Case: Doe 1 v. Patel

COMPLAINT against PAMELA J. BONDI, FEDERAL BUREAU OF INVESTIGATION, KASHYAP P. PATEL, U.S. DEPARTMENT OF JUSTICE ( Filing fee $ 405 receipt number ADCDC-12308663) filed by JOHN DOE 1, JOHN DOE 2. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Civil Cover Sheet, # 6 Summons to Kashyap P. Patel, # 7 Summons to FBI, # 8 Summons to Pamela J. Bondi, # 9 Summons to DOJ, # 10 Summons to USAO-DC)(Tulis, Elizabeth) (Entered: 03/19/2026)

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 Civil Cover Sheet

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6 Summons to Kashyap P. Patel

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7 Summons to FBI

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8 Summons to Pamela J. Bondi

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9 Summons to DOJ

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10 Summons to USAO-DC

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NOTICE of Appearance by Margaret Donovan on behalf of All Plaintiffs (Donovan, Margaret) (Entered: 03/19/2026)

SEALED MOTION for Leave to Proceed Under Pseudonym by JOHN DOE 1, JOHN DOE 2. (Attachments: # 1 Exhibit (Filed Under Seal), # 2 Text of Proposed Order)(Donovan, Margaret) Modified event on 3/20/2026 (znmw). (Entered: 03/19/2026)

1 Exhibit (Filed Under Seal)

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2 Text of Proposed Order

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SEALED DOCUMENT filed by JOHN DOE 1, JOHN DOE 2 re 1 Complaint, (This document is SEALED and only available to authorized persons.)(Donovan, Margaret) (Entered: 03/19/2026)

SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by JOHN DOE 1, JOHN DOE 2 (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Exhibit (Exhibit A), # 2 Text of Proposed Order)(Donovan, Margaret) (Entered: 03/19/2026)

MEMORANDUM OPINION AND ORDER: The Court ORDERS that: 1) Plaintiffs' 3 Motion to Proceed Under Pseudonyms is GRANTED, subject to any further consideration by the United States District Judge to whom this case is randomly assigned; 2) All parties shall use the pseudonyms listed in the Complaint in all documents filed in this action; and 3) Within fourteen days of this Order, Plaintiffs shall file: i) A pseudonymous version of their 3 Motion on the public docket; and ii) A sealed declaration containing their real names and residential addresses. Signed by Chief Judge James E. Boasberg on March 26, 2026. (lcjeb4) (Entered: 03/26/2026)

SUMMONS (5) Issued Electronically as to All Defendants, U.S. Attorney and U.S. Attorney General (Attachments: # 1 Notice and Consent)(znmw) (Entered: 03/27/2026)

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Brittany Hanke, Filing fee $ 100, receipt number ADCDC-12325593. Fee Status: Fee Paid. by JOHN DOE 1, JOHN DOE 2. (Attachments: # 1 Exhibit A - Declaration of Brittany Hanke, # 2 Exhibit B - Certificate of Good Standing, # 3 Text of Proposed Order)(Tulis, Elizabeth) (Entered: 03/27/2026)

ERRATA - Corrected Text of Proposed Order by JOHN DOE 1, JOHN DOE 2 re 8 Motion for Leave to Appear Pro Hac Vice,. (Tulis, Elizabeth) (Entered: 03/27/2026)

Case Assigned/Reassigned

Case Assigned to Judge Jia M. Cobb. (znmw)

SEALED DOCUMENT (Exhibit A) filed by JOHN DOE 1, JOHN DOE 2. re 3 Sealed Motion to Proceed Under Pseudonym. (This document is SEALED and only available to authorized persons.)(znmw) (Entered: 04/01/2026)

MINUTE ORDER granting 8 Motion for Leave to Appear Pro Hac Vice: Attorney Brittany Hanke is hereby admitted pro hac vice to appear in this matter. 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 Jia M. Cobb on March 30, 2026. (lcjmc3)

Order on Motion for Leave to Appear Pro Hac Vice

Order on Sealed Motion for Leave to File Document Under Seal

ORDER granting 5 Sealed Motion for Leave to File Document Under Seal. Signed by Judge Jia M. Cobb on 3/30/2026. (zed)

NOTICE of Appearance by Brittany Hanke on behalf of JOHN DOE 1, JOHN DOE 2 (Hanke, Brittany) (Entered: 04/01/2026)

RESPONSE TO ORDER OF THE COURT re 6 Order,,, Memorandum & Opinion,, filed by JOHN DOE 1, JOHN DOE 2. (Attachments: # 1 Exhibit ECF No. 3 (unsealed))(Donovan, Margaret) (Entered: 04/06/2026)

1 Exhibit ECF No. 3 (unsealed)

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SEALED DOCUMENT filed by JOHN DOE 1, JOHN DOE 2 re 6 Order,,, Memorandum & Opinion,, (This document is SEALED and only available to authorized persons.)(Donovan, Margaret) (Entered: 04/06/2026)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed as to the United States Attorney. Date of Service Upon United States Attorney on 3/27/2026. Answer due for ALL FEDERAL DEFENDANTS by 5/26/2026. (Attachments: # 1 Exhibit Proof of Service - USAO-DC)(Donovan, Margaret) (Entered: 04/15/2026)

NOTICE of Appearance by Isaac Belfer on behalf of All Defendants (Belfer, Isaac) (Entered: 05/26/2026)

Unopposed MOTION to Stay re 14 Summons Returned Executed as to US Attorney, Defendants Unopposed Motion to Stay Their Deadline to Respond to the Complaint Pending the Entry of a Briefing Schedule for Their Motion to Dismiss by PAMELA J. BONDI, FEDERAL BUREAU OF INVESTIGATION, KASHYAP P. PATEL, U.S. DEPARTMENT OF JUSTICE. (Attachments: # 1 Text of Proposed Order)(Belfer, Isaac) (Entered: 05/26/2026)

1 Text of Proposed Order

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MINUTE ORDER granting 16 Motion to Stay: Having considered the motion, and for good cause shown, the Court GRANTS the motion. Defendants' deadline to respond to the complaint is stayed pending the entry of a briefing schedule. The parties are further ORDERED to file a joint status report with their proposed briefing schedule by June 11, 2026. Signed by Judge Jia M. Cobb on May 28, 2026. (lcjmc3)

Order on Motion to Stay AND Set/Reset Deadlines

Joint STATUS REPORT by PAMELA J. BONDI, FEDERAL BUREAU OF INVESTIGATION, KASHYAP P. PATEL, U.S. DEPARTMENT OF JUSTICE. (Belfer, Isaac) (Entered: 06/10/2026)

MOTION to Dismiss the Complaint for Failure to State a Claim for Relief by PAMELA J. BONDI, FEDERAL BUREAU OF INVESTIGATION, KASHYAP P. PATEL, U.S. DEPARTMENT OF JUSTICE. (Attachments: # 1 Memorandum in Support, # 2 Text of Proposed Order)(Belfer, Isaac) (Entered: 06/18/2026)

1 Memorandum in Support

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2 Text of Proposed Order

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Memorandum in opposition to re 18 MOTION to Dismiss the Complaint for Failure to State a Claim for Relief filed by JOHN DOE 1, JOHN DOE 2. (Attachments: # 1 Declaration of Elizabeth Tulis, # 2 Exhibit 1 - OPR Policy Guide, # 3 Exhibit 2 - Offense Codes and Penalty Guidelines)(Tulis, Elizabeth) (Entered: 07/28/2026)

1 Declaration of Elizabeth Tulis

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2 Exhibit 1 - OPR Policy Guide

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3 Exhibit 2 - Offense Codes and Penalty Guidelines

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Consent MOTION for Leave to File Amicus Brief by JACK M. BALKIN, HEIDI KITROSSER, CHRISTINA KONINGISOR, GENEVIEVE LAKIER, GREGORY P. MAGARIAN, BURT NEUBORNE, FRANCESCA PROCACCINI. (Attachments: # 1 Exhibit A. Proposed Brief of Amici Curiae First Amendment Scholars in Support of Plaintiffs' Opposition to Defendants' Motion to Dismiss, # 2 Text of Proposed Order Granting First Amendment Scholars' Motion for Leave to File Amici Curiae Brief)(Schulz, David) (Entered: 07/29/2026)

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NOTICE of Appearance by David A. Schulz on behalf of JACK M. BALKIN, HEIDI KITROSSER, CHRISTINA KONINGISOR, GENEVIEVE LAKIER, GREGORY P. MAGARIAN, BURT NEUBORNE, FRANCESCA PROCACCINI (Schulz, David) (Main Document 21 replaced on 7/30/2026) (znmw). (Entered: 07/29/2026)

Order on Motion for Leave to File Amicus Brief

MINUTE ORDER granting 20 Motion for Leave to File Amicus Brief: The motion for leave to file is GRANTED. The Clerk of Court is directed to docket the proposed amicus brief, ECF 20-1. Signed by Judge Jia M. Cobb on July 30, 2026. (lcjmc3)

Unopposed MOTION for Leave to File Amicus Brief(as Amici Curiae in Support of Plaintiffs' Complaints and in Opposition to the Motion to Dismiss) by LAWYERS FOR THE RULE OF LAW, INC.. (Attachments: # 1 Text of Proposed Order, # 2 Exhibit)(Ginsberg, Nina) (Entered: 07/31/2026)

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Ilana Haramati, Filing fee $ 100, receipt number ADCDC-12581519. Fee Status: Fee Paid. by LAWYERS FOR THE RULE OF LAW, INC.. (Attachments: # 1 Text of Proposed Order, # 2 Declaration, # 3 Exhibit Certificate of Good Standing)(Ginsberg, Nina) (Entered: 07/31/2026)

Unopposed MOTION for Leave to File Amicus Brief by FEDERAL BUREAU OF INVESTIGATION AGENTS ASSOCIATION. (Attachments: # 1 Exhibit Proposed Amicus Brief, # 2 Text of Proposed Order)(Shenkman, Michael) (Entered: 07/31/2026)

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Order on Motion for Leave to File Amicus Brief

Order on Motion for Leave to Appear Pro Hac Vice

MINUTE ORDER granting 23 Motion for Leave to Appear Pro Hac Vice: Attorney Ilana Haramati is hereby admitted pro hac vice to appear in this matter. 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 Jia M. Cobb on July 31, 2026. (lcjmc3)

MINUTE ORDER granting 22 Motion for Leave to File Amicus Brief: The motion for leave to file is GRANTED. The Clerk of Court is directed to docket the proposed amicus brief, ECF 22-2. Signed by Judge Jia M. Cobb on July 31, 2026. (lcjmc3)

Unopposed MOTION for Leave to File Amicus Brief in Support of Plaintiffs' Opposition to Defendants' Motion to Dismiss by JUSTICE CONNECTION, 38 FORMER FBI PERSONNEL. (Attachments: # 1 Proposed Amicus Curiae Brief, # 2 Exhibit A to Amicus Brief, # 3 Proposed Order)(Waxman, Seth) (Entered: 08/03/2026)

NOTICE of Appearance by Seth Paul Waxman on behalf of 38 FORMER FBI PERSONNEL, JUSTICE CONNECTION (Waxman, Seth) (Entered: 08/03/2026)

NOTICE of Appearance by Kevin Lee Owen on behalf of FORMER SENIOR DOJ OFFICIALS (Owen, Kevin) (Entered: 08/03/2026)

NOTICE of Appearance by Kevin Lee Owen on behalf of FORMER SENIOR DOJ OFFICIALS (Owen, Kevin) (Entered: 08/04/2026)

Unopposed MOTION for Leave to File Amicus Brief by FORMER SENIOR DOJ OFFICIALS. (Attachments: # 1 Exhibit Proposed Amicus Brief, # 2 Text of Proposed Order)(Owen, Kevin) (Entered: 08/04/2026)

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MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Stephen Cha-Kim, Filing fee $ 100, receipt number ADCDC-12590174. Fee Status: Fee Paid. by FORMER SENIOR DOJ OFFICIALS. (Attachments: # 1 Affidavit of Stephen Cha-Kim, # 2 Affidavit Certificate of Good Standin)(Owen, Kevin) (Entered: 08/04/2026)

AMICUS BRIEF by JACK M. BALKIN, HEIDI KITROSSER, CHRISTINA KONINGISOR, GENEVIEVE LAKIER, GREGORY P. MAGARIAN, BURT NEUBORNE, FRANCESCA PROCACCINI. (znmw) (Entered: 08/05/2026)

AMICUS BRIEF by LAWYERS FOR THE RULE OF LAW, INC.. (znmw) Modified date filed on 8/5/2026 (znmw). (Entered: 08/05/2026)

Order on Motion for Leave to File Amicus Brief

Order on Motion for Leave to Appear Pro Hac Vice

MINUTE ORDER granting 30 Motion for Leave to Appear Pro Hac Vice: Attorney Stephen Cha-Kim is hereby admitted pro hac vice to appear in this matter. 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 Jia M. Cobb on August 5, 2026. (lcjmc3)

MINUTE ORDER granting 29 Motion for Leave to File Amicus Brief: The motion for leave to file is GRANTED. The Clerk of Court is directed to docket the proposed amicus brief, ECF 29-1. Signed by Judge Jia M. Cobb on August 5, 2026. (lcjmc3)

MINUTE ORDER granting 25 Motion for Leave to File Amicus Brief: The motion for leave to file is GRANTED. The Clerk of Court is directed to docket the proposed amicus brief, ECF 25-1, and the exhibit to the proposed brief, ECF 25-2. Signed by Judge Jia M. Cobb on August 5, 2026. (lcjmc3)

MINUTE ORDER granting 24 Motion for Leave to File Amicus Brief: The motion for leave to file is GRANTED. The Clerk of Court is directed to docket the proposed amicus brief, ECF 24-1. Signed by Judge Jia M. Cobb on August 5, 2026. (lcjmc3)

NOTICE of Appearance by Ilana Haramati on behalf of LAWYERS FOR THE RULE OF LAW, INC. (Haramati, Ilana) (Entered: 08/08/2026)

NOTICE of Appearance by Stephen Seungkun Cha-Kim on behalf of FORMER SENIOR DOJ OFFICIALS (Cha-Kim, Stephen) (Entered: 08/10/2026)

Amicus Brief

Amicus Brief

Amicus Brief

Reply to opposition to motion