Case: State of California v. United States Department of Transportation

State of California et al. v. U.S. Department of Transportation et al.

COMPLAINT against defendant(s) All Plaintiffs (Receipt # AWAWDC-9351175) Attorney Caitlin Soden added to party Commonwealth of Massachusetts(pty:pla), Attorney Caitlin Soden added to party District of Columbia(pty:pla), Attorney Caitlin Soden added to party Governor Josh Shapiro of Pennsylvania(pty:pla), Attorney Caitlin Soden added to party State of Arizona(pty:pla), Attorney Caitlin Soden added to party State of California(pty:pla), Attorney Caitlin Soden added to party State of Colorado(pty:pla), Attorney Caitlin Soden added to party State of Delaware(pty:pla), Attorney Caitlin Soden added to party State of Illinois(pty:pla), Attorney Caitlin Soden added to party State of Maryland(pty:pla), Attorney Caitlin Soden added to party State of Michigan (pty:pla), Attorney Caitlin Soden added to party State of New Jersey(pty:pla), Attorney Caitlin Soden added to party State of New York(pty:pla), Attorney Caitlin Soden added to party State of Oregon(pty:pla), Attorney Caitlin Soden added to party State of Rhode Island (pty:pla), Attorney Caitlin Soden added to party State of Vermont(pty:pla), Attorney Caitlin Soden added to party State of Washington(pty:pla), Attorney Caitlin Soden added to party State of Wisconsin (pty:pla) filed by State of New Jersey, State of Illinois, State of Colorado, State of Wisconsin, State of California, State of Vermont, State of Oregon, District of Columbia, State of Washington, Commonwealth of Massachusetts, State of New York, Governor Josh Shapiro of Pennsylvania, State of Rhode Island, State of Maryland, State of Arizona, State of Michigan, State of Delaware. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Civil Cover Sheet, # 7 Supplement Plaintiffs' Notice of Related Cases, # 8 Summons U.S. DOT, # 9 Summons Sean Duffy, U.S. DOT, # 10 Summons FHWA, # 11 Summons Sean McMaster, FHWA)(Soden, Caitlin) (Entered: 12/16/2025)

1 Exhibit 1

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2 Exhibit 2

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3 Exhibit 3

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4 Exhibit 4

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5 Exhibit 5

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6 Civil Cover Sheet

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7 Supplement Plaintiffs' Notice of Related Cases

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8 Summons U.S. DOT

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9 Summons Sean Duffy, U.S. DOT

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10 Summons FHWA

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11 Summons Sean McMaster, FHWA

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NOTICE of Appearance by attorney Caitlin Soden on behalf of Plaintiffs Commonwealth of Massachusetts, District of Columbia, Governor Josh Shapiro of Pennsylvania, State of Arizona, State of California, State of Colorado, State of Delaware, State of Illinois, State of Maryland, State of Michigan, State of New Jersey, State of New York, State of Oregon, State of Rhode Island, State of Vermont, State of Washington, State of Wisconsin. (Soden, Caitlin) (Entered: 12/16/2025)

NOTICE of Appearance by attorney Leah Brown on behalf of Plaintiff State of Washington. (Brown, Leah) (Entered: 12/16/2025)

APPLICATION OF ATTORNEY Elizabeth A. Jones FOR LEAVE TO APPEAR PRO HAC VICE for Plaintiff State of California (Fee Paid) Receipt No. AWAWDC-9352643 (Soden, Caitlin) (Entered: 12/16/2025)

APPLICATION OF ATTORNEY Theodore A. McCombs FOR LEAVE TO APPEAR PRO HAC VICE for Plaintiff State of California (Fee Paid) Receipt No. AWAWDC-9352677 (Soden, Caitlin) (Entered: 12/16/2025)

APPLICATION OF ATTORNEY Robert Swanson FOR LEAVE TO APPEAR PRO HAC VICE for Plaintiff State of California (Fee Paid) Receipt No. AWAWDC-9352690 (Soden, Caitlin) (Entered: 12/16/2025)

APPLICATION OF ATTORNEY Christopher Len FOR LEAVE TO APPEAR PRO HAC VICE by Plaintiff State of California. Receipt No. AWAWDC-9352671 (Soden, Caitlin) (Entered: 12/16/2025)

Summons(es) Electronically Issued as to defendant(s) Sean Duffy, Federal Highway Administration, Sean McMaster, United States Department of Transportation (Attachments: # 1 Summons Sean Duffy, # 2 Summons Federal Highway Administration, # 3 Summons Sean McMaster)(KB) (Entered: 12/17/2025)

ORDER re 6 Application for Leave to Appear Pro Hac Vice, 4 Application for Leave to Appear Pro Hac Vice, 5 Application for Leave to Appear Pro Hac Vice. The Court ADMITS Attorneys Elizabeth Jones, Theodore McCombs, and Robert D Swanson for State of California, by Clerk Ravi Subramanian. No document associated with this docket entry, text only.NOTE TO COUNSEL: Local counsel agrees to sign all filings and to be prepared to handle the matter, including the trial thereof, in the event the applicant is unable to be present on any date scheduled by the court, pursuant to LCR 83.1(d).(HH) (Entered: 12/17/2025)

Judge Tana Lin added. (KB)

Add and Terminate Judges

Application 7 by attorney Christopher Len will not be processed at this time. The Pro Hac attorney must submit a Pro Hac Vice access request via Manage My Account on PACER, under the Maintenance tab. See page 2 of the Pro Hac Vice Application Guide for detailed instructions. Please contact the Attorney Admissions Clerk at 206-370-8400 or WAWD_Admissions@wawd.uscourts.gov with additional questions. (Ad hoc Attorney Christopher Len) (HH)

APPLICATION OF ATTORNEY Carrie Noteboom FOR LEAVE TO APPEAR PRO HAC VICE for Plaintiff State of Colorado (Fee Paid) Receipt No. AWAWDC-9356751 (Soden, Caitlin) (Entered: 12/18/2025)

APPLICATION OF ATTORNEY Sarah H, Weiss FOR LEAVE TO APPEAR PRO HAC VICE for Plaintiff State of Colorado (Fee Paid) Receipt No. AWAWDC-9356789 (Soden, Caitlin) (Entered: 12/18/2025)

APPLICATION OF ATTORNEY Lauren Cullum FOR LEAVE TO APPEAR PRO HAC VICE for Plaintiff District of Columbia (Fee Paid) Receipt No. AWAWDC-9356813 (Soden, Caitlin) (Entered: 12/18/2025)

ORDER re 10 Application for Leave to Appear Pro Hac Vice, 12 Application for Leave to Appear Pro Hac Vice, 11 Application for Leave to Appear Pro Hac Vice, 7 Application. The Court ADMITS Attorneys Christopher Lee Len for State of California ; attorneys Carrie Noteboom and Sarah Hunter Weiss for State of Colorado; and Lauren Cullum for State of Colorado District of Columbia, by Clerk Ravi Subramanian. No document associated with this docket entry, text only.NOTE TO COUNSEL: Local counsel agrees to sign all filings and to be prepared to handle the matter, including the trial thereof, in the event the applicant is unable to be present on any date scheduled by the court, pursuant to LCR 83.1(d).(HH) Modified on 12/18/2025 to indicate that PHV counsel Lauren Cullum represents Plaintiff District of Columbia (KB). (Entered: 12/18/2025)

Notice of Docket Text Modification

Order on Application for Leave to Appear Pro Hac Vice

NOTICE of Docket Text Modification re 13 Order on Application for Leave to Appear Pro Hac Vice: Modified on 12/18/2025 to indicate that PHV counsel Lauren Cullum represents Plaintiff District of Columbia. (KB)

APPLICATION OF ATTORNEY Jonathan T. Rose FOR LEAVE TO APPEAR PRO HAC VICE for Plaintiff State of Vermont (Fee Paid) Receipt No. AWAWDC-9358705 (Soden, Caitlin) (Entered: 12/19/2025)

NOTICE of Related Case(s) 2:25-cv-00848-TL; 2:25-cv-02578-TL, by All Plaintiffs. (Soden, Caitlin) (Entered: 12/19/2025)

STANDING ORDER REGARDING 28 U.S.C. § 455 AND CANON 3 OF THE CODE OF CONDUCT FOR UNITED STATES JUDGES by Judge Tana Lin. (KMP) (Entered: 12/19/2025)

MINUTE ORDER (text only) made at the direction of Judge Tana Lin: The Court has posted Chambers Procedures at https://www.wawd.uscourts.gov/judges/lin-procedures. All counsel and unrepresented ("pro se") parties are DIRECTED to review them, if they have not already done so. Failure to follow the requirements set forth in the Chambers Procedures may result in the imposition of sanctions. (KMP) (Entered: 12/19/2025)

TL Minute Order re Chambers Procedures

ORDER re 14 Application for Leave to Appear Pro Hac Vice. The Court ADMITS Attorney Jonathan T Rose for State of Vermont, by Clerk Ravi Subramanian. No document associated with this docket entry, text only.NOTE TO COUNSEL: Local counsel agrees to sign all filings and to be prepared to handle the matter, including the trial thereof, in the event the applicant is unable to be present on any date scheduled by the court, pursuant to LCR 83.1(d).(HH) (Entered: 12/22/2025)

Order on Application for Leave to Appear Pro Hac Vice

NOTICE of Appearance by attorney Jonathan T Rose on behalf of Plaintiff State of Vermont. (Rose, Jonathan) (Entered: 12/23/2025)

APPLICATION OF ATTORNEY Katharine Roller FOR LEAVE TO APPEAR PRO HAC VICE for Plaintiff State of Illinois (Fee Paid) Receipt No. AWAWDC-9365244 (Soden, Caitlin) (Entered: 12/23/2025)

APPLICATION OF ATTORNEY Robert Henry Weaver FOR LEAVE TO APPEAR PRO HAC VICE for Plaintiff State of Illinois (Fee Paid) Receipt No. AWAWDC-9365279 (Soden, Caitlin) (Entered: 12/23/2025)

APPLICATION OF ATTORNEY Nicholas M. Vaz FOR LEAVE TO APPEAR PRO HAC VICE for Plaintiff State of Rhode Island (Fee Paid) Receipt No. AWAWDC-9366570 (Soden, Caitlin) (Entered: 12/23/2025)

APPLICATION OF ATTORNEY Jacob Boyer FOR LEAVE TO APPEAR PRO HAC VICE for Plaintiff Josh Shapiro (Fee Paid) Receipt No. AWAWDC-9366591 (Soden, Caitlin) (Entered: 12/23/2025)

APPLICATION OF ATTORNEY Patrick Rowe FOR LEAVE TO APPEAR PRO HAC VICE for Plaintiff State of Oregon (Fee Paid) Receipt No. AWAWDC-9366772 (Soden, Caitlin) (Entered: 12/23/2025)

ORDER re [22] Application for Leave to Appear Pro Hac Vice, [20] Application for Leave to Appear Pro Hac Vice, [24] Application for Leave to Appear Pro Hac Vice, [21] Application for Leave to Appear Pro Hac Vice, [23] Application for Leave to Appear Pro Hac Vice. The Court ADMITS Attorneys Jacob Boyer for Josh Shapiro,Katharine Roller,Robert Henry Weaver for State of Illinois,Patrick Rowe for State of Oregon, and Nicholas M. Vaz for State of Rhode Island, by Clerk Ravi Subramanian. No document associated with this docket entry, text only. NOTE TO COUNSEL: Local counsel agrees to sign all filings and to be prepared to handle the matter, including the trial thereof, in the event the applicant is unable to be present on any date scheduled by the court, pursuant to LCR 83.1(d).(HH)

Order on Application for Leave to Appear Pro Hac Vice

DECLARATION of Service via Hand Delivery re [8] Summons Issued, [2] Notice of Appearance, [3] Notice of Appearance, [1] Complaint,,,,,,,, by Plaintiff State of Washington (Brown, Leah)

DECLARATION of Service via Certified Mail re [8] Summons Issued, [2] Notice of Appearance, [3] Notice of Appearance, [1] Complaint,,,,,,,, by Plaintiff State of Washington (Brown, Leah)

APPLICATION OF ATTORNEY Neil Giovanatti FOR LEAVE TO APPEAR PRO HAC VICE for Plaintiff State of Michigan (Fee Paid) Receipt No. AWAWDC-9381388 (Soden, Caitlin)

APPLICATION OF ATTORNEY Daniel John Ping FOR LEAVE TO APPEAR PRO HAC VICE for Plaintiff State of Michigan (Fee Paid) Receipt No. AWAWDC-9381449 (Soden, Caitlin)

ORDER re [28] Application for Leave to Appear Pro Hac Vice, [29] Application for Leave to Appear Pro Hac Vice. The Court ADMITS Attorneys Neil Giovanatti, and Daniel John Ping for State of Michigan, by Clerk Ravi Subramanian. No document associated with this docket entry, text only. NOTE TO COUNSEL: Local counsel agrees to sign all filings and to be prepared to handle the matter, including the trial thereof, in the event the applicant is unable to be present on any date scheduled by the court, pursuant to LCR 83.1(d).(HH)

Order on Application for Leave to Appear Pro Hac Vice

APPLICATION OF ATTORNEY Nell Hryshko FOR LEAVE TO APPEAR PRO HAC VICE for Plaintiff State of New Jersey (Fee Paid) Receipt No. AWAWDC-9384446 (Soden, Caitlin)

ORDER re [31] Application for Leave to Appear Pro Hac Vice. The Court ADMITS Attorney Nell Maria Miano Hryshko for State of New Jersey, by Clerk Ravi Subramanian. No document associated with this docket entry, text only. NOTE TO COUNSEL: Local counsel agrees to sign all filings and to be prepared to handle the matter, including the trial thereof, in the event the applicant is unable to be present on any date scheduled by the court, pursuant to LCR 83.1(d).(HH)

Order on Application for Leave to Appear Pro Hac Vice

NOTICE of Appearance by attorney Joshua N. Schopf on behalf of Defendants Sean Duffy, Federal Highway Administration, Sean McMaster, United States Department of Transportation. (Schopf, Joshua)

NOTICE of Appearance by attorney Frances Colbert on behalf of Plaintiff State of Wisconsin. (Colbert, Frances)

Notice of Filing Deficiency re [34] Notice of Appearance. Action Required Pro Hac Vice Admission. See attached letter for more information and instructions. (CJS)

APPLICATION OF ATTORNEY Steven J. Goldstein FOR LEAVE TO APPEAR PRO HAC VICE for Plaintiff State of Maryland (Fee Paid) Receipt No. AWAWDC-9407402 (Soden, Caitlin)

APPLICATION OF ATTORNEY Frances Reynolds Colbert FOR LEAVE TO APPEAR PRO HAC VICE for Plaintiff State of Wisconsin (Fee Paid) Receipt No. AWAWDC-9408388 (Soden, Caitlin)

ORDER re [36] Application for Leave to Appear Pro Hac Vice, [37] Application for Leave to Appear Pro Hac Vice. The Court ADMITS Attorney Steven Goldstein for State of Maryland, and Attorney Frances Colbert for State of Wisconsin, by Clerk Joshua C. Lewis. No document associated with this docket entry, text only. NOTE TO COUNSEL: Local counsel agrees to sign all filings and to be prepared to handle the matter, including the trial thereof, in the event the applicant is unable to be present on any date scheduled by the court, pursuant to LCR 83.1(d).(HH)

Order on Application for Leave to Appear Pro Hac Vice

APPLICATION OF ATTORNEY Mary M. Curtin FOR LEAVE TO APPEAR PRO HAC VICE for Plaintiff State of Arizona (Fee Paid) Receipt No. AWAWDC-9430308 (Soden, Caitlin)

APPLICATION OF ATTORNEY Ralph K. Durstein III FOR LEAVE TO APPEAR PRO HAC VICE for Plaintiff State of Delaware (Fee Paid) Receipt No. AWAWDC-9434395 (Soden, Caitlin)

APPLICATION OF ATTORNEY Vanessa L. Kassab FOR LEAVE TO APPEAR PRO HAC VICE for Plaintiff State of Delaware (Fee Paid) Receipt No. AWAWDC-9434444 (Soden, Caitlin)

APPLICATION OF ATTORNEY Ian R. Liston FOR LEAVE TO APPEAR PRO HAC VICE for Plaintiff State of Delaware (Fee Paid) Receipt No. AWAWDC-9434465 (Soden, Caitlin)

APPLICATION OF ATTORNEY Kyle Burns FOR LEAVE TO APPEAR PRO HAC VICE for Plaintiff State of New York (Fee Paid) Receipt No. AWAWDC-9434475 (Soden, Caitlin)

ORDER re [39] Application for Leave to Appear Pro Hac Vice, [40] Application for Leave to Appear Pro Hac Vice, [41] Application for Leave to Appear Pro Hac Vice, [43] Application for Leave to Appear Pro Hac Vice, [42] Application for Leave to Appear Pro Hac Vice. The Court ADMITS Attorney Mary Curtin for State of Arizona, attorneys Ralph K Durstein, III,Vanessa L Kassab,Ian Liston for State of Delaware, and attorney Kyle Williams Burns for State of New York, by Clerk Joshua C. Lewis. No document associated with this docket entry, text only. NOTE TO COUNSEL: Local counsel agrees to sign all filings and to be prepared to handle the matter, including the trial thereof, in the event the applicant is unable to be present on any date scheduled by the court, pursuant to LCR 83.1(d).(HH)

Order on Application for Leave to Appear Pro Hac Vice

ORDER REGARDING INITIAL DISCLOSURES AND JOINT STATUS REPORT by Judge Tana Lin. FRCP 26(f) Conference Deadline is 3/2/2026, Initial Disclosure Deadline is 3/16/2026, Joint Status Report due by 3/30/2026. (KMP)

APPLICATION OF ATTORNEY Julia E. Jonas-Day FOR LEAVE TO APPEAR PRO HAC VICE for Plaintiff Commonwealth of Massachusetts (Fee Paid) Receipt No. AWAWDC-9453097 (Soden, Caitlin)

Application for Leave to Appear Pro Hac Vice46 by attorney Julia E. Jonas-Day will not be processed at this time. The Pro Hac attorney must submit a Pro Hac Vice access request via Manage My Account on PACER, under the Maintenance tab. See page 2 of the Pro Hac Vice Application Guide for detailed instructions. Please contact the Attorney Admissions Clerk at 206-370-8400 or WAWD_Admissions@wawd.uscourts.gov with additional questions. (Ad hoc Attorney Julia E. Jonas-Day) (LRS)

STIPULATION AND PROPOSED ORDER to Consolidate by parties (Schopf, Joshua)

ORDER ON CONSOLIDATION re the Parties' [47] Stipulation. The Court hereby ORDERS: (1) Climate Solutions et al. v. U.S. Department of Transportation, No. C25-2578 (W.D. Wash.) IS CONSOLIDATED with California et al. v. U.S. Department of Transportation, No. C25-2574 (W.D. Wash.). (2) All papers filed subsequently in this consolidated action SHALL be filed solely in California et al. v. U.S. Department of Transportation, No. C25-2574. (3) Defendants SHALL file their responses to the complaints in both actions to the C25-2574 docket no later than March 2, 2026. (4) The initial scheduling deadlines set forth in the Court's orders in each case, dated February 2, 2026, remain in effect and are not impacted by this Stipulation. (5) The Clerk is DIRECTED to file a copy of this Order in Climate Solutions et al. v. U.S. Department of Transportation, No. C25-2578, and to administratively close that case. Signed by Judge Tana Lin. (CJS)

ORDER re [46] Application for Leave to Appear Pro Hac Vice. The Court ADMITS Attorney Julia E. Jonas-Day for Commonwealth of Massachusetts, by Clerk Joshua C. Lewis. No document associated with this docket entry, text only. NOTE TO COUNSEL: Local counsel agrees to sign all filings and to be prepared to handle the matter, including the trial thereof, in the event the applicant is unable to be present on any date scheduled by the court, pursuant to LCR 83.1(d).(LRS)

Order on Application for Leave to Appear Pro Hac Vice

STIPULATION to Extend Deadlines by parties (Schopf, Joshua)

ADMINISTRATIVE RECORD filed by All Defendants. (Attachments: (1) Exhibit Administrative Record)(Schopf, Joshua)

1 Exhibit Administrative Record

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APPLICATION OF ATTORNEY Natalie Collins FOR LEAVE TO APPEAR PRO HAC VICE for Plaintiff State of California (Fee Paid) Receipt No. AWAWDC-9578235 (Soden, Caitlin)

ORDER re [52] Application for Leave to Appear Pro Hac Vice. The Court ADMITS Attorney Natalie Collins for State of California, by Clerk Joshua C. Lewis. No document associated with this docket entry, text only. NOTE TO COUNSEL: Local counsel agrees to sign all filings and to be prepared to handle the matter, including the trial thereof, in the event the applicant is unable to be present on any date scheduled by the court, pursuant to LCR 83.1(d).(PS)

Order on Application for Leave to Appear Pro Hac Vice

MOTION Complete the Administrative Record , filed by Consol Plaintiffs Climate Solutions, Natural Resources Defense Council, Sierra Club, Plaintiffs Commonwealth of Massachusetts, District of Columbia, Josh Shapiro, State of Arizona, State of California, State of Colorado, State of Delaware, State of Illinois, State of Maryland, State of Michigan, State of New Jersey, State of New York, State of Oregon, State of Rhode Island, State of Vermont, State of Washington, State of Wisconsin. (Attachments: (1) Proposed Order) Noting Date 4/21/2026, (Soden, Caitlin)

1 Proposed Order

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DECLARATION of Natalie Collins filed by Consol Plaintiffs Climate Solutions, Natural Resources Defense Council, Sierra Club, Plaintiffs Commonwealth of Massachusetts, District of Columbia, Josh Shapiro, State of Arizona, State of California, State of Colorado, State of Delaware, State of Illinois, State of Maryland, State of Michigan, State of New Jersey, State of New York, State of Oregon, State of Rhode Island, State of Vermont, State of Washington, State of Wisconsin re [54] MOTION Complete the Administrative Record (Attachments: (1) Exhibit 1, (2) Exhibit 2, (3) Exhibit 3, (4) Exhibit 4, (5) Exhibit 5, (6) Exhibit 6, (7) Exhibit 7, (8) Exhibit 8, (9) Exhibit 9)(Soden, Caitlin)

1 Exhibit 1

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2 Exhibit 2

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3 Exhibit 3

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4 Exhibit 4

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5 Exhibit 5

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6 Exhibit 6

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7 Exhibit 7

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8 Exhibit 8

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9 Exhibit 9

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DECLARATION of Joya Manjur filed by Consol Plaintiffs Climate Solutions, Natural Resources Defense Council, Sierra Club, Plaintiffs Commonwealth of Massachusetts, District of Columbia, Josh Shapiro, State of Arizona, State of California, State of Colorado, State of Delaware, State of Illinois, State of Maryland, State of Michigan, State of New Jersey, State of New York, State of Oregon, State of Rhode Island, State of Vermont, State of Washington, State of Wisconsin re [54] MOTION Complete the Administrative Record (Attachments: (1) Exhibit A-C)(Soden, Caitlin)

1 Exhibit A-C

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APPLICATION OF ATTORNEY Elizabeth Rumsey FOR LEAVE TO APPEAR PRO HAC VICE for Plaintiff State of California (Fee Paid) Receipt No. AWAWDC-9612844 (Soden, Caitlin)

ORDER re [57] Application for Leave to Appear Pro Hac Vice. The Court ADMITS Attorney Elizabeth B Rumsey for State of California, by Clerk Joshua C. Lewis. No document associated with this docket entry, text only. NOTE TO COUNSEL: Local counsel agrees to sign all filings and to be prepared to handle the matter, including the trial thereof, in the event the applicant is unable to be present on any date scheduled by the court, pursuant to LCR 83.1(d).(PS)

Order on Application for Leave to Appear Pro Hac Vice

RESPONSE, by Defendants Sean Duffy, Federal Highway Administration, Sean McMaster, United States Department of Transportation, to [54] MOTION Complete the Administrative Record . (Schopf, Joshua)

Second DECLARATION of Maria Lefevre filed by Defendants Sean Duffy, Federal Highway Administration, Sean McMaster, United States Department of Transportation re [54] MOTION Complete the Administrative Record (Schopf, Joshua)