Case: Withrow v. United States of America

Withrow v. United States of America et al.

COMPLAINT against TRAVIS ADKINS, EDDY ARRIOLA, PAUL S. ATKINS, SCOTT BESSENT, FRANK J. BISIGNANO, BEN BLACK, PAM BONDI, RODNEY BOYD, SHANA M. BROUSSARD, CRAIG T. BROWN, DOUG BURGUM, BRENDON CARR, LORI CHAVEZ-DEREMER, ERHARD R. CHORLE, DOUGLAS A. COLLINS, ANNA DAVIS, JANET DHILLON, SEAN DUFFY(in his official capacity as Secretary of the Department of Transportation), SEAN DUFFY(in his official capacity as Acting Administrator of the National Aeronautics and Space Administration), PETER A. FELDMAN, ANDREW FERGUSON, ANDREW FOIS, TULSI GABBARD, ANDREA GACKI, ROCHELLE GARZA, GENERAL SERVICES ADMINISTRATION, MICHAEL F. GERBER, JONATHAN V. GOULD, JAMIESON GREER, TIMOTHY GRIBBEN, JEFFERY HALL, THOMAS R. HARDY, ROGER HARRIS, KYLE S. HAUPTMAN, PETE HEGSETH, HEATHER M. HILL, TRAVIS HILL, JENNIFER HOMENDY, MARY LU JORDAN, JOHN JOVANOVIC, AMY A. KARPEL, ROBERT KENNEDY, HENRY J. KERNER, COLLEEN DUFFY KIKO, SCOTT KUPOR, KARI LAKE, PATRICIA L. LEE, KELLY LOEFFLER, ANDREA R. LUCAS, HOWARD LUTNICK, MICHAEL MCDONALD, LINDA E. MCMAHON, KRISTIE MCNALLY, DON MOUL, KRISTI NOEM, OFFICE OF PERSONNEL MANAGEMENT, JEROME H. POWELL, DAVID PROUTY, JOHN RATCLIFFE, MICHAEL RIGAS, BROOKE L. ROLLINS, MARCO RUBIO(in his official capacity as Secretary of the Department of State), MARCO RUBIO(in his official capacity as Acting Archivist of the United States of the National Archives and Records Administration), MARY G. RYAN, WILLIAM SCHARF, LOREN J. SCIURBA, PAUL SHEA, MICHAEL D. SMITH, JONATHAN L. SNARE, LOUISE SOLA, PATRICIA A. SOLIMENE, DAVID STEINER, BRIAN W. STONE, LOREN E. SWEATT, ROBERT G. TAUB, SCOTT TURNER, ERIC UELAND, UNITED STATES OF AMERICA, RAHUL VARMA, RUSSELL VOUGHT(in his official capacity as Acting Administrator of the United States Agency for International Development), RUSSELL VOUGHT(in his official capacity as Acting Director of the Consumer Financial Protection Board), CHRIS WRIGHT, DAVID A. WRIGHT, LEE ZELDIN ( Filing fee $ 405 receipt number ADCDC-12091874) filed by LEANNE WITHROW. (Attachments: # 1 Civil Cover Sheet, # 2 Summons)(Gleklen, Jonathan) (Entered: 11/20/2025)

1 Civil Cover Sheet

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2 Summons

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MOTION to Certify Class by LEANNE WITHROW. (Attachments: # 1 Declaration Ex 1 - Gleklen Declaration, # 2 Exhibit Ex A to Gleklen Declaration, # 3 Exhibit Ex B to Gleklen Declaration, # 4 Exhibit Ex C to Gleklen Declaration, # 5 Exhibit Ex D to Gleklen Declaration, # 6 Exhibit Ex E to Gleklen Declaration, # 7 Exhibit Ex F to Gleklen Declaration, # 8 Exhibit Ex G to Gleklen Declaration, # 9 Exhibit Ex H to Gleklen Declaration, # 10 Exhibit Ex I to Gleklen Declaration, # 11 Exhibit Ex J to Gleklen Declaration, # 12 Exhibit Ex K to Gleklen Declaration, # 13 Exhibit Ex L to Gleklen Declaration, # 14 Exhibit Ex M to Gleklen Declaration, # 15 Exhibit Ex N to Gleklen Declaration, # 16 Exhibit Ex O to Gleklen Declaration, # 17 Declaration Ex 2 - Withrow Declaration, # 18 Declaration Ex 3 - Kniznik Declaration, # 19 Declaration Ex 4 - Second Gleklen Declaration, # 20 Declaration Ex 5 - Golden Declaration, # 21 Declaration Ex 6 - Perloff Declaration, # 22 Declaration Ex 7 - Garcia Declaration, # 23 Text of Proposed Order Proposed Order)(Gleklen, Jonathan) (Entered: 11/20/2025)

1 Declaration Ex 1 - Gleklen Declaration

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2 Exhibit Ex A to Gleklen Declaration

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3 Exhibit Ex B to Gleklen Declaration

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4 Exhibit Ex C to Gleklen Declaration

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5 Exhibit Ex D to Gleklen Declaration

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6 Exhibit Ex E to Gleklen Declaration

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7 Exhibit Ex F to Gleklen Declaration

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8 Exhibit Ex G to Gleklen Declaration

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9 Exhibit Ex H to Gleklen Declaration

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10 Exhibit Ex I to Gleklen Declaration

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11 Exhibit Ex J to Gleklen Declaration

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12 Exhibit Ex K to Gleklen Declaration

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13 Exhibit Ex L to Gleklen Declaration

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14 Exhibit Ex M to Gleklen Declaration

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15 Exhibit Ex N to Gleklen Declaration

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16 Exhibit Ex O to Gleklen Declaration

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17 Declaration Ex 2 - Withrow Declaration

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18 Declaration Ex 3 - Kniznik Declaration

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19 Declaration Ex 4 - Second Gleklen Declaration

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20 Declaration Ex 5 - Golden Declaration

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21 Declaration Ex 6 - Perloff Declaration

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22 Declaration Ex 7 - Garcia Declaration

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23 Text of Proposed Order Proposed Order

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NOTICE of Appearance by Scott Michelman on behalf of All Plaintiffs (Michelman, Scott) (Entered: 11/20/2025)

NOTICE of Appearance by Michael Krevans Perloff on behalf of All Plaintiffs (Perloff, Michael) (Entered: 11/20/2025)

SEALED DOCUMENT filed by LEANNE WITHROW(This document is SEALED and only available to authorized persons.)(Perloff, Michael) (Entered: 11/20/2025)

NOTICE OF ASSIGNMENT OF CASE TO U.S. MAGISTRATE JUDGE. All parties must consent to or decline the jurisdiction of the Magistrate Judge no later than twenty-one (21) days following the date on which the last defendant to respond to the Complaint files an Answer or motion under Rule 12. The consent or declination form is attached. (zhcn) (Entered: 11/21/2025)

NOTICE of Appearance by Kaitlyn Golden on behalf of LEANNE WITHROW (Golden, Kaitlyn) (Entered: 11/21/2025)

NOTICE of Appearance by Madeline Gitomer on behalf of LEANNE WITHROW (Gitomer, Madeline) (Entered: 11/21/2025)

NOTICE of Appearance by Paul R.Q. Wolfson on behalf of LEANNE WITHROW (Wolfson, Paul) (Entered: 11/21/2025)

Notice of Error- New Case

NOTICE OF NEW CASE ERROR regarding 1 Complaint. The following error(s) need correction: Invalid signature. Please file the signed Complaint using the event Errata. All filings must have an original signature or /s/ Attorney Name to represent an electronic signature of the filer. The filing attorney must sign the complaint. Jonathan Gleklen is the filing attorney. COMPLIANCE DEADLINE is by close of business today. This case will not proceed any further until all errors are satisfied. (zhcn)

Case Assigned/Reassigned

ERRATA by LEANNE WITHROW re 1 Complaint,,,,,,,,. (Gleklen, Jonathan) (Entered: 11/21/2025)

ERRATA Corrected Motion by LEANNE WITHROW re 4 Motion to Certify Class,,,,. (Gleklen, Jonathan) (Entered: 11/21/2025)

Case Assigned to Magistrate Judge Zia M. Faruqui. (zhcn)

SUMMONS (85) Issued Electronically as to All Defendants, U.S. Attorney and U.S. Attorney General (Attachments: # 1 Notice and Consent)(znmw) (Entered: 11/24/2025)

CERTIFICATE OF SERVICE by LEANNE WITHROW re 7 Errata Motion to Certify Class. (Gleklen, Jonathan) (Entered: 11/25/2025)

NOTICE of Appearance by Shana Knizhnik on behalf of All Plaintiffs (Knizhnik, Shana) (Entered: 12/02/2025)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed as to the United States Attorney. Date of Service Upon United States Attorney on 11/25/2025. Answer due for ALL FEDERAL DEFENDANTS by 1/24/2026. (Gleklen, Jonathan) (Entered: 12/05/2025)

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Barbara Schwabauer, Filing fee $ 100, receipt number ADCDC-12136705. Fee Status: Fee Paid. by LEANNE WITHROW. (Knizhnik, Shana) (Entered: 12/15/2025)

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Joshua Block, Filing fee $ 100, receipt number ADCDC-12136767. Fee Status: Fee Paid. by LEANNE WITHROW. (Knizhnik, Shana) (Entered: 12/15/2025)

Order on Motion for Leave to Appear Pro Hac Vice

MINUTE ORDER. Upon consideration of Plaintiffs' 17 Motion for Admission to Appear Pro Hac Vice on Behalf of Plaintiff Leanne Withrow and all those similarly situated, and it appearing to the Court that the attorney referenced therein meets the requirements for pro hac vice admission under this Court's rules, it is hereby ORDERED that the motion is GRANTED. It is further ORDERED that Barbara Schwabauer, American Civil Liberties Union, 125 Broad Street, 18th Floor, New York, NY 10004, is ADMITTED to practice before the Court pro hac vice in this case. Signed by Magistrate Judge Zia M. Faruqui on December 17, 2025.Counsel should register for e-filing via PACER and file a notice of appearance pursuant to LCvR 83.6(a) Click for instructions (lcia)

MINUTE ORDER. Upon consideration of Plaintiffs' 18 Motion for Admission to Appear Pro Hac Vice on Behalf of Plaintiff Leanne Withrow and all those similarly situated, and it appearing to the Court that the attorney referenced therein meets the requirements for pro hac vice admission under this Court's rules, it is hereby ORDERED that the motion is GRANTED. It is further ORDERED that Joshua Block, American Civil Liberties Union, 125 Broad Street, 18th Floor, New York, NY 10004, is ADMITTED to practice before the Court pro hac vice in this case. Signed by Magistrate Judge Zia M. Faruqui on December 17, 2025. Counsel should register for e-filing via PACER and file a notice of appearance pursuant to LCvR 83.6(a) Click for instructions (lcia)

NOTICE of Appearance by Barbara Ann Schwabauer on behalf of LEANNE WITHROW (Schwabauer, Barbara) (Entered: 12/29/2025)

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Harper Seldin, Filing fee $ 100, receipt number ADCDC-12174286. Fee Status: Fee Paid. by LEANNE WITHROW. (Knizhnik, Shana) (Main Document 20 replaced on 1/9/2026) (znmw). (Entered: 01/08/2026)

NOTICE of Appearance by Dimitar Georgiev-Remmel on behalf of UNITED STATES OF AMERICA (Georgiev-Remmel, Dimitar) (Entered: 01/09/2026)

Case randomly reassigned to Judge Jia M. Cobb. Magistrate Judge Zia M. Faruqui is no longer assigned to the case. (ztnr)

Case Assigned/Reassigned

MINUTE ORDER granting 20 Motion for Leave to Appear Pro Hac Vice: Attorney Harper Seldin is hereby admitted pro hac vice to appear in this matter. 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 Jia M. Cobb on January 14, 2026. (lcjmc1)

Order on Motion for Leave to Appear Pro Hac Vice

Joint MOTION for Briefing Schedule re 1 Complaint,,,,,,,, 4 MOTION to Certify Class by UNITED STATES OF AMERICA. (Georgiev-Remmel, Dimitar) Modified event on 1/16/2026 (znmw). (Entered: 01/15/2026)

MINUTE ORDER granting 23 Motion for Briefing Schedule: Having considered the motion, and for good cause shown, the Court GRANTS the motion. Defendants' dispositive motion is due by February 26, 2026, Plaintiff's response is due by March 30, 2026, and Defendants' reply is due by April 23, 2026. It is further ORDERED that briefing of Plaintiff's 4 Motion to Certify Class is stayed pending further order of the Court. Signed by Judge Jia M. Cobb on January 16, 2026. (lcjmc3)

Order on Motion for Briefing Schedule AND Set/Reset Deadlines

MOTION for Extension of Time to File Dispositive Motion by UNITED STATES OF AMERICA. (Georgiev-Remmel, Dimitar) (Entered: 02/20/2026)

Order on Motion for Extension of Time to File AND Set/Reset Deadlines

MINUTE ORDER granting 24 Motion for Extension of Time to File Dispositive Motion: Having considered the motion, and for good cause shown, the Court GRANTS the motion. It is further ORDERED that the dispositive motion briefing schedule is modified as follows: Defendants' dispositive motion is due by March 13, 2026, Plaintiff's response is due by April 14, 2026, and Defendants' reply is due by May 8, 2026. Signed by Judge Jia M. Cobb on February 23, 2026. (lcjmc1)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. TRAVIS ADKINS served on 12/9/2025; BEN BLACK served on 12/9/2025; PAMELA J. BONDI served on 12/9/2025; SHANA M. BROUSSARD served on 12/9/2025; DOUG BURGUM served on 12/9/2025; BRENDON CARR served on 12/9/2025; DOUGLAS A. COLLINS served on 12/9/2025; ANDREW FOIS served on 12/9/2025; ANDREA M. GACKI served on 12/9/2025; TIMOTHY GRIBBEN served on 12/9/2025; JEFFERY HALL served on 12/9/2025; KYLE S. HAUPTMAN served on 12/9/2025; PETE HEGSETH served on 12/9/2025; TRAVIS HILL served on 12/9/2025; HENRY J. KERNER served on 12/9/2025; COLLEEN DUFFY KIKO served on 12/9/2025; SCOTT KUPOR served on 12/9/2025; ANDREA R. LUCAS served on 12/9/2025; HOWARD LUTNICK served on 12/9/2025; MICHAEL MCDONALD served on 12/9/2025; LINDA E. MCMAHON served on 12/3/2025; OFFICE OF PERSONNEL MANAGEMENT served on 12/10/2025; JEROME H. POWELL served on 12/8/2025; MARCO A. RUBIO(in his official capacity as Acting Archivist of the United States of the National Archives and Records Administration) served on 12/19/2025; MARY G. RYAN served on 12/4/2025; WILLIAM SCHARF served on 12/2/2025; LOREN E. SWEATT served on 12/2/2025; RUSSELL VOUGHT(in his official capacity as Acting Administrator of the United States Agency for International Development) served on 12/9/2025; CHRIS WRIGHT served on 12/3/2025; LEE ZELDIN served on 12/3/2025 (Attachments: # 1 Exhibit A, # 2 Exhibit B)(Gleklen, Jonathan) (Entered: 02/25/2026)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. PAUL S. ATKINS served on 12/3/2025; FRANK J. BISIGNANO served on 12/5/2025; ERHARD R. CHORLE served on 12/29/2025; JANET DHILLON served on 12/2/2025; ANDREW FERGUSON served on 1/5/2026; ROCHELLE GARZA served on 12/9/2025; JONATHAN V. GOULD served on 12/3/2025; JAMIESON GREER served on 12/2/2025; THOMAS R. HARDY served on 12/4/2025; ROGER HARRIS served on 12/2/2025; HEATHER M. HILL served on 12/3/2025; JENNIFER HOMENDY served on 12/3/2025; KELLY LOEFFLER served on 12/9/2025; KRISTIE MCNALLY served on 12/3/2025; DON MOUL served on 12/5/2025; PAUL SHEA served on 12/3/2025; JONATHAN L. SNARE served on 12/2/2025; DAVID STEINER served on 12/4/2025; BRIAN W. STONE served on 12/4/2025; ROBERT G. TAUB served on 12/3/2025; DAVID A. WRIGHT served on 12/3/2025 (Attachments: # 1 Exhibit A, # 2 Exhibit B)(Gleklen, Jonathan) (Entered: 02/25/2026)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed on United States Attorney General. Date of Service Upon United States Attorney General 12/4/2025. (Attachments: # 1 Exhibit A, # 2 Exhibit B)(Gleklen, Jonathan) (Entered: 02/25/2026)

MOTION to Dismiss by TRAVIS ADKINS, EDDY ARRIOLA, PAUL S. ATKINS, SCOTT BESSENT, FRANK J. BISIGNANO, BEN BLACK, PAMELA J. BONDI, RODNEY BOYD, SHANA M. BROUSSARD, CRAIG T. BROWN, DOUG BURGUM, BRENDON CARR, LORI CHAVEZ-DEREMER, ERHARD R. CHORLE, DOUGLAS A. COLLINS, ANNA DAVIS, JANET DHILLON, SEAN DUFFY(in his official capacity as Secretary of the Department of Transportation), SEAN DUFFY(in his official capacity as Acting Administrator of the National Aeronautics and Space Administration), PETER A. FELDMAN, ANDREW FERGUSON, ANDREW FOIS, TULSI GABBARD, ANDREA M. GACKI, ROCHELLE GARZA, GENERAL SERVICES ADMINISTRATION, MICHAEL F. GERBER, JONATHAN V. GOULD, JAMIESON GREER, TIMOTHY GRIBBEN, JEFFERY HALL, THOMAS R. HARDY, ROGER HARRIS, KYLE S. HAUPTMAN, PETE HEGSETH, HEATHER M. HILL, TRAVIS HILL, JENNIFER HOMENDY, MARY LU JORDAN, JOHN JOVANOVIC, AMY A. KARPEL, ROBERT KENNEDY, HENRY J. KERNER, COLLEEN DUFFY KIKO, SCOTT KUPOR, KARI LAKE, PATRICIA L. LEE, KELLY LOEFFLER, ANDREA R. LUCAS, HOWARD LUTNICK, MICHAEL MCDONALD, LINDA E. MCMAHON, KRISTIE MCNALLY, DON MOUL, KRISTI L. NOEM, OFFICE OF PERSONNEL MANAGEMENT, JEROME H. POWELL, DAVID PROUTY, JOHN RATCLIFFE, MICHAEL RIGAS, BROOKE L. ROLLINS, MARCO A. RUBIO(in his official capacity as Secretary of the Department of State), MARCO A. RUBIO(in his official capacity as Acting Archivist of the United States of the National Archives and Records Administration), MARY G. RYAN, WILLIAM SCHARF, LOREN J. SCIURBA, PAUL SHEA, MICHAEL D. SMITH, JONATHAN L. SNARE, LOUISE SOLA, PATRICIA A. SOLIMENE, DAVID STEINER, BRIAN W. STONE, LOREN E. SWEATT, ROBERT G. TAUB, SCOTT TURNER, ERIC UELAND, UNITED STATES OF AMERICA, RAHUL VARMA, RUSSELL VOUGHT(in his official capacity as Acting Administrator of the United States Agency for International Development), RUSSELL VOUGHT(in his official capacity as Acting Director of the Consumer Financial Protection Board), CHRIS WRIGHT, DAVID A. WRIGHT, LEE ZELDIN. (Georgiev-Remmel, Dimitar) (Entered: 03/13/2026)

Leave to File Amicus Brief

Appear Pro Hac Vice

Appear Pro Hac Vice

Order on Motion for Leave to Appear Pro Hac Vice

Order on Motion for Leave to File Amicus Brief

Notice of Appearance

Notice of Appearance

Amicus Brief

Extension of Time to File Response/Reply

Notice of Appearance

Order on Motion for Extension of Time to File Response/Reply AND Set/Reset Deadlines