Case: Commonwealth of Massachusetts v. U.S. Department of Agriculture

Commonwealth of Massachusetts et al. v. U.S. Department of Agriculture et al.

COMPLAINT against All Defendants Filing fee: $ 405, receipt number AMADC-11628426 (Fee Status: Filing Fee paid), filed by COMMONWEALTH OF MASSACHUSETTS, Commonwealth of Virginia, District of Columbia, State of California, State of Colorado, State of Connecticut, State of Delaware, State of Hawaii, State of Illinois, State of Maine, State of Maryland, State of Michigan, State of Minnesota, State of New Jersey, State of New Mexico, State of New York, State of Oregon, State of Rhode Island, State of Vermont, State of Washington, State of Wisconsin. (Attachments: # 1 Exhibit A: General Terms and Conditions for Federal Awards, # 2 Exhibit B: General Terms and Conditions for Mutual Interest Agreements, # 3 Exhibit C: 12.31.2025 Rollins Memo, # 4 Civil Cover Sheet, # 5 Category Form)(Klunder, Nita) (Entered: 03/23/2026)

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NOTICE of Appearance by Hannah C. Vail on behalf of COMMONWEALTH OF MASSACHUSETTS (Vail, Hannah) (Entered: 03/23/2026)

NOTICE of Appearance by Jak Kundl on behalf of COMMONWEALTH OF MASSACHUSETTS (Kundl, Jak) (Entered: 03/23/2026)

ELECTRONIC NOTICE of Case Assignment. Judge Myong J. Joun 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 Donald L. Cabell. (JAM) (Entered: 03/23/2026)

Summons Issued as to Brooke L. Rollins, U.S. Department of Agriculture, United States of America. 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: 03/23/2026)

NOTICE of Appearance by Leanne E. Hartmann on behalf of State of Oregon (Hartmann, Leanne) (Entered: 03/23/2026)

MOTION for Leave to Appear Pro Hac Vice for admission of James Luh Filing fee: $ 125, receipt number AMADC-11629829 by State of Maryland. (Attachments: # 1 Affidavit)(Kundl, Jak) (Entered: 03/23/2026)

Notice of Case Assignment

Judge Myong J. Joun: ELECTRONIC ORDER entered GRANTING 7 Motion for Leave to Appear Pro Hac Vice Added James C. Luh. Attorneys admitted Pro Hac Vice must have an individual upgraded PACER account, not a shared firm account, to electronically file in the District of Massachusetts. Counsel may need to link their CM/ECF account to their upgraded individual pacer account. Instructions on how to link CM/ECF accounts to upgraded pacer account can be found at https://www.mad.uscourts.gov/caseinfo/nextgen-current-pacer-accounts.htm#link-account. (SP) (Entered: 03/24/2026)

MOTION for Leave to Appear Pro Hac Vice for admission of Jonathan Rose Filing fee: $ 125, receipt number AMADC-11630961 by State of Vermont. (Attachments: # 1 Affidavit)(Kundl, Jak) (Entered: 03/24/2026)

Notice of Service of Process filed by Commonwealth of Massachusetts. Individual(s)/Entities served: U.S. Department of Agriculture, Brooke L. Rollins, United States of America. (Attachments: # 1 Affidavit Declaration of service by certified mail and courier)(Kundl, Jak) (Entered: 03/24/2026)

NOTICE of Appearance by James C. Luh on behalf of State of Maryland (Luh, James) (Entered: 03/24/2026)

Judge Myong J. Joun: ELECTRONIC ORDER entered GRANTING 9 Motion for Leave to Appear Pro Hac Vice Added Jonathan T. Rose. Attorneys admitted Pro Hac Vice must have an individual upgraded PACER account, not a shared firm account, to electronically file in the District of Massachusetts. Counsel may need to link their CM/ECF account to their upgraded individual pacer account. Instructions on how to link CM/ECF accounts to upgraded pacer account can be found at https://www.mad.uscourts.gov/caseinfo/nextgen-current-pacer-accounts.htm#link-account. (SP) (Entered: 03/24/2026)

MOTION for Leave to Appear Pro Hac Vice for admission of Neil Giovanatti Filing fee: $ 125, receipt number AMADC-11632482 by State of Michigan. (Attachments: # 1 Certification)(Kundl, Jak) (Entered: 03/24/2026)

Order on Motion for Leave to Appear

NOTICE of Appearance by Jonathan T Rose on behalf of State of Vermont (Rose, Jonathan) (Entered: 03/25/2026)

Judge Myong J. Joun: ELECTRONIC ORDER entered GRANTING 13 Motion for Leave to Appear Pro Hac Vice Added Neil Giovanatti. Attorneys admitted Pro Hac Vice must have an individual upgraded PACER account, not a shared firm account, to electronically file in the District of Massachusetts. Counsel may need to link their CM/ECF account to their upgraded individual pacer account. Instructions on how to link CM/ECF accounts to upgraded pacer account can be found at https://www.mad.uscourts.gov/caseinfo/nextgen-current-pacer-accounts.htm#link-account. (SP) (Entered: 03/25/2026)

NOTICE of Appearance by Neil Giovanatti on behalf of State of Michigan (Giovanatti, Neil) (Entered: 03/25/2026)

NOTICE of Appearance by Michael Fitzgerald on behalf of Brooke L. Rollins, U.S. Department of Agriculture, United States of America (Fitzgerald, Michael) (Entered: 03/25/2026)

Joint MOTION for Leave to File Excess Pages by Commonwealth of Massachusetts.(Klunder, Nita) (Entered: 03/25/2026)

Judge Myong J. Joun: ELECTRONIC ORDER entered GRANTING 18 Joint MOTION for Leave to File Excess Pages by Commonwealth of Massachusetts. Motion for Leave to File Excess Pages ; 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. (SP) (Entered: 03/25/2026)

MOTION for Leave to Appear Pro Hac Vice for admission of Samuel Wolter, Kristopher Brambila Filing fee: $ 250, receipt number AMADC-11635839 by State of Colorado. (Attachments: # 1 SW Certification, # 2 KAB Certification)(Kundl, Jak) (Entered: 03/25/2026)

MOTION for Leave to Appear Pro Hac Vice for admission of Vikas Didwania, Aleeza Strubel, Michael M. Tresnowski Filing fee: $ 375, receipt number AMADC-11635853 by State of Illinois. (Attachments: # 1 VD Certification, # 2 MT Certification, # 3 AS Certification)(Kundl, Jak) (Entered: 03/25/2026)

Judge Myong J. Joun: ELECTRONIC ORDER entered GRANTING 20 Motion for Leave to Appear Pro Hac Vice Added Kristopher Brambila and Sam Wolter. 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. (SP) (Entered: 03/25/2026)

MOTION for Leave to Appear Pro Hac Vice for admission of Katherine Thompson Filing fee: $ 125, receipt number AMADC-11635858 by State of Maine. (Attachments: # 1 Certification)(Kundl, Jak) (Entered: 03/25/2026)

MOTION for Leave to Appear Pro Hac Vice for admission of Rabia Muqaddam, Natasha Korgaonkar, Matthew Faiella Filing fee: $ 375, receipt number AMADC-11635861 by State of New York. (Attachments: # 1 RM Certification, # 2 NK Certification, # 3 MF Certification)(Kundl, Jak) (Entered: 03/25/2026)

NOTICE of Appearance by Amy Senier on behalf of State of New Mexico (Senier, Amy) (Entered: 03/25/2026)

Order on Motion for Leave to Appear

Order on Motion for Leave to File Excess Pages

Judge Myong J. Joun: ELECTRONIC ORDER entered GRANTING 21 Motion for Leave to Appear Pro Hac Vice Added Vikas Didwania, Aleeza Strubel, Michael M. Tresnowski. Attorneys admitted Pro Hac Vice must have an individual upgraded PACER account, not a shared firm account, to electronically file in the District of Massachusetts. Counsel may need to link their CM/ECF account to their upgraded individual pacer account. Instructions on how to link CM/ECF accounts to upgraded pacer account can be found at https://www.mad.uscourts.gov/caseinfo/nextgen-current-pacer-accounts.htm#link-account. (CEH) (Entered: 03/26/2026)

Judge Myong J. Joun: ELECTRONIC ORDER entered GRANTING 23 Motion for Leave to Appear Pro Hac Vice Added Katherine Thompson. 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. (CEH) (Entered: 03/26/2026)

Judge Myong J. Joun: ELECTRONIC ORDER entered GRANTING 24 Motion for Leave to Appear Pro Hac Vice Added Rabia Muqaddam, Natasha Korgaonkar, Matthew Faiella. Attorneys admitted Pro Hac Vice must have an individual upgraded PACER account, not a shared firm account, to electronically file in the District of Massachusetts. Counsel may need to link their CM/ECF account to their upgraded individual pacer account. Instructions on how to link CM/ECF accounts to upgraded pacer account can be found at https://www.mad.uscourts.gov/caseinfo/nextgen-current-pacer-accounts.htm#link-account. (CEH) (Entered: 03/26/2026)

NOTICE of Appearance by Natasha Korgaonkar on behalf of State of New York (Korgaonkar, Natasha) (Entered: 03/26/2026)

NOTICE of Appearance by Rabia Muqaddam on behalf of State of New York (Muqaddam, Rabia) (Entered: 03/26/2026)

Order on Motion for Leave to Appear

NOTICE of Appearance by Aleeza M. Strubel on behalf of State of Illinois (Strubel, Aleeza) (Entered: 03/27/2026)

MOTION for Leave to Appear Pro Hac Vice for admission of Lynn Lodahl Filing fee: $ 125, receipt number AMADC-11638874 by State of Wisconsin. (Attachments: # 1 Certification)(Kundl, Jak) (Entered: 03/27/2026)

MOTION for Leave to Appear Pro Hac Vice for admission of Paul Meosky Filing fee: $ 125, receipt number AMADC-11638882 by State of Rhode Island. (Attachments: # 1 Certification)(Kundl, Jak) (Entered: 03/27/2026)

MOTION for Leave to Appear Pro Hac Vice for admission of Samantha Hall Filing fee: $ 125, receipt number AMADC-11638900 by District of Columbia. (Attachments: # 1 Certification)(Kundl, Jak) (Entered: 03/27/2026)

NOTICE of Appearance by Michael M. Tresnowski on behalf of State of Illinois (Tresnowski, Michael) (Entered: 03/27/2026)

Judge Myong J. Joun: ELECTRONIC ORDER entered GRANTING 32 Motion for Leave to Appear Pro Hac Vice Added Lynn Lodahl. Attorneys admitted Pro Hac Vice must have an individual upgraded PACER account, not a shared firm account, to electronically file in the District of Massachusetts. Counsel may need to link their CM/ECF account to their upgraded individual pacer account. Instructions on how to link CM/ECF accounts to upgraded pacer account can be found at https://www.mad.uscourts.gov/caseinfo/nextgen-current-pacer-accounts.htm#link-account. (CEH) (Entered: 03/27/2026)

Judge Myong J. Joun: ELECTRONIC ORDER entered GRANTING 33 Motion for Leave to Appear Pro Hac Vice Added Paul Meosky. 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. (CEH) (Entered: 03/27/2026)

Judge Myong J. Joun: ELECTRONIC ORDER entered GRANTING 34 Motion for Leave to Appear Pro Hac Vice Added Samantha Hall. Attorneys admitted Pro Hac Vice must have an individual upgraded PACER account, not a shared firm account, to electronically file in the District of Massachusetts. Counsel may need to link their CM/ECF account to their upgraded individual pacer account. Instructions on how to link CM/ECF accounts to upgraded pacer account can be found at https://www.mad.uscourts.gov/caseinfo/nextgen-current-pacer-accounts.htm#link-account. (CEH) (Entered: 03/27/2026)

NOTICE of Appearance by Samantha Hall on behalf of District of Columbia (Hall, Samantha) (Entered: 03/27/2026)

NOTICE of Appearance by Paul Timothy James Meosky on behalf of State of Rhode Island (Meosky, Paul) (Entered: 03/27/2026)

Order on Motion for Leave to Appear

NOTICE of Appearance by Vikas Didwania on behalf of State of Illinois (Didwania, Vikas) (Entered: 03/30/2026)

MOTION for Preliminary Injunction by Commonwealth of Massachusetts. (Attachments: # 1 Text of Proposed Order)(Klunder, Nita) (Entered: 03/30/2026)

1 Text of Proposed Order

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MEMORANDUM in Support re 42 MOTION for Preliminary Injunction filed by Commonwealth of Massachusetts. (Klunder, Nita) (Entered: 03/30/2026)

AFFIDAVIT in Support re 42 MOTION for Preliminary Injunction filed by Commonwealth of Massachusetts. (Attachments: # 1 Exhibit 1 - Memo re The Golden Age, # 2 Exhibit 2 - FNS Terms and Conditions, # 3 Exhibit 3 - Letter to Newsom, # 4 Exhibit 4 - Letter to Mills, # 5 Exhibit 5 - CBS news article, # 6 Exhibit 6 - Rollins X post, # 7 Exhibit 7 - FNS memo, # 8 Exhibit 8 - meet and confer email, # 9 Exhibit 9 - McClelland Declaration, # 10 Exhibit 10 - Moseley Declaration, # 11 Exhibit 11 - Reeder Declaration, # 12 Exhibit 12 - Riley Declaration, # 13 Exhibit 13 - Kostman-Fesler Declaration, # 14 Exhibit 14 - Hadler Declaration, # 15 Exhibit 15 - Pessolano Declaration, # 16 Exhibit 16 - Beckwith Declaration, # 17 Exhibit 17 - Sadlon Declaration, # 18 Exhibit 18 - Staats Declaration, # 19 Exhibit 19 - Veron Declaration, # 20 Exhibit 20 - White Declaration, # 21 Exhibit 21 - Beam Declaration, # 22 Exhibit 22 - Isbell Declaration, # 23 Exhibit 23 - Bess Declaration, # 24 Exhibit 24 - Sanders Declaration, # 25 Exhibit 25 - Ramos Declaration, # 26 Exhibit 26 - Reagan Declaration, # 27 Exhibit 27 - Davis Declaration, # 28 Exhibit 28 - Barton Declaration, # 29 Exhibit 29 - Colchamiro Declaration, # 30 Exhibit 30 - Bell Declaration, # 31 Exhibit 31 - Cooper Declaration, # 32 Exhibit 32 - Bell Declaration, # 33 Exhibit 33 - Burnett Declaration, # 34 Exhibit 34 - O'Shea Declaration, # 35 Exhibit 35 - Fletcher Declaration, # 36 Exhibit 36 - Kurtz Declaration, # 37 Exhibit 37 - Yaffe Declaration, # 38 Exhibit 38 - Va Declaration, # 39 Exhibit 39 - McLucas Declaration, # 40 Exhibit 40 - McBrady Declaration, # 41 Exhibit 41 - Hertel Declaration, # 42 Exhibit 42 - Priya Declaration, # 43 Exhibit 43 - Golzynski Declaration, # 44 Exhibit 44 - Boring Declaration, # 45 Exhibit 45 - Bowen Declaration, # 46 Exhibit 46 - Moore Declaration, # 47 Exhibit 47 - Thielen Declaration, # 48 Exhibit 48 - Straka Declaration, # 49 Exhibit 49 - Weeks Declaration, # 50 Exhibit 50 - LaRegina Declaration, # 51 Exhibit 51 - Matis Declaration, # 52 Exhibit 52 - Kozlowski Declaration, # 53 Exhibit 53 - Gonzales Declaration, # 54 Exhibit 54 - Kozlowski Declaration, # 55 Exhibit 55 - Tricarico Declaration, # 56 Exhibit 56 - Hoffman Declaration, # 57 Exhibit 57 - Tumer Declaration, # 58 Exhibit 58 - Sanna Declaration, # 59 Exhibit 59 - Wetherell Declaration, # 60 Exhibit 60 - KC Declaration, # 61 Exhibit 61 - Merolla-Brito Declaration, # 62 Exhibit 62 - Jenkins Declaration, # 63 Exhibit 63 - Echelson Declaration, # 64 Exhibit 64 - Marshall Declaration, # 65 Exhibit 65 - Campagna Declaration, # 66 Exhibit 66 - Green Declaration, # 67 Exhibit 67 - Krueger Declaration, # 68 Exhibit 68 - Reyes Declaration, # 69 Exhibit 69 - Tybo Declaration, # 70 Exhibit 70 - Grejner-Brzezinska Declaration, # 71 Exhibit 71 - Tran Declaration, # 72 Exhibit 72 - McCarthy Declaration, # 73 Exhibit 73 - Aquino Declaration, # 74 Exhibit 74 - Tran Declaration, # 75 Exhibit 75 - Frinzell Declaration, # 76 Exhibit 76 - McGrattan Declaration, # 77 Exhibit 77 - Cole - Declaration, # 78 Exhibit 78 - Walton Declaration, # 79 Exhibit 79 - Melvin Declaration, # 80 Exhibit 80 - Lasher Declaration, # 81 Exhibit 81 - Maldonado Declaration, # 82 Exhibit 82 - Kaiser Declaration)(Klunder, Nita) (Entered: 03/30/2026)

1 Exhibit 1 - Memo re The Golden Age

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2 Exhibit 2 - FNS Terms and Conditions

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3 Exhibit 3 - Letter to Newsom

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4 Exhibit 4 - Letter to Mills

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5 Exhibit 5 - CBS news article

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6 Exhibit 6 - Rollins X post

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7 Exhibit 7 - FNS memo

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8 Exhibit 8 - meet and confer email

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9 Exhibit 9 - McClelland Declaration

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10 Exhibit 10 - Moseley Declaration

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11 Exhibit 11 - Reeder Declaration

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12 Exhibit 12 - Riley Declaration

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13 Exhibit 13 - Kostman-Fesler Declaration

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14 Exhibit 14 - Hadler Declaration

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15 Exhibit 15 - Pessolano Declaration

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16 Exhibit 16 - Beckwith Declaration

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17 Exhibit 17 - Sadlon Declaration

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18 Exhibit 18 - Staats Declaration

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19 Exhibit 19 - Veron Declaration

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20 Exhibit 20 - White Declaration

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21 Exhibit 21 - Beam Declaration

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22 Exhibit 22 - Isbell Declaration

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23 Exhibit 23 - Bess Declaration

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24 Exhibit 24 - Sanders Declaration

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25 Exhibit 25 - Ramos Declaration

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26 Exhibit 26 - Reagan Declaration

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27 Exhibit 27 - Davis Declaration

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28 Exhibit 28 - Barton Declaration

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29 Exhibit 29 - Colchamiro Declaration

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30 Exhibit 30 - Bell Declaration

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31 Exhibit 31 - Cooper Declaration

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32 Exhibit 32 - Bell Declaration

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33 Exhibit 33 - Burnett Declaration

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34 Exhibit 34 - O'Shea Declaration

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35 Exhibit 35 - Fletcher Declaration

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36 Exhibit 36 - Kurtz Declaration

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37 Exhibit 37 - Yaffe Declaration

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38 Exhibit 38 - Va Declaration

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39 Exhibit 39 - McLucas Declaration

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40 Exhibit 40 - McBrady Declaration

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41 Exhibit 41 - Hertel Declaration

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42 Exhibit 42 - Priya Declaration

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43 Exhibit 43 - Golzynski Declaration

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44 Exhibit 44 - Boring Declaration

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45 Exhibit 45 - Bowen Declaration

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46 Exhibit 46 - Moore Declaration

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47 Exhibit 47 - Thielen Declaration

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48 Exhibit 48 - Straka Declaration

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49 Exhibit 49 - Weeks Declaration

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50 Exhibit 50 - LaRegina Declaration

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51 Exhibit 51 - Matis Declaration

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52 Exhibit 52 - Kozlowski Declaration

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53 Exhibit 53 - Gonzales Declaration

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54 Exhibit 54 - Kozlowski Declaration

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55 Exhibit 55 - Tricarico Declaration

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56 Exhibit 56 - Hoffman Declaration

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57 Exhibit 57 - Tumer Declaration

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58 Exhibit 58 - Sanna Declaration

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59 Exhibit 59 - Wetherell Declaration

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60 Exhibit 60 - KC Declaration

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61 Exhibit 61 - Merolla-Brito Declaration

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62 Exhibit 62 - Jenkins Declaration

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63 Exhibit 63 - Echelson Declaration

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64 Exhibit 64 - Marshall Declaration

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65 Exhibit 65 - Campagna Declaration

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66 Exhibit 66 - Green Declaration

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67 Exhibit 67 - Krueger Declaration

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68 Exhibit 68 - Reyes Declaration

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69 Exhibit 69 - Tybo Declaration

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70 Exhibit 70 - Grejner-Brzezinska Declaration

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71 Exhibit 71 - Tran Declaration

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72 Exhibit 72 - McCarthy Declaration

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73 Exhibit 73 - Aquino Declaration

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74 Exhibit 74 - Tran Declaration

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75 Exhibit 75 - Frinzell Declaration

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76 Exhibit 76 - McGrattan Declaration

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77 Exhibit 77 - Cole - Declaration

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78 Exhibit 78 - Walton Declaration

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79 Exhibit 79 - Melvin Declaration

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80 Exhibit 80 - Lasher Declaration

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81 Exhibit 81 - Maldonado Declaration

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82 Exhibit 82 - Kaiser Declaration

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MOTION for Leave to Appear Pro Hac Vice for admission of Erica R. Franklin Filing fee: $ 125, receipt number AMADC-11650453 by State of Washington. (Attachments: # 1 Certification)(Kundl, Jak) (Entered: 04/01/2026)

Judge Myong J. Joun: ELECTRONIC ORDER entered GRANTING 45 Motion for Leave to Appear Pro Hac Vice Added Erica R. Franklin. Attorneys admitted Pro Hac Vice must have an individual upgraded PACER account, not a shared firm account, to electronically file in the District of Massachusetts. Counsel may need to link their CM/ECF account to their upgraded individual pacer account. Instructions on how to link CM/ECF accounts to upgraded pacer account can be found at https://www.mad.uscourts.gov/caseinfo/nextgen-current-pacer-accounts.htm#link-account. (SP) (Entered: 04/01/2026)

Order on Motion for Leave to Appear

NOTICE of Appearance by Erica Ruth Franklin on behalf of State of Washington (Franklin, Erica) (Entered: 04/02/2026)

NOTICE of Appearance by Katherine Thompson on behalf of State of Maine (Thompson, Katherine) (Entered: 04/07/2026)

Opposition to Motion

Notice of Appearance

Notice of Appearance