Case: American Federation of Government Employees, AFL-CIO v. Kupor

American Federation of Government Employees v. Kupor

American Federation of Government Employees v. Kupor

American Federation of Government Employees v. Kupor

American Federation of Government Employees, AFL-CIO et al. v. Kupor et al.

Donald J. Trump

COMPLAINT against The United States of America, Scott Kupor, Office of Personnel Management Filing fee: $ 405, receipt number AMADC-11345230 (Fee Status: Filing Fee paid), filed by American Federation of Government Employees, AFL-CIO, American Federation of State, County and Municipal Employees, AFL-CIO, National Association of Government Employees, Inc.. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Civil Cover Sheet, # 7 Category Form)(Hoshijima, Tsuki) (Entered: 11/06/2025)

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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6 Civil Cover Sheet

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7 Category Form

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MOTION for Leave to Appear Pro Hac Vice for admission of Matthew Stark Blumin Filing fee: $ 125, receipt number AMADC-11345271 by American Federation of Government Employees, AFL-CIO, American Federation of State, County and Municipal Employees, AFL-CIO, National Association of Government Employees, Inc.. (Attachments: # 1 Declaration)(Hoshijima, Tsuki) (Entered: 11/06/2025)

ELECTRONIC NOTICE of Case Assignment. Judge George A. OToole, Jr 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 Jessica D. Hedges. (LBO) (Entered: 11/06/2025)

Summons Issued as to Scott Kupor, Office of Personnel Management, The United States of America. 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. (FGD) (Entered: 11/06/2025)

Judge George A. OToole, Jr: ELECTRONIC ORDER entered GRANTING 2 Motion for Leave to Appear Pro Hac Vice Added Matthew Stark Blumin. 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. (FGD) (Entered: 11/06/2025)

MOTION for Leave to Appear Pro Hac Vice for admission of Sarah Suszczyk Filing fee: $ 125, receipt number AMADC-11345847 by American Federation of Government Employees, AFL-CIO, American Federation of State, County and Municipal Employees, AFL-CIO, National Association of Government Employees, Inc.. (Attachments: # 1 Declaration)(Hoshijima, Tsuki) (Entered: 11/06/2025)

MOTION for Leave to Appear Pro Hac Vice for admission of Rushab Sanghvi Filing fee: $ 125, receipt number AMADC-11345854 by American Federation of Government Employees, AFL-CIO, American Federation of State, County and Municipal Employees, AFL-CIO, National Association of Government Employees, Inc.. (Attachments: # 1 Declaration)(Hoshijima, Tsuki) (Entered: 11/06/2025)

MOTION for Leave to Appear Pro Hac Vice for admission of Jacek Pruski Filing fee: $ 125, receipt number AMADC-11345856 by American Federation of Government Employees, AFL-CIO, American Federation of State, County and Municipal Employees, AFL-CIO, National Association of Government Employees, Inc.. (Attachments: # 1 Declaration)(Hoshijima, Tsuki) (Entered: 11/06/2025)

MOTION for Leave to Appear Pro Hac Vice for admission of Cara R. Meyer Filing fee: $ 125, receipt number AMADC-11345861 by American Federation of Government Employees, AFL-CIO, American Federation of State, County and Municipal Employees, AFL-CIO, National Association of Government Employees, Inc.. (Attachments: # 1 Declaration)(Hoshijima, Tsuki) (Entered: 11/06/2025)

MOTION for Leave to Appear Pro Hac Vice for admission of Webb Lyons Filing fee: $ 125, receipt number AMADC-11345863 by American Federation of Government Employees, AFL-CIO, American Federation of State, County and Municipal Employees, AFL-CIO, National Association of Government Employees, Inc.. (Attachments: # 1 Declaration)(Hoshijima, Tsuki) (Entered: 11/06/2025)

MOTION for Leave to Appear Pro Hac Vice for admission of Ori Lev Filing fee: $ 125, receipt number AMADC-11345864 by American Federation of Government Employees, AFL-CIO, American Federation of State, County and Municipal Employees, AFL-CIO, National Association of Government Employees, Inc.. (Attachments: # 1 Declaration)(Hoshijima, Tsuki) (Entered: 11/06/2025)

MOTION for Leave to Appear Pro Hac Vice for admission of Charlotte J. Kamai Filing fee: $ 125, receipt number AMADC-11345865 by American Federation of Government Employees, AFL-CIO, American Federation of State, County and Municipal Employees, AFL-CIO, National Association of Government Employees, Inc.. (Attachments: # 1 Declaration)(Hoshijima, Tsuki) (Entered: 11/06/2025)

MOTION for Leave to Appear Pro Hac Vice for admission of Elena Goldstein Filing fee: $ 125, receipt number AMADC-11345867 by American Federation of Government Employees, AFL-CIO, American Federation of State, County and Municipal Employees, AFL-CIO, National Association of Government Employees, Inc.. (Attachments: # 1 Declaration)(Hoshijima, Tsuki) (Entered: 11/06/2025)

MOTION for Leave to Appear Pro Hac Vice for admission of Sara R. Fitzpatrick Filing fee: $ 125, receipt number AMADC-11345869 by American Federation of Government Employees, AFL-CIO, American Federation of State, County and Municipal Employees, AFL-CIO, National Association of Government Employees, Inc.. (Attachments: # 1 Declaration)(Hoshijima, Tsuki) (Entered: 11/06/2025)

MOTION for Leave to Appear Pro Hac Vice for admission of Warren A. Braunig Filing fee: $ 125, receipt number AMADC-11345873 by American Federation of Government Employees, AFL-CIO, American Federation of State, County and Municipal Employees, AFL-CIO, National Association of Government Employees, Inc.. (Attachments: # 1 Declaration)(Hoshijima, Tsuki) (Entered: 11/06/2025)

Order on Motion for Leave to Appear

Notice of Case Assignment

Judge George A. OToole, Jr: ELECTRONIC ORDER entered GRANTING 6 Motion for Leave to Appear Pro Hac Vice Added Sarah Suszczyk. 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. (FGD) (Entered: 11/07/2025)

Judge George A. OToole, Jr: ELECTRONIC ORDER entered GRANTING 7 Motion for Leave to Appear Pro Hac Vice Added Rushab Sanghvi. 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. (FGD) (Entered: 11/07/2025)

Judge George A. OToole, Jr: ELECTRONIC ORDER entered GRANTING 8 Motion for Leave to Appear Pro Hac Vice Added Jacek Pruski. 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. (FGD) (Entered: 11/07/2025)

Judge George A. OToole, Jr: ELECTRONIC ORDER entered GRANTING 9 Motion for Leave to Appear Pro Hac Vice Added Cara R. Meyer. 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. (FGD) (Entered: 11/07/2025)

Judge George A. OToole, Jr: ELECTRONIC ORDER entered GRANTING 10 Motion for Leave to Appear Pro Hac Vice Added Webb Lyons. 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. (FGD) (Entered: 11/07/2025)

Judge George A. OToole, Jr: ELECTRONIC ORDER entered GRANTING 11 Motion for Leave to Appear Pro Hac Vice Added Ori Lev. 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. (FGD) (Entered: 11/07/2025)

Judge George A. OToole, Jr: ELECTRONIC ORDER entered GRANTING 12 Motion for Leave to Appear Pro Hac Vice Added Charlotte J. Kamai. 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. (FGD) (Entered: 11/07/2025)

Judge George A. OToole, Jr: ELECTRONIC ORDER entered GRANTING 13 Motion for Leave to Appear Pro Hac Vice Added Elena Goldstein. 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. (FGD) (Entered: 11/07/2025)

Judge George A. OToole, Jr: ELECTRONIC ORDER entered GRANTING 14 Motion for Leave to Appear Pro Hac Vice Added Sara R. Fitzpatrick. 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. (FGD) (Entered: 11/07/2025)

Judge George A. OToole, Jr: ELECTRONIC ORDER entered GRANTING 15 Motion for Leave to Appear Pro Hac Vice Added Warren A. Braunig. 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. (FGD) (Entered: 11/07/2025)

Order on Motion for Leave to Appear

NOTICE of Appearance by Ori Lev on behalf of American Federation of Government Employees, AFL-CIO, American Federation of State, County and Municipal Employees, AFL-CIO, National Association of Government Employees, Inc. (Lev, Ori) (Entered: 11/12/2025)

NOTICE of Appearance by Sarah Elizabeth Suszczyk on behalf of National Association of Government Employees, Inc. (Suszczyk, Sarah) (Entered: 11/13/2025)

NOTICE of Appearance by Rushab Sanghvi on behalf of American Federation of Government Employees, AFL-CIO (Sanghvi, Rushab) (Entered: 11/13/2025)

NOTICE of Appearance by Matthew Stark Blumin on behalf of American Federation of State, County and Municipal Employees, AFL-CIO (Blumin, Matthew) (Entered: 11/13/2025)

NOTICE of Appearance by Jacek Pruski on behalf of American Federation of Government Employees, AFL-CIO, American Federation of State, County and Municipal Employees, AFL-CIO, National Association of Government Employees, Inc. (Pruski, Jacek) (Entered: 11/14/2025)

NOTICE of Appearance by Charlotte Kamai on behalf of American Federation of Government Employees, AFL-CIO, American Federation of State, County and Municipal Employees, AFL-CIO, National Association of Government Employees, Inc. (Kamai, Charlotte) (Entered: 11/17/2025)

Consent MOTION for Leave to File Excess Pages by American Federation of Government Employees, AFL-CIO, American Federation of State, County and Municipal Employees, AFL-CIO, National Association of Government Employees, Inc..(Kamai, Charlotte) (Entered: 11/17/2025)

MOTION for Leave to File Nonparty Declarations Under Pseudonyms by American Federation of Government Employees, AFL-CIO, American Federation of State, County and Municipal Employees, AFL-CIO, National Association of Government Employees, Inc.. (Attachments: # 1 Proposed Order)(Kamai, Charlotte) (Entered: 11/17/2025)

DECLARATION re 33 MOTION for Leave to File Nonparty Declarations Under Pseudonyms by American Federation of Government Employees, AFL-CIO, American Federation of State, County and Municipal Employees, AFL-CIO, National Association of Government Employees, Inc.. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit I, # 10 Exhibit J, # 11 Exhibit K, # 12 Exhibit L, # 13 Exhibit M, # 14 Exhibit N)(Kamai, Charlotte) (Entered: 11/17/2025)

NOTICE of Appearance by Elena Goldstein on behalf of American Federation of Government Employees, AFL-CIO, American Federation of State, County and Municipal Employees, AFL-CIO, National Association of Government Employees, Inc. (Goldstein, Elena) (Entered: 11/17/2025)

NOTICE of Appearance by Warren Andrew Braunig on behalf of American Federation of Government Employees, AFL-CIO, American Federation of State, County and Municipal Employees, AFL-CIO, National Association of Government Employees, Inc. (Braunig, Warren) (Entered: 11/17/2025)

NOTICE of Appearance by Cara Meyer on behalf of American Federation of Government Employees, AFL-CIO, American Federation of State, County and Municipal Employees, AFL-CIO, National Association of Government Employees, Inc. (Meyer, Cara) (Entered: 11/17/2025)

NOTICE of Appearance by Edward Webb Lyons on behalf of American Federation of Government Employees, AFL-CIO, American Federation of State, County and Municipal Employees, AFL-CIO, National Association of Government Employees, Inc. (Lyons, Edward) (Entered: 11/18/2025)

MOTION for Preliminary Injunction and for Stay Under 5 USC § 705 by American Federation of Government Employees, AFL-CIO, American Federation of State, County and Municipal Employees, AFL-CIO, National Association of Government Employees, Inc..(Braunig, Warren) (Entered: 11/19/2025)

MEMORANDUM in Support re 39 MOTION for Preliminary Injunction and for Stay Under 5 USC § 705 filed by American Federation of Government Employees, AFL-CIO, American Federation of State, County and Municipal Employees, AFL-CIO, National Association of Government Employees, Inc.. (Braunig, Warren) (Main Document 40 replaced on 11/20/2025) (FGD). (Entered: 11/19/2025)

Proposed Document(s) submitted by American Federation of Government Employees, AFL-CIO, American Federation of State, County and Municipal Employees, AFL-CIO, National Association of Government Employees, Inc.. Document received: Proposed Order Granting Motion for Stay Under 5 U.S.C. 705 and for Preliminary Injunction 39 . (Braunig, Warren) (Entered: 11/19/2025)

Judge George A. O'Toole, Jr: ELECTRONIC ORDER entered GRANTING 32 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. (JMF) (Entered: 11/19/2025)

AFFIDAVIT of Cara R. Meyer in Support re 39 MOTION for Preliminary Injunction and for Stay Under 5 USC § 705 filed by American Federation of Government Employees, AFL-CIO, American Federation of State, County and Municipal Employees, AFL-CIO, National Association of Government Employees, Inc.. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit I, # 10 Exhibit J, # 11 Exhibit K, # 12 Exhibit L, # 13 Exhibit M, # 14 Exhibit N, # 15 Exhibit O, # 16 Exhibit P, # 17 Exhibit Q, # 18 Exhibit R, # 19 Exhibit S, # 20 Exhibit T, # 21 Exhibit U, # 22 Exhibit V, # 23 Exhibit W)(Braunig, Warren) (Entered: 11/19/2025)

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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6 Exhibit F

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7 Exhibit G

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8 Exhibit H

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9 Exhibit I

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10 Exhibit J

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11 Exhibit K

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12 Exhibit L

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13 Exhibit M

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14 Exhibit N

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15 Exhibit O

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16 Exhibit P

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17 Exhibit Q

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18 Exhibit R

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19 Exhibit S

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20 Exhibit T

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21 Exhibit U

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22 Exhibit V

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23 Exhibit W

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AFFIDAVIT of Everett Kelley in Support re 39 MOTION for Preliminary Injunction and for Stay Under 5 USC § 705 filed by American Federation of Government Employees, AFL-CIO, American Federation of State, County and Municipal Employees, AFL-CIO, National Association of Government Employees, Inc.. (Braunig, Warren) (Entered: 11/19/2025)

AFFIDAVIT of Lee Sutton in Support re 39 MOTION for Preliminary Injunction and for Stay Under 5 USC § 705 filed by American Federation of Government Employees, AFL-CIO, American Federation of State, County and Municipal Employees, AFL-CIO, National Association of Government Employees, Inc.. (Braunig, Warren) (Entered: 11/19/2025)

AFFIDAVIT of Fernando Colon in Support re 39 MOTION for Preliminary Injunction and for Stay Under 5 USC § 705 filed by American Federation of Government Employees, AFL-CIO, American Federation of State, County and Municipal Employees, AFL-CIO, National Association of Government Employees, Inc.. (Braunig, Warren) (Entered: 11/19/2025)

AFFIDAVIT of Federal Worker 1 in Support re 39 MOTION for Preliminary Injunction and for Stay Under 5 USC § 705 filed by American Federation of Government Employees, AFL-CIO, American Federation of State, County and Municipal Employees, AFL-CIO, National Association of Government Employees, Inc.. (Braunig, Warren) (Entered: 11/19/2025)

AFFIDAVIT of Federal Worker 2 in Support re 39 MOTION for Preliminary Injunction and for Stay Under 5 USC § 705 filed by American Federation of Government Employees, AFL-CIO, American Federation of State, County and Municipal Employees, AFL-CIO, National Association of Government Employees, Inc.. (Braunig, Warren) (Entered: 11/19/2025)

AFFIDAVIT of Federal Worker 3 in Support re 39 MOTION for Preliminary Injunction and for Stay Under 5 USC § 705 filed by American Federation of Government Employees, AFL-CIO, American Federation of State, County and Municipal Employees, AFL-CIO, National Association of Government Employees, Inc.. (Braunig, Warren) (Entered: 11/19/2025)

AFFIDAVIT of Federal Worker 4 in Support re 39 MOTION for Preliminary Injunction and for Stay Under 5 USC § 705 filed by American Federation of Government Employees, AFL-CIO, American Federation of State, County and Municipal Employees, AFL-CIO, National Association of Government Employees, Inc.. (Braunig, Warren) (Entered: 11/19/2025)

Order on Motion for Leave to File Excess Pages

SUMMONS Returned Executed as to US Attorney by American Federation of Government Employees, AFL-CIO, National Association of Government Employees, Inc., American Federation of State, County and Municipal Employees, AFL-CIO. Scott Kupor served on 11/10/2025, answer due 1/9/2026; Office of Personnel Management served on 11/10/2025, answer due 1/9/2026; The United States of America served on 11/10/2025, answer due 1/9/2026. (Hoshijima, Tsuki) (Entered: 11/20/2025)

SUMMONS Returned Executed (Hoshijima, Tsuki) (Entered: 11/20/2025)

SUMMONS Returned Executed (Hoshijima, Tsuki) (Entered: 11/20/2025)

SUMMONS Returned Executed (Hoshijima, Tsuki) (Entered: 11/20/2025)

SUMMONS Returned Executed by American Federation of Government Employees, AFL-CIO, National Association of Government Employees, Inc., American Federation of State, County and Municipal Employees, AFL-CIO. (Hoshijima, Tsuki) (Entered: 11/20/2025)

NOTICE of Appearance by Ryan Underwood on behalf of Scott Kupor, Office of Personnel Management, The United States of America (Underwood, Ryan) (Entered: 11/24/2025)

RESPONSE to Motion re 39 MOTION for Preliminary Injunction and for Stay Under 5 USC § 705 filed by Scott Kupor, Office of Personnel Management, The United States of America. (Underwood, Ryan) (Entered: 12/03/2025)

MOTION for Leave to File a Reply Brief - Dkt. 57 by American Federation of Government Employees, AFL-CIO, American Federation of State, County and Municipal Employees, AFL-CIO, National Association of Government Employees, Inc.. (Attachments: # 1 Exhibit A)(Braunig, Warren) (Entered: 12/10/2025)

Reply to Response to Motion

Order on Motion for Leave to File Document