PROTECT DEMOCRACY PROJECT, INC. v. U.S. DEPARTMENT OF JUSTICE et al
| PROTECT DEMOCRACY PROJECT, INC. |
| DEPARTMENT OF STATE, DEPARTMENT OF DEFENSE, DEPARTMENT OF JUSTICE, U.S. DEPARTMENT OF JUSTICE, U.S. DEPARTMENT OF DEFENSE and U.S. DEPARTMENT OF STATE |
| 1:2020cv00172 |
| January 22, 2020 |
| US District Court for the District of Columbia |
| Rudolph Contreras |
| Freedom of Information Act |
| 05 U.S.C. § 552 Freedom of Information Act |
| None |
Docket Report
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This docket was last retrieved on August 4, 2021. A more recent docket listing may be available from PACER.
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Filing 47
Joint STATUS REPORT by U.S. DEPARTMENT OF DEFENSE, U.S. DEPARTMENT OF JUSTICE, U.S. DEPARTMENT OF STATE. (Snow, Kyla)
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MINUTE ORDER: It is hereby ORDERED that the parties shall meet, confer, and submit a joint status report informing the Court if this matter may be closed or if further proceedings are contemplated on or before August 4, 2021. SO ORDERED. Signed by Judge Rudolph Contreras on 7/21/2021. (lcrc1)
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Filing 46
ORDER granting in part and denying in part #31 Defendants' Motion for Summary Judgment and granting in part and denying in part #34 Plaintiff's Motion for Summary Judgment. See document for details. Signed by Judge Rudolph Contreras on 5/17/2021. (lcrc1)
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Filing 45
NOTICE of Production of Document for In Camera Review by U.S. DEPARTMENT OF DEFENSE, U.S. DEPARTMENT OF JUSTICE, U.S. DEPARTMENT OF STATE (Snow, Kyla)
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Filing 44
MEMORANDUM OPINION deferring ruling on #31 Defendants' Motion for Summary Judgment and #34 Plaintiff's Motion for Summary Judgment. See document for details. Signed by Judge Rudolph Contreras on 3/26/2021. (lcrc1)
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Filing 43
ORDER deferring ruling on #31 Defendants' Motion for Summary Judgment and #34 Plaintiff's Motion for Summary Judgment. See document for details. Signed by Judge Rudolph Contreras on 3/26/2021. (lcrc1)
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Filing 42
NOTICE OF SUBSTITUTION OF COUNSEL by Kyla Marie Snow on behalf of All Defendants Substituting for attorney Kari E. D'Ottavio (Snow, Kyla)
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Filing 41
REPLY to opposition to motion re #34 MOTION for Summary Judgment filed by PROTECT DEMOCRACY PROJECT, INC.. (Attachments: #1 Statement of Facts Plaintiff Response to Defendant Statement of Undisputed Fact, #2 Declaration of Brian Sutherland ISO Reply, #3 Exhibit AA to Brian Sutherland Declaration ISO Reply)(Sutherland, Brian)
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Filing 40
Memorandum in opposition to #34 MOTION for Summary Judgment filed by U.S. DEPARTMENT OF DEFENSE, U.S. DEPARTMENT OF JUSTICE, U.S. DEPARTMENT OF STATE. (Attachments: #1 Statement of Facts in response to Plaintiff's Statement of Facts)(D'Ottavio, Kari); Modified text on 7/31/2020 (ztth).
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Filing 39
REPLY to opposition to motion re #31 MOTION for Summary Judgment filed by U.S. DEPARTMENT OF DEFENSE, U.S. DEPARTMENT OF JUSTICE, U.S. DEPARTMENT OF STATE. (Attachments: #1 Statement of Facts in response to Plaintiff's Statement of Facts)(D'Ottavio, Kari); Modified text and added/deleted docket entry relationship on 7/31/2020 (ztth).
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Filing 38
NOTICE of Filing Statement of Material Facts by U.S. DEPARTMENT OF DEFENSE, U.S. DEPARTMENT OF JUSTICE, U.S. DEPARTMENT OF STATE re #31 MOTION for Summary Judgment (D'Ottavio, Kari)
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MINUTE ORDER: It is hereby ORDERED that #37 Defendants' Unopposed Motion for Leave to File Statement of Material Facts is GRANTED. SO ORDERED. Signed by Judge Rudolph Contreras on 7/21/2020. (lcrc1)
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Filing 37
Unopposed MOTION for Leave to File Statement of Material Facts by U.S. DEPARTMENT OF DEFENSE, U.S. DEPARTMENT OF JUSTICE, U.S. DEPARTMENT OF STATE (Attachments: #1 Text of Proposed Order)(D'Ottavio, Kari)
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NOTICE OF ERROR re #34 Motion for Summary Judgment; emailed to bsutherland@reedsmith.com, cc'd 9 associated attorneys -- The PDF file you docketed contained errors: 1. Two-part docket entry, 2. DO NOT REFILE. In future, please docket all parts of pleading. (ztth, )
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NOTICE OF CORRECTED DOCKET ENTRY: re 35 MOTION for Hearing re #34 MOTION for Summary Judgment was entered in error. (ztth)
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Filing 36
Memorandum in opposition to #31 MOTION for Summary Judgment filed by PROTECT DEMOCRACY PROJECT, INC. (See Docket Entry #34 to view document) (ztth)
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Filing 35
ENTERED IN ERROR.....MOTION for Hearing re #34 MOTION for Summary Judgment by PROTECT DEMOCRACY PROJECT, INC. (See Docket Entry #34 to view document) (ztth); Modified on 7/20/2020 (ztth).
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Filing 34
MOTION for Summary Judgment by PROTECT DEMOCRACY PROJECT, INC. (Attachments: #1 Memorandum in Support its Motion for Summary Judgment, #2 Text of Proposed Order Proposed Order, #3 Statement of Facts Separate Statement, #4 Statement of Facts Statement of Undisclosure, #5 Declaration of Brian Sutherland, #6 Exhibit A, #7 Exhibit B, #8 Exhibit C, #9 Exhibit D, #10 Exhibit E, #11 Exhibit F, #12 Exhibit G, #13 Exhibit H, #14 Exhibit I, #15 Exhibit J, #16 Exhibit K, #17 L, #18 Exhibit M, #19 Exhibit N, #20 Exhibit O, #21 Exhibit P, #22 Exhibit Q, #23 Exhibit R, #24 Exhibit S, #25 Exhibit T, #26 Exhibit U, #27 Exhibit V, #28 Exhibit W, #29 Exhibit X, #30 Exhibit Y, #31 Exhibit Z)(Sutherland, Brian)
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Filing 33
NOTICE of Appearance- Pro Bono by Brian A. Sutherland on behalf of PROTECT DEMOCRACY PROJECT, INC. (Sutherland, Brian)
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Filing 32
MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Brian A. Sutherland, Filing fee $ 100, receipt number ADCDC-7336264. Fee Status: Fee Paid. by PROTECT DEMOCRACY PROJECT, INC. (Attachments: #1 Declaration of Brian A. Sutherland, #2 Text of Proposed Order)(Tindall, Anne)
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MINUTE ORDER granting #32 Motion for Leave to Appear Pro Hac Vice: Pursuant to Local Civil Rule 83.2(d), it is hereby ORDERED that Brian A. Sutherland is admitted to represent Plaintiff pro hac vice in this case. SO ORDERED. 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 Rudolph Contreras on 7/14/2020 . (lcrc1)
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Filing 31
MOTION for Summary Judgment by U.S. DEPARTMENT OF DEFENSE, U.S. DEPARTMENT OF JUSTICE, U.S. DEPARTMENT OF STATE (Attachments: #1 Declaration, #2 Text of Proposed Order)(D'Ottavio, Kari)
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Set/Reset Deadlines: Cross Motions due by 7/16/2020. Response to Cross Motions due by 7/30/2020. Reply to Cross Motions due by 8/6/2020. Summary Judgment motions due by 7/2/2020. Response to Motion for Summary Judgment due by 7/16/2020. Reply to Motion for Summary Judgment due by 7/30/2020. (tj)
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Filing 30
Joint STATUS REPORT and Proposed Briefing Schedule by PROTECT DEMOCRACY PROJECT, INC.. (Paredes, Eric John)
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MINUTE ORDER: In light of the representations in #30 the parties' most recent joint status report, #14 Plaintiff's motion for preliminary injunction and #15 Plaintiff's motion for expedited hearing and briefing schedule are DENIED as moot. SO ORDERED. Signed by Judge Rudolph Contreras on 6/22/2020. (lcrc1)
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MINUTE ORDER: Consistent with the briefing schedule proposed by the parties in #30 their joint status report, it is hereby ORDERED that the following schedule shall govern summary judgment briefing in this case: the Government shall file its motion for summary judgment on or before July 2, 2020; Plaintiff shall file its opposition and cross-motion for summary judgment on or before July 16, 2020; the Government shall file its opposition and reply on or before July 30, 2020; and Plaintiff shall file its reply on or before August 6, 2020. SO ORDERED. Signed by Judge Rudolph Contreras on 6/22/2020. (lcrc1)
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Set/Reset Deadlines: Status Report due by 7/31/2020. (tj)
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Filing 29
Joint STATUS REPORT by U.S. DEPARTMENT OF DEFENSE, U.S. DEPARTMENT OF JUSTICE, U.S. DEPARTMENT OF STATE. (D'Ottavio, Kari)
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MINUTE ORDER: Upon consideration of #29 the parties' joint status report, it is hereby ORDERED that the parties shall file another joint status report on or before July 31, 2020. SO ORDERED. Signed by Judge Rudolph Contreras on 5/29/2020. (lcrc1)
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Set/Reset Deadlines: Status Report due by 5/29/2020 (tj)
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Filing 28
Joint STATUS REPORT by U.S. DEPARTMENT OF DEFENSE, U.S. DEPARTMENT OF JUSTICE, U.S. DEPARTMENT OF STATE. (D'Ottavio, Kari)
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MINUTE ORDER: Upon consideration of #28 the parties' joint status report, it is hereby ORDERED that the parties shall file another joint status report on or before May 29, 2020. The Court also expresses its appreciation for the manner in which the parties have cooperatively worked together in light of the extraordinary strain COVID-19 has put on the Court, the Department of Justice, the responding agencies, and the public at large. SO ORDERED. Signed by Judge Rudolph Contreras on 4/3/2020. (lcrc1)
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MINUTE ORDER: Upon consideration of #26 the parties' joint status report, it is hereby ORDERED that the parties shall file another joint status report on or before April 3, 2020. SO ORDERED. Signed by Judge Rudolph Contreras on 3/26/2020. (lcrc1)
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Set/Reset Deadlines: Status Report due by 4/3/2020 (tj)
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Filing 27
TRANSCRIPT OF MOTION HEARING before Judge Rudolph Contreras held on March 12, 2020; Page Numbers: 1-25. Date of Issuance:March 24, 2020. Court Reporter/Transcriber Lisa A. Moreira, RDR, CRR, Telephone number (202) 354-3187, 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 cour t 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 4/14/2020. Redacted Transcript Deadline set for 4/24/2020. Release of Transcript Restriction set for 6/22/2020.(Moreira, Lisa)
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| Filing 26 Joint STATUS REPORT and Partial Proposed Schedules by PROTECT DEMOCRACY PROJECT, INC.. (Paredes, Eric John) |
| Filing 25 NOTICE of OLC memorandum by U.S. DEPARTMENT OF DEFENSE, U.S. DEPARTMENT OF JUSTICE, U.S. DEPARTMENT OF STATE (D'Ottavio, Kari) |
| Set/Reset Deadlines: Proposed Schedules due by 3/19/2020. (tj) |
| Filing 24 NOTICE Regarding Escalating Hostilities with Iran by PROTECT DEMOCRACY PROJECT, INC. (Tindall, Anne) |
| NOTICE OF CORRECTED DOCKET ENTRY: re #23 Joint MOTION for Leave to Appear by Telephone at the March 19, 2020 Hearing. In the future said document should be filed in pleading format. Please refer to LCvR 5.1(a). (ztth) |
| Filing 23 Joint MOTION for Leave to Appear by Telephone at the March 19, 2020 Hearing by PROTECT DEMOCRACY PROJECT, INC. (Paredes, Eric John) |
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MINUTE ORDER: In light of the concerns raised in #23 the joint motion concerning the coronavirus (COVID-19), but given that a teleconference would implicate similar concerns by requiring court personnel (including a courtroom deputy, court reporter, etc.) to travel to the courthouse, the upcoming hearing is hereby VACATED and the parties shall, instead, by close of business on March 19, 2020, submit written proposed schedules to govern this case. SO ORDERED. Signed by Judge Rudolph Contreras on 3/16/2020. (lcrc1)
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| Minute Entry for proceedings held before Judge Rudolph Contreras: Motion Hearing held on 3/12/2020 re #14 MOTION for Preliminary Injunction filed by PROTECT DEMOCRACY PROJECT, INC. Government brief due by 3/19/2020. Next Hearing set for 3/19/2020 at 2:00 PM in Courtroom 14 before Judge Rudolph Contreras.). (Court Reporter: Lisa Moreira.) (tj) |
| Filing 22 NOTICE of Legislation by U.S. DEPARTMENT OF DEFENSE, U.S. DEPARTMENT OF JUSTICE, U.S. DEPARTMENT OF STATE (D'Ottavio, Kari) |
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MINUTE ORDER: As stated on the record during the hearing on March 12, 2020, a further hearing is scheduled for March 19, 2020, at 2:00 p.m. in Courtroom 14. It is FURTHER ORDERED that Defendants shall, sometime before 12:00 noon on March 19, 2020, submit a filing on behalf of OLC indicating whether it possesses a memorandum or opinion responsive to Plaintiff's FOIA requests. SO ORDERED. Signed by Judge Rudolph Contreras on 3/12/2020. (lcrc1)
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| Filing 21 NOTICE with Updated Declarations by U.S. DEPARTMENT OF DEFENSE, U.S. DEPARTMENT OF JUSTICE, U.S. DEPARTMENT OF STATE (D'Ottavio, Kari) |
| Set/Reset Hearings: Status Conference set for 3/12/2020 at 2:00 PM in Courtroom 14 before Judge Rudolph Contreras. (tj) |
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MINUTE ORDER: It is hereby ORDERED that a hearing on #14 Plaintiff's motion for a preliminary injunction is scheduled for March 12, 2020, at 2:00 p.m. in Courtroom 14 before Judge Rudolph Contreras. It is FURTHER ORDERED that, on March 11, 2020, Defendants file updated versions of the declarations supporting their #17 memorandum in opposition to the motion. SO ORDERED. Signed by Judge Rudolph Contreras on 3/6/2020. (lcrc1)
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| Filing 20 ANSWER to #13 Amended Complaint, by U.S. DEPARTMENT OF DEFENSE, U.S. DEPARTMENT OF JUSTICE, U.S. DEPARTMENT OF STATE.(D'Ottavio, Kari) |
| Filing 19 REPLY to opposition to motion re #14 MOTION for Preliminary Injunction filed by PROTECT DEMOCRACY PROJECT, INC.. (Attachments: #1 Declaration of John Paredes, #2 Exhibit N)(Paredes, Eric John) |
| Filing 18 NOTICE of Appearance by Benjamin Leon Berwick on behalf of PROTECT DEMOCRACY PROJECT, INC. (Berwick, Benjamin) |
| Filing 17 Memorandum in opposition to re #14 MOTION for Preliminary Injunction filed by U.S. DEPARTMENT OF DEFENSE, U.S. DEPARTMENT OF JUSTICE, U.S. DEPARTMENT OF STATE. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5)(D'Ottavio, Kari) |
| Filing 16 NOTICE of Appearance by Eric John Galvez Paredes on behalf of PROTECT DEMOCRACY PROJECT, INC. (Paredes, Eric John) |
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MINUTE ORDER granting #12 Motion for Leave to Appear Pro Hac Vice: Pursuant to Local Civil Rule 83.2(d), it is hereby ORDERED that John Paredes is admitted to represent Plaintiff pro hac vice in this case. SO ORDERED. 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 Rudolph Contreras on 2/24/2020. (l crc1)
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| Filing 15 Emergency MOTION for expedited briefing and argument schedule re #14 MOTION for Preliminary Injunction by PROTECT DEMOCRACY PROJECT, INC. (Attachments: #1 Proposed Order)(Tindall, Anne) Modified event on 2/20/2020 (ztth). |
| Filing 14 MOTION for Preliminary Injunction by PROTECT DEMOCRACY PROJECT, INC. (Attachments: #1 Memorandum in Support, #2 Declaration of Anne H. Tindall, #3 Exhibit A, #4 Exhibit B, #5 Exhibit C, #6 Exhibit D, #7 Exhibit E, #8 Exhibit F, #9 Exhibit G, #10 Exhibit H, #11 Exhibit I, #12 Exhibit J, #13 Exhibit K, #14 Exhibit L, #15 Exhibit M, #16 Proposed Order)(Tindall, Anne) |
| Filing 13 AMENDED COMPLAINT against All Defendants filed by PROTECT DEMOCRACY PROJECT, INC.. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Exhibit F, #7 Exhibit G, #8 Exhibit H, #9 Exhibit I, #10 Exhibit J, #11 Exhibit K, #12 Exhibit L, #13 Exhibit M)(Tindall, Anne) |
| Filing 12 MOTION for Leave to Appear Pro Hac Vice :Attorney Name- John Paredes, Filing fee $ 100, receipt number ADCDC-6845023. Fee Status: Fee Paid. by PROTECT DEMOCRACY PROJECT, INC. (Attachments: #1 Declaration of John Paredes, #2 Proposed Order)(Tindall, Anne) |
| Filing 11 NOTICE OF WITHDRAWAL OF MOTION re #3 by PROTECT DEMOCRACY PROJECT, INC. (Tindall, Anne) Modified to add link on 2/5/2020 (znmw). |
| Filing 10 NOTICE of Appearance by Kari E. D'Ottavio on behalf of All Defendants (D'Ottavio, Kari) |
| NOTICE OF ERROR re #9 Certificate of Service; emailed to anne.tindall@protectdemocracy.org, cc'd 1 associated attorneys -- The PDF file you docketed contained errors: 1. Incorrect event used, 2. Please refile document, 3. The correct event can be found under the Service of Process heading. (ztth, ) |
| NOTICE OF ERROR re #8 Certificate of Service; emailed to anne.tindall@protectdemocracy.org, cc'd 1 associated attorneys -- The PDF file you docketed contained errors: 1. Incorrect event used, 2. Please refile document, 3. The correct event can be found under the Service of Process heading. (ztth, ) |
| Filing 9 ENTERED IN ERROR.....CERTIFICATE OF SERVICE by PROTECT DEMOCRACY PROJECT, INC. on January 27, 2020, as to U.S. Attorney for the District of Columbia, pursuant to F.R.C.P. 4(i). (Tindall, Anne) Modified on 1/29/2020 (ztth). |
| Filing 8 ENTERED IN ERROR.....CERTIFICATE OF SERVICE by PROTECT DEMOCRACY PROJECT, INC. on January 27, 2020, as to U.S. Attorney General, pursuant to F.R.C.P. 4(i). (Tindall, Anne) Modified on 1/29/2020 (ztth). |
| Filing 7 RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. U.S. DEPARTMENT OF STATE served on 1/27/2020 (Attachments: #1 Delivery confirmation, #2 Receipt)(Tindall, Anne) |
| Filing 6 RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. U.S. DEPARTMENT OF DEFENSE served on 1/27/2020 (Attachments: #1 Delivery confirmation, #2 Receipt)(Tindall, Anne) |
| Filing 5 RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. U.S. DEPARTMENT OF JUSTICE served on 1/27/2020 (Attachments: #1 Delivery confirmation, #2 Receipt)(Tindall, Anne) |
| Filing 4 SUMMONS (3) Issued Electronically as to U.S. DEPARTMENT OF DEFENSE, U.S. DEPARTMENT OF JUSTICE, U.S. DEPARTMENT OF STATE. (Attachment: #1 Notice and Consent)(zmc) |
| Case assigned to Judge Rudolph Contreras. (zmc) |
| Filing 3 WITHDRAWN PURSUANT TO NOTICE FILED ON 2/3/2020..... MOTION for Preliminary Injunction by PROTECT DEMOCRACY PROJECT, INC. (Attachments: #1 Memorandum in Support of Motion for Preliminary Injunction, #2 Text of Proposed Order, #3 Declaration of Anne H. Tindall, #4 Exhibit A, #5 Exhibit B, #6 Exhibit C, #7 Exhibit D, #8 Exhibit E, #9 Exhibit F, #10 Exhibit G, #11 Exhibit H, #12 Exhibit I, #13 Exhibit J, #14 Declaration of Ian Bassin (Ex. K))(Tindall, Anne); Modified on 2/4/2020 (ztth). |
| Filing 2 LCvR 26.1 CERTIFICATE OF DISCLOSURE of Corporate Affiliations and Financial Interests by PROTECT DEMOCRACY PROJECT, INC. (Tindall, Anne) |
| Filing 1 COMPLAINT against DEPARTMENT OF DEFENSE, DEPARTMENT OF JUSTICE, DEPARTMENT OF STATE ( Filing fee $ 400 receipt number ADCDC-6756736) filed by PROTECT DEMOCRACY PROJECT, INC.. (Attachments: #1 Civil Cover Sheet, #2 Exhibit A, #3 Exhibit B, #4 Exhibit C, #5 Exhibit D, #6 Exhibit E, #7 Exhibit F, #8 Exhibit G, #9 Exhibit H, #10 Exhibit I, #11 Exhibit J, #12 Summons, #13 Summons, #14 Summons)(Tindall, Anne) |
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