Case: Iranian American Legal Defense Fund v. Rubio

Iranian American Legal Defense Fund v. Rubio et al.

COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF against All Defendants ( Filing fee $ 405 receipt number ADCDC-12527922) filed by IRANIAN AMERICAN LEGAL DEFENSE FUND. (Attachments: # 1 Civil Cover Sheet, # 2 Summons to Marco Rubio, # 3 Summons to U.S. Department of State, # 4 Summons to Markwayne Mullin, # 5 Summons to U.S. Department of Homeland Security, # 6 Summons to David Venturella, # 7 Summons to U.S. Immigration and Customs Enforcement)(Kirkpatrick, Michael) (Entered: 07/07/2026)

1 Civil Cover Sheet

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2 Summons to Marco Rubio

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3 Summons to U.S. Department of State

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4 Summons to Markwayne Mullin

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5 Summons to U.S. Department of Homeland Security

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6 Summons to David Venturella

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7 Summons to U.S. Immigration and Customs Enforcement

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LCvR 26.1 CERTIFICATE OF DISCLOSURE of Corporate Affiliations and Financial Interests by IRANIAN AMERICAN LEGAL DEFENSE FUND (Kirkpatrick, Michael) (Entered: 07/07/2026)

SUMMONS (6) Issued Electronically as to All Defendants. (Attachments: # 1 Notice and Consent)(zmtm) (Entered: 07/07/2026)

NOTICE of Appearance by Hoyeon Kelly Lew on behalf of IRANIAN AMERICAN LEGAL DEFENSE FUND (Lew, Hoyeon) (Entered: 07/07/2026)

REQUEST FOR SUMMONS TO ISSUE filed by IRANIAN AMERICAN LEGAL DEFENSE FUND. Related document: Notice of Error- New Case,. (Attachments: # 1 Summons to U.S. Attorney, # 2 Summons to U.S. Attorney General)(Kirkpatrick, Michael) (Entered: 07/07/2026)

STANDING ORDER. The Court ORDERS the parties to comply with its Standing Order. See Order for details. Signed by Judge Ana C. Reyes on 7/7/2026. (lcacr1) (Entered: 07/07/2026)

Case Assigned/Reassigned

Notice of Error- New Case

Case Assigned to Judge Ana C. Reyes. (zmtm)

NOTICE OF NEW CASE ERROR The following error(s) need correction: Missing summonses- U.S. government. When naming a U.S. government agent or agency as a defendant, you must supply a summons for each defendant & two additional summonses for the U.S. Attorney & U.S. Attorney General. Please submit using the event Request for Summons to Issue. (zmtm)

SUMMONS (2) Issued Electronically as to U.S. Attorney and U.S. Attorney General (znmw) (Entered: 07/09/2026)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed as to the United States Attorney. Date of Service Upon United States Attorney on 7/9/2026. Answer due for ALL FEDERAL DEFENDANTS by 9/7/2026. (Attachments: # 1 Exhibit Confirmation of Receipt by USAO)(Kirkpatrick, Michael) (Entered: 07/09/2026)

MOTION for Preliminary Injunction and Section 705 Stay by IRANIAN AMERICAN LEGAL DEFENSE FUND. (Attachments: # 1 Memorandum in Support, # 2 Index of Exhibits, # 3 Exhibit 1 Declaration of Ali Rahnama, # 4 Exhibit 2 Second Declaration of Ali Rahnama, # 5 Exhibit 2 Second Declaration of Ali Rahnama Part 2, # 6 Exhibit 3 Declaration of Cyrus Mehria, # 7 Exhibit 4 Declaration of Pastor Hoospianmer, # 8 Exhibit 5 Congressional Research Service, Iran: Background and Policy (May 22, 2025), # 9 Exhibit 6 U.S. Department of State, U.S. Relations with Iran (Apr. 1, 2022), # 10 Exhibit 7 N.Y. Times, Pakistan to Handle Iranian Affairs in U.S. (Mar. 17, 1992), # 11 Exhibit 8 U.S. Department of State, Iran 2024 Human Rights Report (Aug. 12, 2025), # 12 Exhibit 9 U.N. Human Rights Office, Iran: UN Experts Demand Transparency and Accountability Following Nationwide Protests (Feb. 20, 2026), # 13 Exhibit 10 Iran Human Rights Monitor, Monthly Report June 2026, # 14 Exhibit 11 Reuters, Third Batch of Iranians Deported by US to Return Home (Jan. 26, 2026), # 15 Exhibit 12 N.Y. Times, U.S. Deports Planeload of Iranians After Deal With Tehran, Officials Say (Sept. 30, 2025), # 16 Exhibit 13 N.Y. Times, U.S. Deports Second Planeload of Iranians, Officials Say (Dec. 7, 2025), # 17 Text of Proposed Order)(Kirkpatrick, Michael). Added MOTION to Stay on 7/15/2026 (znmw). (Entered: 07/15/2026)

1 Memorandum in Support

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2 Index of Exhibits

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3 Exhibit 1 Declaration of Ali Rahnama

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4 Exhibit 2 Second Declaration of Ali Rahnama

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5 Exhibit 2 Second Declaration of Ali Rahnama Part 2

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6 Exhibit 3 Declaration of Cyrus Mehria

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7 Exhibit 4 Declaration of Pastor Hoospianmer

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8 Exhibit 5 Congressional Research Service, Iran: Background and Policy (May 22, 2

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9 Exhibit 6 U.S. Department of State, U.S. Relations with Iran (Apr. 1, 2022)

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10 Exhibit 7 N.Y. Times, Pakistan to Handle Iranian Affairs in U.S. (Mar. 17, 1992)

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11 Exhibit 8 U.S. Department of State, Iran 2024 Human Rights Report (Aug. 12, 2025

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12 Exhibit 9 U.N. Human Rights Office, Iran: UN Experts Demand Transparency and Acc

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13 Exhibit 10 Iran Human Rights Monitor, Monthly Report June 2026

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14 Exhibit 11 Reuters, Third Batch of Iranians Deported by US to Return Home (Jan.

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15 Exhibit 12 N.Y. Times, U.S. Deports Planeload of Iranians After Deal With Tehran

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16 Exhibit 13 N.Y. Times, U.S. Deports Second Planeload of Iranians, Officials Say

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17 Text of Proposed Order

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RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. MARCO RUBIO served on 7/13/2026 (Attachments: # 1 USPS Tracking History)(Kirkpatrick, Michael) (Entered: 07/15/2026)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. U.S. DEPARTMENT OF STATE served on 7/13/2026 (Attachments: # 1 USPS Tracking History)(Kirkpatrick, Michael) (Entered: 07/15/2026)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. MARKWAYNE MULLIN served on 7/13/2026 (Attachments: # 1 USPS Tracking History)(Kirkpatrick, Michael) (Entered: 07/15/2026)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. U.S. DEPARTMENT OF HOMELAND SECURITY served on 7/13/2026 (Attachments: # 1 USPS Tracking History)(Kirkpatrick, Michael) (Entered: 07/15/2026)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. DAVID VENTURELLA served on 7/13/2026 (Attachments: # 1 USPS Tracking History)(Kirkpatrick, Michael) (Entered: 07/15/2026)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. U.S. IMMIGRATION AND CUSTOMS ENFORCEMENT served on 7/13/2026 (Attachments: # 1 USPS Tracking History)(Kirkpatrick, Michael) (Entered: 07/15/2026)

NOTICE of Appearance by Dimitar Georgiev-Remmel on behalf of MARKWAYNE MULLIN, MARCO RUBIO, U.S. DEPARTMENT OF HOMELAND SECURITY, U.S. DEPARTMENT OF STATE, U.S. IMMIGRATION AND CUSTOMS ENFORCEMENT, DAVID VENTURELLA (Georgiev-Remmel, Dimitar) (Entered: 07/15/2026)

MOTION for Extension of Time to File Response/Reply as to 9 MOTION for Preliminary Injunction and Section 705 Stay MOTION to Stay by MARKWAYNE MULLIN, MARCO RUBIO, U.S. DEPARTMENT OF HOMELAND SECURITY, U.S. DEPARTMENT OF STATE, U.S. IMMIGRATION AND CUSTOMS ENFORCEMENT, DAVID VENTURELLA. (Georgiev-Remmel, Dimitar) (Entered: 07/17/2026)

Memorandum in opposition to re 17 MOTION for Extension of Time to File Response/Reply as to 9 MOTION for Preliminary Injunction and Section 705 Stay MOTION to Stay filed by IRANIAN AMERICAN LEGAL DEFENSE FUND. (Attachments: # 1 Text of Proposed Order)(Kirkpatrick, Michael) (Entered: 07/17/2026)

1 Text of Proposed Order

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NOTICE of Appearance by Ali Rahnama on behalf of IRANIAN AMERICAN LEGAL DEFENSE FUND (Rahnama, Ali) (Entered: 07/17/2026)

.Order

Order

Order on Motion for Extension of Time to File Response/Reply

MINUTE ORDER. Upon consideration of Defendants' 17 Motion for Extension of Time, the Court ORDERS Plaintiff to file any opposition to Defendants' Motion by the close of business today. Signed by Judge Ana C. Reyes on 7/17/2026. (lcacr3)

MINUTE ORDER granting in part 17 Defendants' Motion for Extension of Time. The Court ORDERS Defendants to file their response to Plaintiff's 9 Motion for Preliminary Injunction and Section 705 Stay on or before July 29, 2026. Signed by Judge Ana C. Reyes on 7/17/2026. (lcacr3)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed on United States Attorney General. Date of Service Upon United States Attorney General 07/20/2026. (Attachments: # 1 USPS Tracking History)(Kirkpatrick, Michael) (Entered: 07/20/2026)

NOTICE of Appearance by Dhruman Y. Sampat on behalf of MARKWAYNE MULLIN, MARCO RUBIO, U.S. DEPARTMENT OF HOMELAND SECURITY, U.S. DEPARTMENT OF STATE, U.S. IMMIGRATION AND CUSTOMS ENFORCEMENT, DAVID VENTURELLA (Sampat, Dhruman) (Entered: 07/21/2026)

MOTION for Hearing re 9 MOTION for Preliminary Injunction and Section 705 Stay MOTION to Stay by IRANIAN AMERICAN LEGAL DEFENSE FUND. (Attachments: # 1 Text of Proposed Order)(Kirkpatrick, Michael) (Entered: 07/27/2026)

Order on Motion for Hearing

MINUTE ORDER granting 22 Motion for Hearing. The Court ORDERS the parties to appear for a hearing on the 9 Motion for Preliminary Injunction and Section 705 Stay on August 5, 2026, at 3pm in Courtroom 12. Signed by Judge Ana C. Reyes on 7/27/2026. (lcacr1)

Memorandum in opposition to re 9 MOTION for Preliminary Injunction and Section 705 Stay MOTION to Stay filed by MARKWAYNE MULLIN, MARCO RUBIO, U.S. DEPARTMENT OF HOMELAND SECURITY, U.S. DEPARTMENT OF STATE, U.S. IMMIGRATION AND CUSTOMS ENFORCEMENT, DAVID VENTURELLA. (Attachments: # 1 Exhibit, # 2 Declaration)(Georgiev-Remmel, Dimitar) (Entered: 07/29/2026)

1 Exhibit

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2 Declaration

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Set/Reset Deadlines/Hearings

Set/Reset Deadlines/Hearings: Motion Hearing set for 8/5/2026 at 3:00 PM in Courtroom 12 before Judge Ana C. Reyes. (zcdw)

Set/Reset Deadlines/Hearings: Motion Hearing (Public Access Line available) set for 8/5/2026 at 3:00 PM in Courtroom 12 before Judge Ana C. Reyes. (zcdw) Modified on 8/4/2026 to update hearing location. (zcdw).

REPLY to opposition to motion re 9 Motion for Preliminary Injunction,,,,,, Motion to Stay,,,,, filed by IRANIAN AMERICAN LEGAL DEFENSE FUND. (Kirkpatrick, Michael) (Entered: 07/31/2026)

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Becca Steinberg, Filing fee $ 100, receipt number ADCDC-12584964. Fee Status: Fee Paid. by IRANIAN AMERICAN LEGAL DEFENSE FUND. (Attachments: # 1 Declaration of Becca Steinberg for pro hac vice admission, # 2 Text of Proposed Order)(Kirkpatrick, Michael) (Entered: 08/03/2026)

ERRATA by IRANIAN AMERICAN LEGAL DEFENSE FUND re 25 Motion for Leave to Appear Pro Hac Vice,. (Attachments: # 1 Certificate of Good Standing)(Kirkpatrick, Michael) (Entered: 08/04/2026)

NOTICE of Appearance by Becca Steinberg on behalf of IRANIAN AMERICAN LEGAL DEFENSE FUND (Steinberg, Becca) (Entered: 08/04/2026)

Notice of Error

NOTICE OF ERROR regarding 25 MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Becca Steinberg, Filing fee $ 100, receipt number ADCDC-12584964. Fee Status: Fee Paid.. The following error(s) need correction: Pro Hac Vice motion must be accompanied by a Certificate of Good Standing issued within the last 30 days (LCvR 83.2(c)(2)). Please file certificate as an Errata (znmw)

.Order

Order on Motion for Leave to Appear Pro Hac Vice

MINUTE ORDER granting 25 Motion for Leave to Appear Pro Hac Vice. Attorney Becca Steinberg is admitted pro hac vice. 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 Ana C. Reyes on 8/4/2026. (lcacr1)

Order

MINUTE ORDER. The hearing scheduled for August 5, 2026, at 3:00 p.m. will be made accessible to the public telephonically via the Courtroom Public Access Line. The Public Access telephone number is 1-833-990-9400, and the meeting ID is 787605272. Persons remotely accessing court proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting any court proceedings (including those held by telephone or videoconference). Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry/denial of entry to future hearings, or any other sanctions the Court deems necessary. Signed by Judge Ana C. Reyes on 8/4/2026. (lcacr1)

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Bardia Arasteh, Filing fee $ 100, receipt number ADCDC-12590564. Fee Status: Fee Paid. by IRANIAN AMERICAN LEGAL DEFENSE FUND. (Attachments: # 1 Declaration Declaration and Attorney Certification, # 2 Text of Proposed Order Proposed Order)(Rahnama, Ali) (Attachment 1 replaced on 8/5/2026) (znmw). (Entered: 08/05/2026)

1 Declaration Declaration and Attorney Certification

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2 Text of Proposed Order Proposed Order

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Notice of Error

NOTICE OF ERROR regarding 28 MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Bardia Arasteh, Filing fee $ 100, receipt number ADCDC-12590564. Fee Status: Fee Paid.. The following error(s) need correction: Declaration must have an original, ink signature. Please refile using the event Declaration. (znmw)

Motion Hearing

Minute Entry for proceedings held before Judge Ana C. Reyes: Motion Hearing held on 8/5/2026 re 9 Motion for Stay Under 5 U.S.C. § 705 and for a Preliminary Injunction. Motion heard and taken under advisement. Parties directed to contact the Courtroom Deputy to schedule an Evidentiary Hearing for a date in August or September. (Court Reporter: Lisa Edwards) (zcdw)

TRANSCRIPT OF MOTION HEARING before Judge Ana C. Reyes held on August 5, 2026; Page Numbers: 1-51. Date of Issuance: August 6, 2026. Court Reporter/Transcriber Lisa Edwards, Telephone number (202) 354-3269, Transcripts may be ordered by submitting the Transcript Order FormFor the first 90 days after this filing date, the transcript may be viewed at the courthouse at a public terminal or purchased from the court reporter referenced above. After 90 days, the transcript may be accessed via PACER. Other transcript formats, (multi-page, condensed, CD or ASCII) may be purchased from the court reporter.NOTICE RE REDACTION OF TRANSCRIPTS: The parties have twenty-one days to file with the court and the court reporter any request to redact personal identifiers from this transcript. If no such requests are filed, the transcript will be made available to the public via PACER without redaction after 90 days. The policy, which includes the five personal identifiers specifically covered, is located on our website at www.dcd.uscourts.gov. Redaction Request due 8/27/2026. Redacted Transcript Deadline set for 9/6/2026. Release of Transcript Restriction set for 11/4/2026.(Edwards, Lisa) (Entered: 08/06/2026)

NOTICE by MARKWAYNE MULLIN, MARCO RUBIO, U.S. DEPARTMENT OF HOMELAND SECURITY, U.S. DEPARTMENT OF STATE, U.S. IMMIGRATION AND CUSTOMS ENFORCEMENT, DAVID VENTURELLA re Motion Hearing, 29 Transcript,,,,, (Attachments: # 1 Exhibit)(Georgiev-Remmel, Dimitar) (Entered: 08/12/2026)

1 Exhibit

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Emergency MOTION for Discovery by IRANIAN AMERICAN LEGAL DEFENSE FUND. (Attachments: # 1 Exhibit Proposed Interrogatories, # 2 Exhibit Proposed Requests for Production, # 3 Text of Proposed Order)(Kirkpatrick, Michael) (Entered: 08/14/2026)

1 Exhibit Proposed Interrogatories

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2 Exhibit Proposed Requests for Production

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3 Text of Proposed Order

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NOTICE OF WITHDRAWAL OF APPEARANCE as to IRANIAN AMERICAN LEGAL DEFENSE FUND. Attorney Hoyeon Kelly Lew terminated. (Lew, Hoyeon) (Entered: 08/18/2026)

.Order

MINUTE ORDER. On August 14, 2026, Plaintiff filed an emergency motion for discovery 31 . The motion indicates that Defendants oppose the motion. Defendants have not yet responded to the motion. The Court ORDERS Defendants to file a response to the emergency motion for discovery on or before August 25, 2026. Signed by Judge Ana C. Reyes on 8/24/2026. (lcacr1)

Set/Reset Deadlines/Hearings

Set/Reset Deadlines/Hearings: Response to 31 due by 8/25/2026. (zcdw)

Memorandum in opposition to re 31 Emergency MOTION for Discovery filed by MARKWAYNE MULLIN, MARCO A. RUBIO, U.S. DEPARTMENT OF HOMELAND SECURITY, U.S. DEPARTMENT OF STATE, U.S. IMMIGRATION AND CUSTOMS ENFORCEMENT, DAVID VENTURELLA. (Attachments: # 1 Exhibit)(Georgiev-Remmel, Dimitar) (Entered: 08/25/2026)

MOTION for Order by MARKWAYNE MULLIN, MARCO A. RUBIO, U.S. DEPARTMENT OF HOMELAND SECURITY, U.S. DEPARTMENT OF STATE, U.S. IMMIGRATION AND CUSTOMS ENFORCEMENT, DAVID VENTURELLA. (Attachments: # 1 Exhibit)(Georgiev-Remmel, Dimitar) (Entered: 08/25/2026)

1 Exhibit

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Order on Motion for Order

MINUTE ORDER. The Court DENIES Defendants' Motion for Order 34 to the extent that it requests the Court lift the parties' obligations to schedule an evidentiary hearing. Although the Court previously instructed the parties to schedule the evidentiary hearing for August or September, the Court ORDERS the parties to contact the Courtroom Deputy, Chashawn White (chashawn_white@dcd.uscourts.gov), to reschedule the hearing for the week of October 12, 2026. The Court also DENIES Defendants' Motion for Order 34 to the extent that it requests the Court stay Defendants' obligation to respond to the Complaint. Defendants' response remains due on or before September 8, 2026. The Court will consider Plaintiff's Emergency Motion for Discovery 31 at the evidentiary hearing. Signed by Judge Ana C. Reyes on 8/26/2026. (lcacr1)

REPLY to opposition to motion re 31 Motion for Discovery filed by IRANIAN AMERICAN LEGAL DEFENSE FUND. (Steinberg, Becca) (Entered: 08/27/2026)

NOTICE of Factual Developments by IRANIAN AMERICAN LEGAL DEFENSE FUND (Steinberg, Becca) (Entered: 09/01/2026)