Case: Withrow v. United States of America

Withrow v. United States of America et al.

COMPLAINT against TRAVIS ADKINS, EDDY ARRIOLA, PAUL S. ATKINS, SCOTT BESSENT, FRANK J. BISIGNANO, BEN BLACK, PAM BONDI, RODNEY BOYD, SHANA M. BROUSSARD, CRAIG T. BROWN, DOUG BURGUM, BRENDON CARR, LORI CHAVEZ-DEREMER, ERHARD R. CHORLE, DOUGLAS A. COLLINS, ANNA DAVIS, JANET DHILLON, SEAN DUFFY(in his official capacity as Secretary of the Department of Transportation), SEAN DUFFY(in his official capacity as Acting Administrator of the National Aeronautics and Space Administration), PETER A. FELDMAN, ANDREW FERGUSON, ANDREW FOIS, TULSI GABBARD, ANDREA GACKI, ROCHELLE GARZA, GENERAL SERVICES ADMINISTRATION, MICHAEL F. GERBER, JONATHAN V. GOULD, JAMIESON GREER, TIMOTHY GRIBBEN, JEFFERY HALL, THOMAS R. HARDY, ROGER HARRIS, KYLE S. HAUPTMAN, PETE HEGSETH, HEATHER M. HILL, TRAVIS HILL, JENNIFER HOMENDY, MARY LU JORDAN, JOHN JOVANOVIC, AMY A. KARPEL, ROBERT KENNEDY, HENRY J. KERNER, COLLEEN DUFFY KIKO, SCOTT KUPOR, KARI LAKE, PATRICIA L. LEE, KELLY LOEFFLER, ANDREA R. LUCAS, HOWARD LUTNICK, MICHAEL MCDONALD, LINDA E. MCMAHON, KRISTIE MCNALLY, DON MOUL, KRISTI NOEM, OFFICE OF PERSONNEL MANAGEMENT, JEROME H. POWELL, DAVID PROUTY, JOHN RATCLIFFE, MICHAEL RIGAS, BROOKE L. ROLLINS, MARCO RUBIO(in his official capacity as Secretary of the Department of State), MARCO RUBIO(in his official capacity as Acting Archivist of the United States of the National Archives and Records Administration), MARY G. RYAN, WILLIAM SCHARF, LOREN J. SCIURBA, PAUL SHEA, MICHAEL D. SMITH, JONATHAN L. SNARE, LOUISE SOLA, PATRICIA A. SOLIMENE, DAVID STEINER, BRIAN W. STONE, LOREN E. SWEATT, ROBERT G. TAUB, SCOTT TURNER, ERIC UELAND, UNITED STATES OF AMERICA, RAHUL VARMA, RUSSELL VOUGHT(in his official capacity as Acting Administrator of the United States Agency for International Development), RUSSELL VOUGHT(in his official capacity as Acting Director of the Consumer Financial Protection Board), CHRIS WRIGHT, DAVID A. WRIGHT, LEE ZELDIN ( Filing fee $ 405 receipt number ADCDC-12091874) filed by LEANNE WITHROW. (Attachments: # 1 Civil Cover Sheet, # 2 Summons)(Gleklen, Jonathan) (Entered: 11/20/2025)

1 Civil Cover Sheet

View on PACER

2 Summons

View on PACER

MOTION to Certify Class by LEANNE WITHROW. (Attachments: # 1 Declaration Ex 1 - Gleklen Declaration, # 2 Exhibit Ex A to Gleklen Declaration, # 3 Exhibit Ex B to Gleklen Declaration, # 4 Exhibit Ex C to Gleklen Declaration, # 5 Exhibit Ex D to Gleklen Declaration, # 6 Exhibit Ex E to Gleklen Declaration, # 7 Exhibit Ex F to Gleklen Declaration, # 8 Exhibit Ex G to Gleklen Declaration, # 9 Exhibit Ex H to Gleklen Declaration, # 10 Exhibit Ex I to Gleklen Declaration, # 11 Exhibit Ex J to Gleklen Declaration, # 12 Exhibit Ex K to Gleklen Declaration, # 13 Exhibit Ex L to Gleklen Declaration, # 14 Exhibit Ex M to Gleklen Declaration, # 15 Exhibit Ex N to Gleklen Declaration, # 16 Exhibit Ex O to Gleklen Declaration, # 17 Declaration Ex 2 - Withrow Declaration, # 18 Declaration Ex 3 - Kniznik Declaration, # 19 Declaration Ex 4 - Second Gleklen Declaration, # 20 Declaration Ex 5 - Golden Declaration, # 21 Declaration Ex 6 - Perloff Declaration, # 22 Declaration Ex 7 - Garcia Declaration, # 23 Text of Proposed Order Proposed Order)(Gleklen, Jonathan) (Entered: 11/20/2025)

1 Declaration Ex 1 - Gleklen Declaration

View on PACER

2 Exhibit Ex A to Gleklen Declaration

View on PACER

3 Exhibit Ex B to Gleklen Declaration

View on PACER

4 Exhibit Ex C to Gleklen Declaration

View on PACER

5 Exhibit Ex D to Gleklen Declaration

View on PACER

6 Exhibit Ex E to Gleklen Declaration

View on PACER

7 Exhibit Ex F to Gleklen Declaration

View on PACER

8 Exhibit Ex G to Gleklen Declaration

View on PACER

9 Exhibit Ex H to Gleklen Declaration

View on PACER

10 Exhibit Ex I to Gleklen Declaration

View on PACER

11 Exhibit Ex J to Gleklen Declaration

View on PACER

12 Exhibit Ex K to Gleklen Declaration

View on PACER

13 Exhibit Ex L to Gleklen Declaration

View on PACER

14 Exhibit Ex M to Gleklen Declaration

View on PACER

15 Exhibit Ex N to Gleklen Declaration

View on PACER

16 Exhibit Ex O to Gleklen Declaration

View on PACER

17 Declaration Ex 2 - Withrow Declaration

View on PACER

18 Declaration Ex 3 - Kniznik Declaration

View on PACER

19 Declaration Ex 4 - Second Gleklen Declaration

View on PACER

20 Declaration Ex 5 - Golden Declaration

View on PACER

21 Declaration Ex 6 - Perloff Declaration

View on PACER

22 Declaration Ex 7 - Garcia Declaration

View on PACER

23 Text of Proposed Order Proposed Order

View on PACER

NOTICE of Appearance by Scott Michelman on behalf of All Plaintiffs (Michelman, Scott) (Entered: 11/20/2025)

NOTICE of Appearance by Michael Krevans Perloff on behalf of All Plaintiffs (Perloff, Michael) (Entered: 11/20/2025)

SEALED DOCUMENT filed by LEANNE WITHROW(This document is SEALED and only available to authorized persons.)(Perloff, Michael) (Entered: 11/20/2025)

NOTICE OF ASSIGNMENT OF CASE TO U.S. MAGISTRATE JUDGE. All parties must consent to or decline the jurisdiction of the Magistrate Judge no later than twenty-one (21) days following the date on which the last defendant to respond to the Complaint files an Answer or motion under Rule 12. The consent or declination form is attached. (zhcn) (Entered: 11/21/2025)

NOTICE of Appearance by Kaitlyn Golden on behalf of LEANNE WITHROW (Golden, Kaitlyn) (Entered: 11/21/2025)

NOTICE of Appearance by Madeline Gitomer on behalf of LEANNE WITHROW (Gitomer, Madeline) (Entered: 11/21/2025)

NOTICE of Appearance by Paul R.Q. Wolfson on behalf of LEANNE WITHROW (Wolfson, Paul) (Entered: 11/21/2025)

Notice of Error- New Case

NOTICE OF NEW CASE ERROR regarding 1 Complaint. The following error(s) need correction: Invalid signature. Please file the signed Complaint using the event Errata. All filings must have an original signature or /s/ Attorney Name to represent an electronic signature of the filer. The filing attorney must sign the complaint. Jonathan Gleklen is the filing attorney. COMPLIANCE DEADLINE is by close of business today. This case will not proceed any further until all errors are satisfied. (zhcn)

Case Assigned/Reassigned

ERRATA by LEANNE WITHROW re 1 Complaint,,,,,,,,. (Gleklen, Jonathan) (Entered: 11/21/2025)

ERRATA Corrected Motion by LEANNE WITHROW re 4 Motion to Certify Class,,,,. (Gleklen, Jonathan) (Entered: 11/21/2025)

Case Assigned to Magistrate Judge Zia M. Faruqui. (zhcn)

SUMMONS (85) Issued Electronically as to All Defendants, U.S. Attorney and U.S. Attorney General (Attachments: # 1 Notice and Consent)(znmw) (Entered: 11/24/2025)

CERTIFICATE OF SERVICE by LEANNE WITHROW re 7 Errata Motion to Certify Class. (Gleklen, Jonathan) (Entered: 11/25/2025)

NOTICE of Appearance by Shana Knizhnik on behalf of All Plaintiffs (Knizhnik, Shana) (Entered: 12/02/2025)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed as to the United States Attorney. Date of Service Upon United States Attorney on 11/25/2025. Answer due for ALL FEDERAL DEFENDANTS by 1/24/2026. (Gleklen, Jonathan) (Entered: 12/05/2025)