CHURCH et al v. BIDEN et al
STEVEN CHURCH, LESLEY CHURCH, ALMA GONZALEZ, DYNIKA BARNWELL, DOUGLAS CZERWINSKI, JASON COFFEY, JOSHUA SCHMIDT, MELINA ROYER, TAMIKA WALLS, JAIME ESPITIA, SOMER STEPHENS, ALEX BERNE, ALAN CAMP, STEPHANIE PERROTTA, CHRISTOPHER AXTELL, GRACE BROWN, KRISTOFOR HALLFRISCH, DOROTHY MORGAN, ANDREW SOTO, CHRISTOPHER HALL and ALL PLAINTIFFS |
JOSEPH R. BIDEN, LLOYD J. AUSTIN III, ANTONY J. BLINKEN, JANET YELLEN, MERRICK BRIAN GARLAND, DEBRA ANN HAALAND, THOMAS J. VILSACK, GINA M. RAIMONDO, MARTIN J. WALSH, XAVIER BECERRA, MARCIA L. FUDGE, PETER BUTTIGIEG, JENNIFER M. GRANHOLM, MIGUEL CARDONA, ALEJANDRO MAYORKAS, CLARENCE W. NELSON II, KILOLO KIJAKAZI, ROBIN CARNAHAN, DENIS MCDONOUGH, LLOYD J. AUSTIN, III, ANTONY BLINKEN and MERRICK B. GARLAND |
1:2021cv02815 |
October 24, 2021 |
US District Court for the District of Columbia |
Tanya S Chutkan |
Colleen Kollar-Kotelly |
Civil Rights: Other |
28 U.S.C. § 1331 Fed. Question |
Plaintiff |
Docket Report
This docket was last retrieved on May 11, 2022. A more recent docket listing may be available from PACER.
Document Text |
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Filing 28 REPLY to opposition to motion re #23 MOTION to Dismiss MOTION to Dismiss for Lack of Jurisdiction filed by LLOYD J. AUSTIN, III, XAVIER BECERRA, JOSEPH R. BIDEN, ANTONY BLINKEN, PETER BUTTIGIEG, MIGUEL CARDONA, ROBIN CARNAHAN, MARCIA L. FUDGE, MERRICK B. GARLAND, JENNIFER M. GRANHOLM, DEBRA ANN HAALAND, KILOLO KIJAKAZI, ALEJANDRO MAYORKAS, DENIS MCDONOUGH, CLARENCE W. NELSON II, GINA M. RAIMONDO, THOMAS J. VILSACK, MARTIN J. WALSH, JANET YELLEN. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5)(Robinson, Stuart) |
Filing 27 Memorandum in opposition to re #23 MOTION to Dismiss MOTION to Dismiss for Lack of Jurisdiction filed by ALL PLAINTIFFS. (Attachments: #1 Affidavit of Jason Coffey, #2 Affidavit of Somer Stephens)(Yoder, Michael) |
Filing 26 NOTICE OF DENIAL OF RELIGIOUS ACCOMMODATION REQUEST by LLOYD J. AUSTIN, III, XAVIER BECERRA, JOSEPH R. BIDEN, ANTONY BLINKEN, PETER BUTTIGIEG, MIGUEL CARDONA, ROBIN CARNAHAN, MARCIA L. FUDGE, MERRICK B. GARLAND, JENNIFER M. GRANHOLM, DEBRA ANN HAALAND, ALEJANDRO MAYORKAS, DENIS MCDONOUGH, CLARENCE W. NELSON II, GINA M. RAIMONDO, THOMAS J. VILSACK, MARTIN J. WALSH, JANET YELLEN (Robinson, Stuart) |
Filing 25 ORDER granting #24 Joint Motion for Extension of Time. Plaintiffs shall file their opposition to Defendants' motion to dismiss by FEBRUARY 25, 2022 and Defendants shall file their reply by MARCH 11, 2022. Signed by Judge Colleen Kollar-Kotelly on 2/11/22. (lcckk3) |
Filing 24 Joint MOTION for Extension of Time to complete briefing on motion to dismiss by LLOYD J. AUSTIN, III, XAVIER BECERRA, JOSEPH R. BIDEN, ANTONY BLINKEN, PETER BUTTIGIEG, MIGUEL CARDONA, ROBIN CARNAHAN, MARCIA L. FUDGE, MERRICK B. GARLAND, JENNIFER M. GRANHOLM, DEBRA ANN HAALAND, KILOLO KIJAKAZI, ALEJANDRO MAYORKAS, DENIS MCDONOUGH, CLARENCE W. NELSON II, GINA M. RAIMONDO, THOMAS J. VILSACK, MARTIN J. WALSH, JANET YELLEN. (Attachments: #1 Text of Proposed Order)(Myers, Steven) |
Set/Reset Deadlines: Plaintiffs' opposition to #23 due by 2/25/2022. Defendants' Reply to #23 due by 3/11/2022. (dot) |
Filing 23 MOTION to Dismiss , MOTION to Dismiss for Lack of Jurisdiction by LLOYD J. AUSTIN, III, XAVIER BECERRA, JOSEPH R. BIDEN, ANTONY BLINKEN, PETER BUTTIGIEG, MIGUEL CARDONA, ROBIN CARNAHAN, MARCIA L. FUDGE, MERRICK B. GARLAND, JENNIFER M. GRANHOLM, DEBRA ANN HAALAND, KILOLO KIJAKAZI, ALEJANDRO MAYORKAS, DENIS MCDONOUGH, CLARENCE W. NELSON II, GINA M. RAIMONDO, THOMAS J. VILSACK, MARTIN J. WALSH, JANET YELLEN. (Attachments: #1 Exhibit 1 - Declaration of David J. Furness, #2 Exhibit 2 - Declaration of William M. Jurney, #3 Exhibit 3 - Declaration of Jeremy W. Beaven, #4 Exhibit 4 - Declaration of Adrian Bennett, #5 Exhibit 5 - Declaration of Terri L. Wales, #6 Text of Proposed Order)(Myers, Steven) |
MINUTE ORDER. The Court is in receipt of Defendants' #23 Motion to Dismiss. The Court ORDERS Plaintiffs to file a response to Defendants' motion to dismiss by no later than FEBRUARY 18, 2022 and Defendants to file a reply by no later than FEBRUARY 25, 2022. Signed by Judge Colleen Kollar-Kotelly on 2/4/22. (lcckk3) |
Set/Reset Deadlines: Plaintiffs' Response to #23 due by 2/18/2022. Defendants' Reply to #23 due by 2/25/2022. (dot) |
Filing 22 NOTICE of Appearance by Stuart Justin Robinson on behalf of All Defendants (Robinson, Stuart) |
MINUTE ORDER. The Court is in receipt of Plaintiffs' #21 Notice, in which they indicate that they no longer intend to amend their #1 Complaint. Accordingly, the Court ORDERS Defendants to answer or otherwise respond to Plaintiffs' #1 Complaint by no later than FEBRUARY 4, 2022. Signed by Judge Colleen Kollar-Kotelly on 1/24/22. (lcckk3) |
Set/Reset Deadlines: Defendants to answer or otherwise respond to Plaintiffs' #1 Complaint by 2/4/2022. (dot) |
Filing 21 NOTICE of Intent to Proceed on the Merits of Plaintiffs' Original Complaint (ECF No. 1) by ALL PLAINTIFFS (Yoder, Michael) |
Set/Reset Deadlines: Amended Complaint due by 1/21/2022. (dot) |
MINUTE ORDER. The Court is in receipt of Plaintiffs' #20 Notice. As proposed therein, the Court ORDERS Plaintiffs to file their amended complaint by no later than JANUARY 21, 2022 in compliance with Fed. R. Civ. P. 15(a) and the applicable local rules. Signed by Judge Colleen Kollar-Kotelly on 1/18/22. (lcckk3) |
Filing 20 NOTICE , re: Minute Order dated 1/12/22 by ALL PLAINTIFFS (Yoder, Michael) |
MINUTE ORDER. On January 5, 2022, the Court granted Defendants' #19 Consent Motion to Stay Deadline, in which Defendants requested a stay of their January 11, 2022 deadline to answer or otherwise respond to Plaintiffs' Complaint because Plaintiffs' counsel had indicated that Plaintiffs intended to file an amended complaint by January 7, 2022. As of the date of this Minute Order, no amended complaint has been filed. The Court ORDERS Plaintiffs to file a notice by no later than JANUARY 14, 2022 indicating whether or not they intend to file an amended complaint and, if so, a proposed date for doing so. Signed by Judge Colleen Kollar-Kotelly on 1/12/22. (lcckk3) |
Filing 19 Consent MOTION to Stay re #1 Complaint,,,,,,, (Motion to Stay Deadline to Respond to Complaint) by LLOYD J. AUSTIN, III, XAVIER BECERRA, JOSEPH R. BIDEN, ANTONY BLINKEN, PETER BUTTIGIEG, MIGUEL CARDONA, ROBIN CARNAHAN, MARCIA L. FUDGE, MERRICK B. GARLAND, JENNIFER M. GRANHOLM, DEBRA ANN HAALAND, ALEJANDRO MAYORKAS, DENIS MCDONOUGH, CLARENCE W. NELSON II, GINA M. RAIMONDO, THOMAS J. VILSACK, MARTIN J. WALSH, JANET YELLEN. (Attachments: #1 Text of Proposed Order)(Myers, Steven) |
MINUTE ORDER. The Court is in receipt of Defendants' #19 Consent Motion to Stay Deadline, in which Defendants seek a stay of their deadline to answer or otherwise respond to Plaintiffs' Complaint, which is currently due by January 11, 2022. Defendants indicate that Plaintiffs' counsel has informed Defendants' counsel that Plaintiffs intend to file an amended complaint by January 7, 2022. Accordingly, Defendants seek a stay of their current deadline to answer or otherwise respond to the Complaint "to avoid any possibility of failing to timely respond to the original complaint in the unanticipated event that Plaintiffs do not file their amended complaint prior to January 11, 2022." Plaintiffs consent to Defendants' motion to stay. Accordingly, the Court GRANTS Defendants' #19 motion and ORDERS that Defendants' deadline to answer or otherwise respond to the Complaint is STAYED pending further order of this Court. Signed by Judge Colleen Kollar-Kotelly on 1/5/22. (lcckk3) |
Filing 18 Joint STATUS REPORT by LLOYD J. AUSTIN, III, XAVIER BECERRA, JOSEPH R. BIDEN, ANTONY J. BLINKEN, PETER BUTTIGIEG, MIGUEL CARDONA, ROBIN CARNAHAN, MARCIA L. FUDGE, MERRICK B. GARLAND, JENNIFER M. GRANHOLM, DEBRA ANN HAALAND, KILOLO KIJAKAZI, ALEJANDRO MAYORKAS, DENIS MCDONOUGH, CLARENCE W. NELSON II, GINA M. RAIMONDO, THOMAS J. VILSACK, MARTIN J. WALSH, JANET YELLEN. (Myers, Steven) |
MINUTE ORDER. The Court ORDERS the parties to file by no later than NOVEMBER 12, 2021 a joint status report indicating how they intend to proceed in this matter, including a proposed schedule for briefing Defendants' motion to dismiss. Signed by Judge Colleen Kollar-Kotelly on 11/9/21. (lcckk3) |
Filing 17 MEMORANDUM OPINION accompanying #16 Order. Signed by Judge Colleen Kollar-Kotelly on 11/8/2021. (lcckk3) |
Filing 16 ORDER denying #5 Emergency Application for Temporary Restraining Order and Motion for Preliminary Injunction. Signed by Judge Colleen Kollar-Kotelly on 11/8/2021. (lcckk3) |
Filing 15 NOTICE by LLOYD J. AUSTIN, III, XAVIER BECERRA, JOSEPH R. BIDEN, ANTONY J. BLINKEN, PETER BUTTIGIEG, MIGUEL CARDONA, ROBIN CARNAHAN, MARCIA L. FUDGE, MERRICK BRIAN GARLAND, JENNIFER M. GRANHOLM, DEBRA ANN HAALAND, KILOLO KIJAKAZI, ALEJANDRO MAYORKAS, DENIS MCDONOUGH, CLARENCE W. NELSON II, GINA M. RAIMONDO, THOMAS J. VILSACK, MARTIN J. WALSH, JANET YELLEN re #13 Memorandum in Opposition,,,, (Myers, Steven) |
Filing 14 REPLY to opposition to motion re #5 MOTION for Temporary Restraining Order MOTION for Preliminary Injunction filed by ALL PLAINTIFFS, CHRISTOPHER AXTELL, DYNIKA BARNWELL, ALEX BERNE, GRACE BROWN, ALAN CAMP, LESLEY CHURCH, STEVEN CHURCH, JASON COFFEY, DOUGLAS CZERWINSKI, JAIME ESPITIA, ALMA GONZALEZ, CHRISTOPHER HALL, KRISTOFOR HALLFRISCH, DOROTHY MORGAN, STEPHANIE PERROTTA, MELINA ROYER, JOSHUA SCHMIDT, ANDREW SOTO, SOMER STEPHENS, TAMIKA WALLS. (Attachments: #1 Exhibit NAVMC 118(11), Kimberly Taylor)(Yoder, Michael) |
Filing 13 Memorandum in opposition to re #5 MOTION for Temporary Restraining Order MOTION for Preliminary Injunction filed by LLOYD J. AUSTIN, III, XAVIER BECERRA, JOSEPH R. BIDEN, ANTONY J. BLINKEN, PETER BUTTIGIEG, MIGUEL CARDONA, ROBIN CARNAHAN, MARCIA L. FUDGE, MERRICK BRIAN GARLAND, JENNIFER M. GRANHOLM, DEBRA ANN HAALAND, KILOLO KIJAKAZI, ALEJANDRO MAYORKAS, DENIS MCDONOUGH, CLARENCE W. NELSON II, GINA M. RAIMONDO, THOMAS J. VILSACK, MARTIN J. WALSH, JANET YELLEN. (Attachments: #1 Exhibit 1 - Declaration of Peter Marks, #2 Exhibit 2 - FRAGO 5, #3 Exhibit 3 - Air Force Implementation Guidance, #4 Exhibit 4 - Declaration of David J. Furness, #5 Exhibit 5 - Declaration of Jeremy W. Beaven, #6 Exhibit 6 - Declaration of William M. Jurney, #7 Exhibit 7 - Declaration of Kerry A. Cerny, #8 Exhibit 8 - EOP Vaccination Policy, #9 Exhibit 9 - Declaration of Colonel Tonya Rans, #10 Exhibit 10 - Memorandum for Air Force Commanders, #11 Exhibit 11 - Declaration of Major Scott Stanley, #12 Text of Proposed Order)(Myers, Steven) |
Filing 12 ORDER ESTABLISHING PROCEDURES FOR CASES ASSIGNED TO JUDGE COLLEEN KOLLAR-KOTELLY. Signed by Judge Colleen Kollar-Kotelly on 11/01/2021. (DM) |
Filing 11 ORDER. Signed by Judge Colleen Kollar-Kotelly on October 29, 2021. (lcckk1) |
Filing 10 TRANSCRIPT OF TELEPHONIC CONFERENCE before Judge Colleen Kollar-Kotelly held on October 27, 2021; Page Numbers: 1-26. Date of Issuance: October 29, 2021. 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 11/19/2021. Redacted Transcript Deadline set for 11/29/2021. Release of Transcript Restriction set for 1/27/2022.(Edwards, Lisa) |
Filing 9 NOTICE (Supplemental) in response to Court order by LLOYD J. AUSTIN, III, XAVIER BECERRA, JOSEPH R. BIDEN, ANTONY J. BLINKEN, PETER BUTTIGIEG, MIGUEL CARDONA, ROBIN CARNAHAN, MARCIA L. FUDGE, MERRICK BRIAN GARLAND, JENNIFER M. GRANHOLM, DEBRA ANN HAALAND, KILOLO KIJAKAZI, ALEJANDRO MAYORKAS, DENIS MCDONOUGH, CLARENCE W. NELSON II, GINA M. RAIMONDO, THOMAS J. VILSACK, MARTIN J. WALSH, JANET YELLEN (Myers, Steven) |
Set/Reset Deadlines: Government's Response to #5 due by 11/2/2021. Plaintiffs' Reply to #5 due by 11/3/2021. (dot) |
Filing 8 NOTICE in response to Court order by LLOYD J. AUSTIN, III, XAVIER BECERRA, JOSEPH R. BIDEN, ANTONY J. BLINKEN, PETER BUTTIGIEG, MIGUEL CARDONA, ROBIN CARNAHAN, MARCIA L. FUDGE, MERRICK BRIAN GARLAND, JENNIFER M. GRANHOLM, DEBRA ANN HAALAND, KILOLO KIJAKAZI, ALEJANDRO MAYORKAS, DENIS MCDONOUGH, CLARENCE W. NELSON II, GINA M. RAIMONDO, THOMAS J. VILSACK, MARTIN J. WALSH, JANET YELLEN (Myers, Steven) |
MINUTE ORDER. The Court is in receipt of Defendants' #8 Notice, in which Defendants indicate that none of the civilian employee plaintiffs will be subject to discipline while his or her request for a religious exception is pending. See Notice 1, n.1. Defendants also indicate that the active duty military plaintiffs, whose religious exception requests have been denied, will not be disciplined or separated during the pendency of their appeals. See Notice 2. In sum, Defendants indicate that plaintiffs will not be disciplined by their employers while their employers consider their exception requests. However, Defendants' notice provides no guarantee of what will happen to plaintiffs if their exception requests are denied and if they reach the point of being disciplined or terminated pending briefing of Plaintiffs' #5 Motion for Temporary Restraining Order ("TRO Motion") and Defendants' forthcoming motion to dismiss. Defendants indicate merely that they shall "notify the Court" if any plaintiff receives a final determination denying his or her request for a religious exception pending the briefing of and the Court's resolution of Plaintiffs' TRO Motion and Defendants' proposed motion to dismiss. It is not clear to the Court that this Notice sufficiently addresses the Court's concern that the Plaintiffs will not be disciplined or terminated while briefing is completed pursuant to the extended scheduled requested by Defendants. It therefore appears that Plaintiffs may be prejudiced by the proposed extended briefing schedule. Accordingly, the Court ORDERS Defendants to file a supplemental notice by no later than OCTOBER 29, 2021 at 12:00 p.m. indicating whether or not they shall agree voluntarily that no plaintiff will be disciplined or terminated pending the Court's ruling on the TRO Motion. Absent such agreement, the Court shall order bifurcated briefing, requiring Defendants to file an expedited opposition to the TRO Motion (by no later than November 2, with a reply due by no later than November 3) and to file their proposed motion to dismiss in accordance with the schedule discussed during the October 27, 2021 teleconference. Signed by Judge Colleen Kollar-Kotelly on 10/28/21. (lcckk3) |
Filing 7 NOTICE of Appearance by Andrew Evan Carmichael on behalf of All Defendants (Carmichael, Andrew) |
Filing 6 NOTICE of Appearance by Steven A. Myers on behalf of All Defendants (Myers, Steven) |
Filing 5 MOTION for Temporary Restraining Order , MOTION for Preliminary Injunction by CHRISTOPHER AXTELL, DYNIKA BARNWELL, ALEX BERNE, GRACE BROWN, ALAN CAMP, LESLEY CHURCH, STEVEN CHURCH, JASON COFFEY, DOUGLAS CZERWINSKI, JAIME ESPITIA, ALMA GONZALEZ, CHRISTOPHER HALL, KRISTOFOR HALLFRISCH, DOROTHY MORGAN, STEPHANIE PERROTTA, MELINA ROYER, JOSHUA SCHMIDT, ANDREW SOTO, SOMER STEPHENS, TAMIKA WALLS. (Attachments: #1 Memorandum in Support)(Yoder, Michael) |
MINUTE ORDER. The Court held a teleconference in this matter on October 27, 2021 to discuss a briefing schedule on Plaintiffs' #5 Motion for Temporary Restraining Order and Preliminary Injunction. As discussed during the scheduling teleconference, Defendants shall file a Notice regarding the policies applicable to Plaintiffs pending consideration of exemption requests and appeals by no later than OCTOBER 28, 2021 at 6:00 p.m. Upon review of Defendants' Notice, the Court shall order a briefing schedule on Plaintiffs' TRO Motion and Defendants' proposed motion to dismiss. Signed by Judge Colleen Kollar-Kotelly on 10/27/21. (lcckk3) |
Filing 4 Case directly reassigned to Judge Colleen Kollar-Kotelly as related. Judge Tanya S. Chutkan is no longer assigned to the case. (ztnr) |
Filing 3 SUMMONS (19) Issued Electronically as to All Defendants and U.S. Attorney General (Attachment: #1 Notice and Consent)(znmg) |
Case Assigned to Judge Tanya S. Chutkan. (znmg) |
Filing 2 MOTION for Permission to Omit Home Addresses From Caption pursuant to LCvR 5.1(c)(1) by ALL PLAINTIFFS. (Attachments: #1 Memorandum in Support Memorandum of Law, #2 Affidavit Affidavit of Steven Church, #3 Affidavit Affidavit of Lesley Church, #4 Affidavit Affidavit of Grace Brown, #5 Affidavit Affidavit of Alma Gonzalez, #6 Affidavit Affidavit of Dynika Barnwell, #7 Affidavit Affidavit of Douglas Czerwinski, #8 Affidavit Affidavit of Special Agent Jason Coffey, #9 Affidavit Affidavit of Joshua Schmidt, #10 Affidavit Affidavit of Melina Royer, #11 Affidavit Affidavit of Tamika Walls, #12 Affidavit Affidavit of Jaime Espitia, #13 Affidavit Affidavit of Somer Stephens, #14 Affidavit Affidavit of Alex Berne, #15 Affidavit Affidavit of Alan Camp, #16 Affidavit Affidavit of Stephanie Perrotta, #17 Affidavit Affidavit of Christopher Axtell, #18 Affidavit Affidavit of Special Agent Kristofor Hallfrisch, #19 Affidavit Affidavit of Dorothy Morgan)(Yoder, Michael) Modified on 10/25/2021 to edit docket text (znmg). |
Filing 1 COMPLAINT STEVEN CHURCH, et al. against ALL DEFENDANTS with Jury Demand ( Filing fee $ 402 receipt number ADCDC-8819231) filed by ALL PLAINTIFFS. (Attachments: #1 Civil Cover Sheet Civil Cover Sheet, #2 Summons Summons to President Joseph R. Biden, #3 Summons Summons to Secretary Lloyd J. Austin III, #4 Summons Summons to Secretary Antony J. Blinken, #5 Summons Summons to Secretary Janet Yellen, #6 Summons Summons to Attorney General Merrick Garland, #7 Summons Summons to Secretary Debra Ann Haaland, #8 Summons Summons to Secretary Thomas J. Vilsack, #9 Summons Summons to Secretary Gina M. Raimondo, #10 Summons Summons to Secretary Martin J. Walsh, #11 Summons Summons to Secretary Xavier Becerra, #12 Summons Summons to Secretary Marcia L. Fudge, #13 Summons Summons to Secretary Peter Buttigieg, #14 Summons Summons to Secretary Jennifer M. Granholm, #15 Summons Summons to Secretary Miguel Cardona, #16 Summons Summons to Secretary Denis McDonough, #17 Summons Summons to Secretary Alejandro Mayorkas, #18 Summons Summons to Administrator Clarence W. Nelson II, #19 Summons Summons to Acting Commissioner Kilolo Kijakazi, #20 Summons Summons to Administrator Robin Carnahan, #21 Exhibit Executive Order 13991, #22 Exhibit SECDEF Order, #23 Exhibit Executive Order 14043, #24 Exhibit Task Force Guidance, #25 Exhibit Task Force Video Footage (.mp4 file to Clerk of Court), #26 Exhibit Affidavit of Authentication, #27 Exhibit Affidavit of Authentication, #28 Exhibit Affidavit of Authentication, #29 Exhibit Dept. of Navy Denial Letter, #30 Exhibit Dept. of Navy Denial Letter, #31 Exhibit COVID-19 Statistics, #32 Exhibit DOJ Memorandum to the President)(Yoder, Michael) Modified on 10/25/2021 to edit docket text (znmg). |
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