Case: Democracy Defenders Fund v DOJ

Democracy Defenders Fund v. U.S. Department of Justice

COMPLAINT against All Plaintiffs ( Filing fee $ 405 receipt number ADCDC-11904731) filed by DEMOCRACY DEFENDERS FUND. (Attachments: # 1 Civil Cover Sheet Civil Cover Sheet, # 2 Exhibit Exhibits A-E, # 3 Summons DOJ Summons, # 4 Summons AG Summons, # 5 Summons USAO Summons)(Null, Taryn) (Entered: 08/21/2025)

1 Civil Cover Sheet Civil Cover Sheet

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2 Exhibit Exhibits A-E

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3 Summons DOJ Summons

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4 Summons AG Summons

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5 Summons USAO Summons

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REQUEST FOR SUMMONS TO ISSUE filed by DEMOCRACY DEFENDERS FUND. (Attachments: # 1 Summons USAO Summons, # 2 Summons AG Summons)(Null, Taryn) (Entered: 08/25/2025)

SUMMONS (3) Issued Electronically as to U.S. DEPARTMENT OF JUSTICE, U.S. Attorney and U.S. Attorney General (Attachments: # 1 Notice and Consent)(zmbs) (Entered: 08/25/2025)

ORDER ESTABLISHING PROCEDURES FOR CIVIL CASES ASSIGNED TO JUDGE COLLEEN KOLLAR-KOTELLY. Signed by Judge Colleen Kollar-Kotelly on 8/25/2025. (lcckk3) (Entered: 08/25/2025)

Notice of Error- New Case

Case Assigned/Reassigned

Case Assigned to Judge Colleen Kollar-Kotelly. (zmbs)

NOTICE OF NEW CASE ERROR regarding 1 Complaint,. The following error(s) need correction: Incorrect summonses. Please locate the summons applicable to your case at www.dcd.uscourts.gov/new-case-forms and file using the event Request for Summons to issue. (zmbs)

NOTICE of Appearance by Tianna Jade Mays on behalf of DEMOCRACY DEFENDERS FUND (Mays, Tianna) (Entered: 08/27/2025)

NOTICE of Appearance by Norman Larry Eisen on behalf of DEMOCRACY DEFENDERS FUND (Eisen, Norman) (Entered: 08/27/2025)

NOTICE of Appearance by Pooja Chaudhuri on behalf of DEMOCRACY DEFENDERS FUND (Chaudhuri, Pooja) (Entered: 08/27/2025)

NOTICE of Appearance by Jacob Kovacs-Goodman on behalf of DEMOCRACY DEFENDERS FUND (Kovacs-Goodman, Jacob) (Entered: 08/27/2025)

AMENDED COMPLAINT against U.S. DEPARTMENT OF JUSTICE filed by DEMOCRACY DEFENDERS FUND. (Attachments: # 1 Civil Cover Sheet Civil Cover Sheet, # 2 Exhibit Exhibits A - G)(Null, Taryn) (Entered: 09/11/2025)

NOTICE of Appearance by Jason Altabet on behalf of U.S. DEPARTMENT OF JUSTICE (Altabet, Jason) (Entered: 09/22/2025)

Unopposed MOTION for Extension of Time to File Answer re 9 Amended Complaint by 30 Days by U.S. DEPARTMENT OF JUSTICE. (Attachments: # 1 Text of Proposed Order)(Altabet, Jason) (Entered: 09/22/2025)

NOTICE In Support of Unopposed Motion for Extension of Time to Answer the Amended Complaint by U.S. DEPARTMENT OF JUSTICE re 11 Motion for Extension of Time to File Answer (Altabet, Jason) (Entered: 09/25/2025)

Order on Motion for Extension of Time to Answer

Set/Reset Deadlines

ORDER granting 11 Motion for Extension of Time to Answer. U.S. DEPARTMENT OF JUSTICE answer due 10/27/2025. Signed by Judge Colleen Kollar-Kotelly on 9/25/2025. (lcckk3)

Set/Reset Deadlines: Answer due by 10/27/2025. (dot)

MOTION for Leave to File Second Amended Complaint by DEMOCRACY DEFENDERS FUND. (Attachments: # 1 Exhibit Second Amended Complaint with Exhibits, # 2 Exhibit Comparison Second Amended and Amended Complaints, # 3 Text of Proposed Order Proposed Order on Motion for Leave to File Amended Complaint)(Null, Taryn) (Entered: 10/03/2025)

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AMENDED COMPLAINT DEMOCRACY DEFENDERS FUND against U.S. DEPARTMENT OF JUSTICE filed by DEMOCRACY DEFENDERS FUND.(Null, Taryn) (Entered: 10/08/2025)

Order on Motion for Leave to File

MINUTE ORDER granting 13 Motion for Leave to File. Signed by Judge Colleen Kollar-Kotelly on 10/8/2025. (lcckk3)

MOTION for Summary Judgment by DEMOCRACY DEFENDERS FUND. (Attachments: # 1 Text of Proposed Order Proposed Order, # 2 Supplement Brief, # 3 Declaration Declarations and Exhibits, # 4 Statement of Facts Statement of Facts)(Null, Taryn) (Entered: 10/21/2025)

1 Text of Proposed Order Proposed Order

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2 Supplement Brief

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3 Declaration Declarations and Exhibits

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4 Statement of Facts Statement of Facts

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Unopposed MOTION to Expedite Consideration, Joint MOTION for Briefing Schedule by DEMOCRACY DEFENDERS FUND. (Attachments: # 1 Text of Proposed Order Proposed Order)(Null, Taryn) (Entered: 11/17/2025)

1 Text of Proposed Order Proposed Order

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ENTERED IN ERROR.....MOTION for Leave to File Supplement Complaint by DEMOCRACY DEFENDERS FUND. (Attachments: # 1 Supplement Supplemental Complaint, # 2 Text of Proposed Order Proposed Order)(Null, Taryn) Modified on 11/18/2025, pursuant to Counsel (mg). (Entered: 11/17/2025)

ORDER granting 16 Motion to Expedite; granting 16 Motion for Briefing Schedule. Signed by Judge Colleen Kollar-Kotelly on 11/18/2025. (lcckk3) (Entered: 11/19/2025)

Set/Reset Deadlines: Defendant's Cross Motion due by 12/11/2025. Defendant's Opposition to Motion for Summary Judgment due by 12/11/2025. Plaintiff's Reply to Motion for Summary Judgment due by 12/22/2025. (dot)

MOTION for Leave to File THIRD AMENDED COMPLAINT by DEMOCRACY DEFENDERS FUND. (Attachments: # 1 Supplement Third Amended Complaint with Exhibits, # 2 Supplement Exhibit Comparison Third Amended and Amended Complaints, # 3 Text of Proposed Order Proposed Oder)(Null, Taryn) (Entered: 12/04/2025)

1 Supplement Third Amended Complaint with Exhibits

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2 Supplement Exhibit Comparison Third Amended and Amended Complaints

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3 Text of Proposed Order Proposed Oder

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Set/Reset Deadlines

Memorandum in opposition to re 15 MOTION for Summary Judgment filed by U.S. DEPARTMENT OF JUSTICE. (Attachments: # 1 Statement of Facts, # 2 Text of Proposed Order)(Altabet, Jason) (Entered: 12/11/2025)

1 Statement of Facts

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2 Text of Proposed Order

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REPLY to opposition to motion re 15 Motion for Summary Judgment, filed by DEMOCRACY DEFENDERS FUND. (Null, Taryn) (Entered: 12/22/2025)

AMENDED COMPLAINT against U.S. DEPARTMENT OF JUSTICE filed by DEMOCRACY DEFENDERS FUND.(Null, Taryn) (Entered: 12/30/2025)

Order on Motion for Leave to File

MINUTE ORDER: The Court is in receipt of Plaintiff's 19 Motion for Leave to File Third Amended Complaint. Defendant consents to portions of Plaintiff's proposed amendments and objects to others. For the reasons that follow, the Court shall GRANT Plaintiff's 19 Motion. Plaintiff's Motion implicates the following three FOIA requests made by Plaintiff to various components of DOJ: (i) a July 22, 2025, request to the Criminal Division of DOJ ("CRM"), the Executive Office for United States Attorneys for DOJ ("EOUSA"), and the FBI for investigative files regarding Jeffrey Epstein and Ghislaine Maxwell that mention President Trump or his home in Mar-a-Lago; (ii) a July 28, 2025, request to the CRM, the EOUSA, the FBI, the Office of Attorney General ("OAG"), and the Office of the Deputy Attorney General ("DAG") for documents relating to DOJ's dissemination of information regarding Epstein and Maxwell; and (iii) an August 6, 2025, request to ODAG, OAG, and the Federal Bureau of Prisons ("BOP") for documents relating to Maxwell's transfer to Federal Prison Camp Bryan. The operative Complaint in this matter---Plaintiff's Second Amended Complaint---already contains factual allegations regarding Plaintiff's July 22, 2025, request to CRM and Plaintiff's July 28, 2025, request to CRM, OAG, and DAG. In other words, the operative Complaint contains allegations against all the DOJ components involved in the July 22 and July 28 requests except the EOUSA and the FBI. Plaintiff's proposed Third Amended Complaint would amend Plaintiff's factual allegations to include Plaintiff's July 22 July 28 requests to the EOUSA and the FBI. Plaintiff has conferred with Defendant regarding these amendments and represents that Defendant consents to these amendments. Accordingly, the Court shall GRANT Plaintiff's 19 Motion with respect to the amendments concerning the July 22, 2025, request and the July 28, 2025, request. Plaintiff also seeks to amend its Complaint to include factual allegations regarding its August 6, 2025, request to ODAG, OAG, and BOP for documents relating to Maxwell's transfer to Federal Prison Camp Bryan. Plaintiff represents that Defendant objects to this amendment because it involves a request that is not identical to the requests already in the case. The Court shall GRANT Plaintiff's 19 Motion with respect to the amendment concerning the August 6, 2025, request. The Federal Rules of Civil Procedure instruct courts to "freely give leave [to amend] when justice so requires." Fed. R. Civ. P. 15(a)(2). This Rule "is to be construed liberally." Belizan v. Hershon, 434 F.3d 579, 582 (D.C. Cir. 2006). "In the absence of any apparent or declared reason---such as undue delay, bad faith or dilatory motive on the part of the movant, repeated failure to cure deficiencies by amendments previously allowed, undue prejudice to the opposing party by virtue of allowance of the amendment, futility of amendment, etc.---the leave sought should, as the rules require, be freely given." Foman v. Davis, 371 U.S. 178, 182 (1962). Defendant has not provided any reason to support its opposition to Plaintiff's proposed amendment. Furthermore, Plaintiff has shown that Defendant would not be unduly prejudiced by the addition of the August 6 request because the August 6 request is closely related to the requests already being litigated in this case. Accordingly, the Court shall GRANT Plaintiff's 19 Motion with respect to the amendment involving the August 6, 2025, request, as well. Accordingly, it is hereby ORDERED that Plaintiff's 19 Motion for Leave to File Third Amended Complaint is GRANTED . Signed by Judge Colleen Kollar-Kotelly on 12/30/2025. (lcckk3)

NOTICE REGARDING DOJ COMPLIANCE WITH EPSTEIN FILES TRANSPARENCY ACT by DEMOCRACY DEFENDERS FUND (Attachments: # 1 Supplement Final DOJ Response Letter)(Null, Taryn) (Entered: 04/15/2026)

1 Supplement Final DOJ Response Letter

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NOTICE of Appearance by James D. Todd, Jr on behalf of All Defendants (Todd, James) (Entered: 04/16/2026)

RESPONSE re 23 Notice (Other) filed by U.S. DEPARTMENT OF JUSTICE. (Todd, James) (Entered: 04/29/2026)

NOTICE OF WITHDRAWAL OF APPEARANCE as to U.S. DEPARTMENT OF JUSTICE. Attorney Jason Altabet terminated. (Altabet, Jason) (Entered: 04/30/2026)

ORDER granting in part and denying in part Plaintiff's 15 Motion for Summary Judgment. Signed by Judge Colleen Kollar-Kotelly on 9/30/2026. (lcckk3) (Entered: 09/30/2026)

MEMORANDUM OPINION accompanying 27 Order. Signed by Judge Colleen Kollar-Kotelly on 9/30/2026. (lcckk3)