ALLIANCE FOR RETIRED AMERICANS et al v. BESSENT et al

Filing 16

MOTION for Leave to File Supplement to the Record by ALLIANCE FOR RETIRED AMERICANS, AMERICAN FEDERATION OF GOVERNMENT EMPLOYEES, SERVICE EMPLOYEES INTERNATIONAL UNION AFL-CIO. (Attachments: # 1 Memorandum in Support, # 2 Exhibit Exhibit 1, # 3 Exhibit Exhibit 2, # 4 Exhibit Exhibit 3, # 5 Exhibit Exhibit 4, # 6 Exhibit Exhibit 5, # 7 Exhibit Exhibit 6, # 8 Exhibit Exhibit 7, # 9 Text of Proposed Order)(Joshi, Nandan)

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
Alliance for Retired Americans, et
al.,
Plaintiffs,
v.

Civil Action No. 25-313 (CKK)

Scott Bessent, in his official
capacity as Secretary of the
Treasury, et al.,
Defendants.
PLAINTIFFS’ MOTION TO SUPPLEMENT THE RECORD
Pursuant to Local Civil Rule 65.1(d), Plaintiffs Alliance for Retired Americans
(ARA), American Federation of Government Employees, AFL-CIO (AFGE), and
Service Employees International Union, AFL-CIO (SEIU) move to supplement the
record to include declarations from Carol Rosenblatt, a member of ARA; Jeanette L.
McElhaney, a member of AFGE; and Barbara Casey, Henrietta Jenkins, Pia
Morrison, Patrice Peterson, and Susan Tousignant, members of SEIU, regarding
their interests in preventing the so-called Department of Government Efficiency
(DOGE) from accessing the personal and financial information stored in the records
of Defendant Bureau of the Fiscal Service. The declarations are attached as exhibits
hereto.
Counsel for Defendants have advised that Defendants oppose grant of this
motion.

Dated: February 11, 2025

Respectfully submitted,
/s/ Nandan M. Joshi
Nandan M. Joshi (DC Bar No. 456750)
Nicolas Sansone (DC Bar No. 1686810)
Allison M. Zieve (DC Bar No. 424786)
Public Citizen Litigation Group
1600 20th Street NW
Washington, DC 20009
[phone]
Norman L. Eisen (DC Bar No. 435051)
State Democracy Defenders Fund
600 Pennsylvania Avenue SE
#15180
Washington, DC 20003

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