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1
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COMPLAINT for Declaratory and Injunctive Relief against DEPARTMENT OF DEFENSE, PETE HEGSETH, SEAN PARNELL ( Filing fee $ 405 receipt number ADCDC-12113704) filed by THE NEW YORK TIMES COMPANY, JULIAN E. BARNES. (Attachments: # 1 Exhibit A - Oct. 6, 2025 Policy, # 2 Exhibit B - RCFP Letter to Parnell, # 3 Exhibit C - Parnell Letter to RCFP, # 4 Exhibit D - Redlined Acknowledgment, # 5 Exhibit E - Sept. 18, 2025 Policy, # 6 Exhibit F - Updated Physical Control Measures, # 7 Civil Cover Sheet, # 8 Summons - Attorney General Pamela J. Bondi, # 9 Summons - Department of Defense a/k/a Department of War, # 10 Summons - Pete Hegseth, in his official capacity as Secretary of Defense, # 11 Summons - Sean Parnell, in his official capacity as Chief Pentagon Spokesman, # 12 Summons - Jeanine F. Pirro, U.S. Attorney for the District of Columbia)(Boutrous, Theodore) (Entered: 12/04/2025)
1 Exhibit A - Oct. 6, 2025 Policy
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2 Exhibit B - RCFP Letter to Parnell
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3 Exhibit C - Parnell Letter to RCFP
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4 Exhibit D - Redlined Acknowledgment
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5 Exhibit E - Sept. 18, 2025 Policy
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6 Exhibit F - Updated Physical Control Measures
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7 Civil Cover Sheet
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8 Summons - Attorney General Pamela J. Bondi
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9 Summons - Department of Defense a/k/a Department of War
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10 Summons - Pete Hegseth, in his official capacity as Secretary of Defense
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11 Summons - Sean Parnell, in his official capacity as Chief Pentagon Spokesman
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12 Summons - Jeanine F. Pirro, U.S. Attorney for the District of Columbia
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Dec. 4, 2025
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Dec. 4, 2025
Clearinghouse
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2
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LCvR 26.1 CERTIFICATE OF DISCLOSURE of Corporate Affiliations and Financial Interests by THE NEW YORK TIMES COMPANY (Boutrous, Theodore) (Entered: 12/04/2025)
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Dec. 4, 2025
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Dec. 4, 2025
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3
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NOTICE of Appearance by Lee Ross Crain on behalf of JULIAN E. BARNES, THE NEW YORK TIMES COMPANY (Crain, Lee) (Entered: 12/04/2025)
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Dec. 4, 2025
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Dec. 4, 2025
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4
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NOTICE of Appearance by KatieLynn Boyd Townsend on behalf of JULIAN E. BARNES, THE NEW YORK TIMES COMPANY (Townsend, KatieLynn) (Entered: 12/04/2025)
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Dec. 4, 2025
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Dec. 4, 2025
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5
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SUMMONS (5) Issued Electronically as to All Defendants, U.S. Attorney and U.S. Attorney General (Attachments: # 1 Notice and Consent)(zhcn) (Entered: 12/04/2025)
1 Notice and Consent
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Dec. 4, 2025
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Dec. 4, 2025
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6
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MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Susan M. Pelletier, Filing fee $ 100, receipt number ADCDC-12115912. Fee Status: Fee Paid. by JULIAN E. BARNES, NEW YORK TIMES COMPANY. (Attachments: # 1 Declaration of Susan M. Pelletier in Support of Motion for Admission Pro Hac Vice, # 2 Exhibit B - District of Columbia Certificate of Good Standing, # 3 Text of Proposed Order for Admission Pro Hac Vice of Susan M. Pelletier)(Boutrous, Theodore) (Entered: 12/04/2025)
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Dec. 4, 2025
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Dec. 4, 2025
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Case Assigned/Reassigned
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Dec. 4, 2025
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Dec. 4, 2025
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Case Assigned to Judge Paul L. Friedman. (zhcn)
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Dec. 4, 2025
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Dec. 4, 2025
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7
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NOTICE of Appearance by Michael Benjamin Bruns on behalf of All Defendants (Bruns, Michael) (Entered: 12/05/2025)
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Dec. 5, 2025
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Dec. 5, 2025
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Order on Motion for Leave to Appear Pro Hac Vice
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Dec. 5, 2025
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Dec. 5, 2025
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MINUTE ORDER granting 6 Motion for Leave to Appear Pro Hac Vice. Counsel should register for e-filing via PACER and file a notice of appearance pursuant to LCvR 83.6(a). Click for instructions. Signed by Judge Paul L. Friedman on December 5, 2025. (lcao)
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Dec. 5, 2025
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Dec. 5, 2025
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8
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Joint MOTION for Briefing Schedule / JOINT MOTION FOR ENTRY OF A BRIEFING SCHEDULE FOR EXPEDITED SUMMARY JUDGMENT AND OTHER RELATED RELIEF by JULIAN E. BARNES, NEW YORK TIMES COMPANY. (Boutrous, Theodore) (Entered: 12/17/2025)
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Dec. 17, 2025
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Dec. 17, 2025
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9
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NOTICE of Production of Administrative Record by DEPARTMENT OF DEFENSE, PETE HEGSETH, SEAN PARNELL (Attachments: # 1 Affidavit certifying AR, # 2 Exhibit AR Index)(Bruns, Michael) (Entered: 12/23/2025)
1 Affidavit certifying AR
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2 Exhibit AR Index
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Dec. 23, 2025
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Dec. 23, 2025
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.Order
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Dec. 23, 2025
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Dec. 23, 2025
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MINUTE ORDER granting the parties' 8 Joint Motion for Entry of a Briefing Schedule. Defendants shall serve the administrative record on plaintiffs on or before December 23, 2025. Plaintiffs shall file their motion for summary judgment on or before January 5, 2026. Plaintiff-side amicus briefs, if any, shall be filed on or before January 15, 2026. Defendants shall file their response and cross-motion for summary judgment on or before January 30, 2026. Defendant-side amicus briefs, if any, shall be filed on or before February 10, 2026. Plaintiffs shall file their response and reply on or before February 18, 2026. Defendants shall file their reply on or before February 27, 2026. Defendants' deadline to answer the complaint shall be extended until 21 days after the Court rules on the parties' cross-motions for summary judgment. The Court dispenses with the requirement that the parties appear for a Rule 26(f) conference. Signed by Judge Paul L. Friedman on December 23, 2025. (lcao)
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Dec. 23, 2025
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Dec. 23, 2025
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MINUTE ORDER: it is hereby ORDERED that the parties shall appear for oral argument on their cross-motions for summary judgment at 10:00 a.m. on Friday, March 6, 2026, in Courtroom 29 in the William B. Bryant Annex to the E. Barrett Prettyman Courthouse at 333 Constitution Avenue N.W., Washington, D.C. 20001. SO ORDERED. Signed by Judge Paul L. Friedman on December 23, 2025. (lcao)
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Dec. 23, 2025
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Dec. 23, 2025
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Order
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Dec. 23, 2025
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Dec. 23, 2025
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Set/Reset Deadlines/Hearings
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Dec. 29, 2025
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Dec. 29, 2025
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Set/Reset Deadlines/Hearings: Amicus Brief due by 1/15/2026. Summary Judgment motions due by 1/5/2026. Response to Motion for Summary Judgment due by 1/30/2026. Reply to Motion for Summary Judgment due by 2/18/2026. Cross Motions due by 1/30/2026. Response to Cross Motions due by 2/18/2026. Reply to Cross Motions due by 2/27/2026. Motion Hearing set for 3/6/2026 at 10:00 AM in Courtroom 29A- In Person before Judge Paul L. Friedman. (tj)
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Dec. 29, 2025
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Dec. 29, 2025
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10
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MOTION for Summary Judgment and Declaratory and Permanent Injunctive Relief by JULIAN E. BARNES, NEW YORK TIMES COMPANY. (Attachments: # 1 Memorandum in Support, # 2 Text of Proposed Order, # 3 Declaration of Julian E. Barnes, # 4 Declaration of Robert Burns, # 5 Declaration of Richard W. Stevenson, # 6 Declaration of Pete Williams, # 7 Exhibit A, # 8 Declaration of Theodore J.Boutrous, Jr., # 9 Exhibit 1, # 10 Exhibit 2, # 11 Exhibit 3, # 12 Exhibit 4, # 13 Exhibit 5, # 14 Exhibit 6, # 15 Exhibit 7, # 16 Exhibit 8, # 17 Exhibit 9, # 18 Exhibit 10, # 19 Exhibit 11, # 20 Exhibit 12, # 21 Exhibit 13, # 22 Exhibit 14, # 23 Exhibit 15, # 24 Exhibit 16, # 25 Exhibit 17, # 26 Exhibit 18, # 27 Exhibit 19, # 28 Exhibit 20, # 29 Exhibit 21, # 30 Exhibit 22, # 31 Exhibit 23, # 32 Exhibit 24, # 33 Exhibit 25, # 34 Exhibit 26, # 35 Exhibit 27, # 36 Statement of Facts)(Boutrous, Theodore) Modified on 1/7/2026, sealed exhibit pursuant to Theodore Boutrous (mg). (Entered: 01/05/2026)
1 Memorandum in Support
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2 Text of Proposed Order
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3 Declaration of Julian E. Barnes
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4 Declaration of Robert Burns
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5 Declaration of Richard W. Stevenson
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6 Declaration of Pete Williams
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7 Exhibit A
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8 Declaration of Theodore J.Boutrous, Jr.
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9 Exhibit 1
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10 Exhibit 2
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11 Exhibit 3
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12 Exhibit 4
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13 Exhibit 5
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14 Exhibit 6
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15 Exhibit 7
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16 Exhibit 8
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17 Exhibit 9
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18 Exhibit 10
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19 Exhibit 11
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20 Exhibit 12
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21 Exhibit 13
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22 Exhibit 14
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23 Exhibit 15
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24 Exhibit 16
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25 Exhibit 17
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26 Exhibit 18
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27 Exhibit 19
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28 Exhibit 20
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29 Exhibit 21
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30 Exhibit 22
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31 Exhibit 23
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32 Exhibit 24
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33 Exhibit 25
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34 Exhibit 26
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35 Exhibit 27
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36 Statement of Facts
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Jan. 5, 2026
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Jan. 5, 2026
Clearinghouse
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11
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NOTICE of Appearance by Susan Pelletier on behalf of JULIAN E. BARNES, NEW YORK TIMES COMPANY (Pelletier, Susan) (Entered: 01/06/2026)
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Jan. 6, 2026
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Jan. 6, 2026
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12
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DECLARATION of Pete Williams in Support of Motion for Summary Judgment and Declaratory and Permanent Injunctive Relief by JULIAN E. BARNES, NEW YORK TIMES COMPANY re 10 MOTION for Summary Judgment and Declaratory and Permanent Injunctive Relief. (Attachments: # 1 Exhibit A [Redacted])(Boutrous, Theodore) (Entered: 01/07/2026)
1 Exhibit A [Redacted]
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Jan. 7, 2026
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Jan. 7, 2026
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13
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AMICUS BRIEF in support of plaintiff's motion for summary judgment by STATE OF NEW YORK. (Murdukhayeva, Ester) (Entered: 01/15/2026)
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Jan. 15, 2026
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Jan. 15, 2026
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14
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NOTICE of Appearance by David A. Schulz on behalf of Pentagon Press Association (Schulz, David) (Entered: 01/15/2026)
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Jan. 15, 2026
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Jan. 15, 2026
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15
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Unopposed MOTION for Leave to File Amicus Brief by Pentagon Press Association. (Attachments: # 1 Exhibit Proposed Amicus Brief, # 2 Exhibit Text of Proposed Order)(Schulz, David) (Entered: 01/15/2026)
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Jan. 15, 2026
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Jan. 15, 2026
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16
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NOTICE of Appearance by Bruce D. Brown on behalf of The Reporters Committee for Freedom of the Press, The Reporters Committee for Freedom of the Press and 23 Other Media Organizations (Brown, Bruce) (Entered: 01/15/2026)
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Jan. 15, 2026
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Jan. 15, 2026
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17
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Consent MOTION for Leave to File Amicus Brief by REPORTERS COMMITTEE FOR FREEDOM OF THE PRESS. (Attachments: # 1 Memorandum in Support Proposed Amici Curiae Brief)(Brown, Bruce) (Entered: 01/15/2026)
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Jan. 15, 2026
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Jan. 15, 2026
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18
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Consent MOTION for Leave to File Amicus Briefin Support of Plaintiffs by AMERICAN CIVIL LIBERTIES UNION OF THE DISTRICT OF COLUMBIA, AMERICAN CIVIL LIBERTIES UNION. (Attachments: # 1 Proposed Amicus Brief, # 2 Text of Proposed Order)(Michelman, Scott) (Entered: 01/15/2026)
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Jan. 15, 2026
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Jan. 15, 2026
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Order on Motion for Leave to File Amicus Brief
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Jan. 16, 2026
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Jan. 16, 2026
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MINUTE ORDER granting the Pentagon Press Association's 15 Unopposed Motion for Leave to File Amicus Curiae Brief in Support of Plaintiffs' Motion for Summary Judgment. The Clerk of Court is directed to file on the docket the Proposed Amicus Brief that is attached to the motion [15-1]. Signed by Judge Paul L. Friedman on January 16, 2026. (lcao)
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Jan. 16, 2026
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Jan. 16, 2026
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MINUTE ORDER granting the Reporters Committee for Freedom of the Press and 23 Other Media Organizations' 17 Consent Motion for Leave to File Amicus Curiae Brief in Support of Plaintiffs' Motion for Summary Judgment. The Clerk of Court is directed to file on the docket the Proposed Amicus Brief that is attached to amici's motion [17-1]. Signed by Judge Paul L. Friedman on January 16, 2026. (lcao)
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Jan. 16, 2026
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Jan. 16, 2026
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MINUTE ORDER granting the American Civil Liberties Union and the American Civil Liberties Union of the District of Columbia's 18 Consent Motion for Leave to File Amicus Curiae Brief in Support of Plaintiffs' Motion for Summary Judgment. The Clerk of Court is directed to file on the docket the Proposed Amicus Brief that is attached to amici's motion [18-1]. Signed by Judge Paul L. Friedman on January 16, 2026. (lcao)
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Jan. 16, 2026
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Jan. 16, 2026
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19
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AMICUS BRIEF by PENTAGON PRESS ASSOCIATION. (zjm) (Entered: 01/26/2026)
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Jan. 26, 2026
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Jan. 26, 2026
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20
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AMICUS BRIEF by REPORTERS COMMITTEE FOR FREEDOM OF THE PRESS. (zjm) (Entered: 01/26/2026)
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Jan. 26, 2026
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Jan. 26, 2026
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21
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AMICUS BRIEF by AMERICAN CIVIL LIBERTIES UNION, AMERICAN CIVIL LIBERTIES UNION OF THE DISTRICT OF COLUMBIA. (zjm) (Entered: 01/26/2026)
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Jan. 26, 2026
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Jan. 26, 2026
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22
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Cross MOTION for Summary Judgment by DEPARTMENT OF DEFENSE, PETE HEGSETH, SEAN PARNELL. (Attachments: # 1 Memorandum in Support, # 2 Statement of Facts, # 3 Text of Proposed Order)(Bruns, Michael) (Entered: 01/30/2026)
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Jan. 30, 2026
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Jan. 30, 2026
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23
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Memorandum in opposition to re 10 MOTION for Summary Judgment and Declaratory and Permanent Injunctive Relief MOTION for Permanent Injunction filed by DEPARTMENT OF DEFENSE, PETE HEGSETH, SEAN PARNELL. (Bruns, Michael) (Entered: 01/30/2026)
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Jan. 30, 2026
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Jan. 30, 2026
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24
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Memorandum in opposition to re 22 Cross MOTION for Summary Judgment filed by JULIAN E. BARNES, NEW YORK TIMES COMPANY. (Attachments: # 1 Declaration /Supplemental Declaration of Theodore J. Boutrous, Jr. in Opposition to Defendants' Cross-Motion for Summary Judgment, # 2 Exhibit 1, # 3 Exhibit 2, # 4 Exhibit 3, # 5 Exhibit 4, # 6 Exhibit 5, # 7 Exhibit 6, # 8 Exhibit 7)(Boutrous, Theodore) (Entered: 02/18/2026)
1 Declaration /Supplemental Declaration of Theodore J. Boutrous, Jr. in Oppositio
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2 Exhibit 1
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3 Exhibit 2
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4 Exhibit 3
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5 Exhibit 4
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6 Exhibit 5
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7 Exhibit 6
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8 Exhibit 7
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Feb. 18, 2026
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Feb. 18, 2026
RECAP
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25
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REPLY to opposition to motion re 10 Motion for Summary Judgment,,,,, Motion for Permanent Injunction,,,, filed by JULIAN E. BARNES, NEW YORK TIMES COMPANY. (Boutrous, Theodore) (Entered: 02/18/2026)
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Feb. 18, 2026
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Feb. 18, 2026
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26
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ORDER directing parties to file a joint report on or before March 4, 2026. See Order for details. Signed by Judge Paul L. Friedman on February 23, 2026. (lccm) (Entered: 02/23/2026)
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Feb. 23, 2026
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Feb. 23, 2026
RECAP
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Set/Reset Deadlines
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Feb. 23, 2026
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Feb. 23, 2026
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Set/Reset Deadlines: Joint Report due by 3/4/2026. (tj)
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Feb. 23, 2026
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Feb. 23, 2026
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27
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REPLY to opposition to motion re 22 Motion for Summary Judgment filed by DEPARTMENT OF DEFENSE, PETE HEGSETH, SEAN PARNELL. (Attachments: # 1 Declaration of Christopher C. Garver)(Bruns, Michael) (Entered: 02/27/2026)
1 Declaration of Christopher C. Garver
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Feb. 27, 2026
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Feb. 27, 2026
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28
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Joint STATUS REPORT re: March 6, 2026 Hearing on Cross-Motion for Summary Judgment [ECF. 26] by JULIAN E. BARNES, NEW YORK TIMES COMPANY. (Boutrous, Theodore) (Entered: 03/03/2026)
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March 3, 2026
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March 3, 2026
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MINUTE ORDER: the Court will connect the public-access telephone line for the motions hearing scheduled for March 6, 2026 at 10:00 a.m. Any member of the public or media may access the public-access line by dialing (833) 990-9400 and using meeting ID 492497252. As a reminder, any use of the public-access telephone line requires adherence to the general prohibition against recording, livestreaming, and rebroadcasting of court proceedings (including those held by videoconference). 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 other sanctions deemed necessary by the Court. Signed by Judge Paul L. Friedman on March 3, 2026. (lccm)
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March 3, 2026
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March 3, 2026
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.Order
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March 3, 2026
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March 3, 2026
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29
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JOINT APPENDIX pursuant to LCvR 7 by JULIAN E. BARNES, NEW YORK TIMES COMPANY. (Boutrous, Theodore) (Entered: 03/04/2026)
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March 4, 2026
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March 4, 2026
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MINUTE ORDER: The Court adopts the proposal for the March 6, 2026 hearing on the parties' cross-motions for summary judgment outlined in the parties' 28 Joint Status Report. Signed by Judge Paul L. Friedman on March 5, 2026. (lccm)
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March 5, 2026
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March 5, 2026
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.Order
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March 5, 2026
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March 5, 2026
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Minute Entry for Motions Hearing held on 3/6/2026 before Judge Paul L. Friedman: The matter was before the court on the parties' cross-motions for summary judgment. Theodore J. Boutrous, Jr., KatieLynn B. Townsend, and Susan Pelletier present on behalf of Plaintiffs. David A. Schulz present on behalf of Pentagon Press Association. Michael B. Bruns and Timothy Parlatore present on behalf of Defendants. The matters were fully briefed, argued, and taken under advisement. As stated from the bench, the parties shall file revised proposed orders of relief by the end of day, Monday, March 9, 2026. (Court Reporter Lorraine Herman)(mhp)
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March 6, 2026
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March 6, 2026
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1 - Terminate Motion and R&R Deadlines/Hearings AND 1 - Terminate Scheduling Order Deadlines AND 1 - Terminate Trial Management Order Deadlines AND Motion Hearing
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March 6, 2026
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March 6, 2026
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30
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NOTICE of Proposed Order by DEPARTMENT OF DEFENSE, PETE HEGSETH, SEAN PARNELL re Motion Hearing,,, Terminate Motion and R&R Deadlines/Hearings,,, Terminate Scheduling Order Deadlines,,, Terminate Trial Management Order Deadlines,, (Bruns, Michael) (Entered: 03/09/2026)
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March 9, 2026
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March 9, 2026
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31
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NOTICE of Proposed Order / FILING OF REVISED PROPOSED ORDER by JULIAN E. BARNES, NEW YORK TIMES COMPANY (Attachments: # 1 Text of Proposed Order - Revised Proposed Order, # 2 Addendum A)(Boutrous, Theodore) (Entered: 03/09/2026)
1 Text of Proposed Order - Revised Proposed Order
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2 Addendum A
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March 9, 2026
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March 9, 2026
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32
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NOTICE of Clarification Regarding Statements Made at Oral Argument by DEPARTMENT OF DEFENSE, PETE HEGSETH, SEAN PARNELL (Bruns, Michael) (Entered: 03/12/2026)
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March 12, 2026
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March 12, 2026
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33
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RESPONSE re 32 Notice (Other) /Plaintiffs' Response to Defendants' "Notice of Clarification" filed by JULIAN E. BARNES, NEW YORK TIMES COMPANY. (Boutrous, Theodore) (Entered: 03/13/2026)
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March 13, 2026
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March 13, 2026
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34
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ORDER granting plaintiffs' 10 Motion for Summary Judgment and denying defendants' 22 Cross Motion for Summary Judgment. Defendants shall file a status report on or before March 27, 2026. See Order for details. Signed by Judge Paul L. Friedman on March 20, 2026. (lccm) (Entered: 03/20/2026)
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March 20, 2026
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March 20, 2026
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35
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OPINION granting plaintiffs' 10 Motion for Summary Judgment and denying defendants' 22 Cross Motion for Summary Judgment. Defendants shall file a status report on or before March 27, 2026. See Opinion for details. Signed by Judge Paul L. Friedman on March 20, 2026. (lccm) (Entered: 03/20/2026)
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March 20, 2026
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March 20, 2026
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