Case: United States v. City of Boston

United States of America v. City of Boston

The White House

COMPLAINT against All Defendants (Fee Status: US Government), filed by UNITED STATES OF AMERICA. (Attachments: # 1 Exhibit 1 - 2014 Boston Trust Act, # 2 Exhibit 2 - 2019 Boston Trust Act, # 3 Exhibit 3 - 2015 BPDs Boston Trust Act Report, # 4 Exhibit 4 2016 BPDs Boston Trust Act Report, # 5 Exhibit 2017 BPDs Boston Trust Act Report, # 6 Exhibit 2018 BPDs Boston Trust Act Report, # 7 Exhibit 2021 BPDs Boston Trust Act Report, # 8 Exhibit 2022 BPDs Boston Trust Act Report, # 9 Exhibit 2023 BPDs Boston Trust Act Report, # 10 Exhibit 2024 BPDs Boston Trust Act Report, # 11 Civil Cover Sheet, # 12 Category Form)(Wen, James). (Entered: 09/04/2025)

1 Exhibit Exhibit 1 - 2014 Boston Trust Act

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2 Exhibit Exhibit 2 - 2019 Boston Trust Act

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3 Exhibit Exhibit 3 - 2015 BPDs Boston Trust Act Report

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4 Exhibit Exhibit 4 2016 BPDs Boston Trust Act Report

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5 Exhibit Exhibit 5 2017 BPDs Boston Trust Act Report

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6 Exhibit Exhibit 6 2018 BPDs Boston Trust Act Report

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7 Exhibit Exhibit 7 2021 BPDs Boston Trust Act Report

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8 Exhibit Exhibit 8 2022 BPDs Boston Trust Act Report

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9 Exhibit Exhibit 9 2023 BPDs Boston Trust Act Report

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10 Exhibit Exhibit 10 2024 BPDs Boston Trust Act Report

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11 Civil Cover Sheet

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12 Category Form

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NOTICE of Appearance by James Wen on behalf of UNITED STATES OF AMERICA (Wen, James) (Entered: 09/04/2025)

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 Paul G. Levenson. (NMC) (Entered: 09/05/2025)

Summons Issued as to All Defendants. 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. (NVB) (Entered: 09/05/2025)

NOTICE of Appearance by Jordan Hulseberg on behalf of The United States of America (Hulseberg, Jordan) (Entered: 09/05/2025)

Notice of Case Assignment

SUMMONS Returned Executed The United States of America served on 9/11/2025, answer due 10/2/2025. (Wen, James) Modified on 9/17/2025: Document removed and properly refiled as separate entries. See entries 7, 8, 9, and 10 . (FGD) (Entered: 09/17/2025)

SUMMONS Returned Executed. Michael A. Cox served on 9/11/2025, answer due 10/2/2025. (FGD) (Entered: 09/17/2025)

SUMMONS Returned Executed. The City of Boston served on 9/11/2025, answer due 10/2/2025. (FGD) (Entered: 09/17/2025)

SUMMONS Returned Executed. Michelle Wu served on 9/11/2025, answer due 10/2/2025. (FGD) (Entered: 09/17/2025)

SUMMONS Returned Executed. Boston Police Department served on 9/11/2025, answer due 10/2/2025. (FGD) (Entered: 09/17/2025)

Summons Returned Executed

Joint MOTION for Extension of Time to 11/17/2025 to File Answer by Boston Police Department, Michael A. Cox, The City of Boston, Michelle Wu.(Dinning, Sam) (Entered: 09/26/2025)

District Judge Leo T. Sorokin: ELECTRONIC ORDER entered re: 11 Joint MOTION for Extension of Time to 11/17/2025 to File Answer.ALLOWED. Boston Police Department answer due 11/17/2025; Michael A. Cox answer due 11/17/2025; The City of Boston answer due 11/17/2025; Michelle Wu answer due 11/17/2025. (FGD) (Entered: 09/29/2025)

Order on Motion for Extension of Time to Answer

District Judge Leo T. Sorokin: ORDER entered. New Civil Cases General Procedural ORDER. (FGD) (Entered: 10/16/2025)

NOTICE of Appearance by Thomas Broom on behalf of Boston Police Department, Michael A. Cox, The City of Boston, Michelle Wu (Broom, Thomas) (Entered: 11/12/2025)

MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by Boston Police Department, Michael A. Cox, The City of Boston, Michelle Wu.(Dinning, Sam) (Entered: 11/17/2025)

MEMORANDUM in Support re 15 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM filed by Boston Police Department, Michael A. Cox, The City of Boston, Michelle Wu. (Dinning, Sam) (Entered: 11/17/2025)

NOTICE of Appearance by Toby Merrill on behalf of Boston Police Department, Michael A. Cox, The City of Boston, Michelle Wu (Merrill, Toby) (Entered: 11/17/2025)

First MOTION for Leave to Appear Pro Hac Vice for admission of Erin Monju Filing fee: $ 125, receipt number AMADC-11363449 by Boston Police Department, Michael A. Cox, The City of Boston, Michelle Wu.(Merrill, Toby) (Main Document 18 replaced on 11/18/2025, detached from supporting document.) (FGD) (Additional attachment(s) added on 11/18/2025: # 1 Declaration of Erin Monju) (FGD). (Entered: 11/17/2025)

1 Declaration of Erin Monju

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District Judge Leo T. Sorokin: ELECTRONIC ORDER entered granting 18 Motion for Leave to Appear Pro Hac Vice Added Erin Monju. 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. (FGD) (Entered: 11/18/2025)

Order on Motion for Leave to Appear

NOTICE of Appearance by Erin Monju on behalf of Boston Police Department, Michael A. Cox, The City of Boston, Michelle Wu (Monju, Erin) (Entered: 11/20/2025)

NOTICE of Appearance by Edward F. Whitesell, Jr on behalf of Michael A. Cox, The City of Boston, Michelle Wu (Whitesell, Edward) (Entered: 11/21/2025)

Amicus Curiae APPEARANCE entered by Jared B. Cohen on behalf of COMMONWEALTH OF MASSACHUSETTS. (Cohen, Jared) (Entered: 11/24/2025)

Assented to MOTION for Leave to File Brief of Amicus Curiae by COMMONWEALTH OF MASSACHUSETTS. (Attachments: # 1 Brief of Amicus Curiae Commonwealth of Massachusetts)(Cohen, Jared) (Entered: 11/24/2025)

1 Brief of Amicus Curiae Commonwealth of Massachusetts

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Amicus Curiae APPEARANCE entered by Laura Greenberg-Chao on behalf of Amici Curiae 27 Cities, Counties, and Elected Officials. (Greenberg-Chao, Laura) (Entered: 11/24/2025)

MOTION for Leave to Appear Pro Hac Vice for admission of Rupa Bhattacharyya Filing fee: $ 125, receipt number AMADC-11378756 by Amici Curiae 27 Cities, Counties, and Elected Officials. (Attachments: # 1 Exhibit Certificate of Rupa Bhattacharyya, # 2 Exhibit Proposed Order)(Greenberg-Chao, Laura) (Entered: 11/24/2025)

1 Exhibit Certificate of Rupa Bhattacharyya

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2 Exhibit Proposed Order

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MOTION for Leave to Appear Pro Hac Vice for admission of Tinesha Zandamela Filing fee: $ 125, receipt number AMADC-11378791 by Amici Curiae 27 Cities, Counties, and Elected Officials. (Attachments: # 1 Certificate of Tinesha Zandamela, # 2 Proposed Order)(Greenberg-Chao, Laura) (Entered: 11/24/2025)

1 Certificate of Tinesha Zandamela

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2 Proposed Order

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Assented to MOTION for Leave to File Amicus Brief by Amici Curiae 27 Cities, Counties, and Elected Officials. (Attachments: # 1 Proposed Brief)(Greenberg-Chao, Laura) (Entered: 11/24/2025)

1 Proposed Brief

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NOTICE of Appearance by Austin Paganelli Anderson on behalf of Amici Curiae Law Enforcement Officials (Anderson, Austin) (Entered: 11/24/2025)

First MOTION for Leave to Appear Pro Hac Vice for admission of Ames Grawert Filing fee: $ 125, receipt number BMADC-11378831 by Amici Curiae Law Enforcement Officials. (Attachments: # 1 Affidavit of A Grawert re PHV)(Anderson, Austin) (Entered: 11/24/2025)

1 Affidavit Affidavit of A Grawert re PHV

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First MOTION for Leave to Appear Pro Hac Vice for admission of Brianna Seid Filing fee: $ 125, receipt number AMADC-11378852 by Amici Curiae Law Enforcement Officials. (Attachments: # 1 Affidavit of B Seid re PHV)(Anderson, Austin) (Entered: 11/24/2025)

1 Affidavit of B Seid re PHV

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First MOTION for Leave to File Amicus Brief by Amici Curiae Law Enforcement Officials. (Attachments: # 1 Exhibit Proposed Amicus Brief)(Anderson, Austin) (Entered: 11/24/2025)

1 Exhibit Proposed Amicus Brief

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Assented to MOTION for Leave to File Memo of Amici Curiae by The American Civil Liberties Union of Massachusetts (ACLUM), Brazilian Women's Group, The Cape Cod Coalition for Safe Communities, Dignidad, The Dominican Development Center, Inc., The East Boston Community Council, Greater Boston Legal Services, The Haitian American New Vision of Waltham, Haitian Americans United Inc., The Immigrant Support Alliance, The International Institute of New England, Jane Doe Inc., The Massachusetts Immigrant and Refugee Advocacy Coalition, The Massachusetts Law Reform Institute, The Sisters of St. Joseph of Boston, The Student Clinic for Immigrant Justice, The Watertown Citizens for Peace, Justice & the Environment's Refugee Support Working Group. (Attachments: # 1 Exhibit PROPOSED MEMORANDUM OF AMICI CURIAE)(Rossman, Jessie) (Entered: 11/24/2025)

1 Exhibit PROPOSED MEMORANDUM OF AMICI CURIAE

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District Judge Leo T. Sorokin: ELECTRONIC ORDER entered re: 23 Assented to MOTION for Leave to File Brief of Amicus Curiae by Commonwealth of Massachusetts. 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: 11/25/2025)

District Judge Leo T. Sorokin: ELECTRONIC ORDER entered granting 25 Motion for Leave to Appear Pro Hac Vice Added Rupa Bhattacharyya. 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. (FGD) (Entered: 11/25/2025)

District Judge Leo T. Sorokin: ELECTRONIC ORDER entered granting 26 Motion for Leave to Appear Pro Hac Vice Added Tinesha Zandamela. 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. (FGD) (Entered: 11/25/2025)

District Judge Leo T. Sorokin: ELECTRONIC ORDER entered re: 27 Assented to MOTION for Leave to File Amicus Brief by Amici Curiae 27 Cities, Counties, and Elected Officials.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: 11/25/2025)

District Judge Leo T. Sorokin: ELECTRONIC ORDER entered granting 29 Motion for Leave to Appear Pro Hac Vice Added Ames Grawert. 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. (FGD) (Entered: 11/25/2025)

District Judge Leo T. Sorokin: ELECTRONIC ORDER entered granting 30 Motion for Leave to Appear Pro Hac Vice Added Brianna Seid. 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. (FGD) (Entered: 11/25/2025)

District Judge Leo T. Sorokin: ELECTRONIC ORDER entered re: 31 First MOTION for Leave to File Amicus Brief by Amici Curiae Law Enforcement Officials.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: 11/25/2025)

District Judge Leo T. Sorokin: ELECTRONIC ORDER entered re: 32 Assented to MOTION for Leave to File Memo of Amici Curiae.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: 11/25/2025)

AMICUS BRIEF re 15 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM filed by Amici Curiae Law Enforcement Officials. (Anderson, Austin) Modified docket text on 11/25/2025. (FGD) (Entered: 11/25/2025)

AMICUS BRIEF filed by Brazilian Women's Group, Dignidad, Greater Boston Legal Services, Haitian Americans United Inc., Jane Doe Inc., The American Civil Liberties Union of Massachusetts (ACLUM), The Cape Cod Coalition for Safe Communities, The Dominican Development Center, Inc., The East Boston Community Council, The Haitian American New Vision of Waltham, The Immigrant Support Alliance, The International Institute of New England, The Massachusetts Immigrant and Refugee Advocacy Coalition, The Massachusetts Law Reform Institute, The Sisters of St. Joseph of Boston, The Student Clinic for Immigrant Justice, The Watertown Citizens for Peace, Justice & the Environment's Refugee Support Working Group . (Rossman, Jessie) (Entered: 11/25/2025)

AMICUS BRIEF filed by Amici Curiae 27 Cities, Counties, and Elected Officials . (Greenberg-Chao, Laura) (Entered: 11/25/2025)

AMICUS BRIEF filed by Commonwealth of Massachusetts . (Cohen, Jared) (Entered: 11/25/2025)

NOTICE of Appearance by Rupa Bhattacharyya on behalf of Amici Curiae 27 Cities, Counties, and Elected Officials (Bhattacharyya, Rupa) (Entered: 11/25/2025)

NOTICE of Appearance by Tinesha Zandamela on behalf of Amici Curiae 27 Cities, Counties, and Elected Officials (Zandamela, Tinesha) (Entered: 11/25/2025)

Order on Motion for Leave to File Document

Order on Motion for Leave to Appear

NOTICE of Appearance by Ames Grawert on behalf of Amici Curiae Law Enforcement Officials (Grawert, Ames) (Entered: 11/26/2025)

NOTICE of Appearance by Brianna Seid on behalf of Amici Curiae Law Enforcement Officials (Seid, Brianna) (Main Document 48 replaced on 12/2/2025, with corrected PDF). (FGD) (Entered: 12/01/2025)

Consent MOTION for Extension of Time to January 7, 2026 to To File Response to Defendants' Motion to Dismiss by The United States of America. (Attachments: # 1 Text of Proposed Order)(Wen, James) (Entered: 12/09/2025)

1 Text of Proposed Order

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District Judge Leo T. Sorokin: ELECTRONIC ORDER entered re: 49 Consent MOTION for Extension of Time to January 7, 2026 to File Response re 15 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM.ALLOWED. Responses due by 1/7/2026. (FGD) (Entered: 12/10/2025)

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

Assented to MOTION for Leave to File Excess Pages in Plaintiff's Opposition and Defendants' Reply by The United States of America.(Hulseberg, Jordan)

District Judge Leo T. Sorokin: ELECTRONIC ORDER entered re: [51] Assented to MOTION for Leave to File Excess Pages in Plaintiff's Opposition and Defendants' Reply.

Order on Motion for Leave to File Excess Pages

Opposition re [15] MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM filed by The United States of America. (Hulseberg, Jordan)

NOTICE of Appearance by Matthew James O'Brien on behalf of Federation for American Immigration Reform (O'Brien, Matthew)

Assented to MOTION for Leave to File an amicus brief in support of Plaintiff by Federation for American Immigration Reform. (Attachments: (1) Amicus Brief, (2) Proposed Order)(O'Brien, Matthew)

1 Amicus Brief

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2 Proposed Order

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District Judge Leo T. Sorokin: ELECTRONIC ORDER entered re: [55] Assented to MOTION for Leave to File an amicus brief in support of Plaintiff.

AMICUS BRIEF filed by Federation for American Immigration Reform . (O'Brien, Matthew)

Order on Motion for Leave to File Document

REPLY to Response to [15] MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM filed by Boston Police Department, Michael A. Cox, The City of Boston, Michelle Wu. (Dinning, Sam)

District Judge Leo T. Sorokin: ELECTRONIC ORDER entered. The parties’ briefing does not address whether the United States has Article III standing as to each of its claims against the City of Boston—that is, whether the United States has suffered cognizable injuries in fact traceable to the challenged conduct that are likely to be redressed by an order of this Court. See, e.g., Spokeo, Inc. v. Robins, 578 U.S. 330, 338 (2016); Lujan v. Defs. of Wildlife, 504 U.S. 555, 560–61 (1992). “Standing is not dispensed in gross. Rather, a plaintiff must demonstrate standing for each claim [it] seeks to press and for each form of relief that is sought.” FEC v. Davis, 554 U.S. 724, 734 (2008) (citation modified). Standing must be shown before the Court can proceed to evaluate the merits of the motion to dismiss. Accordingly, the Court orders the parties to file supplemental briefing as follows: The parties shall brief the United States’ Article III standing as to each claim and form of relief sought against the City of Boston, considering in particular (1) Massachusetts law regarding detention based on civil immigration detainers, Lunn v. Commonwealth, 78 N.E.3d 1143 (Mass. 2017), and (2) the Boston Trust Act’s information-sharing savings clause, Bos., Mass., Mun. Code ch. 11 § 1.9(D)(3) (2019). The United States’ brief is due April 1, 2026, limited to 10 pages. Defendants’ response is due April 15, 2026, limited to 14 pages. The United States’ reply is due April 22, 2026, limited to 4 pages.(FGD) (Entered: 03/18/2026)

Order

Letter/request (non-motion) from Defendants . (Attachments: # 1 Exhibit United States v. Colorado Order)(Merrill, Toby) (Entered: 04/01/2026)

1 Exhibit United States v. Colorado Order

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Supplemental MEMORANDUM in Support re 15 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM filed by The United States of America. (Hulseberg, Jordan) (Entered: 04/01/2026)

First MOTION for Leave to Appear Pro Hac Vice for admission of Grace Lee Filing fee: $ 125, receipt number AMADC-11653798 by Boston Police Department, Michael A. Cox, The City of Boston, Michelle Wu. (Attachments: (1) Affidavit Declaration)(Merrill, Toby)

1 Affidavit Declaration

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District Judge Leo T. Sorokin: ELECTRONIC ORDER entered granting 62 Motion for Leave to Appear Pro Hac Vice Added Grace Lee. 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. (FGD) (Entered: 04/03/2026)

Order on Motion for Leave to Appear

NOTICE of Appearance by Grace Lee on behalf of Boston Police Department, Michael A. Cox, The City of Boston, Michelle Wu (Lee, Grace)

Supplemental MEMORANDUM in Support re [15] MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM filed by Boston Police Department, Michael A. Cox, The City of Boston, Michelle Wu. (Dinning, Sam)