Case: Richman v. United States

Richman v. United States of America

Richman v. United States of America

Richman v. United States of America

Richman v. United States of America

Richman v. United States of America

Richman v. United States of America

MOTION for Return of Property by DANIEL RICHMAN. (Attachments: # 1 Memorandum in Support, # 2 Civil Cover Sheet, # 3 Summons)(znmw) (Entered: 12/02/2025)

1 Memorandum in Support

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2 Civil Cover Sheet

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3 Summons

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SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by DANIEL RICHMAN. (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Memorandum in Support, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D)(znmw) (Entered: 12/02/2025)

Filing fee received: $ 52, receipt number: 210870. (znmw)

CERTIFICATE OF SERVICE by DANIEL RICHMAN re 1 MOTION for Return of Property (Corrected). (Hansen, Mark) (Entered: 12/02/2025)

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Nicholas J. Lewin, Filing fee $ 100, receipt number ADCDC-12110495. Fee Status: Fee Paid. by DANIEL RICHMAN. (Attachments: # 1 Declaration of Nicholas J. Lewin, # 2 Certificate of Good Standing, # 3 Text of Proposed Order)(Hansen, Mark) (Entered: 12/02/2025)

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Jonathan F. Bolz, Filing fee $ 100, receipt number ADCDC-12110506. Fee Status: Fee Paid. by DANIEL RICHMAN. (Attachments: # 1 Declaration of Jonathan F. Bolz, # 2 Certificate of Good Standing, # 3 Text of Proposed Order)(Hansen, Mark) (Entered: 12/02/2025)

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Jessie-Lauren Ratcliffe Pierce, Filing fee $ 100, receipt number ADCDC-12110509. Fee Status: Fee Paid. by DANIEL RICHMAN. (Attachments: # 1 Declaration of Jessie-Lauren Ratcliffe Pierce, # 2 Certificate of Good Standing, # 3 Text of Proposed Order)(Hansen, Mark) (Entered: 12/02/2025)

Filing Fee Received

MINUTE ORDER: The Court is in receipt of Petitioner Richman's 1 Motion for Return of Property, which was randomly assigned to this Court earlier this afternoon.Because the 1 Motion references and attaches as exhibits certain materials that are currently under seal, the accompanying 2 Motion for Leave to File Under Seal is GRANTED, the attached documents are PROVISIONALLY SEALED, and the Clerk of the Court is respectfully directed to docket the attachments at Dkt. No. 2, under seal, as Petitioner Richman's Sealed Motion and Exhibits, which shall remain under seal until further order of this Court. A redacted version of Petitioner Richman's Sealed Motion appears on the docket at Dkt. No. 1.Finally, Petitioner Richman's 1 Motion requests that this Court "issue a temporary restraining order enjoining the [G]overnment from using or relying on in any way" the materials at issue in his 1 Motion while this matter is pending. Consistent with Local Rule of Civil Procedure 65.1, it is ORDERED that Petitioner Richman shall file his application for a temporary restraining order by separate motion, accompanied by a certificate of counsel that either (1) states the Government has received actual notice of the application and "copies of all pleadings and papers filed in the action to date or to be presented to the Court" in connection with the application; or (2) identifies "the efforts made by the applicant to give such notice and furnish such copies." LCvR 65.1(a). Signed by Judge Colleen Kollar-Kotelly on 12/02/2025. (lcckk1)

Order on Sealed Motion for Leave to File Document Under Seal

MINUTE ORDER: The 4, 5, and 6 Motions for Admission Pro Hac Vice filed on behalf of attorneys Nicholas J. Lewin, Jonathan F. Bolz, and Jessie-Lauren Ratcliffe Pierce are GRANTED, CONTINGENT ON Attorneys Lewin, Bolz, and Pierce filing declarations certifying their familiarity with the Local Rules of this Court on or before December 10, 2025. Counsel shall promptly register for e-filing via PACER and file notices of appearance pursuant to LCvR 83.6(a). Click for instructions. Signed by Judge Colleen Kollar-Kotelly on 12/03/2025. (lcckk1)

Order on Motion for Leave to Appear Pro Hac Vice AND Order on Motion for Leave to Appear Pro Hac Vice AND Order on Motion for Leave to Appear Pro Hac Vice

NOTICE of Appearance by Nicholas James Lewin on behalf of DANIEL RICHMAN (Attachments: # 1 Declaration of Nicholas J. Lewin)(Lewin, Nicholas) (Entered: 12/04/2025)

NOTICE of Appearance by Jonathan Bolz on behalf of DANIEL RICHMAN (Attachments: # 1 Declaration of Jonathan F. Bolz)(Bolz, Jonathan) (Entered: 12/04/2025)

1 Declaration of Jonathan F. Bolz

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MOTION for Temporary Restraining Order by DANIEL RICHMAN. (Attachments: # 1 Memorandum of Law in Support of Petitioner Daniel Richman's Motion for Temporary Restraining Order, # 2 Exhibit A to Memorandum of Law in Support of Petitioner Daniel Richman's Motion for Temporary Restraining Order, # 3 Proposed Order Granting Temporary Restraining Order, # 4 Certificate of Counsel in Compliance with Local Civil Rule 65.1)(Bolz, Jonathan) (Entered: 12/05/2025)

1 Memorandum of Law in Support of Petitioner Daniel Richman's Motion for Tem

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2 Exhibit A to Memorandum of Law in Support of Petitioner Daniel Richman's M

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3 Proposed Order Granting Temporary Restraining Order

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4 Certificate of Counsel in Compliance with Local Civil Rule 65.1

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ORDER granting in part and deferring in part the Petitioner's 9 Motion for Temporary Restraining Order. Signed by Judge Colleen Kollar-Kotelly on 12/06/2025. (lcckk1) (Entered: 12/06/2025)

NOTICE of Appearance by Jessie-Lauren Ratcliffe Pierce on behalf of DANIEL RICHMAN (Attachments: # 1 Declaration of Jessie-Lauren Pierce)(Pierce, Jessie-Lauren) (Entered: 12/06/2025)

1 Declaration of Jessie-Lauren Pierce

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MOTION for Order to Dissolve Temporary Restraining Order by UNITED STATES OF AMERICA. (Bailey, John) (Entered: 12/09/2025)

Memorandum in opposition to re 1 MOTION for Return of Property filed by UNITED STATES OF AMERICA. (Bailey, John) (Entered: 12/09/2025)

ORDER setting deadlines for submissions regarding the Government's access to materials covered by the Court's 10 Order dated December 6, 2025. Signed by Judge Colleen Kollar-Kotelly on 12/09/2025. (lcckk1) (Entered: 12/09/2025)

REPLY to opposition to motion re 12 Motion for Order, 1 Motion for Return of Property, 9 Motion for TRO, filed by DANIEL RICHMAN. (Pierce, Jessie-Lauren) (Entered: 12/09/2025)

ORDER setting deadlines for the filing of notices of appearance and the Government's certification of compliance with this Court's 10 Order dated December 6, 2025. Signed by Judge Colleen Kollar-Kotelly on 12/10/2025. (lcckk1) (Entered: 12/10/2025)

NOTICE OF ERROR regarding 9 MOTION for Temporary Restraining Order . The following error(s) need correction: DO NOT REFILE. Counsel is reminded that log in and password should match signature page. (zjm)

Notice of Error

NOTICE OF ERROR regarding 13 Memorandum in Opposition, 12 MOTION for Order to Dissolve Temporary Restraining Order. The following error(s) need correction: Invalid attorney signature- signature on document must match PACER login. Please refile as an Errata. (zjm)

NOTICE OF ERROR regarding 15 Reply to opposition to Motion. The following error(s) need correction: DO NOT REFILE. Counsel is reminded that log in and password should match signature page. (zjm)

NOTICE of Appearance by Lindsey Halligan on behalf of UNITED STATES OF AMERICA (Halligan, Lindsey) (Entered: 12/11/2025)

NOTICE of Appearance by Robert Kennedy McBride on behalf of UNITED STATES OF AMERICA (McBride, Robert) (Entered: 12/11/2025)

NOTICE Certificate of Compliance by UNITED STATES OF AMERICA (Halligan, Lindsey) (Entered: 12/11/2025)

ORDER granting the Petitioner's 1 Motion for Return of Property, denying as moot the remaining requests for relief in the Petitioner's 9 Motion for Temporary Restraining Order, and denying as moot the Government's 12 Motion to Dissolve Temporary Restraining Order. Signed by Judge Colleen Kollar-Kotelly on 12/12/2025. (lcckk1) (Entered: 12/12/2025)

REDACTED MEMORANDUM OPINION accompanying 20 Order. Signed by Judge Colleen Kollar-Kotelly on 12/12/2025. (lcckk1) (Entered: 12/12/2025)

Emergency MOTION Clarify and Modify Order No. 20, Emergency MOTION for Extension of Time to Comply by UNITED STATES OF AMERICA. (Attachments: # 1 Exhibit)(Halligan, Lindsey) (Entered: 12/15/2025)

1 Exhibit

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NOTICE of Appearance by Lindsey Halligan on behalf of UNITED STATES OF AMERICA (Halligan, Lindsey) (Entered: 12/15/2025)

SEALED MEMORANDUM OPINION. (This document is SEALED and only available to authorized persons.) Signed by Judge Colleen Kollar-Kotelly on 12/12/25. (zdot) (Entered: 12/15/2025)

NOTICE of Appearance by Robert Kennedy McBride on behalf of UNITED STATES OF AMERICA (McBride, Robert) (Entered: 12/15/2025)

ORDER granting in part and deferring ruling in part Government's 22 Motion to Clarify and Modify Order and Extend Compliance Deadline. Signed by Judge Colleen Kollar-Kotelly on 12/15/2025. (lcckk3) (Entered: 12/15/2025)

Notice of Error

NOTICE OF ERROR regarding 18 Notice of Appearance, 17 Notice of Appearance. The following error(s) need correction: Invalid attorney signature- signature on document must match PACER login. Please refile. (zjm)

ORDER directing expedited submissions regarding the Government's 22 Emergency Motion to Clarify and Modify the Court's 20 Order dated December 12, 2025. Signed by Judge Colleen Kollar-Kotelly on 12/16/2025. (lcckk1) (Entered: 12/16/2025)

Unopposed MOTION for Extension of Time to Respond to Court Order by UNITED STATES OF AMERICA. (Halligan, Lindsey) (Entered: 12/16/2025)

Order on Motion for Extension of Time to

MINUTE ORDER: The Court is in receipt of the Government's 28 Motion for Additional Time to Respond to this Court's 27 Order for supplemental submissions, which the Government filed at 6:28 p.m. ET this evening. The Government's 28 Motion is GRANTED IN PART and DENIED IN PART. The Government's Motion is GRANTED as to the 9:00 a.m. deadline for the submission of "best practices on safekeeping evidence," which is CONTINUED to 9:00 a.m. ET on Friday, December 19, 2025. The Motion is GRANTED IN PART and DENIED IN PART as to the Government's deadline to respond to the factual questions presented in this Court's 27 Order. The Government shall file brief responses to these questions no later than 12:00 p.m. ET on Wednesday, December 17, 2025. The Motion is otherwise DENIED. Petitioner Richman's response deadline is unchanged. Signed by Judge Colleen Kollar-Kotelly on 12/16/2025. (lcckk3)

RESPONSE TO ORDER OF THE COURT re Order on Motion for Extension of Time to,,, Respond to Order filed by UNITED STATES OF AMERICA. (Halligan, Lindsey) (Entered: 12/17/2025)

RESPONSE TO ORDER OF THE COURT re Order on Motion for Extension of Time to,,, filed by DANIEL RICHMAN. (Lewin, Nicholas) (Entered: 12/17/2025)

MOTION for Order Supplement to Emergency Motion and Status Report by UNITED STATES OF AMERICA. (McBride, Robert) (Entered: 12/18/2025)

MOTION Leave to Copy Covered Materials by UNITED STATES OF AMERICA. (Attachments: # 1 Text of Proposed Order)(McBride, Robert) (Entered: 12/18/2025)

1 Text of Proposed Order

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.Order

MINUTE ORDER: The Court has been informed that the Department of Justice's Litigation Security Group ("LSG") has received a deposit of materials from the Government related to this case. The Court ORDERS that, no later than 10:00 AM on December 19, 2025, the Government shall file a status report advising the Court whether the materials deposited with the LSG constitute a complete copy of the materials covered by the Court's 20 Order. Signed by Judge Colleen Kollar-Kotelly on 12/18/2025. (lcckk3)

Emergency MOTION to Clarify Court Order, Emergency MOTION for Extension of Time to Certify Compliance by UNITED STATES OF AMERICA. (Halligan, Lindsey) (Entered: 12/19/2025)

ORDER re Government's 32 Motion for Leave to Copy Covered Materials and second 33 Emergency Motion to Clarify and for Extension of Time to Certify Compliance. Signed by Judge Colleen Kollar-Kotelly on 12/19/2025. (lcckk3) (Entered: 12/19/2025)

SEALED ORDER: The Government's deadline to certify compliance with the Court's December 12, 2025, Order is continued to 4:00 PM ET on December 29, 2025. Petitioner Richman response to Government's 31 due December 22, 2025, at 5:00 PM ET on December 22, 2025. (This document is SEALED and only available to authorized persons.) Signed by Judge Colleen Kollar-Kotelly on 12/19/25. (zdot) (Entered: 12/22/2025)

MINUTE ORDER: The Court is in receipt of the Government's 31 Motion for Order regarding its Supplement to Emergency Motion and Status Report. In its Motion, the Government informs the Court for the first time that, on December 15, 2025, it "lodged a complete copy of the covered materials (including classified information) that it had created" following the Court's December 12, 2025, Order with a Classified Information Security Officer ("CISO") in Washington, DC. Gov't's Mot., Dkt. No. 31 at 1, fn. 1 (internal citations omitted). In its December 12, 2025, Order, the Court ordered the Government to "return to Petitioner Richman all copies of the covered materials, except for the single copy that the Court [] allowed to be deposited, under seal, with the U.S. District Court for the Eastern District of Virginia." See Dkt. No. 20. The Court ordered the Government to certify compliance with its Order by 4:00 p.m. ET on December 15, 2025. Id. The Court further ordered that, until the Government certified compliance with its December 12 Order, the Government was "not to... share, disseminate, or disclose the covered materials to any person, without first seeking and obtaining leave of this Court." See Order, Dkt. No. 20 at 2 (incorporating the terms of Order, Dkt. No. 10). On December 15 (the Government's original deadline to certify compliance with the Court's December 12 Order), the Government requested a seven-day extension of its deadline to certify compliance with the Court's December 12 Order. Dkt. No. 22. Petitioner Richman consented to this extension. Id. And the Government represented that it would "continue to comply with its obligation... not to access or share the covered materials without leave of the Court." Id. at 11 (citing Order, Dkt. No. 10 and Order, Dkt. No. 20). So the Court granted the Government's request for extension, thereby continuing the Government's deadline to certify compliance with the Court's December 12 Order to 4:00 p.m. ET on December 22. Order, Dkt. No. 26. As of this date, the Government has not certified compliance with the Court's December 12 Order. Accordingly, the Government is still under a Court order that prohibits it from accessing Petitioner Richman's covered materials or sharing, disseminating, or disclosing Petitioner Richman's covered materials to any person without first seeking and obtaining leave of this Court. See Dkt. No. 10; Dkt. No. 20; Dkt. No. 22; Dkt. No. 26. As the Government admits, the Government provided this copy of Petitioner Richman's materials to the CISO "after the Government filed its emergency motion," Gov't's Mot., Dkt. No. 31 at 1, fn. 1, in which the Government represented that it would "continue to comply with its obligation... not to access or share the covered materials without leave of the Court." Dkt. No. 22 at 11. Three days after the Government "lodged a complete copy" of Petitioner Richman's materials with a CISO in DC, the Government moves the Court to order "that a complete copy of the covered materials can be lodged with the Department of Justice's Litigation Security Group." Dkt. No. 31 at 1. The Government does not explain this position any further, but it appears to be arguing that the copy of Petitioner Richman's materials that the Court initially permitted the Government to deposit with the District Court in the Eastern District of Virginia should instead be deposited with the Department of Justice's Litigation Security Group. The Court would benefit from more briefing from the parties given the uncertainty surrounding the Government's request to deposit Petitioner Richman's materials with the DOJ's Litigation Security Group instead of the District Court in the Eastern District of Virginia. Accordingly, the Court hereby ORDERS that Petitioner Richman shall file a response to Defendant's 31 Motion on or before 5:00 p.m. ET on Monday, December 22, 2025. This response shall address the Government's argument that the Court should permit the Government to deposit a copy of Petitioner Richman's materials with the Department of Justice's Litigation Security Group instead of the District Court in the Eastern District of Virginia. It is further ORDERED that, pursuant to the Court's December 12 Order, the Government shall not access Petitioner Richmans covered materials or share, disseminate, or disclose those covered materials to any person without first seeking and obtaining leave of the Court. Signed by Judge Colleen Kollar-Kotelly on 12/18/2025. (lcckk3)

.Order

SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by DANIEL RICHMAN (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Exhibit Unredacted Response of Petitioner Daniel Richman to the Court's December 18 and 19, 2025 Orders, # 2 Exhibit Proposed Order to Seal)(Lewin, Nicholas) (Entered: 12/22/2025)

RESPONSE TO ORDER OF THE COURT re Order,, Order,,,,,,,,,,,,,,,,,,, Redacted Response of Petitioner Daniel Richman to the Court's December 18 and 19, 2025 Orders filed by DANIEL RICHMAN. (Attachments: # 1 Declaration of Nicholas J. Lewin, # 2 Text of Proposed Order)(Lewin, Nicholas) (Entered: 12/22/2025)

1 Declaration of Nicholas J. Lewin

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2 Text of Proposed Order

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SEALED RESPONSE TO ORDER OF THE COURT filed by DANIEL RICHMAN. (This document is SEALED and only available to authorized persons.)(zjm) (Entered: 12/29/2025)

SEALED MINUTE ORDER: The Court is in receipt of Petitioner Richman's 37 Response to Order of the Court. Because the 37 Response references certain materials that are currently under seal, the accompanying 36 Sealed Motion for Leave to File Under Seal is GRANTED, the attached documents are PROVISIONALLY SEALED, and the Clerk of the Court is respectfully directed to docket the material at Dkt. No. 36, under seal, as Petitioner Richman's Sealed Motion and Exhibits, which shall remain under seal until further order of this Court. A redacted version of Petitioner Richman's Sealed Motion appears on the docket at Dkt. No. 37. (This document is SEALED and only available to authorized persons.) Signed by Judge Colleen Kollar-Kotelly on 12/22/25. (zdot)

ORDER denying 31 Motion for Order; denying 32 Motion for Leave to Copy; granting in part and denying in part 33 Motion to Clarify; granting in part and denying in part 33 Motion for Extension of Time; granting in part and denying in part 22 Motion to Modify and Clarify. Signed by Judge Colleen Kollar-Kotelly on 12/23/2025. (lcckk3) (Entered: 12/23/2025)

MEMORANDUM OPINION accompanying 38 Order. Signed by Judge Colleen Kollar-Kotelly on 12/23/2025. (lcckk3)

Sealed Order

Emergency MOTION for Extension of Time to Comply by UNITED STATES OF AMERICA. (Halligan, Lindsey) (Entered: 12/24/2025)

ORDER granting in part and denying in part 40 Motion for Extension of Time. Signed by Judge Colleen Kollar-Kotelly on 12/27/2025. (lcckk3) (Entered: 12/27/2025)

NOTICE of Appearance by Stanley Edmund Woodward, Jr on behalf of UNITED STATES OF AMERICA (Woodward, Stanley) (Entered: 01/02/2026)

Unopposed MOTION for Extension of Time to Submit Certificate of Compliance by UNITED STATES OF AMERICA. (Attachments: # 1 Text of Proposed Order)(Woodward, Stanley) (Entered: 01/02/2026)

1 Text of Proposed Order

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Order on Motion for Extension of Time to

MINUTE ORDER: For good cause shown, the Government's 44 Unopposed Motion for Extension of Time is GRANTED. The deadline for the Attorney General or her designee to certify to this Court, with specificity, that the Government has complied with this Court's 20 Order dated December 12, 2025, as clarified and modified by any subsequent Order of this Court, is EXTENDED to January 12, 2026. As previously ordered, the Government and its agents shall not access Petitioner Richman's covered materials, except for the limited purpose of deleting the purportedly classified memorandum identified in the record, or share, disseminate, disclose, or transfer those materials to any person, without first seeking and obtaining leave of this Court. Signed by Judge Colleen Kollar-Kotelly on 01/04/2026. (lcckk1)

Set/Reset Deadlines: Time to Submit Certificate of Compliance due by 1/12/2026. (dot)

Set/Reset Deadlines

Consent MOTION for Extension of Time to by UNITED STATES OF AMERICA. (Attachments: # 1 Text of Proposed Order)(Woodward, Stanley) (Entered: 01/12/2026)

1 Text of Proposed Order

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Order on Motion for Extension of Time to

MINUTE ORDER: The Court is in receipt of the Government's Unopposed 45 Motion for Extension of Time. Given the late hour of this filing, which the Court received at 7:50 p.m. this evening, and with the understanding that the Government has complied with the Court's 20 Order (as clarified and amended) in all respects except for the narrow unresolved issues identified in the 45 Motion, it is ORDERED that the deadline for the Attorney General or her designee to certify compliance with the Court's Order is STAYED through January 13, 2026. The Court otherwise DEFERS RULING on the Government's 45 Motion for Extension of Time. The Court shall resolve the 45 Motion by further order in due course. Signed by Judge Colleen Kollar-Kotelly on 01/12/2026. (lcckk1)

Order on Motion for Extension of Time to AND Set/Reset Deadlines

MINUTE ORDER: Upon further consideration of the Government's 45 Motion for Extension of Time, it is ORDERED that the Government's 45 Motion is GRANTED to the following extent: It is ORDERED that the deadline for the Attorney General or her designee to certify to this Court, with specificity, that the Government has complied with this Court's 20 Order dated December 12, 2025, as clarified and modified by any subsequent Order of this Court, including the provisions regarding both the return of certain materials to Petitioner Richman and the deposit of certain materials in the U.S. District Court for the Eastern District of Virginia, is EXTENDED to 5:00 p.m. ET on January 20, 2026.It is further ORDERED that the parties shall file a joint status report, no later than 9:00 a.m. ET on January 16, 2026, advising the Court of (1) the progress of the Government's efforts to comply with the Court's 20 Order, and (2) whether Petitioner Richman possesses a copy of any files or other materials that the Government proposes to delete or destroy on the basis that they are stored on a device or in an image that contains classified information.As previously ordered, the Government and its agents shall not access Petitioner Richman's covered materials, except for the limited purpose of deleting the purportedly classified memorandum already identified in the record, or share, disseminate, disclose, or transfer those materials to any person, without first seeking and obtaining leave of this Court. Signed by Judge Colleen Kollar-Kotelly on 01/13/2026. (lcckk1)

STATUS REPORT Re Government's Efforts to Comply with the Court's Order and Petitioners Possession of Covered Materials Per 1/13/2026 Order by DANIEL RICHMAN. (Lewin, Nicholas) (Entered: 01/16/2026)