Case: Brennan v. Blanche

1:26-cv-02323 | U.S. District Court for the District of District of Columbia

Filed Date: July 1, 2026

Case Ongoing

Clearinghouse coding complete

Case Summary

This case seeks to force the United States to preserve investigative records of any potential prosecution of former Central Intelligence Agency (CIA) director John Brennan. On July 1, 2026, ex-director Brennan filed this lawsuit in the United States District Court for the District of Columbia. The plaintiff sued the Department of Justice, CIA, President Trump, and various other federal officials under the Mandamus Act  and All Writs Act. The plaintiff alleged that President Trump repeatedly bra…

This case seeks to force the United States to preserve investigative records of any potential prosecution of former Central Intelligence Agency (CIA) director John Brennan. On July 1, 2026, ex-director Brennan filed this lawsuit in the United States District Court for the District of Columbia. The plaintiff sued the Department of Justice, CIA, President Trump, and various other federal officials under the Mandamus Act  and All Writs Act. The plaintiff alleged that President Trump repeatedly branded him as a criminal, before a conviction or even an investigation, and wished to prosecute him for years. As a result, the plaintiff argued that he may have a due process defense for selective and vindictive prosecution in a future criminal proceeding, and investigative records from the federal government may prove useful in establishing that defense. The plaintiff argued that the federal government’s history of failing to preserve critical records warranted a writ requiring the government to preserve records pertaining to any future criminal case against him. Represented by private counsel, the plaintiff seeks a declaratory judgment and an order requiring the defendants to preserve investigative records relating to any future criminal charges against the plaintiff.

Alongside his complaint, the plaintiff moved for a preliminary injunction on July 1, 2026.

The case was assigned to District Judge Jia M. Cobb.

On July 28, 2026, the defendants moved to dismiss the case for lack of subject-matter jurisdiction and failure to state a claim. As of August 7, 2026, the Court has not ruled on the motion to dismiss or the motion for preliminary injunction.

 

Summary Authors

Sam Black (8/7/2026)

People

For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/73562893/parties/brennan-v-blanche/


Attorney for Plaintiff

Gelber, Daniel (District of Columbia)

Greenberg, Gerald Edward (District of Columbia)

Harnwell-Davis, Natasha (District of Columbia)

Attorney for Defendant
Expert/Monitor/Master/Other

Carroll, Kevin T. (District of Columbia)

Francois, Aderson Bellegarde (District of Columbia)

Documents in the Clearinghouse

Documents in this case
1

1:26-cv-02323

Complaint

Brennan v. Blanche et al.

July 1, 2026

July 1, 2026

Complaint

Docket

See docket on RECAP: https://www.courtlistener.com/docket/73562893/brennan-v-blanche/

Last updated Aug. 22, 2026, 3:08 a.m.

Docket for: BRENNAN v. BLANCHE
ECF Number Date Description Link
1 July 1, 2026

COMPLAINT against TODD W. BLANCHE, CENTRAL INTELLIGENCE AGENCY, JOSEPH E. DIGENOVA, EXECUTIVE OFFICE OF THE PRESIDENT, OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, KASH P. PATEL, JOHN L. RATCLIFFE, JASON A. REDING QUIONES, DONALD J. TRUMP, UNITED STATES DEPARTMENT OF JUSTICE, SUSAN L. WILES ( Filing fee $ 405 receipt number ADCDC-12520371) filed by JOHN O. BRENNAN. (Attachments: # 1 Appendix A, # 2 Appendix B, # 3 Summons - Todd Blanche, # 4 Summons - Department of Justice, # 5 Summons - Jason A. Reding Quinones, # 6 Summons - Joseph E. diGenova, # 7 Summons - Kash Patel, # 8 Summons - Donald J. Trump, # 9 Summons - Executive Office of the President, # 10 Summons - Susan L. Wiles, # 11 Summons - John Ratcliffe, # 12 Summons - Central Intelligence Agency, # 13 Summons - Office of the Director of National Intelligence, # 14 Summons - U.S. Attorney for the District of Columbia, # 15 Civil Cover Sheet)(Wainstein, Kenneth) (Entered: 07/01/2026)

1 Appendix A

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2 Appendix B

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3 Summons - Todd Blanche

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4 Summons - Department of Justice

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5 Summons - Jason A. Reding Quinones

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6 Summons - Joseph E. diGenova

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7 Summons - Kash Patel

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8 Summons - Donald J. Trump

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9 Summons - Executive Office of the President

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10 Summons - Susan L. Wiles

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11 Summons - John Ratcliffe

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12 Summons - Central Intelligence Agency

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13 Summons - Office of the Director of National Intelligence

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14 Summons - U.S. Attorney for the District of Columbia

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15 Civil Cover Sheet

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Clearinghouse
2 July 1, 2026

MOTION for Preliminary Injunction by JOHN O. BRENNAN. (Attachments: # 1 Memorandum in Support, # 2 Declaration of Kenneth L. Wainstein, # 3 Exhibit 1, # 4 Exhibit 2, # 5 Exhibit 3, # 6 Exhibit 4, # 7 Exhibit 5, # 8 Exhibit 6, # 9 Exhibit 7, # 10 Exhibit 8, # 11 Exhibit 9, # 12 Exhibit 10, # 13 Exhibit 11, # 14 Exhibit 12, # 15 Exhibit 13, # 16 Exhibit 14, # 17 Exhibit 15, # 18 Exhibit 16, # 19 Exhibit 17, # 20 Exhibit 18, # 21 Exhibit 19, # 22 Exhibit 20, # 23 Exhibit 21, # 24 Exhibit 22, # 25 Exhibit 23, # 26 Exhibit 24, # 27 Exhibit 25, # 28 Exhibit 26, # 29 Exhibit 27, # 30 Exhibit 28, # 31 Exhibit 29, # 32 Exhibit 30, # 33 Exhibit 31, # 34 Exhibit 32, # 35 Exhibit 33, # 36 Exhibit 34, # 37 Exhibit 35, # 38 Exhibit 36, # 39 Exhibit 37, # 40 Exhibit 38, # 41 Exhibit 39, # 42 Exhibit 40, # 43 Exhibit 41, # 44 Exhibit 42, # 45 Exhibit 43, # 46 Exhibit 44, # 47 Exhibit 45, # 48 Exhibit 46, # 49 Exhibit 47, # 50 Exhibit 48, # 51 Exhibit 49, # 52 Exhibit 50, # 53 Exhibit 51, # 54 Exhibit 52, # 55 Exhibit 53, # 56 Exhibit 54, # 57 Exhibit 55, # 58 Exhibit 56, # 59 Exhibit 57, # 60 Exhibit 58, # 61 Exhibit 59, # 62 Exhibit 60, # 63 Exhibit 61, # 64 Exhibit 62, # 65 Exhibit 63, # 66 Exhibit 64, # 67 Exhibit 65, # 68 Exhibit 66, # 69 Exhibit 67, # 70 Exhibit 68, # 71 Exhibit 69, # 72 Exhibit 70, # 73 Exhibit 71, # 74 Exhibit 72, # 75 Exhibit 73, # 76 Exhibit 74, # 77 Exhibit 75, # 78 Exhibit 76, # 79 Exhibit 77, # 80 Exhibit 78, # 81 Exhibit 79, # 82 Text of Proposed Order)(Wainstein, Kenneth) (Entered: 07/01/2026)

1 Memorandum in Support

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2 Declaration of Kenneth L. Wainstein

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3 Exhibit 1

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4 Exhibit 2

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5 Exhibit 3

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6 Exhibit 4

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7 Exhibit 5

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8 Exhibit 6

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9 Exhibit 7

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10 Exhibit 8

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11 Exhibit 9

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12 Exhibit 10

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13 Exhibit 11

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14 Exhibit 12

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15 Exhibit 13

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16 Exhibit 14

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17 Exhibit 15

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18 Exhibit 16

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19 Exhibit 17

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20 Exhibit 18

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21 Exhibit 19

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22 Exhibit 20

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23 Exhibit 21

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24 Exhibit 22

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25 Exhibit 23

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26 Exhibit 24

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27 Exhibit 25

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28 Exhibit 26

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29 Exhibit 27

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30 Exhibit 28

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31 Exhibit 29

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32 Exhibit 30

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33 Exhibit 31

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34 Exhibit 32

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35 Exhibit 33

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36 Exhibit 34

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37 Exhibit 35

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38 Exhibit 36

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39 Exhibit 37

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40 Exhibit 38

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41 Exhibit 39

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42 Exhibit 40

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43 Exhibit 41

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44 Exhibit 42

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45 Exhibit 43

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46 Exhibit 44

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47 Exhibit 45

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48 Exhibit 46

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49 Exhibit 47

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50 Exhibit 48

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51 Exhibit 49

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52 Exhibit 50

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53 Exhibit 51

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54 Exhibit 52

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55 Exhibit 53

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56 Exhibit 54

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57 Exhibit 55

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58 Exhibit 56

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59 Exhibit 57

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60 Exhibit 58

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61 Exhibit 59

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62 Exhibit 60

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63 Exhibit 61

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64 Exhibit 62

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65 Exhibit 63

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66 Exhibit 64

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67 Exhibit 65

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68 Exhibit 66

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69 Exhibit 67

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70 Exhibit 68

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71 Exhibit 69

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72 Exhibit 70

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73 Exhibit 71

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74 Exhibit 72

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75 Exhibit 73

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76 Exhibit 74

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77 Exhibit 75

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78 Exhibit 76

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79 Exhibit 77

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80 Exhibit 78

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81 Exhibit 79

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82 Text of Proposed Order

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3 July 1, 2026

SEALED DOCUMENT filed by JOHN O. BRENNAN re 1 Complaint,,, (This document is SEALED and only available to authorized persons.)(Wainstein, Kenneth) (Entered: 07/01/2026)

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4 July 1, 2026

NOTICE of Appearance by Kenneth Leonard Wainstein on behalf of JOHN O. BRENNAN (Wainstein, Kenneth) (Entered: 07/01/2026)

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5 July 1, 2026

NOTICE of Appearance by Natasha Harnwell-Davis on behalf of JOHN O. BRENNAN (Harnwell-Davis, Natasha) (Entered: 07/01/2026)

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6 July 1, 2026

SUMMONS (12) Issued Electronically as to All Defendants, U.S. Attorney and U.S. Attorney General (Attachments: # 1 Notice and Consent)(gsk) (Entered: 07/01/2026)

1 Notice and Consent

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July 1, 2026

Case Assigned/Reassigned

July 1, 2026

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

July 2, 2026

Status Report Order

July 2, 2026

MINUTE ORDER re Plaintiff's 2 Motion for Preliminary Injunction: The Court intends to set a briefing schedule and hearing date regarding the motion.The Local Civil Rules of this Court provide that by default, an opposition to a motion for preliminary injunction is to be filed within seven days of the service of the application for preliminary injunction. LCvR 65.1(c). However, the Court cannot set this date yet as it is not clear that Defendants have been served with the complaint or motion.Should the Parties wish to set a briefing schedule outside of the default deadlines under Local Civil Rule 65.1, including to provide for the opportunity for any reply, the Parties shall confer and file a proposed briefing schedule for the preliminary injunction motion by July 8, 2026 at 10:00 AM. Given that Defendants have not yet entered an appearance, to the extent that Plaintiff has been in contact with counsel for the Government who will represent Defendants in this case, Plaintiff shall send a copy of this order to counsel for Defendants. Signed by Judge Jia M. Cobb on July 2, 2026. (lcjmc1)

7 July 7, 2026

NOTICE of Appearance by Jeremy Samuel Bloch Newman on behalf of All Defendants (Newman, Jeremy) (Entered: 07/07/2026)

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8 July 7, 2026

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Daniel S. Gelber, Filing fee $ 100, receipt number ADCDC-12530510. Fee Status: Fee Paid. by JOHN O. BRENNAN. (Wainstein, Kenneth) (Entered: 07/07/2026)

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9 July 7, 2026

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Joan M. Silverstein, Filing fee $ 100, receipt number ADCDC-12530530. Fee Status: Fee Paid. by JOHN O. BRENNAN. (Wainstein, Kenneth) (Entered: 07/07/2026)

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10 July 8, 2026

MOTION for Briefing Schedule for Plaintiff's Motion for a Preliminary Injunction by JOHN O. BRENNAN. (Attachments: # 1 Text of Proposed Order)(Wainstein, Kenneth) (Entered: 07/08/2026)

1 Text of Proposed Order

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July 8, 2026

Order on Motion for Briefing Schedule AND Set/Reset Deadlines

July 8, 2026

Order on Motion for Leave to Appear Pro Hac Vice

July 8, 2026

MINUTE ORDER granting 10 Motion for Briefing Schedule: Having considered Plaintiff's Motion to Approve the Parties' Agreed-Upon Briefing Schedule, it is hereby ORDERED that, for good cause shown, the motion is GRANTED; it is further ORDERED that Plaintiff's 2 Motion for Preliminary Injunction shall be briefed according to the following schedule: Any amicus curiae briefs in support of either party shall be filed on or before July 23, 2026; Defendants shall file any response to Plaintiff's motion on or before July 28, 2026; and Plaintiff shall file a reply in support of his motion on or before August 11, 2026.The Court finds that, based on the Parties' mutual consent to this briefing schedule, good cause exists to set a hearing on the motion beyond the 21 days set in Local Civil Rule 65.1(d), and that a later hearing date will not cause prejudice. Signed by Judge Jia M. Cobb on July 8, 2026. (lcjmc1)

July 8, 2026

MINUTE ORDER granting 8 Motion for Leave to Appear Pro Hac Vice: Attorney Daniel Saul Gelber 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 8, 2026. (lcjmc1)

July 8, 2026

MINUTE ORDER granting 9 Motion for Leave to Appear Pro Hac Vice: Attorney Joan Maxine Silverstein 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 8, 2026. (lcjmc1)

11 July 9, 2026

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Gerald E. Greenberg, Filing fee $ 100, receipt number ADCDC-12535487. Fee Status: Fee Paid. by JOHN O. BRENNAN. (Attachments: # 1 Declaration, # 2 Certificate of Good Standing, # 3 Text of Proposed Order)(Wainstein, Kenneth) (Entered: 07/09/2026)

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July 9, 2026

Order on Motion for Leave to Appear Pro Hac Vice

July 9, 2026

MINUTE ORDER granting 11 Motion for Leave to Appear Pro Hac Vice: Attorney Gerald Edward Greenberg 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 9, 2026. (lcjmc1)

12 July 10, 2026

NOTICE of Appearance by Joan Maxine Silverstein on behalf of JOHN O. BRENNAN (Silverstein, Joan) (Entered: 07/10/2026)

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13 July 10, 2026

NOTICE of Appearance by Daniel Gelber on behalf of JOHN O. BRENNAN (Gelber, Daniel) (Entered: 07/10/2026)

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14 July 14, 2026

NOTICE of Appearance by Gerald Edward Greenberg on behalf of JOHN O. BRENNAN (Greenberg, Gerald) (Entered: 07/14/2026)

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15 July 22, 2026

NOTICE of Appearance by Aderson Bellegarde Francois on behalf of LAWYERS DEFENDING AMERICAN DEMOCRACY, INC (Francois, Aderson) (Main Document 15 replaced on 7/23/2026) (znmw). (Entered: 07/22/2026)

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16 July 23, 2026

MOTION for Leave to File Amicus Brief by LAWYERS DEFENDING AMERICAN DEMOCRACY, INC. (Attachments: # 1 Memorandum in Support, # 2 Text of Proposed Order)(Francois, Aderson) (Entered: 07/23/2026)

1 Memorandum in Support

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2 Text of Proposed Order

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17 July 23, 2026

Unopposed MOTION for Leave to File Amicus Briefby The Steady State on behalf of Plaintiff by STEADY STATE. (Attachments: # 1 Declaration Declaration of Steven A. Cash, # 2 Text of Proposed Order Proposed order granting leave to file an amicus brief, # 3 Exhibit Brief in support of Plaintiff's motion for injunctive relief, # 4 Declaration Certificate of compliance, # 5 Certificate of Service Certificate of service)(Carroll, Kevin) Modified filer on 7/24/2026 (znmw). (Entered: 07/23/2026)

3

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July 24, 2026

.Order AND ~Util - Set/Reset Deadlines/Hearings

July 24, 2026

MINUTE ORDER: It is hereby ORDERED that the Parties shall appear for a motion hearing regarding Plaintiff's 2 Motion for a Preliminary Injunction. At the request of the Parties, the hearing shall be set for September 14, 2026, at 1:30 PM. The hearing will be on the record before Judge Jia M. Cobb in Courtroom 3. Signed by Judge Jia M. Cobb on July 24, 2026. (lcjmc1)

18 July 27, 2026

AMICUS BRIEF in support of Plaintiff's motion for injunctive relief by STEADY STATE. (Carroll, Kevin) (Entered: 07/27/2026)

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19 July 27, 2026

AMICUS BRIEF by LAWYERS DEFENDING AMERICAN DEMOCRACY, INC. (znmw) (Entered: 07/28/2026)

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July 27, 2026

Order on Motion for Leave to File Amicus Brief

July 27, 2026

MINUTE ORDER granting 16 Motion for Leave to File Amicus Brief: Having considered Lawyers Defending American Democracy's unopposed motion for leave to file a brief as amicus curiae, the Court GRANTS the motion. It is further ORDERED that the proposed brief accompanying the motion, ECF 16-1, be filed.Signed by Judge Jia M. Cobb on July 27, 2026. (lcjmc1)

July 27, 2026

MINUTE ORDER granting 17 Motion for Leave to File Amicus Brief: Having considered The Steady State's unopposed motion for leave to file a brief as amicus curiae, the Court GRANTS the motion. It is further ORDERED that the proposed brief accompanying the motion, ECF 17-3, be filed.Signed by Judge Jia M. Cobb on July 27, 2026. (lcjmc1)

20 July 28, 2026

Memorandum in opposition to re 2 MOTION for Preliminary Injunction filed by TODD W. BLANCHE, CENTRAL INTELLIGENCE AGENCY, JOSEPH E. DIGENOVA, EXECUTIVE OFFICE OF THE PRESIDENT, OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, KASH P. PATEL, JOHN L. RATCLIFFE, JASON A. REDING QUIONES, DONALD J. TRUMP, UNITED STATES DEPARTMENT OF JUSTICE, SUSAN L. WILES. (Attachments: # 1 Text of Proposed Order)(Newman, Jeremy) (Entered: 07/28/2026)

1 Text of Proposed Order

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21 July 28, 2026

MOTION to Dismiss for Lack of Jurisdiction, MOTION to Dismiss the Complaint by TODD W. BLANCHE, CENTRAL INTELLIGENCE AGENCY, JOSEPH E. DIGENOVA, EXECUTIVE OFFICE OF THE PRESIDENT, OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, KASH P. PATEL, JOHN L. RATCLIFFE, JASON A. REDING QUIONES, DONALD J. TRUMP, UNITED STATES DEPARTMENT OF JUSTICE, SUSAN L. WILES. (Attachments: # 1 Memorandum in Support, # 2 Text of Proposed Order)(Newman, Jeremy) (Entered: 07/28/2026)

1 Memorandum in Support

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2 Text of Proposed Order

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22 July 31, 2026

MOTION for Leave to File Corrected Brief by LAWYERS DEFENDING AMERICAN DEMOCRACY, INC. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Text of Proposed Order)(Francois, Aderson) (Entered: 07/31/2026)

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23 July 31, 2026

Amended AMICUS BRIEF by LAWYERS DEFENDING AMERICAN DEMOCRACY, INC. (znmw) Modified on 8/5/2026 (znmw). (Entered: 08/05/2026)

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July 31, 2026

Order on Motion for Leave to File

July 31, 2026

MINUTE ORDER granting 22 Motion for Leave to File Corrected Amicus Brief: Having considered the motion, the Court GRANTS the motion. It is hereby ORDERED that the proposed corrected amicus brief accompanying the motion, ECF 22-1, be filed in place of ECF 19. Signed by Judge Jia M. Cobb on July 31, 2026. (lcjmc1)

24 Aug. 6, 2026

Unopposed MOTION for Leave to File One Combined Memorandum of Law by JOHN O. BRENNAN. (Attachments: # 1 Text of Proposed Order)(Wainstein, Kenneth) (Entered: 08/06/2026)

1 Text of Proposed Order

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Aug. 6, 2026

Order on Motion for Leave to File

Aug. 6, 2026

MINUTE ORDER granting 24 Motion for Leave to File One Combined Memorandum of Law: Having considered Plaintiff's unopposed motion, the Court GRANTS the motion. Plaintiff shall be permitted to file a combined memorandum of law as his reply in support of the 2 motion for a preliminary injunction and opposition to 21 Defendants' motion to dismiss. Signed by Judge Jia M. Cobb on August 6, 2026. (lcjmc1)

25 Aug. 11, 2026

REPLY to opposition to motion re 2 Motion for Preliminary Injunction,,,,,, filed by JOHN O. BRENNAN. (Attachments: # 1 Supplemental Declaration of Kenneth L Wainstein, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E)(Wainstein, Kenneth) (Entered: 08/11/2026)

1 Supplemental Declaration of Kenneth L Wainstein

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2 Exhibit A

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3 Exhibit B

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4 Exhibit C

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5 Exhibit D

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6 Exhibit E

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26 Aug. 11, 2026

Memorandum in opposition to re 21 MOTION to Dismiss for Lack of Jurisdiction MOTION to Dismiss the Complaint filed by JOHN O. BRENNAN. (Attachments: # 1 Supplemental Declaration of Kenneth Wainstein, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E)(Wainstein, Kenneth) (Entered: 08/11/2026)

1 Supplemental Declaration of Kenneth Wainstein

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2 Exhibit A

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3 Exhibit B

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4 Exhibit C

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5 Exhibit D

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6 Exhibit E

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27 Aug. 18, 2026

REPLY to opposition to motion re 21 Motion to Dismiss/Lack of Jurisdiction,,, filed by TODD W. BLANCHE, CENTRAL INTELLIGENCE AGENCY, JOSEPH E. DIGENOVA, EXECUTIVE OFFICE OF THE PRESIDENT, OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, KASH P. PATEL, JOHN L. RATCLIFFE, JASON A. REDING QUIONES, DONALD J. TRUMP, UNITED STATES DEPARTMENT OF JUSTICE, SUSAN L. WILES. (Newman, Jeremy) (Entered: 08/18/2026)

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Case Details

State / Territory:

District of Columbia

Case Type(s):

Presidential/Gubernatorial Authority

Special Collection(s):

Donald Trump personal capacity lawsuits

Trump Administration 2.0: Challenges to the Government

Key Dates

Filing Date: July 1, 2026

Case Ongoing: Yes

Plaintiffs

Plaintiff Description:

The plaintiff, John Brennan, is a former director of the CIA.

Plaintiff Type(s):

Private Plaintiff

Public Interest Lawyer: No

Filed Pro Se: No

Class Action Sought: No

Class Action Outcome: Not sought

Defendants

Federal

Central Intelligence Agency

Donald Trump

Federal Bureau of Investigation

Office of the Director of National Intelligence

United States Department of Justice

Defendant Type(s):

Jurisdiction-wide

Law-enforcement

Case Details

Causes of Action:

All Writs Act, 28 U.S.C. § 1651

Mandamus, 28 U.S.C. § 1361

Constitutional Clause(s):

Due Process

Due Process: Procedural Due Process

Other Dockets:

District of District of Columbia 1:26-cv-02323

Available Documents:

Complaint (any)

Trial Court Docket

Outcome

Prevailing Party: None Yet / None

Relief Sought:

Declaratory judgment

Injunction

Relief Granted:

None yet

Source of Relief:

None yet

Issues

General/Misc.:

Record-keeping

Recommended Citation