Case: A Woman's Concern, Inc. v. Healey

COMPLAINT against All Defendants Filing fee: $ 405, receipt number AMADC-10561004 (Fee Status: Filing Fee paid), filed by A Woman's Concern, Inc.. (Attachments: # 1 Category Form, # 2 Civil Cover Sheet, # 3 Exhibits A-H, # 4 Exhibits I-P, # 5 Exhibit Exhibit Q)(Whiting, Samuel). (Entered: 08/19/2024)

1 Category Form Category Form

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2 Civil Cover Sheet Civil Cover Sheet

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3 Exhibit Exhibits A-H

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4 Exhibit Exhibits I-P

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5 Exhibit Exhibit Q

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ELECTRONIC NOTICE of Case Assignment. District Judge Leo T. Sorokin assigned to case. If the trial Judge issues an Order of Reference of any matter in this case to a Magistrate Judge, the matter will be transmitted to Magistrate Judge Jessica D. Hedges. (Horvath, Courtney) (Entered: 08/20/2024)

MOTION for Leave to Appear Pro Hac Vice for admission of Olivia F. Summers Filing fee: $ 125, receipt number AMADC-10562235 by A Woman's Concern, Inc.. (Attachments: # 1 Declaration in support of motion)(Whiting, Samuel) (Entered: 08/20/2024)

MOTION for Leave to Appear Pro Hac Vice for admission of Nathan J. Moelker Filing fee: $ 125, receipt number AMADC-10562263 by A Woman's Concern, Inc.. (Attachments: # 1 Declaration in support of motion)(Whiting, Samuel) (Entered: 08/20/2024)

Summons Issued as to Robert Goldstein, Rebecca Hart Holder, Maura T. Healey, Reproductive Equity Now Foundation, Inc.. Counsel receiving this notice electronically should download this summons, complete one for each defendant and serve it in accordance with Fed.R.Civ.P. 4 and LR 4.1. Summons will be mailed to plaintiff(s) not receiving notice electronically for completion of service. (Cook, Savannah) (Entered: 08/20/2024)

District Judge Leo T. Sorokin: ELECTRONIC ORDER entered ALLOWING 3 Motion for Leave to Appear Pro Hac Vice Added Olivia F. Summers. Attorneys admitted Pro Hac Vice must have an individual PACER account, not a shared firm account, to electronically file in the District of Massachusetts. To register for a PACER account, go the Pacer website at https://pacer.uscourts.gov/register-account. You must put the docket number under ADDITIONAL FILER INFORMATION on your form when registering or it will be rejected.Pro Hac Vice Admission Request Instructions https://www.mad.uscourts.gov/caseinfo/nextgen-pro-hac-vice.htm.A Notice of Appearance must be entered on the docket by the newly admitted attorney. (Cooke, Melonie) (Entered: 08/21/2024)

District Judge Leo T. Sorokin: ELECTRONIC ORDER entered: ALLOWING 4 Motion for Leave to Appear Pro Hac Vice Added Nathan J. Moelker. Attorneys admitted Pro Hac Vice must have an individual PACER account, not a shared firm account, to electronically file in the District of Massachusetts. To register for a PACER account, go the Pacer website at https://pacer.uscourts.gov/register-account. You must put the docket number under ADDITIONAL FILER INFORMATION on your form when registering or it will be rejected.Pro Hac Vice Admission Request Instructions https://www.mad.uscourts.gov/caseinfo/nextgen-pro-hac-vice.htm.A Notice of Appearance must be entered on the docket by the newly admitted attorney. (Cooke, Melonie) (Entered: 08/21/2024)

Notice of Case Assignment

NOTICE of Appearance by Nathan Jeremiah Moelker on behalf of A Woman's Concern, Inc. (Moelker, Nathan) (Entered: 08/21/2024)

Order on Motion for Leave to Appear

NOTICE of Appearance by Olivia F. Summers on behalf of A Woman's Concern, Inc. (Summers, Olivia) (Entered: 08/22/2024)

MOTION for Leave to Appear Pro Hac Vice for admission of Christina A. Compagnone Filing fee: $ 125, receipt number AMADC-10566109 by A Woman's Concern, Inc.. (Attachments: # 1 Declaration in support of motion)(Whiting, Samuel) (Entered: 08/22/2024)

MOTION for Leave to Appear Pro Hac Vice for admission of Andrew Ekonomou Filing fee: $ 125, receipt number AMADC-10566118 by A Woman's Concern, Inc.. (Attachments: # 1 Declaration in support of motion)(Whiting, Samuel) (Entered: 08/22/2024)

1 Declaration in support of motion

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District Judge Leo T. Sorokin: ELECTRONIC ORDER entered ALLOWING 10 Motion for Leave to Appear Pro Hac Vice Added Christina A. Compagnone. Attorneys admitted Pro Hac Vice must have an individual PACER account, not a shared firm account, to electronically file in the District of Massachusetts. To register for a PACER account, go the Pacer website at https://pacer.uscourts.gov/register-account. You must put the docket number under ADDITIONAL FILER INFORMATION on your form when registering or it will be rejected.Pro Hac Vice Admission Request Instructions https://www.mad.uscourts.gov/caseinfo/nextgen-pro-hac-vice.htm.A Notice of Appearance must be entered on the docket by the newly admitted attorney. (Cooke, Melonie) (Entered: 08/23/2024)

District Judge Leo T. Sorokin: ELECTRONIC ORDER entered ALLOWING 11 Motion for Leave to Appear Pro Hac Vice Added Andrew Ekonomou. Attorneys admitted Pro Hac Vice must have an individual PACER account, not a shared firm account, to electronically file in the District of Massachusetts. To register for a PACER account, go the Pacer website at https://pacer.uscourts.gov/register-account. You must put the docket number under ADDITIONAL FILER INFORMATION on your form when registering or it will be rejected.Pro Hac Vice Admission Request Instructions https://www.mad.uscourts.gov/caseinfo/nextgen-pro-hac-vice.htm.A Notice of Appearance must be entered on the docket by the newly admitted attorney. (Cooke, Melonie) (Entered: 08/23/2024)

NOTICE of Appearance by Christina Compagnone on behalf of A Woman's Concern, Inc. (Compagnone, Christina) (Entered: 08/23/2024)

CERTIFICATE OF SERVICE pursuant to LR 5.2 by A Woman's Concern, Inc. re 8 Notice of Appearance . (Moelker, Nathan) (Entered: 08/23/2024)

AFFIDAVIT OF SERVICE Executed by A Woman's Concern, Inc.. Maura T. Healey served on 8/23/2024, answer due 9/13/2024. Acknowledgement filed by A Woman's Concern, Inc.. (Whiting, Samuel) (Entered: 08/23/2024)

AFFIDAVIT OF SERVICE Executed by A Woman's Concern, Inc.. Robert Goldstein served on 8/23/2024, answer due 9/13/2024. Acknowledgement filed by A Woman's Concern, Inc.. (Whiting, Samuel) (Entered: 08/23/2024)

Order on Motion for Leave to Appear

WAIVER OF SERVICE Returned Executed by A Woman's Concern, Inc.. Reproductive Equity Now Foundation, Inc. waiver sent on 8/27/2024, answer due 10/28/2024. (Whiting, Samuel) (Entered: 08/28/2024)

WAIVER OF SERVICE Returned Executed by A Woman's Concern, Inc.. Rebecca Hart Holder waiver sent on 8/27/2024, answer due 10/28/2024. (Whiting, Samuel) (Entered: 08/28/2024)

NOTICE of Appearance by Andrew J. Ekonomou on behalf of A Woman's Concern, Inc. (Ekonomou, Andrew) (Entered: 08/29/2024)

NOTICE of Appearance by Carla A. Reeves on behalf of Rebecca Hart Holder, Reproductive Equity Now Foundation, Inc. (Reeves, Carla) (Entered: 09/03/2024)

NOTICE of Appearance by Mariana Korsunsky on behalf of Rebecca Hart Holder, Reproductive Equity Now Foundation, Inc. (Korsunsky, Mariana) (Entered: 09/03/2024)

NOTICE of Appearance by Martin M. Fantozzi on behalf of Rebecca Hart Holder, Reproductive Equity Now Foundation, Inc. (Fantozzi, Martin) (Entered: 09/03/2024)

NOTICE of Appearance by Sarah M. Eberspacher on behalf of Rebecca Hart Holder, Reproductive Equity Now Foundation, Inc. (Eberspacher, Sarah) (Entered: 09/03/2024)

NOTICE of Appearance by Kiman Kaur on behalf of Rebecca Hart Holder, Reproductive Equity Now Foundation, Inc. (Kaur, Kiman) (Entered: 09/06/2024)

NOTICE of Appearance by Phoebe Fischer-Groban on behalf of Robert Goldstein, Maura T. Healey (Fischer-Groban, Phoebe) (Entered: 09/13/2024)

Assented to MOTION for Extension of Time to November 12, 2024 to File Answer re 1 Complaint, by Robert Goldstein, Maura T. Healey.(Fischer-Groban, Phoebe) (Entered: 09/13/2024)

NOTICE of Appearance by Deborah J. Frisch on behalf of Robert Goldstein, Maura T. Healey (Frisch, Deborah) (Entered: 09/13/2024)

District Judge Leo T. Sorokin: ELECTRONIC ORDER entered: re 27 Assented to MOTION for Extension of Time to November 12, 2024 to File Answer re 1 Complaint ALLOWED. Robert Goldstein answer due 11/12/2024; Maura T. Healey answer due 11/12/2024. (Cooke, Melonie) Modified docket text on 9/16/2024 (Cooke, Melonie). (Entered: 09/16/2024)

District Judge Leo T. Sorokin: New Civil Cases General Procedural ORDER entered. (Cooke, Melonie) (Entered: 09/16/2024)

NOTICE of Appearance by Meredith G. Fierro on behalf of Robert Goldstein, Maura T. Healey (Fierro, Meredith) (Entered: 09/16/2024)

Order on Motion for Extension of Time to Answer

Assented to MOTION for Extension of Time to December 13, 2024 to File Answer by Robert Goldstein, Maura T. Healey.(Fierro, Meredith) (Entered: 10/28/2024)

MOTION to Dismiss Plaintiff's Complaint by Rebecca Hart Holder, Reproductive Equity Now Foundation, Inc..(Reeves, Carla) (Entered: 10/28/2024)

MEMORANDUM in Support re 33 MOTION to Dismiss Plaintiff's Complaint filed by Rebecca Hart Holder, Reproductive Equity Now Foundation, Inc.. (Reeves, Carla) (Entered: 10/28/2024)

DECLARATION re 33 MOTION to Dismiss Plaintiff's Complaint, 34 Memorandum in Support of Motion by Rebecca Hart Holder, Reproductive Equity Now Foundation, Inc.. (Attachments: # 1 Exhibit Exhibit I, # 2 Exhibit Exhibit II)(Reeves, Carla) (Entered: 10/28/2024)

District Judge Leo T. Sorokin: ELECTRONIC ORDER entered: re 32 Assented to MOTION for Extension of Time to December 13, 2024 to File Answer ALLOWED. Robert Goldstein answer due 12/13/2024; Maura T. Healey answer due 12/13/2024. (Cooke, Melonie) (Entered: 10/29/2024)

Order on Motion for Extension of Time to Answer

Opposition re 33 MOTION to Dismiss Plaintiff's Complaint filed by A Woman's Concern, Inc.. (Summers, Olivia) (Entered: 11/12/2024)

REPLY to Response to 33 MOTION to Dismiss Plaintiff's Complaint filed by Rebecca Hart Holder, Reproductive Equity Now Foundation, Inc.. (Korsunsky, Mariana) (Entered: 11/19/2024)

DECLARATION of Carla A. Reeves by Rebecca Hart Holder, Reproductive Equity Now Foundation, Inc.. (Attachments: # 1 Exhibit A)(Korsunsky, Mariana) (Entered: 11/19/2024)

1 Exhibit A

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MOTION for Leave to File Excess Pages by Maura T. Healey, Robert Goldstein.(Fischer-Groban, Phoebe) (Entered: 12/13/2024)

District Judge Leo T. Sorokin: ELECTRONIC ORDER entered: re 40 MOTION for Leave to File Excess Pages. ALLOWED. Counsel using the Electronic Case Filing System should now file the document for which leave to file has been granted in accordance with the CM/ECF Administrative Procedures. Counsel must include - Leave to file granted on (date of order)- in the caption of the document. (Dore, Samantha) (Entered: 12/13/2024)

MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by Maura T. Healey, Robert Goldstein.(Fischer-Groban, Phoebe) (Entered: 12/13/2024)

MEMORANDUM in Support re 42 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM filed by Maura T. Healey, Robert Goldstein. (Fischer-Groban, Phoebe) (Entered: 12/13/2024)

Order on Motion for Leave to File Excess Pages

MOTION for Extension of Time to January 10. 2025 to File Response/Reply as to 43 Memorandum in Support of Motion, 42 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by A Woman's Concern, Inc..(Summers, Olivia) (Entered: 12/17/2024)

District Judge Leo T. Sorokin: ELECTRONIC ORDER entered re 44 MOTION for Extension of Time to January 10. 2025 to File Response/Reply as to 43 Memorandum in Support of Motion, 42 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM.ALLOWED. Responses due by 1/10/2025. (de Oliveira, Flaviana) (Entered: 12/18/2024)

Order on Motion for Extension of Time to File Response/Reply

MOTION for Leave to File Amicus Brief by American Civil Liberties Union of Massachusetts. (Attachments: # 1 Proposed Memorandum)(Rossman, Jessie) (Entered: 01/07/2025)

1 Proposed Memorandum

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NOTICE of Appearance by Jessie J. Rossman on behalf of American Civil Liberties Union of Massachusetts (Rossman, Jessie) (Entered: 01/07/2025)

NOTICE of Appearance by Isabel Burlingame on behalf of American Civil Liberties Union of Massachusetts (Burlingame, Isabel) (Entered: 01/08/2025)

NOTICE of Appearance by Rachel Elizabeth Davidson on behalf of American Civil Liberties Union of Massachusetts (Davidson, Rachel) (Entered: 01/08/2025)

Opposition re 42 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM filed by A Woman's Concern, Inc.. (Summers, Olivia) (Entered: 01/10/2025)

REPLY to Response to 42 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM filed by Maura T. Healey, Robert Goldstein. (Fischer-Groban, Phoebe) (Entered: 01/17/2025)

District Judge Leo T. Sorokin: ELECTRONIC ORDER entered: re 46 MOTION for Leave to File Amicus Brief. ALLOWED. Counsel using the Electronic Case Filing System should now file the document for which leave to file has been granted in accordance with the CM/ECF Administrative Procedures. Counsel must include - Leave to file granted on (date of order)- in the caption of the document. (SED) (Entered: 01/24/2025)

AMICUS BRIEF filed by American Civil Liberties Union of Massachusetts . (Rossman, Jessie) (Entered: 01/24/2025)

Order on Motion for Leave to File Document

ELECTRONIC NOTICE Setting Hearing on Motion 42 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM, 33 MOTION to Dismiss Plaintiff's Complaint : Motion Hearing set for 4/22/2025 02:00 PM in Courtroom 13 (In person only) before District Judge Leo T. Sorokin. (SED) (Entered: 04/08/2025)

Notice Setting or Resetting Hearing on Motion

Assented to MOTION to Continue April 22, 2025, Motion Hearing by Maura T. Healey, Robert Goldstein, Reproductive Equity Now Foundation, Inc., Rebecca Hart Holder.(Fierro, Meredith) (Entered: 04/10/2025)

District Judge Leo T. Sorokin: ELECTRONIC ORDER entered: re 55 Assented to MOTION to Continue April 22, 2025, Motion Hearing. ALLOWED. (SED) (Entered: 04/10/2025)

ELECTRONIC NOTICE Resetting Hearing on Motion 42 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM, 33 MOTION to Dismiss Plaintiff's Complaint : Motion Hearing reset for 5/8/2025 10:00 AM in Courtroom 13 (In person only) before District Judge Leo T. Sorokin. (SED) (Entered: 04/10/2025)

Notice Setting or Resetting Hearing on Motion

Order on Motion to Continue

NOTICE by A Woman's Concern, Inc. Plaintiff's Notice of Additional Information (Summers, Olivia) (Entered: 05/01/2025)

Electronic Clerk's Notes for proceedings held before District Judge Leo T. Sorokin: Motion Hearing held on 5/8/2025 re 33 MOTION to Dismiss Plaintiff's Complaint and, 42 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM. The court hears arguments on the motions. The motions are taken under advisement. The court discusses with the parties were to amend the complaint and the next steps. The courts hears from counsel. (Court Reporter: Rachel Lopez at raeufp@gmail.com.)(Attorneys present: Olivia F. Summers, Christina A. Compagnone, Nathan Jeremiah Moelker, Samuel Whiting for the plaintiff Deborah J. Frisch, Meredith G. Fierro, Phoebe Fischer-Groban, Carla A. Reeves, Martin M. Fantozzi for the defendants) (SED) (Entered: 05/08/2025)

Motion Hearing

District Judge Leo T. Sorokin: ELECTRONIC ORDER entered.At the hearing and in its Notice to the Court, Doc. No. 58, Plaintiff requests leave to amend its complaint in light of additional documents it recently received pursuant to the Massachusetts Public Records Act. At the conclusion of the hearing, the Court raised the possibility rather than now resolving the pending Motions, allowing Plaintiff to amend its Complaint, terminating as moot the Motions to Dismiss, and permitting Defendants to file new motions to dismiss either with new briefs or supported by their existing briefs (but not both) to challenge the Amended Complaint. Plaintiff's counsel assented to this process. Defendants requested the Court resolve the pending Motions, but otherwise did not object to the procedure proposed. After due reflection, the Court ALLOWS Plaintiff to file an Amended Complaint, terminates the pending Motions to Dismiss, Doc. Nos. 33, 42, as moot in light of the anticipated Amended Complaint and directs the parties to file within seven days a proposed schedule to govern the filing of the Amended Complaint and the anticipated motions to dismiss. The Court suggests that Plaintiff file one consolidated memo in opposition to the anticipated motions and similarly suggests that Defendants endeavor to coordinate their filings to avoid duplicative arguments. (FGD) (Entered: 05/09/2025)

Order AND ~Util - Terminate Motions

RESPONSE TO COURT ORDER by A Woman's Concern, Inc. re 60 Order,,,,,, Terminate Motions,,,,, Joint Proposed Schedule to Govern Filing Deadlines. (Summers, Olivia) (Entered: 05/14/2025)

District Judge Leo T. Sorokin: ELECTRONIC ORDER entered: re 61 Response to Court Order. The Court ADOPTS the schedule proposed by the parties as the governing schedule. In addition, the Court directs Plaintiff to file a redlined version of the Amended Complaint when it files the Amended Complaint.(SED) (Entered: 05/15/2025)

Order

NOTICE of Withdrawal of Appearance by Isabel Burlingame (Burlingame, Isabel) (Entered: 05/22/2025)

AMENDED COMPLAINT against All Defendants, filed by A Woman's Concern, Inc.. (Attachments: # 1 Redline of Complaint, # 2 Exhibit A-H, # 3 Exhibit I-P, # 4 Exhibit Q, # 5 Exhibit R-U, # 6 Exhibit V, # 7 Exhibit W-Z, # 8 Exhibit AA-GG, # 9 Exhibit HH, # 10 Exhibit II-KK, # 11 Exhibit LL, # 12 Exhibit MM-RR)(Summers, Olivia) (Entered: 06/20/2025)

1 Redline of Complaint

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2 Exhibit A-H

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3 Exhibit I-P

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4 Exhibit Q

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5 Exhibit R-U

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6 Exhibit V

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7 Exhibit W-Z

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8 Exhibit AA-GG

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9 Exhibit HH

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10 Exhibit II-KK

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11 Exhibit LL

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12 Exhibit MM-RR

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Transcript of Motion Hearing held on May 8, 2025, before Judge Leo T. Sorokin. The Transcript may be purchased through the Court Reporter, viewed at the public terminal, or viewed through PACER after it is released. Court Reporter Name and Contact Information: Rachel Lopez at raeufp@gmail.com. Redaction Request due 7/29/2025. Redacted Transcript Deadline set for 8/8/2025. Release of Transcript Restriction set for 10/6/2025. (DRK) (Entered: 07/09/2025)

NOTICE is hereby given that an official transcript of a proceeding has been filed by the court reporter in the above-captioned matter. Counsel are referred to the Court's Transcript Redaction Policy, available on the court website at https://www.mad.uscourts.gov/caseinfo/transcripts.htm (DRK) (Entered: 07/09/2025)

Notice of Filing of Official Transcript

Assented to MOTION for Leave to File Memorandum of Law in Excess of 20 Pages by Robert Goldstein, Maura T. Healey.(Fierro, Meredith) (Entered: 07/24/2025)

NOTICE of Appearance by Kathleen M. Ritter on behalf of Rebecca Hart Holder, Reproductive Equity Now Foundation, Inc. (Ritter, Kathleen) (Entered: 07/24/2025)

District Judge Leo T. Sorokin: ELECTRONIC ORDER entered re: 67 Assented to MOTION for Leave to File Memorandum of Law in Excess of 20 Pages.ALLOWED. Counsel using the Electronic Case Filing System should now file the document for which leave to file has been granted in accordance with the CM/ECF Administrative Procedures. Counsel must include - Leave to file granted on (date of order)- in the caption of the document. (FGD) (Entered: 07/25/2025)

MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by Robert Goldstein, Maura T. Healey.(Fischer-Groban, Phoebe) (Entered: 07/25/2025)

MEMORANDUM in Support re 70 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM filed by Robert Goldstein, Maura T. Healey. (Fischer-Groban, Phoebe) (Entered: 07/25/2025)

MOTION to Dismiss by Rebecca Hart Holder, Reproductive Equity Now Foundation, Inc..(Kaur, Kiman) (Entered: 07/25/2025)

MEMORANDUM in Support re 72 MOTION to Dismiss filed by Rebecca Hart Holder, Reproductive Equity Now Foundation, Inc.. (Kaur, Kiman) (Entered: 07/25/2025)

DECLARATION re 72 MOTION to Dismiss, 73 Memorandum in Support of Motion by Rebecca Hart Holder, Reproductive Equity Now Foundation, Inc.. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3)(Kaur, Kiman) (Entered: 07/25/2025)

1 Exhibit 1

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2 Exhibit 2

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3 Exhibit 3

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Order on Motion for Leave to File Excess Pages

MOTION for Leave to File by American Civil Liberties Union of Massachusetts. (Attachments: # 1 Exhibit)(Rossman, Jessie) (Entered: 08/12/2025)

District Judge Leo T. Sorokin: ELECTRONIC ORDER entered re: 75 Motion for Leave to File Document.ALLOWED. Counsel using the Electronic Case Filing System should now file the document for which leave to file has been granted in accordance with the CM/ECF Administrative Procedures. Counsel must include - Leave to file granted on (date of order)- in the caption of the document. (FGD) (Entered: 08/13/2025)

AMICUS BRIEF filed by American Civil Liberties Union of Massachusetts . (Rossman, Jessie) (Entered: 08/13/2025)

Order on Motion for Leave to File Document

Assented to MOTION for Leave to File A Memorandum of Law in Excess of 20 Pages by A Woman's Concern, Inc..(Moelker, Nathan) (Entered: 08/20/2025)

District Judge Leo T. Sorokin: ELECTRONIC ORDER entered: re 78 Assented to MOTION for Leave to File A Memorandum of Law in Excess of 20 Pages. ALLOWED. Counsel using the Electronic Case Filing System should now file the document for which leave to file has been granted in accordance with the CM/ECF Administrative Procedures. Counsel must include - Leave to file granted on (date of order)- in the caption of the document. (SED) (Entered: 08/21/2025)

Order on Motion for Leave to File Document

RESPONSE to Motion re 70 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM filed by A Woman's Concern, Inc.. (Summers, Olivia) (Entered: 08/22/2025)

RESPONSE to Motion re 72 MOTION to Dismiss filed by A Woman's Concern, Inc.. (Summers, Olivia) (Entered: 08/22/2025)

REPLY to Response to 70 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM filed by Robert Goldstein, Maura T. Healey. (Fischer-Groban, Phoebe) (Entered: 09/12/2025)