY Appearance for Plaintiffs Felipe Agustin Zamacona, Pablo Moreno Gonzalez by Jonathan Matthew Manes (Manes, Jonathan) (Entered: 10/31/2025)

DECLARATION of Kevin Fee regarding motion for temporary restraining order 17 (Fee, Kevin) (Entered: 10/31/2025)

MINUTE entry before the Honorable Robert W. Gettleman: Telephonic scheduling hearing on Plaintiffs' Emergency Motion for a Temporary Restraining Order 17 set for 10/31/2025 at 3:00 p.m. Plaintiffs' Motion For Leave To File Memorandum In Support Of Class Certification In Excess Of Fifteen Pages 6 is granted. The Clerk shall email a copy of this order to Tom Walsh, Chief of the Civil Division, United States Attorney's Office, Northern District of Illinois, Craig Oswald, AUSA, United States Attorney's Office, Northern District of Illinois, and Joshua Press, AUSA, United States Attorney's Office, Northern District of Illinois. To join the telephone conference, dial (650) 479-3207, Access Code 1809 88 3385. Throughout the hearing, each speaker will be expected to identify themselves for the record before speaking. Counsel must be in a quiet area while on the line. Please be sure to keep your phone on mute when you are not speaking. Counsel of record and other essential case participants will receive an email prior to the start of the hearing with instructions to join the hearing. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Emailed notice (cn). (Entered: 10/31/2025)

MEMORANDUM In Support of Plaintiffs' Motion for Class Certification (Fee, Kevin) (Entered: 10/31/2025)

MEMORANDUM In Support of Plaintiffs' Emergency Motion for Temporary Restraining Order (Fee, Kevin) (Entered: 10/31/2025)

MOTION by Plaintiffs Felipe Agustin Zamacona, Pablo Moreno Gonzalez FOR AN EMERGENCY ORDER MANDATING ATTORNEY ACCESS AND REQUIRING THAT THE INDIVIDUAL NAMED PLAINTIFFS REMAIN IN, OR BE RETURNED TO, THIS CIRCUIT (Attachments: # 1 Exhibit 1, # 2 Exhibit 2)(Van Brunt, Alexa) (Entered: 10/31/2025)

1 Exhibit 1

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2 Exhibit 2

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NOTICE of Motion by Alexa Van Brunt for presentment of motion for miscellaneous relief, 27 before Honorable Robert W. Gettleman on 10/31/2025 at 03:00 PM. (Van Brunt, Alexa) (Entered: 10/31/2025)

MINUTE entry before the Honorable Robert W. Gettleman: Telephonic hearing held on 10/31/2025. Plaintiffs' Emergency Motion For An Order Mandating Attorney Access And Requiring That The Individual Named Plaintiffs Remain In, Or Be Returned To, This Circuit 27 is granted in part. The court orders defendants to return the plaintiffs to the Northern District of Illinois, forthwith, by Monday 11/3/2025 at 4:00 p.m. at the latest. Defendants are to take all steps necessary to facilitate communication between the named plaintiffs and their counsel regardless of their location. Defendants are given leave to file a response and any other material that they wish the court to consider by 4:30 p.m. Monday, 11/3/2025. Defendants' counsel are directed to notify plaintiffs' counsel when the plaintiffs are returned to the Northern District of Illinois and their location. In court hearing set for 11/4/2025 at 9:30 a.m. Defendants are to produce plaintiffs for the hearing. If they are not able to produce plaintiffs to be physically present they must make plaintiffs available to appear virtually. All other pending motions are entered and continued to 11/4/2025. Emailed notice (cn). (Entered: 10/31/2025)

case assigned

clerk's notice

CASE ASSIGNED to the Honorable Robert W. Gettleman. Designated as Magistrate Judge the Honorable Laura K. McNally. Case assignment: Random assignment. (Civil Category 1). (man, )

CLERK'S NOTICE: Pursuant to Local Rule 73.1(b), a United States Magistrate Judge of this court is available to conduct all proceedings in this civil action. If all parties consent to have the currently assigned United States Magistrate Judge conduct all proceedings in this case, including trial, the entry of final judgment, and all post-trial proceedings, all parties must sign their names on the attached Consent To form. This consent form is eligible for filing only if executed by all parties. The parties can also express their consent to jurisdiction by a magistrate judge in any joint filing, including the Joint Initial Status Report or proposed Case Management Order. (man, )

DESIGNATION of Jana L. Brady as U.S. Attorney for Defendants Gregory Bovino, Commander-at-Large, U.S. Customs and Border Protection, Marcos Charles, Acting Executive Associate Director, U.S. Immigration and Customs Enforcement and Removal Operations, Department of Homeland Security, Todd M. Lyons, Kristi Noem, Samuel Olson, U.S. Customs and Border Protection, U.S. Immigration and Customs Enforcement (Brady, Jana) (Entered: 11/03/2025)

MOTION by Plaintiffs Felipe Agustin Zamacona, Pablo Moreno Gonzalez to seal EXHIBITS AND TO FILE CORRECTED REDACTED VERSIONS (Unopposed) (Van Brunt, Alexa) (Entered: 11/03/2025)

NOTICE of Motion by Alexa Van Brunt for presentment of motion to seal 33 before Honorable Robert W. Gettleman on 11/4/2025 at 09:30 AM. (Van Brunt, Alexa) (Entered: 11/03/2025)

DESIGNATION of Patrick Walter Johnson as U.S. Attorney for Defendants Gregory Bovino, Commander-at-Large, U.S. Customs and Border Protection, Marcos Charles, Acting Executive Associate Director, U.S. Immigration and Customs Enforcement and Removal Operations, Department of Homeland Security, Todd M. Lyons, Kristi Noem, Samuel Olson, U.S. Customs and Border Protection, U.S. Immigration and Customs Enforcement (Johnson, Patrick) (Entered: 11/03/2025)

SUMMONS Issued (Court Participant) as to Gregory Bovino, Commander-at-Large, U.S. Customs and Border Protection, Marcos Charles, Acting Executive Associate Director, U.S. Immigration and Customs Enforcement and Removal Operations, Department of Homeland Security, Todd M. Lyons, Kristi Noem, Samuel Olson, U.S. Customs and Border Protection, U.S. Immigration and Customs Enforcement, U.S. Attorney, and U.S. Attorney General (Attachments: # 1 summons, # 2 summons, # 3 summons, # 4 summons, # 5 summons, # 6 summons, # 7 summons, # 8 summons, # 9 summons)(axk, ) (Entered: 11/03/2025)

RESPONSE by Defendants Gregory Bovino, Commander-at-Large, U.S. Customs and Border Protection, Marcos Charles, Acting Executive Associate Director, U.S. Immigration and Customs Enforcement and Removal Operations, Department of Homeland Security, Todd M. Lyons, Kristi Noem, Samuel Olson, U.S. Customs and Border Protection, U.S. Immigration and Customs Enforcement to motion for temporary restraining order 17 (Brady, Jana) (Entered: 11/03/2025)

RESPONSE by Defendants Gregory Bovino, Commander-at-Large, U.S. Customs and Border Protection, Marcos Charles, Acting Executive Associate Director, U.S. Immigration and Customs Enforcement and Removal Operations, Department of Homeland Security, Todd M. Lyons, Kristi Noem, Samuel Olson, U.S. Customs and Border Protection, U.S. Immigration and Customs Enforcement to motion for temporary restraining order 17 corrected with signed declaration (Brady, Jana) (Entered: 11/03/2025)

RESPONSE by Defendants Gregory Bovino, Commander-at-Large, U.S. Customs and Border Protection, Marcos Charles, Acting Executive Associate Director, U.S. Immigration and Customs Enforcement and Removal Operations, Department of Homeland Security, Todd M. Lyons, Kristi Noem, Samuel Olson, U.S. Customs and Border Protection, U.S. Immigration and Customs Enforcement to other 5 Opposition to Plaintiffs' Motion for Class Certification (Dkt 5) (Brady, Jana) (Entered: 11/03/2025)

ATTORNEY Appearance for Plaintiffs Felipe Agustin Zamacona, Pablo Moreno Gonzalez by James B. Speta (Speta, James) (Entered: 11/03/2025)

DIGITAL EXHIBIT submitted by Pablo Moreno Gonzalez For more information, please visit https://www.ilnd.uscourts.gov/ExhibitDrop. If you wish to download a digital exhibit, please send your request to the Certified Copy Desk (CCD) inbox at CCD_ILND@ilnd.uscourts.gov. You will be provided with an invoice and charged according to the Fee Schedule. Once your payment has been processed, you will receive a URL via email to download the exhibit. (pjj, ) (Entered: 11/04/2025)

MINUTE entry before the Honorable Robert W. Gettleman: Plaintiffs' unopposed motion to seal exhibits and to file corrected redacted versions 33 is granted. The Clerk is directed to seal exhibit 6 (ECF 2-6), exhibit 15 (ECF 2-15), exhibit 16 (ECF 2-16), exhibit 18 (ECF 2-18), exhibit 25 (ECF 2-25), exhibit 27 (ECF 2-27), exhibit 28 (ECF 2-28), exhibit 29 (ECF 2-29). Plaintiff has leave to file redacted versions. Emailed notice (cn). (Entered: 11/04/2025)

ORDER: In court hearing on Plaintiffs' Emergency Motion for a Temporary Restraining Order 17 held on 11/4/2025. Testimony heard. In court hearing continued to 11/5/2025 at 4:15 p.m. The court orders that the plaintiffs in this case, Pablo Moreno Gonzalez and Felipe Agustin Zamacona, are to be held at the Metropolitan Correctional Center (MCC) until further order of Court. Plaintiffs Moreno Gonzalez and Zamacona are to appear for the court hearing set for 11/5/2025 at 4:15 p.m. via Webex. For the reasons stated on the record, Plaintiffs' Motion for Expedited Discovery 15 is granted limited as stated on the record. Counsel are to confer regarding the individuals to be deposed, the length of time needed for the depositions, records on the amount of people being housed in the Broadview ICE facility cells, and a discovery plan. Plaintiffs' reply in support of their motion for Class Certification 5 due by 11/7/2025. Plaintiffs' Motion for TRO 17 is entered and continued to 11/5/2025. Signed by the Honorable Robert W. Gettleman on 11/4/2025. Emailed notice (cn). (Entered: 11/04/2025)

Exhibit List to Corrected Redacted Complaint Exhibits and Exhibits by Felipe Agustin Zamacona, Pablo Moreno Gonzalez (Attachments: # 1 Exhibit Declaration of Claudia Pereira Guevara, # 2 Exhibit Declaration of Valentin Toto Polito, # 3 Exhibit Declaration of Jose Guerrero Pozos, # 4 Exhibit Declaration of John Cerrone, # 5 Exhibit Declaration of Karina Ayala-Bermejo, # 6 Exhibit Declaration of David A. Mejia, # 7 Exhibit Declaration of Brad Thomson, # 8 Exhibit Declaration of Jacqueline Spreadbury)(Van Brunt, Alexa) (Entered: 11/05/2025)

MINUTE entry before the Honorable Robert W. Gettleman: In Court hearing remains set in this matter for 11/5/2025 at 04:15 PM. Emailed notice (cn). (Entered: 11/05/2025)

MOTION by Plaintiffs Felipe Agustin Zamacona, Pablo Moreno Gonzalez to strike digital exhibit, 43 (Unopposed) (Berkowsky, Danielle) (Entered: 11/05/2025)

TEMPORARY Restraining Order signed by the Honorable Robert W. Gettleman on 11/5/2025. Emailed notice (cn). (Entered: 11/05/2025)

MINUTE entry before the Honorable Robert W. Gettleman: In court hearing held on 11/5/2025. For the reasons stated on the record, Plaintiffs' Emergency Motion for a Temporary Restraining Order 17 is granted. The TRO has been entered on the docket and copies provided to counsel in court. The parties are directed to file a Joint Status Report on compliance with this court's TRO by 12:00 p.m. on 11/7/2025. Plaintiffs' Unopposed Motion To Strike Digital Exhibit 48 is granted. The Clerk is directed to withdraw documents 43 and 44 from the docket. In court hearing before this court set for 11/19/2025 at 10:00 a.m. The court refers discovery supervision to Magistrate Judge McNally. Hearing before Magistrate Judge McNally set for 11/12/2025 at 3:00 p.m. The parties are directed to file a joint status report before the Magistrate Judge by 11/12/2025 at 2:00 p.m. addressing what the parties have agreed to and discovery disagreements. Emailed notice (cn). (Entered: 11/05/2025)

Pursuant to Local Rule 72.1, this case is hereby referred to the calendar of Honorable Laura K. McNally for the purpose of holding proceedings related to: discovery supervision. (cn) Emailed notice. (Entered: 11/05/2025)