Case: United States v. Galvin

United States of America v. Galvin

COMPLAINT against William Francis Galvin (Fee Status: US Government), filed by United States of America. (Attachments: # 1 Civil Cover Sheet, # 2 Civil Cover Sheet Attachment)(Vandenberg, David) Modified on 12/12/2025: to edit docket text (EZG). (Entered: 12/11/2025)

1 Civil Cover Sheet

View on RECAP

2 Civil Cover Sheet Attachment

View on RECAP

ELECTRONIC NOTICE TO COUNSEL: Counsel shall complete and file in PDF format a Local Category Form. The form can be found on the court's website under Resources/Forms. Counsel will use the event under Other Documents- Civil Cover Sheet & Category Sheet. (EZG) (Entered: 12/12/2025)

ELECTRONIC NOTICE of Case Assignment. District Judge Leo T. Sorokin 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. (NMC) (Entered: 12/12/2025)

Summons Issued as to William Francis Galvin. 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. (SP) (Entered: 12/12/2025)

Civil Cover Sheet & Category Sheet re 1 Complaint, by United States of America. (Attachments: # 1 Category Form)(Vandenberg, David) (Entered: 12/12/2025)

1

View on RECAP

MOTION to Compel Production by United States of America. (Vandenberg, David) (Additional attachment(s) added on 12/15/2025: # 1 Declaration of Eric Neff, # 2 Text of Proposed Order) (FGD). Modified on 12/15/2025: Memo is support and exhibits were removed and properly refiled as a separate entry. Please see entry 7 . (FGD). (Entered: 12/12/2025)

1 Declaration of Eric Neff

View on PACER

2 Memorandum in Support of Motion to Compel

View on PACER

3 Exhibit 1

View on PACER

4 Exhibit 2

View on PACER

5 Exhibit 3

View on PACER

6 Exhibit 4

View on PACER

7 Text of Proposed Order

View on PACER

MEMORANDUM in Support re 6 MOTION to Compel Production filed by United States of America. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4) (FGD) (Entered: 12/15/2025)

1

View on RECAP

2

View on RECAP

3

View on RECAP

4

View on RECAP

Notice of Case Assignment

Notice - Other

District Judge Leo T. Sorokin: ELECTRONIC ORDER entered re: 6 MOTION to Compel Production.The deadline for responding to this Motion, filed before proof of service appears on the docket, is 21 days after the later of (1) the date of service or (2) the filing on the docket of this motion. Plaintiff shall provide a copy of this e order to defendant and its counsel when serving the complaint. (FGD) (Entered: 12/15/2025)

Order

MOTION to Intervene by New England State Area Conference of the National Association for the Advancement of Colored People, Massachusetts Alliance for Retired Americans. (Attachments: # 1 Proposed Answer)(Fox, David) (Entered: 12/21/2025)

1 Proposed Answer

View on RECAP

MEMORANDUM in Support re 9 MOTION to Intervene filed by Massachusetts Alliance for Retired Americans, New England State Area Conference of the National Association for the Advancement of Colored People. (Attachments: # 1 Exhibit A, # 2 Exhibit B)(Fox, David) (Entered: 12/21/2025)

1 Exhibit A

View on PACER

2 Exhibit B

View on PACER

CORPORATE DISCLOSURE STATEMENT by New England State Area Conference of the National Association for the Advancement of Colored People. (Fox, David) (Entered: 12/21/2025)

CORPORATE DISCLOSURE STATEMENT by Massachusetts Alliance for Retired Americans. (Fox, David) (Entered: 12/21/2025)

MOTION to Intervene by Common Cause, Jane Doe Inc., Juan Pablo Jaramillo. (Attachments: # 1 Proposed Order, # 2 Motion to Dismiss)(Schlossberg, Suzanne) (Entered: 12/22/2025)

1 Proposed Order

View on PACER

2 Motion to Dismiss

View on PACER

MEMORANDUM in Support re 13 MOTION to Intervene filed by Common Cause, Jane Doe Inc., Juan Pablo Jaramillo. (Schlossberg, Suzanne) (Entered: 12/22/2025)

AFFIDAVIT in Support re 13 MOTION to Intervene filed by Common Cause, Jane Doe Inc., Juan Pablo Jaramillo. (Attachments: # 1 Ex. A - Declaration of G. Foster, # 2 Ex. B - Declaration of H. Sarang-Sieminski, # 3 Ex. C - Declaration of J.P. Jaramillo)(Schlossberg, Suzanne) (Entered: 12/22/2025)

1 Ex. A - Declaration of G. Foster

View on PACER

2 Ex. B - Declaration of H. Sarang-Sieminski

View on PACER

3 Ex. C - Declaration of J.P. Jaramillo

View on PACER

CORPORATE DISCLOSURE STATEMENT by Common Cause, Jane Doe Inc.. (Schlossberg, Suzanne) (Entered: 12/22/2025)

MOTION for Leave to Appear Pro Hac Vice for admission of Tori Shaw Filing fee: $ 125, receipt number AMADC-11440867 by Massachusetts Alliance for Retired Americans, New England State Area Conference of the National Association for the Advancement of Colored People. (Attachments: # 1 Certification)(Fox, David) Modified docket text on 12/29/2025 (FGD). (Entered: 12/26/2025)

District Judge Leo T. Sorokin: ELECTRONIC ORDER entered granting 17 Motion for Leave to Appear Pro Hac Vice Added Tori Shaw. 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: 12/29/2025)

MOTION for Leave to Appear Pro Hac Vice for admission of Ari J. Savitzsky Filing fee: $ 125, receipt number AMADC-11444148 by Common Cause, Juan Pablo Jaramillo, Jane Doe Inc. . (Attachments: # 1 Exhibit A)(Schlossberg, Suzanne) Modified on 12/30/2025: Updated filer names. (FGD) (Entered: 12/29/2025)

Order on Motion for Leave to Appear

District Judge Leo T. Sorokin: ELECTRONIC ORDER entered granting 19 Motion for Leave to Appear Pro Hac Vice Added Ari J. Savitzky. 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: 12/30/2025)

MOTION for Leave to Appear Pro Hac Vice for admission of Kevin Kowalewski Filing fee: $ 125, receipt number AMADC-11445761 by Massachusetts Alliance for Retired Americans, New England State Area Conference of the National Association for the Advancement of Colored People. (Attachments: # 1 Affidavit of Kevin Kowalewski)(Fox, David) (Entered: 12/30/2025)

Order on Motion for Leave to Appear

District Judge Leo T. Sorokin: ELECTRONIC ORDER entered granting 21 Motion for Leave to Appear Pro Hac Vice Added Kevin Kowalewski. 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: 12/31/2025)

Order on Motion for Leave to Appear

NOTICE of Appearance by Tori Shaw on behalf of Massachusetts Alliance for Retired Americans, New England State Area Conference of the National Association for the Advancement of Colored People (Shaw, Tori) (Entered: 01/02/2026)

MOTION for Leave to Appear Pro Hac Vice for admission of MEGAN C. KEENAN Filing fee: $ 125, receipt number AMADC-11452339 by Common Cause, Jane Doe Inc., Juan Pablo Jaramillo. (Attachments: # 1 Exhibit A)(Schlossberg, Suzanne) (Entered: 01/05/2026)

MOTION for Leave to Appear Pro Hac Vice for admission of Sophia Lin Lakin Filing fee: $ 125, receipt number AMADC-11452476 by Common Cause, Jane Doe Inc., Juan Pablo Jaramillo. (Attachments: # 1 Exhibit A)(Schlossberg, Suzanne) (Entered: 01/05/2026)

MOTION for Leave to Appear Pro Hac Vice for admission of Theresa J. Lee Filing fee: $ 125, receipt number AMADC-11452487 by Common Cause, Jane Doe Inc., Juan Pablo Jaramillo. (Attachments: # 1 Exhibit A)(Schlossberg, Suzanne) (Entered: 01/05/2026)

District Judge Leo T. Sorokin: ELECTRONIC ORDER entered granting 24 Motion for Leave to Appear Pro Hac Vice Added Megan C. Keenan. 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: 01/05/2026)

District Judge Leo T. Sorokin: ELECTRONIC ORDER entered granting 25 Motion for Leave to Appear Pro Hac Vice Added Sophia Lin Lakin. 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: 01/05/2026)

District Judge Leo T. Sorokin: ELECTRONIC ORDER entered granting 26 Motion for Leave to Appear Pro Hac Vice Added Theresa J. Lee. 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: 01/05/2026)

Order on Motion for Leave to Appear

District Judge Leo T. Sorokin: ELECTRONIC ORDER entered. Pending before the Court are two timely motions to intervene as defendants, either as of right under Rule 24(a) or with permission under Rule 24(b). Doc. Nos. 9, 13. Proposed intervenors are four organizations with Massachusetts-voter members—the New England State Area Conference of the NAACP (Doc. No. 10-1), the Massachusetts Alliance for Retired Americans (Doc. No. 10-2), Common Cause (Doc. No. 15-1), and Jane Doe Inc. (Doc. No. 15-2)—as well as an individual Massachusetts voter, Juan Pablo Jaramillo (Doc. No. 15-3). The existing parties (plaintiff United States and defendant Secretary Galvin) do not oppose the motions to intervene. Doc. No. 9 at 2; Doc. No. 13 at 2. The motions to intervene (Doc. Nos. 9, 13) are therefore ALLOWED as unopposed.Proof of service on defendant Galvin does not yet appear on the docket, and he has not yet responded to the complaint or motion to compel. The Court previously ordered that Galvin’s deadline for responding to the United States’ motion to compel is “21 days after the later of (1) the date of service or (2) the filing on the docket of [the motion to compel].” Doc. No. 8. The intervenor-defendants have indicated their intent to move to dismiss, Doc. No. 9 at 1 n.1; Doc. No. 13-2, and to respond to the motion to compel, Doc. No. 13 at 2. (Some intervenors did not reference the motion to compel but, of course, they may respond as they are now defendants in this case.)The Court intends to adopt a unified briefing schedule. By January 9, 2026, the parties shall file a joint status report that proposes a briefing schedule for (a) the defendants’ responses to the complaint (including any Rule 12 motions), (b) the defendants’ responses to the motion to compel, and (c) the United States’ responses/replies thereto. Any pending responsive pleading deadlines, including those specified in Doc. No. 8, are stayed pending the Court’s adoption of a briefing schedule. To the extent the United States has not yet served defendant Galvin, the report shall discuss when that might occur, and counsel shall confer with the Office of the Attorney General for the Commonwealth of Massachusetts, as anticipated counsel for Galvin, to discern its position on the matters for the status report.(FGD) (Entered: 01/06/2026)

SUMMONS Returned Executed William Francis Galvin served on 12/18/2025, answer due 1/8/2026. (Vandenberg, David) (Entered: 01/06/2026)

NOTICE of Appearance by Ari J. Savitzky on behalf of Common Cause, Jane Doe Inc., Juan Pablo Jaramillo (Savitzky, Ari) (Entered: 01/06/2026)

Summons Returned Executed

NOTICE of Appearance by Sophia Lin Lakin on behalf of Common Cause, Jane Doe Inc., Juan Pablo Jaramillo (Lakin, Sophia) (Entered: 01/07/2026)

US Marshal Process Receipt and Return for Summons and Complaint. William Francis Galvin served Delivered on 1/18/2025. (FGD) (Entered: 01/07/2026)

US Marshal Process Receipt and Return for Summons and Complaint. Andrea Joy Campbell, Attorney General served Delivered on 12/18/2025. (FGD) (Entered: 01/07/2026)

NOTICE of Appearance by Theresa J. Lee on behalf of Common Cause, Jane Doe Inc., Juan Pablo Jaramillo (Lee, Theresa) (Entered: 01/07/2026)

NOTICE of Appearance by Megan Christine Keenan on behalf of Common Cause, Jane Doe Inc., Juan Pablo Jaramillo (Keenan, Megan) (Entered: 01/07/2026)

NOTICE of Appearance by Jessie J. Rossman on behalf of Common Cause, Jane Doe Inc., Juan Pablo Jaramillo (Rossman, Jessie) (Entered: 01/07/2026)

STATUS REPORT of the Parties by United States of America. (Vandenberg, David) (Entered: 01/09/2026)

NOTICE of Appearance by Anne L. Sterman on behalf of William Francis Galvin (Sterman, Anne) (Entered: 01/09/2026)

NOTICE of Appearance by Phoebe Fischer-Groban on behalf of William Francis Galvin (Fischer-Groban, Phoebe) (Entered: 01/09/2026)

NOTICE of Appearance by Vanessa Azniv Arslanian on behalf of William Francis Galvin (Arslanian, Vanessa) (Entered: 01/09/2026)

District Judge Leo T. Sorokin: ELECTRONIC ORDER enteredre: 39 STATUS REPORT of the Parties.The Court construes the status report as a joint motion of the parties to adopt the briefing schedule proposed. The Court allows that request and adopts the proposed schedule. (FGD) (Entered: 01/12/2026)

Order AND ~Util - Set Deadlines AND ~Util - Set Motion and R&R Deadlines/Hearings

US Marshal Process Receipt and Return for Summons and Complaint. William Francis Galvin served Delivered on 12/18/2025. (FGD) (Entered: 01/27/2026)

US Treasury Process Receipt and Return for Summons and Complaint. Andrea Joy Campbell, Attorney General served Delivered on 12/18/2025. (FGD) (Entered: 01/27/2026)

MOTION to Withdraw as Attorney by Common Cause, Jane Doe Inc., Juan Pablo Jaramillo.(Keenan, Megan) (Entered: 01/28/2026)

District Judge Leo T. Sorokin: ELECTRONIC ORDER entered re: 46 Motion to Withdraw as Attorney. ALLOWED. Attorney Megan Christine Keenan terminated. (FGD) (Entered: 01/29/2026)

Order on Motion to Withdraw as Attorney

NOTICE of Appearance by Kevin Ronald Kowalewski on behalf of Massachusetts Alliance for Retired Americans, New England State Area Conference of the National Association for the Advancement of Colored People (Kowalewski, Kevin) (Entered: 02/06/2026)

MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by Common Cause, Jane Doe Inc., Juan Pablo Jaramillo.(Savitzky, Ari) (Entered: 02/06/2026)

MEMORANDUM in Support re 49 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM filed by Common Cause, Jane Doe Inc., Juan Pablo Jaramillo. (Savitzky, Ari) (Entered: 02/06/2026)

AFFIDAVIT in Support re 49 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM filed by Common Cause, Jane Doe Inc., Juan Pablo Jaramillo. (Attachments: # 1 Exhibit A - Colorado MOU, # 2 Exhibit B - Texas MOU, # 3 Exhibit C - Weber Partial Transcript, # 4 Exhibit D - Bondi Letter)(Savitzky, Ari) (Entered: 02/06/2026)

MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by Massachusetts Alliance for Retired Americans, New England State Area Conference of the National Association for the Advancement of Colored People.(Fox, David) (Entered: 02/06/2026)

Opposition re 6 MOTION to Compel Production filed by Common Cause, Jane Doe Inc., Juan Pablo Jaramillo. (Savitzky, Ari) (Entered: 02/06/2026)

MEMORANDUM in Support re 52 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM filed by Massachusetts Alliance for Retired Americans, New England State Area Conference of the National Association for the Advancement of Colored People. (Fox, David) (Entered: 02/06/2026)

MEMORANDUM in Opposition re 6 MOTION to Compel Production filed by Massachusetts Alliance for Retired Americans, New England State Area Conference of the National Association for the Advancement of Colored People. (Fox, David) (Entered: 02/06/2026)

MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by William Francis Galvin.(Fischer-Groban, Phoebe) (Entered: 02/06/2026)

MEMORANDUM in Support re 56 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM filed by William Francis Galvin. (Fischer-Groban, Phoebe) (Entered: 02/06/2026)

MOTION for Leave to Appear Pro Hac Vice for admission of Daniel Freeman Filing fee: $ 125, receipt number AMADC-11535699 by Democratic National Committee.(Kiley, Thomas) (Additional attachment(s) added on 2/9/2026: # 1 Certification) (FGD). Modified on 2/9/2026: Main Document 58 replaced on 2/9/2026, detached from supporting document. Filing party's name corrected. (FGD) (Entered: 02/09/2026)

MOTION for Leave to File Amicus Brief by Democratic National Committee.(Kiley, Thomas) (Entered: 02/09/2026)

MEMORANDUM in Support re 59 MOTION for Leave to File Amicus Brief filed by Democratic National Committee. (Kiley, Thomas) (Entered: 02/09/2026)

AMICUS BRIEF filed by Democratic National Committee . (Kiley, Thomas) (Entered: 02/09/2026)

District Judge Leo T. Sorokin: ELECTRONIC ORDER entered granting 58 Motion for Leave to Appear Pro Hac Vice Added Daniel J. Freeman. 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: 02/09/2026)

Order on Motion for Leave to Appear

District Judge Leo T. Sorokin: ELECTRONIC ORDER entered re: 59 MOTION for Leave to File Amicus Brief.ALLOWED. 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. (FGD) (Entered: 02/10/2026)

RESPONSE TO COURT ORDER by Democratic National Committee . (Kiley, Thomas) (Entered: 02/10/2026)

NOTICE of Appearance by Daniel J. Freeman on behalf of Democratic National Committee (Freeman, Daniel) (Entered: 02/10/2026)

Order on Motion for Leave to File Document

MOTION for Leave to File Amicus Brief by Former Employees of the U.S. Department of Justice.(Smith, Megan) (Entered: 02/13/2026)

MEMORANDUM in Support re 66 MOTION for Leave to File Amicus Brief filed by Former Employees of the U.S. Department of Justice. (Smith, Megan) (Entered: 02/13/2026)

AMICUS BRIEF filed by Former Employees of the U.S. Department of Justice . (Smith, Megan) (Entered: 02/13/2026)

District Judge Leo T. Sorokin: ELECTRONIC ORDER entered re: 66 MOTION for Leave to File Amicus Brief.ALLOWED. 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. (FGD) (Entered: 02/17/2026)

Order on Motion for Leave to File Document

MOTION for Leave to File Response with Additional Pages by United States of America. (Attachments: # 1 Exhibit Proposed Opposition, # 2 Affidavit Declaration of Eric Neff, # 3 Exhibit Exhibit 1 Georgia Complaint, # 4 Exhibit Exhibit 2 Georgia Consent Decree, # 5 Exhibit Texas MOU, # 6 Exhibit North Carolina Consent Decree, # 7 Exhibit North Carolina 2nd Status Report, # 8 Exhibit Ford Carter Report, # 9 Exhibit Benson Notice of Appeal, # 10 Exhibit Oregon Notice of Appeal, # 11 Exhibit Weber Notice of Appeal)(Gardner, Christopher) (Entered: 02/27/2026)

1 Exhibit Proposed Opposition

View on PACER

2 Affidavit Declaration of Eric Neff

View on PACER

3 Exhibit Exhibit 1 Georgia Complaint

View on PACER

4 Exhibit Exhibit 2 Georgia Consent Decree

View on PACER

5 Exhibit Texas MOU

View on PACER

6 Exhibit North Carolina Consent Decree

View on PACER

7 Exhibit North Carolina 2nd Status Report

View on PACER

8 Exhibit Ford Carter Report

View on PACER

9 Exhibit Benson Notice of Appeal

View on PACER

10 Exhibit Oregon Notice of Appeal

View on PACER

11 Exhibit Weber Notice of Appeal

View on PACER

District Judge Leo T. Sorokin: ELECTRONIC ORDER entered re: 70 MOTION for Leave to File Response with Additional Pages.ALLOWED. 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. (FGD) (Entered: 03/02/2026)

MEMORANDUM in Opposition re 52 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM, 49 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM, 56 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM filed by United States of America. (Attachments: # 1 Exhibit 2nd Neff Declaration, # 2 Exhibit Georgia Complaint, # 3 Exhibit Georgia Consent Decree, # 4 Exhibit Texas MOU, # 5 Exhibit North Carolina Consent Decree, # 6 Exhibit North Carolina Second Status Report, # 7 Exhibit Ford Carter Report, # 8 Exhibit Benson Notice of Appeal, # 9 Exhibit Oregon Notice of Appeal, # 10 Exhibit Weber Notice of Appeal)(Gardner, Christopher) (Entered: 03/02/2026)

1 Exhibit 2nd Neff Declaration

View on PACER

2 Exhibit Georgia Complaint

View on PACER

3 Exhibit Georgia Consent Decree

View on PACER

4 Exhibit Texas MOU

View on PACER

5 Exhibit North Carolina Consent Decree

View on PACER

6 Exhibit North Carolina Second Status Report

View on PACER

7 Exhibit Ford Carter Report

View on PACER

8 Exhibit Benson Notice of Appeal

View on PACER

9 Exhibit Oregon Notice of Appeal

View on PACER

10 Exhibit Weber Notice of Appeal

View on PACER

Order on Motion for Leave to File Document

Reply to Response to Motion

Affidavit in Support of Motion

Reply to Response to Motion

Reply to Response to Motion