Vietnam Veterans Vs. The CIA (Class Action Lawsuit)

What This Case Is About

In this class action, the Plaintiff class sought declaratory and injunctive relief to redress decades of the U.S. Government’s use of them as human test subjects in chemical and biological agent testing experiments, followed by decades of neglect:

Test subjects have been released from oaths of secrecy: 2011 Secrecy Oath Release

On November 19, 2013, the Court ordered the Army to provide Notice: “the Army has an ongoing duty to warn members of the class about newly acquired information that may affect their well-being now and in the future as it becomes available,” including “effects upon their health which may possibly come from such participation”

On April 4, 2017, the Court ordered the Army to provide Medical Care: “the Army has an ongoing duty to provide medical care to the members of the class for any injury or disease that is the proximate result of their participation in Defendant’s chemical or biological substance testing programs”

To apply for medical care from the Army under the Court’s injunction, submit an Application for Medical Care to: U.S. Army Public Health Center (USAPHC), ATTN: Benefits Application Panel, 5158 Blackhawk Road, APG, MD 21010-5403. For more information, please see the Army’s October 2017 letter, and the Army’s follow up May 2018 letter, containing answers to some class member questions. To request notice information, you can submit a Form 2870 Request for the Army to search its databases and provide you with information about your testing participation. If you have questions or need assistance, please call the Army’s toll-free hotline at 1-800-984-8523.

Copyright 2008-19 Morrison & Foerster LLP unless otherwise noted. All rights reserved.

Court-Filed Documents

For your convenience, the primary court-filed documents in our case may be accessed here, without any password or registration. Alternatively, you may access the complete docket of the case and all the documents on file by visiting the website for the United States District Court for the Northern District of California at http://www.cand.uscourts.gov. Click on ECF-Pacer, which will take you to Electronic Case Filing and Pacer. From there, if you have a Pacer account, you may use your login and password to access this case, or any other case filed there in recent years.

Army’s Status Report Pursuant to Medical Care Injunction [1/10/18]
Declaration of Matthew J. Schofield [1/10/18]
Order Granting in Part and Denying in Part Motion to Stay Deadline to File Status Report [12/28/18]
Motion for a Stay of the Deadline to File Status Report [12/26/18]
[Proposed] Order [12/24/18]
Order Granting Plaintiffs’ Motion for Attorneys’ Fees [10/4/18]
Stipulation & Order Regarding Plaintiffs’ Motion for Attorneys’ Fees and Expenses & Service Awards [10/4/18]
Plaintiffs’ Supplemental Brief for Approval of Settlement Regarding Plaintiffs’ Claim for Attorneys’ Fees and Expenses [8/17/18]
Declaration of James P. Bennett in Support of Plaintiffs’ Unopposed Motion for Approval of Settlement Regarding Claim for Attorneys’ Fees and Expenses [8/17/18]
Stipulation & [Proposed] Order Regarding Plaintiffs’ Motion for Attorneys’ Fees and Expenses & Service Awards [8/17/18]
Army’s July 3 Status Report Pursuant to Medical Care Injunction [8/10/18]
Declaration of Matthew J. Schofield [8/10/18]
Joint Status Report Regarding Status of Motion for Fees and Expenses [7/12/18]
Order Regarding Status of Motion for Attorneys’ Fees and Expenses [7/5/18]
Army’s July 3 Status Report Pursuant to Medical Care Injunction [7/3/18]
Declaration of Matthew J. Schofield [7/3/18]
Review of Report and Approach to Evaluating Long-Term Health Effects in Army Test Subjects [4/25/18]
Update to Department of the Army Report Pursuant to the Court’s November 19, 2013 Injunction [3/22/18]
Declaration of John J. Resta [3/22/18]
Examples 1, 3, and 4 [3/22/18]
Assessment of Potential Long-Term Health Effects on Army Human Test Subjects of Relevant Biological and Chemical Agents, Drugs, Medications and Substances [3/22/18]
Army’s January 3 Status Report Pursuant to Medical Care Injunction [1/3/18]
Army Letter to Veterans and Service Members [10/18/17]
Application for Medical Care [10/18/17]
Order Granting Plaintiffs’ Unopposed Administrative Motion to Accept Bill of Costs Under 28 U.S.C. § 2412 and Vacate Clerk’s Notice of Deficiency [8/18/17]
Plaintiffs’ Unopposed Administrative Motion to Accept Bill of Costs Under 28 U.S.C. § 2412 and Vacate Clerk’s Notice of Deficiency [8/17/17]
Declaration of James R. Hancock in Support of Plaintiffs’ Unopposed Administrative Motion to Accept Bill of Costs Under 28 U.S.C. § 2412 and Vacate Clerk’s Notice of Deficiency [8/17/17]
[Proposed] Order Granting Plaintiffs’ Unopposed Administrative Motion to Accept Bill of Costs Under 28 U.S.C. § 2412 and Vacate Clerk’s Notice of Deficiency [8/17/17]
Clerks’ Notice of Deficiency in Bill of Costs [8/3/17]
Bill of Costs [7/18/17]
Plaintiffs’ Notice of Motion & Motion Applying for Attorneys’ Fees and Expenses; Memorandum in Support Thereof [7/18/17]
Declaration of Stacey M. Sprenkel in Support of Motion for Attorneys’ Fees and Expenses [7/18/17]
Stipulation and Order to Stay Further Briefing After the Filing of Plaintiffs’ Fee Petition to Allow Parties Time to Continue Settlement Discussions [7/17/17]
Department of the Army Status Report Pursuant to the Court’s April 4, 2017 Injunction [7/3/17]
Amended Judgment [4/19/17]
Injunction Regarding the Provision of Medical Care [4/4/17]
Defendants’ Response to the Court’s Order Regarding a Proposed Health Care Injunction [3/1/17]
Order on Defendants’ Motion to Extend Deadline to Respond to The Court’s Proposed Modification of the Medical Care Injunction [2/2/17]
Plaintiffs’ Response to the Court’s Proposed Injunction [1/11/17]
Stipulation to Enlarge Injunction Briefing Deadlines and Order [12/16/16]
Order for Further Briefing Regarding Injunction on Remand [12/7/16]
Proposed Plan for Implementing the Provision of Medical Care Pursuant to Army Regulation 70-25 [12/7/16]
Defendants’ Response to The Court’s Order Regarding a Proposed Health Care Injunction [11/15/16]
Declaration of Colonel Brian A. Hugues [11/15/16]
[Proposed] Health Care Injunction Order [11/15/16]
Plaintiffs’ Brief in Support of Proposed Injunction [11/15/16]
[Proposed] Injunction Pursuant to the Court’s February 8, 2016 Order [11/15/16]
Stipulation to Enlarge Injunction Submission Deadlines and Order [10/26/16]
Stipulation to Enlarge Injunction Submission Deadlines and Order [9/2/16]
Stipulation to Enlarge Injunction Submission Deadlines and Order [7/18/16]
Stipulation (Third) to Enlarge Injunction Submission Deadlines and Order [5/1/16]
Stipulation (Second) to Enlarge Injunction Submission Deadlines and Order [4/15/16]
Stipulation to Enlarge Injunction Submission Deadlines and Order [3/2/16]
Order Directing Parties to Meet and Confer [2/11/16]
Mandate [2/4/16]
Order and Amended Opinion [1/26/16]
Appellants’/Cross-Appellees’ Opposition to Petition for Rehearing and Rehearing En Banc [10/8/15]
Defendant-Appellees/Cross Appellants’ Petition for Rehearing and Rehearing En Banc [9/4/15]
Order [7/22/15]
Motion for a 21-Day Extension of Time in Which to File Rehearing Petition [7/17/15]
Bill of Costs [7/14/15]
Plaintiffs-Appellants/Cross-Appellees’ Statement in Support of Bill of Costs [7/14/15]
Order [6/30/15]
Information Regarding Judgment and Post-Judgment Proceedings [6/30/15]
Opinion [6/30/15]
Letter to Judge Fletcher [1/20/15]
Status Report [11/4/14]
Declaration of Tonya Kreps [11/4/14]
Declaration of Uldric L. Fiore, Jr. [11/4/14]
Reply Brief for Defendants-Appellees/Cross-Appellants [4/21/2014]
Department of the Army Revised Report Pursuant to the Court’s April 2, 2014 Order [4/16/14]
Exhibit A
Exhibit B
Exhibit C
Exhibit D
Third Brief on Cross-Appeal: Appellants’/Crossappellees’ Reply Brief and Opposition to Cross-Appeal [4/7/14]
Order Regarding Defendant Department of Army’s March 6, 2014 Report [4/02/14]
Department of the Army Report Pursuant to The Court’s November 19, 2013 Injunction [3/6/14]
Exhibit A: Declaration of Lloyd Roberts, United States Army Medical Research Institute of Chemical Defense [3/6/14]
Opening Brief for Defendants-Appellees/Cross-Appellants [3/5/14]
Supplemental Record Excerpts for Defendants-Appellees/Cross-Appellants [3/5/14]
Order [2/20/14]
Reply in Support of Emergency Motion for Stay and Expedited Review Under Circuit Rule 27-3 [2/12/14]
Opposition to Emergency Motion for Stay and Expedited Review Under Circuit Rule 27-3 [2/10/14]
Emergency Motion for Stay and Expedited Review Under Circuit Rule 27-3 [2/6/14]
Attachment A: Order Granting in Part and Denying in Part Plaintiffs’ Motion for Summary Judgment and Granting in Part and Denying in Part Defendants’ Motion for Summary Judgment [2/6/14]
Attachment B: Declaration of Dee Dodson Morris [2/6/14]
Attachment C: Injunction Pursuant to the Court’s Summary Judgment Order [2/6/14]
Attachment D: Order Denying Defendants’ Motion to Stay [2/6/14]
Order Denying Defendants’ Motion to Stay [2/5/14]
Opening Brief of Appellants [2/3/14]
Excerpts of Record in Support of Appellants’ Opening Brief, Vol. 1, Pp. 1–285 [2/3/14]
Excerpts of Record in Support of Appellants’ Opening Brief, Vol. 2, Pp. 286–578 [2/3/14]
Excerpts of Record in Support of Appellants’ Opening Brief, Vol. 3, Pp. 579–757 [2/3/14]
Defendants’ Reply in Support of Motion for a Stay Pending Plaintiffs’ Appeal and Cross-Appeal by Defendants [1/31/14]
Plaintiffs’ Opposition to Defendants’ Motion for a Stay Pending Plaintiffs’ Appeal and Cross-Appeal by Defendants [1/30/14]
Defendants’ Notice of Motion for a Stay Pending Plaintiffs’ Appeal and Cross-Appeal by Defendants; Memorandum of Points and Authorities [1/22/14]
Declaration of Joshua E. Gardner in Support of Defendants’ Motion for Stay Pending Appeal [1/22/14]
Declaration of Dee Dodson Morris [1/22/14]
Notice of Cross-Appeal [1/21/14]
Order [2/13/13]
Appellee’s Response to Appellants’ Motion to Expedite Appeal [12/16/13]
Order [12/16/13]
Appellants’ Motion to Expedite Appeal [12/10/13]
Time Schedule Order [11/27/13]
Notice of Appeal [11/26/13]
Judgment [11/19/13]
Injunction Pursuant to the Court’s Summary Judgment Order [11/19/13]
Order Granting in Part and Denying in Part Plaintiffs’ Motion for Summary Judgment and Granting in Part and Denying in Part Defendants’ Motion for Summary Judgment [11/19/13]
Plaintiffs’ Response to Defendants’ Response to the Court’s Proposed Injunction and Judgment [10/25/13]
Defendants’ Response to the Court’s Proposed Injunction and Judgment [10/21/13]
Intended Order Granting in Part and Denying in Part Plaintiffs’ Motion for Summary Judgment and Granting in Part and Denying in Part Defendants’ Motion for Summary Judgment [10/11/13]
Intended Judgment [10/11/13]
Intended Injunction Pursuant to the Court’s Summary Judgment Order [10/11/13]
Proposed Injunction and Judgment Pursuant to the Court’s Summary Judgment Order [8/6/13]
Plaintiffs’ Notice of Motion and Motion for Leave to File Motion for Reconsideration Regarding APA Medical Care Claim [8/5/13]
Order Granting in Part and Denying in Part Plaintiffs’ Motion for Summary Judgment and Granting in Part and Denying in Part Defendants’ Motion for Summary Judgment [7/24/13]
Plaintiffs’ Reply in Support of Motion for Partial Summary Judgment and Opposition to Defendants’ Cross-Motion for Summary Judgment [2/1/13]
Declaration of Ben Patterson in Support of Plaintiffs’ Reply in Support of Motion for Partial Summary Judgment and Opposition to Defendants’ Cross-Motion for Summary Judgment [2/1/13]
Exhibit 14
Exhibit 15
Exhibit 16
Exhibit 17
Exhibit 18
Exhibit 19
Exhibit 20
Exhibit 21
Exhibit 22
Exhibit 23
Exhibit 24
Exhibit 25
Exhibit 26
Exhibit 27
Exhibit 28
Exhibit 29
Exhibit 30
Exhibit 31
Exhibit 32
Exhibit 33
Exhibit 34
Exhibit 35
Exhibit 36
Defendants’ Opposition to Plaintiffs’ Motion for Partial Summary Judgment and Notice of Cross-Motion and Cross-Motion for Summary Judgment; Memorandum of Points and Authorities [1/4/13]
Declaration of Joshua E. Gardner in Support of Defendants’ Opposition to Plaintiffs’ Motion for Partial Summary Judgment and Cross-Motion for Summary Judgment [1/4/13]
Plaintiffs’ Notice of Motion and Motion for Partial Summary Judgment; Memorandum of Points and Authorities [12/4/12]
Declaration of Ben Patterson in Support of Plaintiffs’ Motion for Partial Summary Judgment [12/4/12]
Defendants’ Answer to Fourth Amended Complaint [11/16/12]
Fourth Amended Complaint for Declaratory and Injunctive Relief Under United States Constitution and Federal Statutes and Regulations
Exhibit A
Exhibit B
Exhibit C
Order Granting in Part, and Denying in Part, Plaintiffs’ Motion for Class Certification, Denying Defendants’ Motions for Leave to File a Motion for Reconsideration and for Relief From a Nondispositive Order of Magistrate Judge, and Granting in Part, and Denying in Part, Plaintiffs’ Motion to Substitute [9/30/12]
Expert Report of Ronald Alan Greenfield, M.D., M.S., F.A.C.P., F.I.D.S.A. [8/7/12]
Expert Report of Daniel E. Ford, M.D., M.P.H. [8/7/12]
Expert Report of Una D. McCann, M.D. [8/7/12]
Expert Report of Steven B. Bird, M.D. [8/7/12]
Expert Report of Sonya S. Kwon, M.B.A. [8/7/12]
Expert Report of Jeffrey D. Laskin, Ph.D. [8/7/12]
Order Regarding Defendants’ Motion for Partial Relief From A Nondispositive Order of the Magistrate Judge [8/2/12]
Order Re: Plaintiffs’ Motion to Compel [7/31/12]
Order Re: Defendant’s Response to the Court’s July 19, 2012 Order [7/31/12]
Declaration of John J. Spinelli [7/27/12]
Defendants’ Opposition to Plaintiffs’ Motion to Compel Discovery [7/27/12]
Defendant Department of Veterans Affairs’ Response to Questions Posed in the Court’s July 19, 2012 Order and Motion for Clarification of Certain Aspects of That Order [7/26/12]
Defendants’ Motion for Relief From Non-Dispositive Pretrial Order of Magistrate Judge [7/24/12]
Order Re: Plaintiffs’ Motion to Compel [7/19/12]
Declaration of Ben Patterson in Support of Plaintiffs’ Motion to Compel Discovery From Defendant Department of Veterans Affairs [7/13/12]
Plaintiffs’ Notice of Motion and Motion to Compel Discovery From Defendant Department of Veterans Affairs [7/13/12]
Plaintiffs’ Reply in Support of Motion to Compel Discovery From Defendant Department of Veterans Affairs [7/3/12]
Declaration of Lily Sara Farel in Support of Defendants’ Opposition to Plaintiffs’ Motion to Compel Discovery [6/28/12]
Declaration of John J. Spinelli [6/28/12]
Defendants’ Opposition to Plaintiffs’ Motion to Compel Discovery [6/28/12]
Order Re: Magnetic Tapes Dispute (Dkt. No. 425) [6/22/12]
Order Re: Motion to Compel Discovery From Defendant Department of Veterans Affairs (Dkt. No. 447) [6/22/12]
Order Re: Magnetic Tapes Dispute (Dkt. No. 425) [6/15/12]
Order Re: Responses to Court’s May 31, 2012 Order [6/7/12]
Second Declaration of Julie Parrish [6/6/12]
Declaration of Patricia Cameresi, Information Review Officer, Directorate of Science & Technology, Central Intelligence Agency [6/6/12]
Exhibits 1-8 [6/6/12]
Declaration of Kimberly L. Herb in Support of Defendants’ Opposition to Plaintiffs’ Motion to Compel [6/6/12]
Exhibits A-D [6/6/12]
Defendants’ Opposition to Plaintiffs’ Motion to Compel [6/6/12]
Order Re: Remainder of May 1, 2012 in Camera Submission of Documents [5/23/12]
Order Re: Magnetic Tape Dispute [5/22/12]
Defendants’ Reply to Plaintiffs’ Statement of Discovery Disputes, and Motion to Set a Briefing Schedule [5/22/12]
Plaintiffs’ Response to Defendants’ Opposition to Plaintiffs’ Statement of Discovery Disputes and Motion to Set a Briefing Schedule [5/21/12]
Defendants’ Opposition to Plaintiffs’ Statement of Discovery Disputes, and Motion to Set a Briefing Schedule [5/21/12]
Amended and Supplemental Declaration of John Frederick Ashley Addressing Retrievability of Data On Magnetic Tapes [5/21/12]
Plaintiffs’ Supplemental Submission and Defendants’ Position Concerning Magnetic Tapes and Motion to Compel [5/21/12]
Order Re: April 12 and May 1, 2012 in Camera Submissions of Documents [5/14/12]
Order Re: Joint Stipulation and Case Deadlines (Dkt. No. 415) [4/26/12]
Defendants’ Notice of Corrected Filing [4/10/12]
Exhibit 8 [4/10/12]
Exhibit 14 [4/10/12]
Exhibit 20 [4/10/12]
Exhibit 23 [4/10/12]
Exhibit 24 [4/10/12]
Exhibit 26 [4/10/12]
Exhibit 45 [4/10/12]
Exhibit 51 (Public) [4/10/12]
Exhibit 74 [4/10/12]
Order Re: Plaintiffs’ Motion to Compel [4/6/12]
Declaration of Ben Patterson in Support of Plaintiffs’ Motion to Compel Discovery (Amended Pursuant to April 5, 2012 Order) [4/6/12]
Exhibit A [4/6/12]
Exhibit B [4/6/12]
Exhibit C [4/6/12]
Exhibit D [4/6/12]
Exhibit E [4/6/12]
Exhibit F [4/6/12]
Exhibit G [4/6/12]
Exhibit H [4/6/12]
Exhibit I [4/6/12]
Exhibit J [4/6/12]
Exhibit K [4/6/12]
Exhibit L [4/6/12]
Exhibit M [4/6/12]
Exhibit N [4/6/12]
Exhibit O [4/6/12]
Exhibit P [4/6/12]
Exhibit Q [4/6/12]
Exhibit R [4/6/12]
Exhibit S [4/6/12]
Exhibit T [4/6/12]
Exhibit U [4/6/12]
Exhibit V [4/6/12]
Exhibit W [4/6/12]
Exhibit X [4/6/12]
Exhibit Y-0 [4/6/12]
Exhibit Y-1 [4/6/12]
Exhibit Z-0 [4/6/12]
Exhibit Z-1 [4/6/12]
Exhibit AA (Public Redacted) [4/6/12]
Exhibit BB [4/6/12]
Exhibit CC [4/6/12]
Exhibit DD [4/6/12]
Exhibit EE [4/6/12]
Exhibit FF [4/6/12]
Exhibit GG [4/6/12]
Plaintiffs’ Notice of Motion and Motion to Compel Discovery and Memorandum of Points and Authorities in Support Thereof [4/6/12]
Declaration of Kimberly L. Herb in Support of Defendants’ Opposition to Plaintiffs’ Motion for Class Certification [4/2/12]
Defendants’ Opposition to Motion for Class Certification [4/2/12]
Declaration of Tim Michael Josephs in Support of Plaintiffs’ Reply in Support of Motion for Class Certification (Amended Version Pursuant to March 29, 2012 Order) [3/30/12]
Declaration of Bernard Edelman On Behalf of Vietnam Veterans of America in Support of Plaintiffs’ Reply in Support of Motion for Class Certification (Amended Version Pursuant to March 29, 2012 Order) [3/30/12]
Declaration of Stacey M. Sprenkel in Support of Plaintiffs’ Reply in Support of Motion for Class Certification (Amended Version Pursuant to March 29, 2012 Order) [3/30/12]
Exhibit 75 [3/30/12]
Exhibit 76 [3/30/12]
Exhibit 77 [3/30/12]
Exhibit 78 [3/30/12]
Exhibit 79 [3/30/12]
Exhibit 80 [3/30/12]
Exhibit 81 [3/30/12]
Exhibit 82 [3/30/12]
Exhibit 83 [3/30/12]
Exhibit 84 [3/30/12]
Exhibit 85 [3/30/12]
Exhibit 86 [3/30/12]
Exhibit 87 [3/30/12]
Exhibit 88 [3/30/12]
Plaintiffs’ Reply in Support of Motion for Class Certification (Amended Version Pursuant to March 29, 2012 Order) [3/30/12]
Declaration of Joshua E. Gardner in Support of Defendants’ Opposition to Plaintffs’ Motion to Compel [3/15/12]
Exhibits 1-10 [3/15/12]
Exhibit 11 (Part 1) [3/15/12]
Exhibit 11 (Part 2) [3/15/12]
Exhibit 11 (Part 3) [3/15/12]
Exhibits 12-37 [3/15/12]
Declaration of Victor Kalasinsky [3/15/12]
Exhibit A [3/15/12]
Exhibit B [3/15/12]
Exhibit C [3/15/12]
Exhibit D [3/15/12]
Exhibit E [3/15/12]
Declaration of Michael Hogan [3/15/12]
Declaration of Anne Moroz [3/15/12]
Declaration of Michael E. Kilpatrick, M.D. [3/15/12]
Declaration of John J. Spinelli [3/15/12]
Exhibit A [3/15/12]
Defendants’ Opposition to Plaintiffs’ Motion to Compel Discovery [3/15/12]
Declaration of Stacey M. Sprenkel in Support of Plaintiffs’ Motion for Class Certification With Exhibits (Amended Version Pursuant to February 24, 2012 Order) [2/28/12]
Exhibits 1-12 [2/28/12]
Exhibits 13-24 [2/28/12]
Exhibits 25-40 [2/28/12]
Exhibits 41-46 [2/28/12]
Exhibits 47-57 [2/28/12]
Exhibits 58-74 [2/28/12]
Notice of Motion and Motion for Class Certification; Memorandum of Points and Authorities [2/9/12]
Report and Recommendation Re: Plaintiffs’ Motion to Extend Case Deadlines [12/20/11]
Declaration of John Frederick Ashley Addressing Retrievability of Data On Magnetic Tapes [12/14/11]
Plaintiffs’ Supplemental Filing Concerning Magnetic Tapes [12/14/11]
Order Adopting Magistrate Judge’s Report and Recommendation re Motion to Extend the Case Deadlines [12/6/11]
Joint Letter Concerning Discovery Status and Disputes [11/7/11]
Report and Recommendation Re: Plaintiffs’ Motion to Extend Case Deadlines [10/31/11]
Plaintiffs’ Motion for Relief From Portion of Nondispositive Pretrial Order of Magistrate Judge [10/24/11]
Defendants’ Motion for Relief From Non-Dispositive Pretrial Order of Magistrate Judge [10/11/11]
Order Re: Joint Statements of Discovery Disputes Filed October 12, 2011 (Dkt. Nos. 299 & 300) [10/14/11]
Joint Statement of Discovery Dispute Concerning Magnetic Tapes Regarding Database of Edgewood Test Participants and Project “Often” Documents [10/12/11]
Joint Statement of Discovery Dispute Concerning Depositions and Navy and Air Force Document Production [10/12/11]
Defendants’ Opposition to Plaintiffs’ Administrative Motion to Extend Deadlines [10/11/11]
Declaration of Lily Sara Farel in Support of Defendants’ Opposition to Plaintiffs’ Motion to Extend Deadlines [10/11/11]
Defendants’ Motion for Relief From Non-Dispositive Pretrial Order of Magistrate Judge [10/11/11]
Plaintiffs’ Administrative Motion to Extend Case Deadlines [10/07/11]
Motion for a Protective Motion to Compel (Dkt. No. to Compel Rule 30(B)(6) Depositions and Production of Documents (Dkt. No. 258), Ion to Extend Discovery (Dkt. No. 260) [10/05/11]
Plaintiffs’ Reply in Support of Motion to Compel Rule 30(b)(6) Depositions and Production of Documents [9/15/11]
Declaration of Gordon P. Erspamer in Support of Plaintiffs’ Reply in Support of Motion to Compel Rule 30(b)(6) Depositions and Production of Documents [9/15/11]
Declaration of Ben Patterson in Support of Plaintiffs’ Reply in Support of Motion to Compel Rule 30(b)(6) Depositions and Production of Documents [9/15/11]
Plaintiffs’ Reply Memorandum in Support of Motion to Compel Discovery [9/15/11]
Declaration of Stacey Sprenkel in Support of Plaintiffs’ Reply Memorandum in Support of Motion to Compel Discovery [9/15/11]
Defendants’ Reply Brief in Support of Motion for Protective Order Limiting Discovery [9/9/11]
Plaintiffs’ Reply in Support of Motion to Extend Discovery of CIA [9/8/11]
Order Denying Defendants Central Intelligence Agency and Michael J. Morrell’s Motion for Judgment on the Pleadings, Denying Without Prejudice Central Intelligence Agency and Michael J. Morrell’s Motion to Amend the Scheduling Order, and Granting Section I.A of Central Intelligence Agency and Michael J. Morrell’s Motion for A Protective Order [9/2/11]
Defendants’ Opposition to Plaintiffs’ Motion to Compel 30(b)(6) Depositions and Production of Documents [9/1/11]
Declaration of Joshua E. Gardner in Support of Defendants’ Opposition to Plaintiffs’ Motion to Compel Rule 30(b)(6) Depositions and Production of Documents [9/1/11]
Defendants’ Response to Plaintiffs’ Motion to Extend Discovery of CIA [9/1/11]
Defendants’ Opposition to Plaintiffs’ Motion to Compel Discovery Against Defendant VA [9/1/11]
Opposition to Defendants’ Motion for Protective Order Limiting Discovery [8/31/11]
Plaintiffs’ Notice of Motion and Motion to Extend Discovery of CIA and Memorandum of Points and Authorities in Support thereof [8/18/11]
Plaintiffs’ Notice of Motion and Motion to Compel Rule 30(b)(6) Depositions and Production of Documents and Memorandum of Points and Authorities in Support thereof [8/18/11]
Defendant Central Intelligence Agency’s Reply Brief in Support of Motion for Judgment on the Pleadings and, in the Alternative, Motion for Summary Judgment [8/18/11]
Declaration of Ben Patterson in Support of Plaintiffs’ Motion to Compel Rule 30(b)(6) Depositions and Production of Documents [8/18/11]
Plaintiffs’ Notice of Motion and Motion to Compel Discovery and Memorandum of Points and Authorities in Support thereof [8/18/11]
Declaration of Laura O’Neill in Support of Motion to Compel Discovery [8/18/11]
Defendants’ Motion for Protective Order Limiting Discovery [8/15/11]
Declaration of Kimberly L. Herb in Support of Defendants’ Motion for Protective Order Limiting Discovery [8/15/11]
Plaintiffs’ Opposition to Defendant Central Intelligence Agency’s Motion for Judgment on the Pleadings and, in the Alternative, Motion for Summary Judgment [8/11/11]
Order on Defendant Central Intelligence Agency’s Motion for Judgment on the Pleadings [8/9/11]
Defendant Central Intelligence Agency’s Motion for Judgment on the Pleadings and, in the Alternative, Motion for Summary Judgment [7/28/11]
Declaration of Kimberly L. Herb in Support of Defendant Central Intelligence Agency’s Motion for Judgment on the Pleadings and, in the Alternative, Motion for Summary Judgment [7/28/11]
Joint Statement of Discovery Dispute Over Defendant Department of Veterans Affairs’ Responses to Plaintiffs’ Discovery Requests [7/22/11]
Joint Statement of Discovery Dispute Over Plaintiffs’ Requests for Production of Documents [7/1/11]
Joint Statement of Discovery Dispute Over Plaintiffs’ Requests for Rule 30(b)(6) Depositions [7/1/11]
Defendants’ Answer to Third Amended Complaint [6/14/11]
Order Granting in Part and Denying in Part Defendants’ Motion to Dismiss in Part Plaintiffs’ Third Amended Complaint and Denying Plaintiffs’ Motion to Strike [5/31/11]
Defendants’ Response To Plaintiffs’ Letter Regarding 50 U.S.C. § 403g [12/23/10]
Defendants’ Notice of Filing Declaration in Support of Defendant CIA’s Privilege Assertions Under 50 U.S.C. § 403G [12/20/10]
Declaration of Kimberly L. Herb in Support of Notice of Filing Declaration in Support of Defendant CIA’s Privilege Assertions Under 50 U.S.C. § 403G. [12/20/10]
Declaration of Martha M. Lutz, Information Review Officer, Director’s Area, Central Intelligence Agency [12/20/10]
Exhibit A [12/20/10]
Exhibit B [12/20/10]
Plaintiffs’ Letter Regarding 50 U.S.C. § 403g [12/17/10]
Plaintiffs’ Notice of Motion and Renewed Motion to Compel Defendants’ Responses to Interrogatories [12/17/10]
Declaration of Gordon P. Erspamer in Support of Plaintiffs’ Renewed Motion to Compel Defendants’ Responses to Interrogatories [12/17/10]
Exhibit A [12/17/10]
Exhibit B [12/17/10]
Exhibit C [12/17/10]
Exhibit D [12/17/10]
Exhibit E [12/17/10]
Exhibit F [12/17/10]
Exhibit G [12/17/10]
Exhibit H [12/17/10]
Exhibit I [12/17/10]
Exhibit J [12/17/10]
Exhibit K [12/17/10]
Exhibit L [12/17/10]
Exhibit M [12/17/10]
[Proposed] Order Granting Plaintiffs’ Renewed Motion to Compel Defendants’ Responses to Interrogatories [12/17/10]
Defendants’ Reply Memorandum in Support of Partial Motion to Dismiss Plaintiffs’ Third Amended Complaint [12/17/10]
Plaintiffs’ Opposition to Defendants’ Partial Motion to Dismiss Third Amended Complaint [12/13/10]
Declaration of Gordon P. Erspamer in Support of Plaintiffs’ Opposition to Defendants’ Partial Motion to Dismiss Third Amended Complaint [12/13/10]
Defendants’ Partial Motion to Dismiss Plaintiffs’ Third Amended Complaint [12/6/10]
Exhibit A [12/6/10]
Exhibit B [12/6/10]
Exhibit C [12/6/10]
[Proposed] Order Granting Defendants’ Partial Motion to Dismiss Plaintiffs’ Third Amended Complaint [12/6/10]
Protective Order Governing Discovery [12/1/10]
Third Amended Complaint for Declaratory and Injunctive Relief Under United States Constitution and Federal Statutes and Regulations [11/18/10]
Exhibit A [11/18/10]
Exhibit B [11/18/10]
Exhibit C [11/18/10]
Order Granting in Part and Denying in Part Plaintiffs’ Motion to File a Third Amended Complaint [11/15/10]
Order Granting in Part and Denying in Part Plaintiffs’ Motion to Compel Production Of Documents and Motion to Compel 30(B)(6) Depositions; Denying Without Prejudice Plaintiffs’ Motion for Sanctions and Defendants’ Motion for Protective Order Limiting Scope Of Discovery [11/12/10]
Order Granting Plaintiffs’ Motion for Protective Order and to Overrule Objections [11/12/10]
Defendants’ Reply Brief in Support of Motion for Protective Order Limiting Scope of Discovery [10/13/10]
Declaration of Patricia Cameresi [10/13/10]
Declaration of Kimberly L. Herb in Support of Defendants’ Motion for Protective Order Limiting Scope of Discovery [10/13/10]
Exhibit A [10/13/10]
Exhibit B [10/13/10]
Exhibit C [10/13/10]
Exhibit D [10/13/10]
Exhibit E [10/13/10]
Exhibit F [10/13/10]
Exhibit G [10/13/10]
Exhibit H [10/13/10]
Declaration of Michael Kilpatrick Director, Strategic Communications Office of the Under Secretary of Defense for Health Affairs [10/13/10]
Declaration of Lloyd Roberts, U.S. Army Medical Research Institute of Chemical Defense [10/13/10]
Plaintiffs’ Reply in Support of Motion for Sanctions [10/13/10]
Plaintiffs’ Reply in Support of Motion to Overrule Objections and Compel 30(b)(6) Depositions [10/13/10]
Plaintiffs’ Reply in Support of Motion to Overrule Objections and Compel Production of Documents [10/13/10]
Declaration of Gordon P. Erspamer in Support of Plaintiffs’ Reply in Support of Motion to Overrule Objections and Compel Production of Documents [10/13/10]
Exhibit A [10/13/10]
Exhibit B [10/13/10]
Exhibit C [10/13/10]
Exhibit D [10/13/10]
Exhibit E [10/13/10]
Exhibit F [10/13/10]
Exhibit G [10/13/10]
Exhibit H [10/13/10]
Exhibit I [10/13/10]
Exhibit J [10/13/10]
Exhibit K [10/13/10]
Exhibit L [10/13/10]
Plaintiffs’ Reply in Support of Motion for Protective Order and to Overrule Objections [10/13/10]
Declaration of Timothy W. Blakely in Support of Plaintiffs’ Reply in Support of Motion for Protective Order and to Overrule Objections [10/13/10]
Exhibit A [10/13/10]
Exhibit B [10/13/10]
Exhibit C [10/13/10]
[Proposed] Protective Order Governing Discovery [10/13/10]
Order Denying Defendants’ Motion for a Protective Order Staying Further Discovery and for a Modification of the Case Management Order [10/7/10]
Plaintiffs’ Opposition to Defendants’ Motion for Protective Order Limiting Scope of Discovery [10/6/10]
Declaration of Gordon P. Erspamer in Support of Plaintiffs’ Opposition to Defendants’ Motion for Protective Order Limiting Scope of Discovery [10/6/10]
Exhibit A [10/6/10]
Exhibit B [10/6/10]
Exhibit C [10/6/10]
Exhibit D [10/6/10]
Clerk’s Notice Taking Motion Under Submission and Vacating October 7 Hearing Date [9/30/10]
Defendants’ Reply in Support of Their Motion for a Protective Order Staying Further Discovery and for Modification of Case Management Order [9/23/10]
Errata Letter to Judge Wilkin re Plaintiffs’ Opposition to Defendants’ Motion for Protective Order Staying Discovery [9/22/10]
Clerk’s Notice Continuing 10/6/10 Hearing Date to 10/27/10 [9/21/10]
Plaintiffs’ Opposition to Defendants’ Motion for Protective Order Staying Further Discovery and for Modification of Case Management Order [9/16/10]
Declaration of Gordon P. Erspamer in Support of Plaintiffs’ Opposition to Defendants’ Motion for Protective Order Staying Further Discovery [9/16/10]
Exhibit A [9/16/10]
Amended Declaration of Caroline Lewis Wolverton in Support of Defendants’ Opposition to Plaintiffs’ Motion for Sanctions [9/16/10]
Exhibit A [9/16/10]
Exhibit B [9/16/10]
Exhibit C [9/16/10]
Exhibit D [9/16/10]
Exhibit E [9/16/10]
Exhibit F [9/16/10]
Exhibit G [9/16/10]
Exhibit H [9/16/10]
Exhibit I [9/16/10]
Exhibit J [9/16/10]
Exhibit K [9/16/10]
Exhibit L [9/16/10]
Defendants’ Motion for Protective Order Limiting Scope of Discovery [9/15/10]
Declaration of Patricia Cameresi [9/15/10]
Attachment A [9/15/10]
Supplemental Declaration of Patricia Cameresi, Information Review Officer, Directorate of Science & Technology Central Intelligence Agency [9/15/10]
Declaration of Kimberly L. Herb in Support of Defendants’ Motion for Protective Order Limiting Scope of Discovery [9/15/10]
Exhibit A [9/15/10]
Exhibit B [9/15/10]
Exhibit C [9/15/10]
Exhibit D [9/15/10]
Exhibit E [9/15/10]
Exhibit F [9/15/10]
Exhibit G [9/15/10]
Exhibit H [9/15/10]
Exhibit I [9/15/10]
Exhibit J [9/15/10]
Exhibit K [9/15/10]
Exhibit L [9/15/10]
Declaration of Michael Kilpatrick Director, Strategic Communications Office of the Under Secretary of Defense for Health Affairs [9/15/10]
Exhibit 1 [9/15/10]
Declaration of Lloyd Roberts, U.S. Army Medical Research Institute of Chemical Defense [9/15/10]
Declaration of Mr. Richard L. Wiltison, U.S. Army Research, Development, and Engineering Command [9/15/10]
[Proposed] Order Granting Defendants’ Motion for Protective Order Limiting Scope of Discovery [9/15/10]
Defendants’ Opposition to Plaintiffs’ Motion for Sanctions [9/15/10]
Declaration of Patricia Cameresi [9/15/10]
Attachment A [9/15/10]
Declaration of Michael Kilpatrick Director, Strategic Communications Office of the Under Secretary of Defense for Health Affairs [9/15/10]
Exhibit 1 [9/15/10]
Declaration of Anthony Lee, Office of the Under Secretary of Defense for Acquisition, Technology, and Logistics [9/15/10]
Declaration of Caroline Lewis Wolverton in Support of Defendants’ Opposition to Plaintiffs’ Motion for Sanctions [9/15/10]
Exhibit A [9/15/10]
Exhibit B [9/15/10]
Exhibit C [9/15/10]
Exhibit D [9/15/10]
Exhibit E [9/15/10]
Exhibit F [9/15/10]
Exhibit G [9/15/10]
Exhibit H [9/15/10]
Exhibit I [9/15/10]
Exhibit J [9/15/10]
Exhibit K [9/15/10]
[Proposed] Order Denying Plaintiffs’ Motion for Sanctions [9/15/10]
Defendants’ Opposition to Motion to Compel 30(B)(6) Depositions [9/15/10]
Declaration of Brigham J. Bowen [9/15/10]
Exhibit A [9/15/10]
Exhibit B [9/15/10]
Exhibit C [9/15/10]
Exhibit D [9/15/10]
Exhibit E [9/15/10]
Exhibit F [9/15/10]
Exhibit G [9/15/10]
Exhibit H [9/15/10]
Exhibit I [9/15/10]
Exhibit J [9/15/10]
Exhibit K [9/15/10]
Exhibit L [9/15/10]
Exhibit M [9/15/10]
Declaration of Patricia Cameresi [9/15/10]
Attachment A [9/15/10]
Supplemental Declaration of Patricia Cameresi, Information Review Officer, Directorate of Science & Technology Central Intelligence Agency [9/15/10]
Declaration of Patsy A. D’Eramo, Jr., U.S. Army Edgewood Chemical Biological Center [9/15/10]
Declaration of Arnold Dupuy, Office of the Assistant Secretary of Defense for Health Affairs [9/15/10]
Declaration of Michael Kilpatrick Director, Strategic Communications Office of the Under Secretary of Defense for Health Affairs [9/15/10]
Exhibit 1 [9/15/10]
Declaration of Lieutenant Colonel Raymond Laurel, U.S. Army Medical Research and Materiel Command [9/15/10]
Declaration of Anthony Lee, Office of the Under Secretary of Defense for Acquisition, Technology, and Logistics [9/15/10]
Declaration of Lloyd Roberts, U.S. Army Medical Research Institute of Chemical Defense [9/15/10]
Declaration of Mr. Richard L. Wiltison, U.S. Army Research, Development, and Engineering Command [9/15/10]
[Proposed] Order Re 30(b)(6) [9/15/10]
Defendants’ Opposition to Plaintiffs’ Motion to Overrule Objections and Compel Production of Documents [9/15/10]
Declaration of Patricia Cameresi [9/15/10]
Attachment A [9/15/10]
Supplemental Declaration of Patricia Cameresi, Information Review Officer, Directorate of Science & Technology Central Intelligence Agency [9/15/10]
Declaration of Patsy A. D’Eramo, Jr., U.S. Army Edgewood Chemical Biological Center [9/15/10]
Declaration of Michael Kilpatrick Director, Strategic Communications Office of the Under Secretary of Defense for Health Affairs [9/15/10]
Exhibit 1 [9/15/10]
Declaration of Lieutenant Colonel Raymond Laurel, U.S. Army Medical Research and Materiel Command [9/15/10]
Declaration of Anthony Lee, Office of the Under Secretary of Defense for Acquisition, Technology, and Logistics [9/15/10]
Declaration of Lloyd Roberts, U.S. Army Medical Research Institute of Chemical Defense [9/15/10]
Declaration of Caroline Lewis Wolverton in Support of Defendants’ Opposition to Plaintiffs’ Motion to Compel Production of Documents [9/15/10]
Exhibit A [9/15/10]
Exhibit B [9/15/10]
Exhibit C [9/15/10]
Exhibit D [9/15/10]
Exhibit E [9/15/10]
Exhibit F [9/15/10]
Exhibit G [9/15/10]
Exhibit H [9/15/10]
Exhibit I [9/15/10]
Exhibit J [9/15/10]
Exhibit K [9/15/10]
Exhibit L [9/15/10]
Exhibit M [9/15/10]
Exhibit N [9/15/10]
Exhibit O [9/15/10]
[Proposed] Order Denying Plaintiffs’ Motion to Overrule Objections and Compel Production of Documents [9/15/10]
Defendants’ Response to Plaintiffs’ Motion for a Protective Order [9/15/10]
Exhibit A [9/15/10]
Exhibit B [9/15/10]
Defendants’ Motion for A Protective Order Staying Further Discovery and for Modification of Case Management Order [8/27/10]
Declaration of Michael Kilpatrick, Director, Strategic Communications office of The Under Secretary of Defense for Health Affairs [8/27/10]
Declaration of Patricia Cameresi, Associate Information Review Officer, Directorate of Science & Technology, Central Intelligence Agency [8/27/10]
Declaration of Caroline Lewis Wolverton [8/27/10]
[Proposed] Order Granting Defendants’ Motion for a Protective Order Staying Further Discovery and Revising Case Management Schedule [8/27/10]
Plaintiffs’ Notice of Motion and Motion to Overrule Objections and Compel Production of Documents and Memorandum of Points and Authorities in Support Thereof [8/25/10]
Declaration of Daniel J. Vecchio in Support of Plaintiffs’ Motion to Overrule Objections and Compel Production of Documents [8/25/10]
Exhibit A [8/25/10]
Exhibit B [8/25/10]
Exhibit C [8/25/10]
Exhibit D [8/25/10]
Exhibit E [8/25/10]
Exhibit F [8/25/10]
Exhibit G [8/25/10]
Exhibit H [8/25/10]
Exhibit I [8/25/10]
Exhibit J [8/25/10]
Exhibit K [8/25/10]
Exhibit L [8/25/10]
[Proposed] Order Granting Plaintiffs’ Motion to Overrule Objections and Compel Production of Documents [8/25/10]
Plaintiffs’ Notice of Motion and Motion to Overrule Objections and Compel 30(b)(6) Depositions and Memorandum of Points and Authorities in Support Thereof [8/25/10]
Declaration of Daniel J. Vecchio in Support of Plaintiffs’ Motion to Overrule Objectons and Compel 30(b)(6) Depositions [8/25/10]
Exhibit A [8/25/10]
Exhibit B [8/25/10]
Exhibit C [8/25/10]
Exhibit D [8/25/10]
Exhibit E [8/25/10]
Exhibit F [8/25/10]
Exhibit G [8/25/10]
Exhibit H [8/25/10]
Exhibit I [8/25/10]
Exhibit J [8/25/10]
Exhibit K [8/25/10]
Exhibit L [8/25/10]
Exhibit M [8/25/10]
Exhibit N [8/25/10]
[Proposed] Order Granting Plaintiffs’ Motion to Overrule Objections and Compel 30(b)(6) Depositions [8/25/10]
Plaintiffs’ Notice of Motion and Motion for Sanctions [8/25/10]
Declaration of Daniel J. Vecchio in Support of Plaintiffs’ Motion for Sanctions [8/25/10]
Exhibit A [8/25/10]
Exhibit B [8/25/10]
Exhibit C [8/25/10]
Exhibit D [8/25/10]
Exhibit E [8/25/10]
Exhibit F [8/25/10]
Exhibit G [8/25/10]
[Proposed] Order Granting Plaintiffs’ Motion for Sanctions [8/25/10]
Notice of Motion & Motion for Protective Order and to Overrule Objections [8/19/10]
Declaration of Daniel J. Vecchio in Support of Plaintiffs’ Motion for Protective Order [8/19/10]
Exhibit A [8/19/10]
Exhibit B [8/19/10]
Exhibit C [8/19/10]
Exhibit D [8/19/10]
Exhibit E [8/19/10]
Exhibit F [8/19/10]
Exhibit G [8/19/10]
Exhibit H-1 [8/19/10]
Exhibit H-2 [8/19/10]
Exhibit I [8/19/10]
Exhibit J [8/19/10]
Exhibit K [8/19/10]
Exhibit L [8/19/10]
Exhibit M [8/19/10]
[Proposed] Protective Order Governing Discovery [8/19/10]
Reply in Support of Plaintiffs’ Motion for Leave to File Third Amended Complaint [7/15/10]
Exhibit 1 [7/15/10]
Defendants’ Opposition to Plaintiffs’ Motion for Leave to Amend Complaint [6/24/10]
Exhibit A [6/24/2010]
Exhibit B [6/24/2010]
Plaintiffs’ Notice of Errata [6/11/10]
Notice of Motion & Motion for Leave to File Third Amended Complaint [6/7/10]
Memorandum of Points and Authorities in Support of Plaintiffs’ Motion for Leave to File Third Amended Complaint [6/7/10]
Exhibit A (Third Amended Complaint) [6/7/10]
Exhibit A (to Third Amended Complaint) [6/7/10]
Exhibit B (to Third Amended Complaint) [6/7/10]
Exhibit C (to Third Amended Complaint) [6/7/10]
Declaration of Gordon P. Erspamer in Support of Plaintiffs’ Motion for
Leave to File Third Amended Complaint [6/7/10]
[Proposed] Order Granting Plaintiffs’ Motion for Leave to File Third
Amended Complaint [6/7/10]
Defendants’ Amended Answer to Second Amended Complaint [4/7/10]
Defendants’ Answer to Second Amended Complaint [3/17/10]
Order Granting in Part and Denying in Part Defendants’ Motions to Dismiss and Denying Defendants’ Alternative Motion for Summary Judgment [1/19/10]
Clerk’s Notice Taking Motion Under Submission [1/8/10]
[Proposed] Order Granting Defendants’ Motion to Dismiss Second Amended Complaint [1/5/10]
Defendants’ Motion to Dismiss Second Amended Complaint or in the Alternative for Summary Judgment [1/5/10]
Attachment 1 [1/5/10]
Attachment 2 [1/5/10]
Attachment 3 [1/5/10]
Exhibit A, Declaration of Kimberly J. Albers [1/5/10]
Exhibit B, Declaration of Paul Weiss [1/5/10]
Exhibit C, Declaration of Ena Lima [1/5/10]
Exhibit D, Declaration of Clyde Bennett [1/5/10]
Notice of Settlement Conference and Settlement Conference Order [12/31/09]
Minute Order and Case Management Order [12/23/09]
Second Amended Complaint for Declaratory and Injunctive Relief Under United States Constitution and Federal Statutes [12/17/09]
Exhibit A [12/17/09]
Exhibit B [12/17/09]
Exhibit C [12/17/09]
Motion to Dismiss Oral Argument Hearing Transcript [12/3/09]
Stipulation and Order Continuing Hearing on Defendants’ Motion to Dismiss First Amended Complaint and Initial Case Management Conference [10/29/09]
Stipulation and [Proposed] Order Continuing Hearing on Defendants’ Motion to Dismiss First Amended Complaint and Initial Case Management Conference [10/28/09]
Declaration of Adriano Hrvatin In Support of Stipulation and [Proposed] Order Continuing Hearing on Defendants’ Motion to Dismiss First Amended Complaint and Initial Case Management Conference [10/28/09]
Defendants’ Reply in Support of Their Motion to Dismiss First Amended Complaint [10/23/09]
Attachment 1 [10/23/09]
Attachment 2 [10/23/09]
Attachment 3 [10/23/09]
Order Granting Defendants’ Motion to Seal [10/7/09]
Plaintiffs’ Opposition to Defendants’ Motion to Dismiss First Amended Complaint [10/2/09]
Order Concerning Potentially Sealable Documents [8/31/09]
Defendants’ Motion to Dismiss First Amended Complaint [8/14/09]
Exhibit A, Declaration of Kimberly J. Albers [8/14/09]
Exhibit B, Declaration of Paul Weiss [8/14/09]
Exhibit C, Declaration of Ena Lima [8/14/09]
Exhibit D, Declaration of Clyde Bennett [8/14/09]
First Amended Complaint for Declaratory and Injunctive Relief Under United States Constitution and Federal Statutes [7/24/09]
Exhibit A [7/24/09]
Exhibit B [7/24/09]
Exhibit C [7/24/09]
Defendants’ Motion to File Privacy-Act Covered Records Under Seal in the Non-Public Docket [6/30/09]
Declaration of Caroline Lewis Wolverton in Support of Defendants’ Motion to File Privacy-Act Protected Records Under Seal in the Non-Public Docket [6/30/09]
Defendants’ Motion to Dismiss [6/30/09]
Attachment 1 – Declaration of Kimberly J. Albers [6/30/09]
Attachment 2 – Declaration of Paul Weiss [6/30/09]
Attachment 3 – Declaration of Ena Lima [6/30/09]
Attachment 4 – Declaration of Clyde Bennett [6/30/09]
Complaint for Declaratory and Injunctive Relief Under United States Constitution [1/7/09]
Exhibit A [1/7/09]
Exhibit B [1/7/09]
Exhibit C [1/7/09]

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