Case: Healthy Gulf v. Burgum

COMPLAINT for Declaratory and Injunctive Relief against DOUG BURGUM, DANIEL DRISCOLL, PETE HEGSETH, NEIL JACOBS, BROOKE ROLLINS, Pierre Yared, LEE ZELDIN ( Filing fee $ 405 receipt number ADCDC-12336036) filed by FRIENDS OF THE EARTH, SIERRA CLUB, HEALTHY GULF, TURTLE ISLAND RESTORATION NETWORK. (Attachments: # 1 Civil Cover Sheet, # 2 Summons to Doug Burgum, # 3 Summons to Pete Hegseth, # 4 Summons to Brooke Rollins, # 5 Summons to Daniel P. Driscoll, # 6 Summons to Pierre Yared, # 7 Summons to Lee Zeldin, # 8 Summons to Neil Jacobs, # 9 Summons to Earl Matthews, GC of DoD, # 10 Summons to Pam Bondi, AG, # 11 Summons to Jeanine Pirro, District Attorney)(Mashuda, Stephen) (Entered: 04/02/2026)

1 Civil Cover Sheet

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2 Summons to Doug Burgum

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3 Summons to Pete Hegseth

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4 Summons to Brooke Rollins

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5 Summons to Daniel P. Driscoll

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6 Summons to Pierre Yared

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7 Summons to Lee Zeldin

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8 Summons to Neil Jacobs

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9 Summons to Earl Matthews, GC of DoD

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10 Summons to Pam Bondi, AG

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11 Summons to Jeanine Pirro, District Attorney

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LCvR 26.1 CERTIFICATE OF DISCLOSURE of Corporate Affiliations and Financial Interests by HEALTHY GULF (Mashuda, Stephen) (Entered: 04/02/2026)

LCvR 26.1 CERTIFICATE OF DISCLOSURE of Corporate Affiliations and Financial Interests by SIERRA CLUB (Mashuda, Stephen) (Entered: 04/02/2026)

LCvR 26.1 CERTIFICATE OF DISCLOSURE of Corporate Affiliations and Financial Interests by FRIENDS OF THE EARTH (Mashuda, Stephen) (Entered: 04/02/2026)

LCvR 26.1 CERTIFICATE OF DISCLOSURE of Corporate Affiliations and Financial Interests by TURTLE ISLAND RESTORATION NETWORK (Mashuda, Stephen) (Entered: 04/02/2026)

NOTICE OF RELATED CASE by FRIENDS OF THE EARTH, HEALTHY GULF, SIERRA CLUB, TURTLE ISLAND RESTORATION NETWORK. Case related to Case No. 26-cv-00940-RC. (Mashuda, Stephen) (Entered: 04/02/2026)

SUMMONS (9) Issued Electronically as to All Defendants, U.S. Attorney and U.S. Attorney General (Attachments: # 1 Notice and Consent)(zhcn) (Entered: 04/03/2026)

Case Assigned to Judge Rudolph Contreras. (zhcn)

Case Assigned/Reassigned

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Ava Ibanez Amador, Filing fee $ 100, receipt number ADCDC-12346665. Fee Status: Fee Paid. by FRIENDS OF THE EARTH, HEALTHY GULF, TURTLE ISLAND RESTORATION NETWORK. (Attachments: # 1 Declaration of Ava Ibanez Amador, # 2 Certificate of Good Standing, # 3 Text of Proposed Order)(Mashuda, Stephen) (Entered: 04/07/2026)

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Devorah Ancel, Filing fee $ 100, receipt number ADCDC-12346702. Fee Status: Fee Paid. by SIERRA CLUB. (Attachments: # 1 Declaration of Devorah Ancel, # 2 Certificate of Good Standing, # 3 Text of Proposed Order)(Mashuda, Stephen) (Entered: 04/07/2026)

NOTICE of Appearance by Ava Ibanez Amador on behalf of FRIENDS OF THE EARTH, HEALTHY GULF, TURTLE ISLAND RESTORATION NETWORK (Ibanez Amador, Ava) (Entered: 04/07/2026)

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

MINUTE ORDER granting 8 9 Motions for Leave to Appear Pro Hac Vice: Pursuant to Local Civil Rule 83.2, it is hereby ORDERED that Ava Ibanez Amador is admitted to represent Plaintiffs Healthy Gulf, Friends of the Earth, and Turtle Island Restoration Network pro hac vice in this case; and Devorah Ancel is admitted to represent Plaintiff Sierra Club pro hac vice in this case. Counsel should register for e-filing via PACER and file a notice of appearance pursuant to LCvR 83.6(a) Click for instructions. SO ORDERED. Signed by Judge Rudolph Contreras on 04/07/2026. (lcrc1)

NOTICE of Appearance by Devorah Ancel on behalf of SIERRA CLUB (Ancel, Devorah) (Entered: 04/08/2026)

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Brettny Hardy, Filing fee $ 100, receipt number ADCDC-12352479. Fee Status: Fee Paid. by FRIENDS OF THE EARTH, HEALTHY GULF, TURTLE ISLAND RESTORATION NETWORK. (Attachments: # 1 Declaration of Brettny Hardy, # 2 Certificate of Good Standing, # 3 Text of Proposed Order)(Hardy, Brettny) (Entered: 04/09/2026)

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Andrea A. Treece, Filing fee $ 100, receipt number ADCDC-12352499. Fee Status: Fee Paid. by FRIENDS OF THE EARTH, HEALTHY GULF, TURTLE ISLAND RESTORATION NETWORK. (Attachments: # 1 Declaration of Andrea A. Treece, # 2 Certificate of Good Standing, # 3 Text of Proposed Order)(Mashuda, Stephen) (Entered: 04/09/2026)

1 Declaration of Andrea A. Treece

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2 Certificate of Good Standing

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3 Text of Proposed Order

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NOTICE of Appearance by Brettny Elaine Hardy on behalf of FRIENDS OF THE EARTH, HEALTHY GULF, TURTLE ISLAND RESTORATION NETWORK (Hardy, Brettny) (Entered: 04/09/2026)

NOTICE of Appearance by Andrea A. Treece on behalf of FRIENDS OF THE EARTH, HEALTHY GULF, TURTLE ISLAND RESTORATION NETWORK (Treece, Andrea) (Entered: 04/09/2026)

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

MINUTE ORDER granting 12 13 Motions for Leave to Appear Pro Hac Vice: Pursuant to Local Civil Rule 83.2, it is hereby ORDERED that Andrea A. Treece is admitted to represent Plaintiffs Healthy Gulf, Friends of the Earth, and Turtle Island Restoration Network pro hac vice in this case; and Brettny Hardy is admitted to represent Plaintiffs Healthy Gulf, Friends of the Earth, and Turtle Island Restoration Network pro hac vice in this case. Counsel should register for e-filing via PACER and file a notice of appearance pursuant to Local Civil Rule 83.6(a). Click for instructions. SO ORDERED. Signed by Judge Rudolph Contreras on 04/09/2026. (lcrc1)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed as to the United States Attorney. Date of Service Upon United States Attorney on 4/8/2026. Answer due for ALL FEDERAL DEFENDANTS by 6/7/2026. (Mashuda, Stephen) (Entered: 04/21/2026)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed on United States Attorney General. Date of Service Upon United States Attorney General 4/8/2026. (Mashuda, Stephen) (Entered: 04/21/2026)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. DOUG BURGUM served on 4/7/2026; DANIEL P. DRISCOLL served on 4/7/2026; PETE HEGSETH served on 4/7/2026; NEIL JACOBS served on 4/7/2026; BROOKE ROLLINS served on 4/7/2026; PIERRE YARED served on 4/21/2026; LEE ZELDIN served on 4/7/2026 (Attachments: # 1 Proof of Service - Brooke Rollins, Brooke Rollins, Secretary of U.S. Department of Agriculture, # 2 Proof of Service - Daniel P. Driscoll, Secretary of the Department of the Army, # 3 Proof of Service - Lee Zeldin, Administrator of the U.S. Environmental Protection Agency, # 4 Proof of Service - Neil Jacobs, Administrator of National Oceanic and Atmospheric Administration, # 5 Proof of Service - Pete Hesgeth, Secretary of Defense, # 6 Proof of Service - Pierre Yared, Acting Chair of the Council of Economic Advisors)(Mashuda, Stephen) (Entered: 04/21/2026)

AMENDED COMPLAINT against DOUG BURGUM, DANIEL P. DRISCOLL, PETE HEGSETH, NEIL JACOBS, BROOKE ROLLINS, PIERRE YARED, LEE ZELDIN filed by FRIENDS OF THE EARTH, SIERRA CLUB, HEALTHY GULF, TURTLE ISLAND RESTORATION NETWORK, OCEANA, INC..(Mashuda, Stephen) (Entered: 05/26/2026)

MOTION to Intervene by AMERICAN PETROLEUM INSTITUTE. (Attachments: # 1 Proposed Answer to Complaint, # 2 Declaration of Holly Hopkins, # 3 Text of Proposed Order)(Morgan, Jason) (Entered: 06/01/2026)

LCvR 26.1 CERTIFICATE OF DISCLOSURE of Corporate Affiliations and Financial Interests by AMERICAN PETROLEUM INSTITUTE (Morgan, Jason) (Entered: 06/01/2026)

NOTICE of Appearance by Ryan P. Steen on behalf of AMERICAN PETROLEUM INSTITUTE (Steen, Ryan) (Entered: 06/02/2026)

NOTICE of Appearance by Sara Warren on behalf of DOUG BURGUM, DANIEL P. DRISCOLL, PETE HEGSETH, NEIL JACOBS, BROOKE ROLLINS, PIERRE YARED, LEE M. ZELDIN (Warren, Sara) (Entered: 06/09/2026)

NOTICE of Appearance by Davis Aaron Backer on behalf of All Defendants (Backer, Davis) (Entered: 06/09/2026)

MOTION to Dismiss by DOUG BURGUM, DANIEL P. DRISCOLL, PETE HEGSETH, NEIL JACOBS, BROOKE ROLLINS, PIERRE YARED, LEE M. ZELDIN. (Attachments: # 1 Memorandum in Support, # 2 Text of Proposed Order)(Warren, Sara) (Entered: 06/09/2026)

1 Memorandum in Support

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2 Text of Proposed Order

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Joint MOTION to Modify Briefing Schedule for Federal Defendants' Motion to Dismiss by FRIENDS OF THE EARTH, HEALTHY GULF, OCEANA, INC., SIERRA CLUB, TURTLE ISLAND RESTORATION NETWORK. (Attachments: # 1 Text of Proposed Order)(Mashuda, Stephen) (Entered: 06/18/2026)

1 Text of Proposed Order

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Order on Motion to Modify

MINUTE ORDER granting 26 the parties' Joint Motion to Modify Briefing Schedule for Defendants' Motion to Dismiss: It is hereby ORDERED that Plaintiffs' opposition to 25 the Defendants' Motion to Dismiss shall be due on or before July 14, 2026, and Defendants' reply in support shall be due on or before August 4, 2026. SO ORDERED. Signed by Judge Rudolph Contreras on 06/18/2026. (lcrc3)

Set/Reset Deadlines

Set/Reset Deadlines: Responses due by 7/14/2026; Replies due by 8/4/2026. (tj)

ORDER granting 20 American Petroleum Institute's Motion to Intervene. See document for details. Signed by Judge Rudolph Contreras on 07/14/2026. (lcrc3) (Entered: 07/14/2026)

RESPONSE re 25 MOTION to Dismiss filed by FRIENDS OF THE EARTH, HEALTHY GULF, OCEANA, INC., SIERRA CLUB, TURTLE ISLAND RESTORATION NETWORK. (Attachments: # 1 Declaration of Stephen D. Mashuda, # 2 Exhibit 1 - Hegseth Letter to Burgum, # 3 Exhibit 2 - ESC Hearing Transcript, # 4 Text of Proposed Order)(Mashuda, Stephen) (Entered: 07/14/2026)

1 Declaration of Stephen D. Mashuda

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2 Exhibit 1 - Hegseth Letter to Burgum

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3 Exhibit 2 - ESC Hearing Transcript

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4 Text of Proposed Order

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ANSWER to Complaint by AMERICAN PETROLEUM INSTITUTE.(mg) (Entered: 07/16/2026)

NOTICE of Joinder in Defendants' Motion to Dismiss by AMERICAN PETROLEUM INSTITUTE re 25 Motion to Dismiss (Morgan, Jason) (Entered: 07/17/2026)

MOTION for Leave to File Amicus Brief by FRIENDS OF THE EARTH, HEALTHY GULF, OCEANA, INC., SIERRA CLUB, TURTLE ISLAND RESTORATION NETWORK. (Attachments: # 1 Supplement Proposed Amicus Brief, # 2 Text of Proposed Order )(Fein, Ronald) (Entered: 07/21/2026)

Order on Motion for Leave to Appear Pro Hac Vice

MINUTE ORDER denying 33 Motion for Leave to Appear Pro Hac Vice: Pursuant to Local Civil Rule 83.2(c)(2), an attorney seeking to appear pro hac vice before this Court must submit a declaration that sets forth, among other things, "the number of times the attorney has been admitted pro hac vice in this Court within the last two years." Here, the declaration in support of 33 the pro hac vice motion fails to list the number of times the applicant has been admitted pro hac vice in this Court within the last two years. Although the declaration includes a prompt for this question, and the declarant may have intended to indicate by leaving it blank that he has never been admitted pro hac vice in this Court within the last two years, it remains unclear to the Court whether he simply failed to address this question. Accordingly, the Court will deny the motion without prejudice. SO ORDERED. Signed by Judge Rudolph Contreras on 07/23/2026. (lcrc3)

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Nicholas Roethlisberger, Filing fee $ 100, receipt number ADCDC-12573632. Fee Status: Fee Paid. by WILLIAM S. COHEN, ERIC EDELMAN, ARTHUR E. GARY, CHARLES HAGEL, H. DALE HALL, MICHAEL HAYDEN, FRANK KENDALL, CHRIS KOJM, BRIAN MCKEON, ALBERTO MORA, LEON PANETTA, MARA RUDMAN, P. LYNN SCARLETT, ROBERT S. TYRER. (Attachments: # 1 Declaration, # 2 Exhibit Certificate of Good Standing)(Fein, Ronald) (Entered: 07/28/2026)

Order on Motion for Leave to Appear Pro Hac Vice

MINUTE ORDER granting 34 Motion for Leave to Appear Pro Hac Vice: Pursuant to Local Civil Rule 83.2, it is hereby ORDERED that Nicholas Roethlisberger is admitted to represent pro hac vice in this case the former government officials seeking to participate as amici curiae. Counsel should register for e-filing via PACER and file a notice of appearance pursuant to LCvR 83.6(a) Click for instructions. SO ORDERED. Signed by Judge Rudolph Contreras on 07/30/2026. (lcrc3)

NOTICE of Appearance by Nicholas Alan Roethlisberger on behalf of WILLIAM S. COHEN, ERIC EDELMAN, ARTHUR E. GARY, CHARLES HAGEL, H. DALE HALL, MICHAEL HAYDEN, FRANK KENDALL, CHRIS KOJM, BRIAN MCKEON, ALBERTO MORA, LEON PANETTA, MARA RUDMAN, P. LYNN SCARLETT, ROBERT S. TYRER (Roethlisberger, Nicholas) (Entered: 08/03/2026)

RESPONSE re 32 MOTION for Leave to File Amicus Brief filed by DOUG BURGUM, DANIEL P. DRISCOLL, PETE HEGSETH, NEIL JACOBS, BROOKE ROLLINS, PIERRE YARED, LEE M. ZELDIN. (Backer, Davis) (Entered: 08/04/2026)

REPLY to opposition to motion re 25 Motion to Dismiss filed by DOUG BURGUM, DANIEL P. DRISCOLL, PETE HEGSETH, NEIL JACOBS, BROOKE ROLLINS, PIERRE YARED, LEE M. ZELDIN. (Warren, Sara) (Entered: 08/04/2026)

RESPONSE re 32 MOTION for Leave to File Amicus Brief filed by AMERICAN PETROLEUM INSTITUTE. (Steen, Ryan) (Entered: 08/04/2026)

REPLY to opposition to motion re 25 Motion to Dismiss filed by AMERICAN PETROLEUM INSTITUTE. (Steen, Ryan) (Entered: 08/04/2026)