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Case TitlePROTECT DEMOCRACY PROJECT, INC. v. UNITED STATES DEPARTMENT OF JUSTICE
DistrictDistrict of Columbia
CityWashington, DC
Case Number1:2020cv02810
Date Filed2020-10-02
Date Closed2021-07-22
JudgeJudge Emmet G. Sullivan
PlaintiffPROTECT DEMOCRACY PROJECT, INC.
Case DescriptionThe Protect Democracy Project submitted a FOIA request to the Department of Justice for records concerning the participation of U.S. Postal Inspection Service staff in a DOJ voter fraud task force. PDP also requested expedited processing and a fee waiver. The agency acknowledged receipt of the request and told PDP that it fell under the unusual circumstances exception and that it would take more time to process. After hearing nothing further from the agency, PDP filed suit.
Complaint issues: Failure to respond within statutory time limit, Expedited processing, Adequacy - Search, Litigation - Vaughn index, Litigation - Attorney's fees

DefendantUNITED STATES DEPARTMENT OF JUSTICE
Documents
Docket
Complaint
Complaint attachment 1
Complaint attachment 2
Complaint attachment 3
Complaint attachment 4
Complaint attachment 5
Complaint attachment 6
Complaint attachment 7
Opinion/Order [26]
User-contributed Documents
 
Docket Events (Hide)
Date FiledDoc #Docket Text

2020-10-021COMPLAINT against UNITED STATES DEPARTMENT OF JUSTICE ( Filing fee $ 400 receipt number ADCDC-7669695) filed by The Protect Democracy Project, Inc.. (Attachments: # 1 Civil Cover Sheet, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Summons to U.S. Attorney for the District of Columbia, # 6 Summons to United States Department of Justice, # 7 Summons to United States Attorney General)(Schwartztol, Laurence) (Entered: 10/02/2020)
2020-10-022LCvR 26.1 CERTIFICATE OF DISCLOSURE of Corporate Affiliations and Financial Interests by The Protect Democracy Project, Inc. (Schwartztol, Laurence) (Entered: 10/02/2020)
2020-10-053MOTION for Leave to Appear Pro Hac Vice :Attorney Name- David S. Frankel, Filing fee $ 100, receipt number ADCDC-7674403. Fee Status: Fee Paid. by The Protect Democracy Project, Inc. (Attachments: # 1 Declaration Of David S. Frankel, # 2 Text of Proposed Order Proposed Order)(Schwartztol, Laurence) (Entered: 10/05/2020)
2020-10-054MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Harry P. Morgenthau, Filing fee $ 100, receipt number ADCDC-7674495. Fee Status: Fee Paid. by PROTECT DEMOCRACY PROJECT, INC. (Attachments: # 1 Declaration Harry P. Morgenthau, # 2 Text of Proposed Order Proposed Order)(Schwartztol, Laurence) (Entered: 10/05/2020)
2020-10-055MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Daniel I. Sugarman, Filing fee $ 100, receipt number ADCDC-7674553. Fee Status: Fee Paid. by PROTECT DEMOCRACY PROJECT, INC. (Attachments: # 1 Declaration Daniel I. Sugarman, # 2 Text of Proposed Order Proposed Order)(Schwartztol, Laurence) (Entered: 10/05/2020)
2020-10-05Case Assigned to Judge Emmet G. Sullivan. (zsb) (Entered: 10/05/2020)
2020-10-05MINUTE ORDER denying 3 motion for leave to appear pro hac vice for failure to comply with Local Civil Rule 5.1(c)(1) ("All documents signed by an attorney shall contain the name, address, telephone number, and D.C. Bar identification number of the attorney if the attorney is a member of the D.C. Bar."). Signed by Judge Emmet G. Sullivan on 10/5/2020. (lcegs3) (Entered: 10/05/2020)
2020-10-05MINUTE ORDER denying 4 motion for leave to appear pro hac vice for failure to comply with Local Civil Rule 5.1(c)(1) ("All documents signed by an attorney shall contain the name, address, telephone number, and D.C. Bar identification number of the attorney if the attorney is a member of the D.C. Bar."). Signed by Judge Emmet G. Sullivan on 10/5/2020. (lcegs3) (Entered: 10/05/2020)
2020-10-05MINUTE ORDER denying 5 motion for leave to appear pro hac vice for failure to comply with Local Civil Rule 5.1(c)(1) ("All documents signed by an attorney shall contain the name, address, telephone number, and D.C. Bar identification number of the attorney if the attorney is a member of the D.C. Bar."). Signed by Judge Emmet G. Sullivan on 10/5/2020. (lcegs3) (Entered: 10/05/2020)
2020-10-066SUMMONS (3) Issued Electronically as to UNITED STATES DEPARTMENT OF JUSTICE, U.S. Attorney and U.S. Attorney General (Attachment: # 1 Notice and Consent)(adh, ) (Entered: 10/06/2020)
2020-10-06MINUTE ORDER. On October 6, 2020, Chambers received a voicemail message from Plaintiff's counsel regarding 3 , 4 , 5 motions for appearance pro hac vice. To avoid ex parte communications, the Court prohibits telephone calls from parties. Plaintiff's counsel is further reminded that, pursuant to the Local Civil Rules, "[a]ll documents signed by an attorney shall contain the... D.C. Bar identification number of the attorney if the attorney is a member of the D.C. Bar." L. Civ. R. 5.1(c)(1); see also L. Civ. R. 11.1 ("All papers signed by an attorney shall contain the... bar identification number of the attorney."). Signed by Judge Emmet G. Sullivan on 10/6/2020. (lcegs3) (Entered: 10/06/2020)
2020-10-077MOTION for Leave to Appear Pro Hac Vice :Attorney Name- David S. Frankel, Filing fee $ 100, receipt number ADCDC-7684738. Fee Status: Fee Paid. by PROTECT DEMOCRACY PROJECT, INC. (Attachments: # 1 Declaration of David S. Frankel, # 2 Text of Proposed Order)(Schwartztol, Laurence) (Entered: 10/07/2020)
2020-10-078MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Harry P. Morgenthau, Filing fee $ 100, receipt number ADCDC-7684800. Fee Status: Fee Paid. by PROTECT DEMOCRACY PROJECT, INC. (Attachments: # 1 Declaration Harry P. Morgenthau, # 2 Text of Proposed Order)(Schwartztol, Laurence) (Entered: 10/07/2020)
2020-10-079MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Daniel I. Sugarman, Filing fee $ 100, receipt number ADCDC-7684886. Fee Status: Fee Paid. by PROTECT DEMOCRACY PROJECT, INC. (Attachments: # 1 Declaration Daniel I. Sugarman, # 2 Text of Proposed Order)(Schwartztol, Laurence) (Entered: 10/07/2020)
2020-10-0710RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. UNITED STATES DEPARTMENT OF JUSTICE served on 10/7/2020 (Schwartztol, Laurence) (Entered: 10/07/2020)
2020-10-0711RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed as to the United States Attorney. Date of Service Upon United States Attorney on 10/7/2020. Answer due for ALL FEDERAL DEFENDANTS by 11/6/2020. (Schwartztol, Laurence) (Entered: 10/07/2020)
2020-10-0712RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed on United States Attorney General. Date of Service Upon United States Attorney General 10/07/2020. (Schwartztol, Laurence) (Entered: 10/07/2020)
2020-10-0813STANDING ORDER: The parties are directed to read the attached Standing Order Governing Civil Cases Before Judge Emmet G. Sullivan in its entirety upon receipt. The parties are hereby ORDERED to comply with the directives in the attached Standing Order. Signed by Judge Emmet G. Sullivan on 10/08/20. (Attachment: # 1 Exhibit 1) (mac) (Entered: 10/08/2020)
2020-10-08MINUTE ORDER granting 7 motion for leave to appear pro hac vice. David S. Frankel is hereby admitted pro hac vice in this action. 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 Emmet G. Sullivan on 10/8/2020. (lcegs3) (Entered: 10/08/2020)
2020-10-08MINUTE ORDER granting 8 motion for leave to appear pro hac vice. Harry P. Morgenthau is hereby admitted pro hac vice in this action. 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 Emmet G. Sullivan on 10/8/2020. (lcegs3) (Entered: 10/08/2020)
2020-10-08MINUTE ORDER granting 9 motion for leave to appear pro hac vice. Daniel I. Sugarman is hereby admitted pro hac vice in this action. 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 Emmet G. Sullivan on 10/8/2020. (lcegs3) (Entered: 10/08/2020)
2020-10-0914NOTICE of Appearance by David Stanley Frankel on behalf of PROTECT DEMOCRACY PROJECT, INC. (Frankel, David) (Entered: 10/09/2020)
2020-10-0915NOTICE of Appearance by Harry Pattridge Morgenthau on behalf of PROTECT DEMOCRACY PROJECT, INC. (Morgenthau, Harry) (Entered: 10/09/2020)
2020-10-0916MOTION for Preliminary Injunction by PROTECT DEMOCRACY PROJECT, INC. (Attachments: # 1 Memorandum in Support, # 2 Declaration LAURENCE M. SCHWARTZTOL, # 3 Exhibit Exhibit Index, # 4 Exhibit A, # 5 Exhibit B, # 6 Exhibit C, # 7 Exhibit D, # 8 Text of Proposed Order)(Schwartztol, Laurence) (Entered: 10/09/2020)
2020-10-12MINUTE ORDER. In view of 16 plaintiffs' motion for preliminary injunction, plaintiffs are HEREBY DIRECTED to contact forthwith the United States Attorneys Office for the District of Columbia and/or the Department of Justice as appropriate to identify government counsel. The parties shall thereafter file a joint status report by no later than October 14, 2020 at 12:00 PM NOON with recommendations for further proceedings, including, inter alia, (1) whether plaintiffs' motion for a preliminary injunction should be consolidated with the merits under Federal Rule of Civil Procedure 65; and (2) recommendations for further proceedings including, if necessary, a briefing schedule for plaintiffs' motion for a preliminary injunction. Signed by Judge Emmet G. Sullivan on 10/12/2020. (lcegs3) (Entered: 10/12/2020)
2020-10-13Set/Reset Deadlines: Joint Status Report due no later than 12:00PM on 10/14/2020 (mac) (Entered: 10/13/2020)
2020-10-1317NOTICE of Appearance by Daniel I Sugarman on behalf of PROTECT DEMOCRACY PROJECT, INC. (Sugarman, Daniel) (Entered: 10/13/2020)
2020-10-1418NOTICE of Appearance by Indraneel Sur on behalf of UNITED STATES DEPARTMENT OF JUSTICE (Sur, Indraneel) (Entered: 10/14/2020)
2020-10-1419Joint STATUS REPORT Pursuant To Minute Order by UNITED STATES DEPARTMENT OF JUSTICE. (Sur, Indraneel) (Entered: 10/14/2020)
2020-10-14MINUTE ORDER. In view of 19 joint status report, the parties shall adhere to the following briefing schedule: Defendant shall file its response by no later than October 20, 2020. Plaintiff shall file its reply by no later than October 23, 2020. Signed by Judge Emmet G. Sullivan on 10/14/2020. (lcegs3) (Entered: 10/14/2020)
2020-10-15Set/Reset Deadlines: Defendant Response due by 10/20/2020. Plaintiff Reply due by 10/29/2020. (mac) (Entered: 10/15/2020)
2020-10-1620CERTIFICATE OF SERVICE by PROTECT DEMOCRACY PROJECT, INC. re 16 MOTION for Preliminary Injunction . (Morgenthau, Harry) (Entered: 10/16/2020)
2020-10-2021Memorandum in opposition to re 16 MOTION for Preliminary Injunction filed by UNITED STATES DEPARTMENT OF JUSTICE. (Attachments: # 1 Declaration Attorney, # 2 Declaration Criminal Division FOIA Unit, # 3 Declaration Civil Rights Division FOIA Unit, # 4 Text of Proposed Order)(Sur, Indraneel) (Entered: 10/20/2020)
2020-10-2122Exhibit List to Opposition to Mot. for Prelim. Inj. by UNITED STATES DEPARTMENT OF JUSTICE. (Sur, Indraneel) (Entered: 10/21/2020)
2020-10-2323AFFIDAVIT re 21 Memorandum in Opposition, in further support of Def.'s Opposition to Mot. for Prelim. Inj. by UNITED STATES DEPARTMENT OF JUSTICE. (Attachments: # 1 Exhibit Ltr fr Civil Rights Division to Plaintiff)(Sur, Indraneel) (Entered: 10/23/2020)
2020-10-2324REPLY to opposition to motion re 16 MOTION for Preliminary Injunction filed by PROTECT DEMOCRACY PROJECT, INC.. (Frankel, David) (Entered: 10/23/2020)
2020-10-3025ORDER granting in part and denying in part 16 Motion for Preliminary Injunction. Signed by Judge Emmet G. Sullivan on 10/30/2020. (lcegs3) (Entered: 10/30/2020)
2020-10-3026MEMORANDUM OPINION. Signed by Judge Emmet G. Sullivan on 10/30/2020. (lcegs3) (Entered: 10/30/2020)
2020-11-0627ANSWER to Complaint under Freedom of Information Act by UNITED STATES DEPARTMENT OF JUSTICE.(Sur, Indraneel) (Entered: 11/06/2020)
2020-11-1128MOTION for Scheduling Order by PROTECT DEMOCRACY PROJECT, INC. (Attachments: # 1 Declaration of Harry Morgenthau, # 2 Exhibit A - Protect Democracys E-mail Communications with Defendant, # 3 Text of Proposed Order)(Frankel, David) Modified to edit the filer on 11/12/2020 (zrdj). (Entered: 11/11/2020)
2020-11-13MINUTE ORDER. In view of 28 motion for scheduling order, Defendant United States Department of Justice shall file its response by no later than November 13, 2020 at 5:00 PM. Signed by Judge Emmet G. Sullivan on 11/13/2020. (lcegs3) (Entered: 11/13/2020)
2020-11-13Set/Reset Deadlines: United States Department Of Justice Responses due no later than 5:00PM on 11/13/2020. (mac) (Entered: 11/13/2020)
2020-11-1329RESPONSE re 28 MOTION for Scheduling Order Opposition filed by UNITED STATES DEPARTMENT OF JUSTICE. (Attachments: # 1 Declaration, # 2 Text of Proposed Order)(Sur, Indraneel) (Entered: 11/13/2020)
2020-11-1630REPLY to opposition to motion re 28 MOTION for Scheduling Order filed by PROTECT DEMOCRACY PROJECT, INC.. (Frankel, David) (Entered: 11/16/2020)
2020-11-16MINUTE ORDER granting in part and denying in part 28 motion for scheduling order. Consistent with the Court's 25 Order to process Plaintiffs' FOIA request on an expedited basis, it is hereby ORDERED that Defendant United States Department of Justice shall commence rolling productions of responsive documents to Plaintiffs on a weekly basis, with the first production scheduled for November 23, 2020. It is FURTHER ORDERED that the parties shall file a joint status report with a recommendation for further proceedings by no later than December 2, 2020. Signed by Judge Emmet G. Sullivan on 11/16/2020. (lcegs3) (Entered: 11/16/2020)
2020-11-17Set/Reset Deadlines: Joint Status Report due by 12/2/2020 (mac) (Entered: 11/17/2020)
2020-12-0231Joint STATUS REPORT by PROTECT DEMOCRACY PROJECT, INC.. (Attachments: # 1 Exhibit A - November 23, 2020 Letter, # 2 Exhibit B - November 24-27 Emails, # 3 Exhibit C - November 25, 2020 Letter, # 4 Exhibit D - November 30, 2020 Letter, # 5 Exhibit E - December 1, 2020 Email)(Frankel, David) (Entered: 12/02/2020)
2020-12-16MINUTE ORDER. The parties have submitted 31 Joint Status Report in response to this Court's November 16, 2020 Minute Order requiring defendant to "commence rolling productions of responsive documents to Plaintiffs on a weekly basis, with the first production scheduled for November 23, 2020." Min. Order (Nov. 16, 2020). On November 23, 2020, defendant provided plaintiff with a "first interim response" to its FOIA request, informing plaintiff "that a search has been conducted in the appropriate section, and we are continuing to review and process potentially responsive records." Ex. 1 to JSR, ECF No. 31-1 at 2. Defendant further stated that it had referred 211 pages to the agency or entity from which they originated. Id. One week later, on November 30, 2020, the defendant provided plaintiff with a "second interim response," informing plaintiff that it had referred an additional 61 pages of documents to the agency from which they originated. Ex. 4 to JSR, ECF No 31-4. Defendant contends that its interim responses are consistent with the Court's November 16, 2020 Order because that order recognized that the defendant "would conduct its expedited processing on a 'rolling'" basis. JSR, ECF No. 31 at 6. However, defendant's interim responses are not consistent with this Court's Order, which required the production of "responsive documents." Accordingly, by no later than 12:00 pm on December 18, 2020, defendant shall file a Status Report informing the Court of: (1) the number of documents that have been produced to the plaintiff as of that date; (2) the number of responsive documents that have been identified; (3) whether the defendant's search for responsive documents is complete: (4) the number of responsive documents that originated with defendant; (5) the number of responsive documents that have been referred to an originating agency or entity; and (6) if no responsive documents originating with defendant have been produced, the reason no such documents have been produced. Signed by Judge Emmet G. Sullivan on 12/16/2020. (lcegs3) (Entered: 12/16/2020)
2020-12-17Set/Reset Deadlines: Defendant Status Report due no later than 12:00PM on 12/18/2020 (mac) (Entered: 12/17/2020)
2020-12-1832STATUS REPORT by UNITED STATES DEPARTMENT OF JUSTICE. (Sur, Indraneel) (Entered: 12/18/2020)
2020-12-18MINUTE ORDER. In view of 32 status report, the parties are directed to file another joint status report with a recommendation for further proceedings by no later than January 4, 2021. Signed by Judge Emmet G. Sullivan on 12/18/2020. (lcegs3) (Entered: 12/18/2020)
2020-12-18Set/Reset Deadlines: Joint Status Report due by 1/4/2021 (mac) (Entered: 12/18/2020)
2020-12-21ENTERED IN ERROR.....Set/Reset Deadlines: Joint Status Report due by 1/4/2021 (mac) (Entered: 12/21/2020)
2021-01-0433Joint STATUS REPORT by PROTECT DEMOCRACY PROJECT, INC.. (Attachments: # 1 Exhibit A - Defendant's Interim Response Letters, # 2 Exhibit B - Status of Responsive Documents, # 3 Exhibit C - November and December 2020 Letters, # 4 Exhibit D - December 22, 2020 Email, # 5 Exhibit E - December 23, 2020 Email)(Frankel, David) (Entered: 01/04/2021)
2021-01-1534NOTICE of Appearance by Rachel F. Homer on behalf of PROTECT DEMOCRACY PROJECT, INC. (Homer, Rachel) (Entered: 01/15/2021)
2021-01-1935NOTICE OF WITHDRAWAL OF APPEARANCE as to PROTECT DEMOCRACY PROJECT, INC.. Attorney Laurence M. Schwartztol terminated. (Schwartztol, Laurence) (Entered: 01/19/2021)
2021-02-23MINUTE ORDER. In view of 33 joint status report and Defendant's consent to complete the processing of Plaintiff's FOIA request by March 1, 2021, it is hereby ORDERED that the Criminal Division shall complete the processing of Plaintiff's FOIA request by no later than March 1, 2021. It is FURTHER ORDERED that the parties shall submit a joint status report with a recommendation for further proceedings by no later than March 15, 2021. Signed by Judge Emmet G. Sullivan on 2/23/2021. (lcegs3) (Entered: 02/23/2021)
2021-02-24Set/Reset Deadlines: Joint Status Report due by 3/15/2021 (mac) (Entered: 02/24/2021)
2021-02-2636Unopposed MOTION for Extension of Time to Complete DOJ FOIA Processing by UNITED STATES DEPARTMENT OF JUSTICE. (Attachments: # 1 Text of Proposed Order)(Sur, Indraneel) (Entered: 02/26/2021)
2021-02-26MINUTE ORDER granting 36 unopposed motion for extension of time to complete FOIA processing. It is hereby ORDERED that Defendant shall complete the processing of Plaintiff's FOIA request by no later than March 15, 2021. It is FURTHER ORDERED that the parties shall file a joint status report with a recommendation for further proceedings by no later than March 29, 2021. Signed by Judge Emmet G. Sullivan on 2/26/2021. (lcegs3) (Entered: 02/26/2021)
2021-02-27Set/Reset Deadlines: Joint Status Report due by 3/29/2021 (mac) (Entered: 02/27/2021)
2021-03-2937Joint STATUS REPORT by UNITED STATES DEPARTMENT OF JUSTICE. (Sur, Indraneel) (Entered: 03/29/2021)
2021-03-30MINUTE ORDER. In view of 37 joint status report, the parties are directed to file another joint status report with a recommendation for further proceedings by no later than April 21, 2021. Signed by Judge Emmet G. Sullivan on 3/30/2021. (lcegs3) (Entered: 03/30/2021)
2021-03-31Set/Reset Deadlines: Joint Status Report due by 4/21/2021. (mac) (Entered: 03/31/2021)
2021-04-2138Joint STATUS REPORT pursuant to Minute Order by UNITED STATES DEPARTMENT OF JUSTICE. (Sur, Indraneel) (Entered: 04/21/2021)
2021-04-26MINUTE ORDER. In view of 38 joint status report, the parties shall abide by the following schedule: the government shall file its motion for summary judgment by no later than June 21, 2021; Protect Democracy shall file its opposition and cross-motion by no later than July 21, 2021; the government shall file its opposition and reply by no later than August 18, 2021; and Protect Democracy shall file its reply by no later than September 1, 2021. Signed by Judge Emmet G. Sullivan on 4/26/2021. (lcegs3) (Entered: 04/26/2021)
2021-04-26Set/Reset Deadlines: Government Motion For Summary Judgment due by 6/21/2021. Protect Democracy Opposition And Cross-Motion due by 7/21/2021. Government Opposition And Reply due by 8/18/2021. Protect Democracy Reply due by 9/1/2021. (mac) (Entered: 04/26/2021)
2021-06-1539NOTICE of Appearance by Chetan A. Patil on behalf of UNITED STATES DEPARTMENT OF JUSTICE (Patil, Chetan) (Entered: 06/15/2021)
2021-06-1540Consent MOTION for Extension of Time to File Motion for Summary Judgment by UNITED STATES DEPARTMENT OF JUSTICE. (Attachments: # 1 Text of Proposed Order)(Patil, Chetan) (Entered: 06/15/2021)
2021-06-1741MINUTE ORDER granting 40 consent motion for extension of time. The parties shall abide by the following modified schedule: the government shall file its motion for summary judgment by no later than June 28, 2021; Protect Democracy shall file its opposition and cross-motion by no later than July 28, 2021; the government shall file its opposition and reply by no later than August 25, 2021; and Protect Democracy shall file its reply by no later than September 9, 2021. Signed by Judge Emmet G. Sullivan on 6/17/2021. (lcegs3) (Entered: 06/17/2021)
2021-06-17Set/Reset Deadlines: Government Motion For Summary Judgment dye by 6/28/2021. Protect Democracy Opposition And Cross-Motion due by 7/28/2021. Government Opposition And Reply due by 08/25/2021.Protect Democracy Reply due by 9/9/2021. (mac) (Entered: 06/17/2021)
2021-06-2842MOTION for Summary Judgment by UNITED STATES DEPARTMENT OF JUSTICE. (Attachments: # 1 Memorandum in Support, # 2 Statement of Facts, # 3 Exhibit List, # 4 Exhibit Ex. 1 - Brinkmann Decl., # 5 Exhibit Ex. 2 - Kagle Decl., # 6 Exhibit Ex. 3 - Cunningham Decl., # 7 Exhibit Ex. 4 - Warner Decl., # 8 Exhibit Ex. 5 - Seidel Decl., # 9 Exhibit Ex. 6 - Schnepfe Decl., # 10 Text of Proposed Order)(Patil, Chetan) (Entered: 06/28/2021)
2021-07-2143STIPULATION of Dismissal by PROTECT DEMOCRACY PROJECT, INC.. (Frankel, David) (Entered: 07/21/2021)
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