Case: Electronic Privacy Information Center v. U.S. Citizenship and Immigration Services

COMPLAINT against U.S. Citizenship and Immigration Services, Joseph B. Edlow, U.S. Social Security Administration, Frank Bisignano, U.S. Department of Homeland Security, Markwayne Mullin, U.S. Department of State, and Marco Rubio, filed by Electronic Privacy Information Center. (Filing fee $ 405 receipt number AMDDC-12997611) (Attachments: # 1 Civil Cover Sheet, # 2 Exhibit A, # 3 Summons) (dass, Deputy Clerk) (Entered: 09/01/2026)

1 Civil Cover Sheet

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2 Exhibit A

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3 Summons

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Case Assigned to Judge Paula Xinis. (dass, Deputy Clerk)

Case Assigned/Reassigned

Summons Issued 60 days as to U.S. Citizenship and Immigration Services, Joseph B. Edlow, U.S. Social Security Administration, Frank Bisignano, U.S. Department of Homeland Security, Markwayne Mullin, U.S. Department of State, and Marco Rubio, filed by Electronic Privacy Information Center, U.S. Attorney and U.S. Attorney General. (dass, Deputy Clerk) (Entered: 09/01/2026)

Local Rule 103.3 Disclosure Statement by Electronic Privacy Information Center (Sus, Nikhel) (Entered: 09/01/2026)

MOTION to Appear Pro Hac Vice for John B. Hill (Filing fee $100, receipt number AMDDC-13000577.) by Electronic Privacy Information Center(Sus, Nikhel) (Entered: 09/01/2026)

MOTION to Appear Pro Hac Vice for Reuven Dashevsky (Filing fee $100, receipt number AMDDC-13000581.) by Electronic Privacy Information Center(Sus, Nikhel) (Entered: 09/01/2026)

SUMMONS Returned Executed by Electronic Privacy Information Center. All Defendants.(Sus, Nikhel) (Entered: 09/03/2026)

MOTION for Summary Judgment by Electronic Privacy Information Center (Attachments: # 1 Memorandum in Support, # 2 Affidavit of John B. Hill, # 3 Exhibit A - June 8, 2026 Implementation Memo, # 4 Exhibit B - Executive Order 14399, # 5 Exhibit C - Mail-in ballot Truth Social post, # 6 Exhibit D - Census Bureau Truth Social post, # 7 Exhibit E - SAVE America Act webpage, # 8 Exhibit F - Executive Order No. 14248, # 9 Exhibit G - Privacy Impact Assessment for SAVE Oct. 31, 2025, # 10 Exhibit H - SAVE Privacy Threshold Analysis July 17, 2025, # 11 Exhibit I - SAVE Privacy Threshold Analysis Sept. 11, 2025, # 12 Exhibit J - Narrative Statement, # 13 Exhibit K - Intra-agency agreement May 15, 2025, # 14 Exhibit L - Intra-agency agreement Aug. 2025, # 15 Exhibit M - Bernstein Comment, # 16 Exhibit N - Ltr. to Fair Elections Center from SSA, # 17 Exhibit O - Congressional Response Report on SSA Numident File Accuracy, # 18 Exhibit P - Trumps Homeland Security Chief Threatens Election Officials with Prison Time, # 19 Exhibit Q - State Citizenship Lists Portal webpage, # 20 Exhibit R - Not Ready for Prime Time. A Federal Tool to Check Voter Citizenship Keeps Making Mistakes, # 21 Exhibit S - Application for Stay, Trump v. California, No. 26A124 (U.S. July. 27, 2026), # 22 Exhibit T - The Federal Database That Could Upend the Midterm Elections, # 23 Exhibit U - OMB Circular No. A-108, # 24 Exhibit V - SSA POMS, Disclosure and Verification of SSN Without Consent, # 25 Exhibit W - SSA POMS, Disclosure to DHS, # 26 Exhibit X - Voter Registration and Voter List Maintenance Fact Sheet Aug. 27, 2025, # 27 Exhibit Y - Defendants Statement of Undisputed Material Facts, LWV v. Trump, No. 26-cv-11581 (D. Mass. May 7, 2026), # 28 Exhibit Z - Additional Actions Are Needed To Reduce Undeliverable Mail, # 29 Exhibit AA - Sept. 2, 2026 Email, # 30 Affidavit of Lorraine Kisselburgh, # 31 Affidavit of Anthony Nel, # 32 Exhibit 1 - Oct. 21, 2025 Ltr. from Denton Cnty. Voter Registrar, # 33 Exhibit 2 - Dec. 3, 2025 Ltr. from Denton Cnty. Voter Registrar, # 34 Affidavit of Alan Butler, # 35 Text of Proposed Order)(Sus, Nikhel) (Entered: 09/03/2026)

1 Memorandum in Support

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2 Affidavit of John B. Hill

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3 Exhibit A - June 8, 2026 Implementation Memo

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4 Exhibit B - Executive Order 14399

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5 Exhibit C - Mail-in ballot Truth Social post

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6 Exhibit D - Census Bureau Truth Social post

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7 Exhibit E - SAVE America Act webpage

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8 Exhibit F - Executive Order No. 14248

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9 Exhibit G - Privacy Impact Assessment for SAVE Oct. 31, 2025

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10 Exhibit H - SAVE Privacy Threshold Analysis July 17, 2025

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11 Exhibit I - SAVE Privacy Threshold Analysis Sept. 11, 2025

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12 Exhibit J - Narrative Statement

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13 Exhibit K - Intra-agency agreement May 15, 2025

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14 Exhibit L - Intra-agency agreement Aug. 2025

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15 Exhibit M - Bernstein Comment

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16 Exhibit N - Ltr. to Fair Elections Center from SSA

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17 Exhibit O - Congressional Response Report on SSA Numident File Accuracy

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18 Exhibit P - Trumps Homeland Security Chief Threatens Election Officials with Pri

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19 Exhibit Q - State Citizenship Lists Portal webpage

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20 Exhibit R - Not Ready for Prime Time. A Federal Tool to Check Voter Citizenship

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21 Exhibit S - Application for Stay, Trump v. California, No. 26A124 (U.S. July. 27

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22 Exhibit T - The Federal Database That Could Upend the Midterm Elections

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23 Exhibit U - OMB Circular No. A-108

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24 Exhibit V - SSA POMS, Disclosure and Verification of SSN Without Consent

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25 Exhibit W - SSA POMS, Disclosure to DHS

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26 Exhibit X - Voter Registration and Voter List Maintenance Fact Sheet Aug. 27, 20

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27 Exhibit Y - Defendants Statement of Undisputed Material Facts, LWV v. Trump, No.

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28 Exhibit Z - Additional Actions Are Needed To Reduce Undeliverable Mail

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29 Exhibit AA - Sept. 2, 2026 Email

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30 Affidavit of Lorraine Kisselburgh

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31 Affidavit of Anthony Nel

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32 Exhibit 1 - Oct. 21, 2025 Ltr. from Denton Cnty. Voter Registrar

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33 Exhibit 2 - Dec. 3, 2025 Ltr. from Denton Cnty. Voter Registrar

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34 Affidavit of Alan Butler

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35 Text of Proposed Order

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MOTION to Expedite CONSIDERATION OF ITS MOTION FOR PARTIAL SUMMARY JUDGMENT by Electronic Privacy Information Center (Attachments: # 1 Text of Proposed Order)(Sus, Nikhel) (Entered: 09/03/2026)

1 Text of Proposed Order

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ORDER granting 8 MOTION to Expedite CONSIDERATION OF ITS MOTION FOR PARTIAL SUMMARY JUDGMENT. Signed by Judge Paula Xinis on 9/4/2026. (kb3s, Deputy Clerk) (Entered: 09/04/2026)

NOTICE of Appearance by Joshua N. Schopf on behalf of Frank Bisignano, Joseph B. Edlow, Markwayne Mullin, Marco Rubio, U.S. Citizenship and Immigration Services, U.S. Department of Homeland Security, U.S. Department of State, U.S. Social Security Administration (Schopf, Joshua) (Entered: 09/04/2026)

CORRECTED ORDER granting 8 MOTION to Expedite CONSIDERATION OF ITS MOTION FOR PARTIAL SUMMARY JUDGMENT. Signed by Judge Paula Xinis on 9/4/2026. (kb3s, Deputy Clerk) (Entered: 09/04/2026)

QC NOTICE: 4 Motion to Appear Pro Hac Vice filed by Electronic Privacy Information Center needs to be modified. See attachment for details and corrective actions needed regarding missing or incomplete information. (mh4s, Deputy Clerk) (Entered: 09/04/2026)

QC NOTICE: 5 Motion to Appear Pro Hac Vice filed by Electronic Privacy Information Center needs to be modified. See attachment for details and corrective actions needed regarding missing or incomplete information. (mh4s, Deputy Clerk) (Entered: 09/04/2026)

CORRECTED MOTION to Appear Pro Hac Vice for John B. Hill by Electronic Privacy Information Center. The fee has already been paid.(Sus, Nikhel) (Entered: 09/04/2026)

CORRECTED MOTION to Appear Pro Hac Vice for Reuven Dashevsky by Electronic Privacy Information Center. The fee has already been paid.(Sus, Nikhel) (Entered: 09/04/2026)

MOTION for Reconsideration re 11 Order, 9 Order on Motion to Expedite Briefing Schedule ECF 9 and 11 by Markwayne Mullin, Marco Rubio, U.S. Citizenship and Immigration Services, U.S. Department of Homeland Security, U.S. Department of State, U.S. Social Security Administration (Attachments: # 1 Text of Proposed Order)(Corcoran, Tom) (Entered: 09/04/2026)

RESPONSE in Opposition re 16 MOTION for Reconsideration re 11 Order, 9 Order on Motion to Expedite Briefing Schedule ECF 9 and 11 filed by Electronic Privacy Information Center.(Sus, Nikhel) (Entered: 09/06/2026)

PAPERLESS ORDER: A recorded call has been scheduled for today, September 8, 2026, at 3:00 p.m. Instructions will be emailed to the parties. Signed by Judge Paula Xinis on 9/8/2026. (tb2s, Chambers) (Entered: 09/08/2026)

PAPERLESS ORDER granting 14 Corrected Motion to Appear Pro Hac Vice on behalf of John B. Hill. Directing attorney John B. Hill to register for pro hac vice filing in the District of Maryland through PACER at https://pacer.uscourts.gov/ if attorney has not already done so. The Pro Hac Vice option must be selected when registering. Signed by Clerk on 9/8/2026. (mh4s, Deputy Clerk) (Entered: 09/08/2026)

PAPERLESS ORDER granting 15 Corrected Motion to Appear Pro Hac Vice on behalf of Reuven Dashevsky. Directing attorney Reuven Dashevsky to register for pro hac vice filing in the District of Maryland through PACER at https://pacer.uscourts.gov/ if attorney has not already done so. The Pro Hac Vice option must be selected when registering. Signed by Clerk on 9/8/2026. (mh4s, Deputy Clerk) (Entered: 09/08/2026)

NOTICE of Appearance by Elizabeth J. Shapiro on behalf of All Defendants (Shapiro, Elizabeth) (Entered: 09/08/2026)

Telephone Conference held on 9/8/2026 before Judge Paula Xinis.(Court Reporter: Paula Leeper - 2C) (bus, Deputy Clerk) (Entered: 09/08/2026)

PAPERLESS ORDER: For the reasons discussed during today's recorded conference, the Motion for Reconsideration at ECF No. 16 is DENIED without prejudice. In the absence of a further order by this Court, the parties SHALL comply with the expedited briefing schedule detailed in ECF No. 9. Signed by Judge Paula Xinis on 9/8/2026. (kk5s, Deputy Clerk) (Entered: 09/09/2026)

MOTION to Appear Pro Hac Vice for Rodkangyil Orion Danjuma (Filing fee $100, receipt number AMDDC-13019457.) by Electronic Privacy Information Center (Attachments: # 1 Attachment List of Courts and Dates of Admittance)(Sus, Nikhel) (Entered: 09/10/2026)

MOTION to Appear Pro Hac Vice for Shelby Teeter (Filing fee $100, receipt number AMDDC-13019534.) by Electronic Privacy Information Center (Attachments: # 1 Attachment List of Courts and Dates of Admittance)(Sus, Nikhel) (Entered: 09/10/2026)

PAPERLESS ORDER granting 24 Motion to Appear Pro Hac Vice on behalf of Rodkangyil Orion Danjuma. Directing attorney Rodkangyil Orion Danjuma to register for pro hac vice filing in the District of Maryland through PACER at https://pacer.uscourts.gov/ if attorney has not already done so. The Pro Hac Vice option must be selected when registering. Signed by Clerk on 9/10/2026. (mh4s, Deputy Clerk) (Entered: 09/10/2026)

PAPERLESS ORDER granting 25 Motion to Appear Pro Hac Vice on behalf of Shelby Teeter. Directing attorney Shelby Teeter to register for pro hac vice filing in the District of Maryland through PACER at https://pacer.uscourts.gov/ if attorney has not already done so. The Pro Hac Vice option must be selected when registering. Signed by Clerk on 9/10/2026. (mh4s, Deputy Clerk) (Entered: 09/10/2026)

MOTION to Appear Pro Hac Vice for Jane Bentrott (Filing fee $100, receipt number AMDDC-13020421.) by Electronic Privacy Information Center (Attachments: # 1 Attachment List of Courts and Dates of Admittance)(Sus, Nikhel) (Entered: 09/10/2026)

MOTION to Appear Pro Hac Vice for Julia L. Torti (Filing fee $100, receipt number AMDDC-13020431.) by Electronic Privacy Information Center (Attachments: # 1 Attachment List of Courts and Dates of Admittance)(Sus, Nikhel) (Entered: 09/10/2026)

MOTION to Appear Pro Hac Vice for Sara Chimene-Weiss (Filing fee $100, receipt number AMDDC-13020478.) by Electronic Privacy Information Center (Attachments: # 1 Attachment List of Courts and Dates of Admittance)(Sus, Nikhel) (Entered: 09/10/2026)

MOTION to Appear Pro Hac Vice for Mayu Hermine Tobin-Miyaji (Filing fee $100, receipt number AMDDC-13020598.) by Electronic Privacy Information Center(Sus, Nikhel) (Entered: 09/10/2026)

PAPERLESS ORDER granting 28 Motion to Appear Pro Hac Vice on behalf of Jane Bentrott. Directing attorney Jane Bentrott to register for pro hac vice filing in the District of Maryland through PACER at https://pacer.uscourts.gov/ if attorney has not already done so. The Pro Hac Vice option must be selected when registering. Signed by Clerk on 9/10/2026. (mh4s, Deputy Clerk) (Entered: 09/10/2026)

PAPERLESS ORDER granting 29 Motion to Appear Pro Hac Vice on behalf of Julia L. Torti. Directing attorney Julia L. Torti to register for pro hac vice filing in the District of Maryland through PACER at https://pacer.uscourts.gov/ if attorney has not already done so. The Pro Hac Vice option must be selected when registering. Signed by Clerk on 9/10/2026. (mh4s, Deputy Clerk) (Entered: 09/10/2026)

PAPERLESS ORDER granting 30 Motion to Appear Pro Hac Vice on behalf of Sara Chimene-Weiss. Directing attorney Sara Chimene-Weiss to register for pro hac vice filing in the District of Maryland through PACER at https://pacer.uscourts.gov/ if attorney has not already done so. The Pro Hac Vice option must be selected when registering. Signed by Clerk on 9/10/2026. (mh4s, Deputy Clerk) (Entered: 09/10/2026)

PAPERLESS ORDER granting 31 Motion to Appear Pro Hac Vice on behalf of Mayu Hermine Tobin-Miyaji. Directing attorney Mayu Hermine Tobin-Miyaji to register for pro hac vice filing in the District of Maryland through PACER at https://pacer.uscourts.gov/ if attorney has not already done so. The Pro Hac Vice option must be selected when registering. Signed by Clerk on 9/10/2026. (mh4s, Deputy Clerk) (Entered: 09/10/2026)

RESPONSE in Opposition re 7 MOTION for Summary Judgment filed by Frank Bisignano, Joseph B. Edlow, Markwayne Mullin, Marco Rubio, U.S. Citizenship and Immigration Services, U.S. Department of Homeland Security, U.S. Department of State. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Text of Proposed Order)(Schopf, Joshua) (Entered: 09/10/2026)

NOTICE OF FILING OF OFFICIAL TRANSCRIPT of Proceedings - Telephone Conference - held on 09/08/2026, before Judge Paula Xinis. Court Reporter/Transcriber Paula Leeper, Telephone number (301)344-3229. Total number of pages filed: 20. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained from the Court Reporter or through PACER. Redaction Request due 10/2/2026. Redacted Transcript Deadline set for 10/13/2026. Release of Transcript Restriction set for 12/10/2026.(pl, Court Reporter) (Entered: 09/11/2026)