Case 1:17-cv-01597 Document 1 Filed 08/09/17 Page 1 of 15

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
JANE DOE 1, JANE DOE 2, JANE DOE 3,
JANE DOE 4, and JANE DOE 5,

)
)
)
Plaintiffs,
)
)
v.
)
)
DONALD J. TRUMP, in his official capacity as )
President of the United States; JAMES N.
)
MATTIS, in his official capacity as Secretary of )
Defense; JOSEPH F. DUNFORD, JR., in his
)
official capacity as Chairman of the Joint Chiefs )
of Staff; the UNITED STATES DEPARTMENT )
OF THE ARMY; RYAN D. MCCARTHY, in
)
his official capacity as Secretary of the Army;
)
the UNITED STATES DEPARTMENT OF
)
THE AIR FORCE; HEATHER A. WILSON, in )
her official capacity as Secretary of the Air
)
Force; the UNITED STATES COAST GUARD; )
ELAINE C. DUKE, in her official capacity as
)
Secretary of Homeland Security; and the
)
UNITED STATES OF AMERICA,
)
)
Defendants.
)

Case No.

17-cv-1597

COMPLAINT FOR
DECLARATORY AND
INJUNCTIVE RELIEF

INTRODUCTION
1.

This is a constitutional and equitable challenge to President Donald J. Trump’s

decision to reverse the current policy of the United States Armed Forces by prohibiting
transgender servicemembers from “serv[ing] in any capacity in the U.S. military.”
2.

In June 2016, the United States Department of Defense announced after an

exhaustive review process that it would allow transgender people to serve openly in the United
States Armed Forces.
3.

Since that time, Plaintiffs, along with thousands of servicemembers, have

followed protocol in informing their chain of command that they are transgender. They did so in

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reliance on the United States’ express promises that it would permit them to continue to serve
their country openly. These servicemembers, like many others, have built their lives around their
military service.
4.

On July 26, 2017, President Trump announced in a series of tweets that he would

reverse the Department of Defense’s policy on transgender servicemembers, stating that “the
United States Government will not accept or allow transgender individuals to serve in any
capacity in the U.S. Military.” The President’s announcement, which upon information and
belief was made without consulting the Joint Chiefs of Staff, upset the reasonable expectations of
Plaintiffs and thousands of other transgender servicemembers and the men and women with
whom they serve and fight.
5.

Upon information and belief, the White House turned that decision into official

guidance, approved by the White House counsel’s office, to be communicated to the Department
of Defense.
6.

Plaintiffs here are five servicemembers who collectively have served this nation

for decades in various branches of the United States military.
7.

Execution of the President’s directive will result in an end to service by openly

transgender service members and has already resulted in immediate, concrete injury to Plaintiffs
by unsettling and destabilizing plaintiffs’ reasonable expectation of continued service.
8.

The directive to reinstate a ban on open service by transgender people violates

both the Equal Protection component of the Fifth Amendment and the Due Process Clause of the
Fifth Amendment to the United States Constitution. Additionally, Defendants are estopped from
terminating the continued service of Plaintiffs and other active duty transgender servicemembers.

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9.

This lawsuit seeks declaratory and permanent injunctive relief against

implementation of the President’s directive to prohibit transgender individuals from serving in
the Armed Forces.
JURISDICTION AND VENUE
10.

This court has jurisdiction over the claims under 28 U.S.C. §§ 1331 and 1343.

11.

Venue is proper in this district under 28 U.S.C. § 1391(b) because the acts

described in this Complaint occurred in this judicial district.
PLAINTIFFS
12.

Plaintiffs are active duty servicemembers in the United States military who serve

openly as transgender people. They proceed under pseudonyms here for fear of retribution.
13.

Jane Doe 1 has served with distinction in the United States Coast Guard for more

than a decade.
14.

In or around June 2016, in reliance on the issuance of the policy permitting open

service by transgender servicemembers, Jane Doe 1 notified her command that she is
transgender.
15.

Since that time, she has continued to serve without incident and has furthered her

gender transition in reliance on the Department of Defense’s policy permitting open service by
transgender servicemembers.
16.

Following President Trump’s tweets, Jane Doe 1 submitted a prospective letter of

resignation stating that she would resign rather than be involuntarily terminated on account of
her transgender status. Were the Department of Defense to retreat from the policy announced by
President Trump, Jane Doe 1 would withdraw her resignation and continue to serve.
17.

Jane Doe 2 has been enlisted in the National Guard since 2003 and has been on

active duty in the United States Army since 2006.
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18.

Jane Doe 2 notified her command that she is transgender after the United States

Department of Defense announced in June 2016 that it would allow transgender servicemembers
to serve openly in the military.
19.

In reliance on the Department’s promise to allow transgender servicemembers to

serve openly, Jane Doe 2 began to seek medical treatment relating to her gender transition in
September 2016.
20.

Since informing her command that she is transgender, Jane Doe 2 has continued

serving in her post without incident.
21.

Jane Doe 2’s current contract with the military extends through November 2018.

She is counting on the compensation and benefits accrued during that time to pay for further
education and training to begin a civilian career, but she fears that the ban may result in early
termination of her contract.
22.

Jane Doe 3 has served in the United States Army since 2015. She has previously

been deployed to Afghanistan and expects to be deployed to Iraq soon.
23.

In or around June of 2016, in reliance on the Department of Defense policy

permitting transgender people to serve openly in the military, Jane Doe 3 notified her command
that she is transgender. Since then, she has continued serving her post without incident.
24.

Jane Doe 3’s current contract with the military extends through December 2018.

She plans to renew her contract, but fears that she will not be allowed to do so because of the
ban.
25.

Jane Doe 4 has served in the United States Army since 2000.

26.

In or around June of 2016, in reliance on the Department of Defense policy

permitting transgender people to serve openly in the military, Jane Doe 4 met with her

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commanding officer to identify herself as transgender. She began receiving medical treatment
related to her gender transition in September 2016.
27.

Since coming out as transgender, Jane Doe 4 continued serving in her post

without incident.
28.

Jane Doe 4’s current contract with the military extends through June 2018. She

plans to renew her contract to complete two additional years of service following the expiration
of her current contract so that she can reach twenty years of service and receive retirement
benefits. She fears that the President’s directive banning transgender people from military
service will result in her discharge from the military before she can reach this twenty-year
benchmark, thus leading to a substantial decrease in her retirement payments.
Jane Doe 5 has been an active duty member of the United States Air Force for nearly twenty
years, serving multiple tours of duty abroad, including two in Iraq.
29.

After June 2016, in reliance on the announcement that transgender people would

be permitted to serve openly, she notified her superiors that she is transgender. She has served in
the intervening time without incident.
30.

Jane Doe 5’s livelihood depends on her military service. Separation from the

military would have devastating financial and emotional consequences for her.
DEFENDANTS
31.

Defendant Donald J. Trump is President of the United States and Commander in

Chief of the Armed Forces. On July 26, 2017, President Trump stated on Twitter that
transgender people would not be permitted to serve “in any capacity in the U.S. military.” Upon
information and belief, President Trump subsequently directed that decision to be turned into
official guidance to be transmitted for implementation to the Department of Defense.

5

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32.

Defendant James N. Mattis is the United States Secretary of Defense. He is the

leader of the Department of Defense.
33.

Defendant Joseph F. Dunford, Jr. is a United States Marine Corps General and

services as the current Chairman of the Joint Chiefs of Staff.
34.

Defendant Department of the Army is one of three military departments of the

Department of Defense and is responsible for the administration and operation of the United
States Army.
35.

Defendant Ryan D. McCarthy is the Acting United States Secretary of the Army.

He is the leader of the Department of the Army.
36.

Defendant Department of the Air Force is one of three military departments of the

Department of Defense and is responsible for the administration and operation of the United
States Air Force.
37.

Defendant Heather A. Wilson is the United States Secretary of the Air Force. She

is the leader of the Department of the Air Force.
38.

Defendant United States Coast Guard is one of the five branches of the United

States Armed Forces.
39.

Defendant Elaine C. Duke is the Acting United States Secretary of Homeland

Security. She is the leader of the Department of Homeland Security. The Department of
Homeland Security is responsible for the administration and operation of the United States Coast
Guard.
40.

Defendant United States of America includes all federal government agencies and

departments responsible for the implementation of the President’s decision.
41.

All of the Defendants are sued in their official capacities.

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STATEMENT OF FACTS
Background on Transgender People Serving Openly In the Military
42.

In May 2014, then-Secretary of Defense Chuck Hagel, a decorated U.S. Army

combat veteran, recommended that the military conduct a review of whether transgender people
should be permitted to serve openly in the Armed Forces.
43.

In August 2014, the Department of Defense issued a new regulation that

eliminated its categorical ban on open service by transgender persons and instructed each branch
of the Armed Forces to reassess whether maintaining a service-wide ban on service by openly
transgender persons was justified.
44.

Secretary Hagel explained that “[e]very qualified American who wants to serve

our country should have an opportunity to do so if they fit the qualifications and can do it.”
45.

Secretary Hagel was succeeded as Secretary of Defense by Ashton B. Carter, who

had previously served many years within the Department, including as Deputy Secretary of
Defense, Under Secretary of Defense for Acquisition, Technology and Logistics, Assistant
Secretary of Defense for International Security Policy, and as a member of the Defense Policy
Board and the Defense Science Board. In July 2015, Secretary Carter announced that the
military would begin a comprehensive analysis of whether to maintain the prohibition on
military service by transgender people.
46.

Over the course of a year, Secretary Carter oversaw a comprehensive review of

this issue by the leadership of the Armed Services, the Joint Chiefs of Staff, the service
secretaries, and personnel, training, readiness, and medical specialists from across the
Department of Defense.

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47.

That year-long process examined all the data available on the issue, including but

not limited to existing studies and research and input from transgender servicemembers, outside
expert groups, and medical professionals.
48.

This process also included a careful review of the eighteen other countries that

permit military service by openly transgender people.
49.

This process also included consultation with doctors, employers, and insurance

companies regarding the provision of medical care to transgender people.
50.

The Department of Defense also commissioned the RAND Corporation, an

organization formed after World War II to connect military planning with research and
development decisions and which now operates as an independent think tank financed by the
U.S. government, to analyze relevant data and studies to determine the impact of permitting
transgender servicemembers to serve openly.
51.

The study, titled “Assessing the Implications of Allowing Transgender Personnel

to Serve Openly” (the “RAND Study”), concluded that allowing transgender people to serve
openly would “cost little and have no significant impact on unit readiness.”
52.

The RAND Study concluded that health care costs for transgender

servicemembers would represent “an exceedingly small proportion of [the Department of
Defense’s] overall health care expenditures.” The RAND Study also concluded that this minimal
incremental cost would likely be offset by savings through diminished rates of other health care
costs that would be achieved by providing servicemembers with necessary transition-related
medical care.

8

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53.

Based on the results of this comprehensive, year-long review process, the

Department of Defense concluded that the needs of the military would be best served by
permitting openly transgender people to serve.
54.

As laid out by Secretary Carter in remarks delivered on June 30, 2016, that

conclusion was based on a number of considerations, including: the need to recruit and retain the
most highly qualified people to serve in our nation’s Armed Forces; the fact that thousands of
transgender people are already serving and that the military has already invested thousands of
dollars to train each servicemember; the benefits to the military of retaining individuals who are
already trained and who have already proven themselves; the need to provide both transgender
servicemembers and their commanders with clear guidance on questions such as deployment and
medical treatment; and the principle that “Americans who want to serve and can meet our
standards should be afforded the opportunity to compete to do so.”
55.

On June 30, 2016, Secretary Carter announced that “[e]ffective immediately,

transgender Americans may serve openly. They can no longer be discharged or otherwise
separated from the military just for being transgender.”
56.

Also on June 30, 2016, Secretary Carter issued Directive-Type Memorandum 16-

005, titled “Military Service of Transgender Service Members.” The memorandum states: “The
policy of the Department of Defense is that service in the United States military should be open
to all who can meet the rigorous standards for military service and readiness. Consistent with the
policies and procedures set forth in this memorandum, transgender individuals shall be allowed
to serve in the military. These policies and procedures are premised on my conclusion that open
service by transgender Service members while being subject to the same standards and
procedures as other members with regard to their medical fitness for duty, physical fitness,

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uniform and grooming, deployability, and retention, is consistent with military readiness and
with strength through diversity.”
57.

In September 2016, the Department of Defense issued an implementation

handbook entitled “Transgender Service in the United States Military.” The 71-page document
set forth guidance and instructions to both military servicemembers and commanders about how
to implement and understand the new policies enabling open service of transgender
servicemembers.
58.

On October 1, 2016, the Office of the Undersecretary of Defense for Personnel

and Readiness issued “DoD Instruction 1300.28—In-Service Transition for Transgender Service
Members.” The instruction set forth further guidance to ensure open service by transgender
servicemembers, including details regarding revisions to medical treatment provisions. This
instruction was further implemented by a memorandum issued by the Acting Assistant Secretary
of Defense for Health Affairs entitled “Guidance for Treatment of Gender Dysphoria for Active
and Reserve Component Service Members.”
59.

On November 29, 2016, the Department of Defense revised “DoD Directive

1020.02E—Diversity Management and Equal Opportunity in the DoD” to prohibit
discrimination and harassment on the basis of gender identity.
60.

In 2016, the United States Coast Guard adopted policies and procedures for

service by transgender servicemembers that are substantially the same as the Department of
Defense policies described above.

10

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The Ban on Transgender Servicemembers
61.

Early in the morning of July 26, 2017, without any prior indication that he would

address military transgender policy, President Trump announced in a series of tweets that the
military would no longer permit the service of transgender Americans.
62.

His tweets read: “After consultation with my generals and military experts, please

be advised that the United States government will not accept or allow transgender individuals to
serve in any capacity in the U.S. military. Our military must be focused on decisive and
overwhelming victory and cannot be burdened with the tremendous medical costs and disruption
that transgender in the military would entail.”
63.

Shortly following the announcement, the new policy met with substantial

criticism from members of Congress belonging to both political parties. These critics included
Senator John McCain, chairman of the Senate Armed Services Committee, who said in a
statement that “there is no reason to force servicemembers who are able to fight, train, and
deploy to leave the military—regardless of their gender identity.” Senator Joni Ernst, another
Republican member of the Senate Armed Services Committee, also publicly expressed
opposition to the new policy.
64.

Upon information and belief, the President did not consult either the Joint Chiefs

of Staff or the Department of Defense before making his announcement.
65.

Shortly after the announcement, fifty-six former generals and admirals issued a

public statement denouncing the new policy.
66.

Commandant Admiral Paul Zukunft of the United States Coast Guard criticized

the proposed policy and expressly reached out to all openly transgender members of the Coast
Guard, vowing not to “turn [his] back” on transgender servicemembers. Commandant Admiral

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Zukunft has arranged for Judge Advocate General’s Corps officers to assist transgender Coast
Guard members affected by the change in policy.
67.

Upon information and belief, the White House outlined a plan to end the active

service of transgender servicemembers to be transmitted to the Department of Defense for
implementation.
COUNT I
(Fifth Amendment – Equal Protection)
68.

All previous paragraphs are incorporated as though fully set forth herein.

69.

The Due Process Clause of the Fifth Amendment prohibits the federal

government from denying equal protection of the laws.
70.

President Trump’s directive to exclude transgender people from military service

discriminates against Plaintiffs based on their sex and transgender status, without lawful
justification, in violation of the Equal Protection component of the Due Process Clause of the
Fifth Amendment.
71.

The categorical exclusion of transgender people from military service lacks a

rational basis, is arbitrary, and cannot be justified by sufficient federal interests.
72.

Through the actions above, Defendants have violated the Equal Protection

component of the Due Process Clause of the Fifth Amendment.
COUNT II
(Fifth Amendment – Due Process)
73.

All previous paragraphs are incorporated as though fully set forth herein.

74.

The Due Process Clause of the Fifth Amendment prohibits the federal

government from depriving individuals of their property or liberty interests without due process
of law.

12

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75.

The Due Process Clause of the Fifth Amendment requires, at a minimum, that

government action have some rational basis.
76.

The President’s directive to exclude transgender people from military service is

arbitrary and capricious and lacks any rational basis.
77.

Defendants’ 2016 policy permitting transgender people to serve openly in the

military, together with Plaintiffs’ reliance on that policy in notifying their superiors of their
transgender status, created a protected interest in Plaintiffs’ ability to continue serving in the
military as openly transgender servicemembers.
78.

Defendants’ arbitrary reversal of the United States’ June 2016 policy threatens to

exclude Plaintiffs from continued military service because they are transgender, thus depriving
Plaintiffs of those interests without due process of law.
79.

Defendants’ arbitrary reversal of the United States’ June 2016 policy also

impermissibly burdens Plaintiffs’ fundamental rights to autonomy and privacy.
80.

Through the actions above, Defendants have violated the Due Process Clause of

the Fifth Amendment.
COUNT III
(Estoppel)
81.

All previous paragraphs are incorporated as though fully set forth herein.

82.

By virtue of its June 2016 policy allowing transgender servicemembers to serve

openly in the United States Armed Forces, Defendants promised Plaintiffs that they could serve
openly and continue to serve openly, subject to the same rights, responsibilities, benefits, and
opportunities as other servicemembers.

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83.

From the implementation of its June 2016 policy until the President’s June 26,

2017 announcement, Defendants provided Plaintiffs with ongoing support for their continued
service in the military as openly transgender persons.
84.

In reliance upon that promise from Defendants, Plaintiffs informed their

commanding officers that they are transgender.
85.

In reliance upon that promise from Defendants, Plaintiffs have undergone medical

treatment for the purpose of gender transition.
86.

Because they identified themselves as transgender in reliance on Defendants’

earlier promise, Plaintiffs have lost the stability and certainty they had in their careers and
benefits, including post-military and retirement benefits that depend on the length of their
service.
87.

Plaintiffs have served honorably and successfully in the military since coming out

as transgender, and their transgender status has not had any detrimental effect on their ability to
serve or to fulfill their duties.
88.

Through the actions above, Defendants are estopped from rescinding the rights,

benefits, and protections promised to Plaintiffs.
PRAYER FOR RELIEF
Plaintiffs ask the Court to grant the following relief:
1.

Issue a declaratory judgment that the President’s directive to categorically exclude

transgender people from military service is unconstitutional;
2.

Issue a preliminary injunction prohibiting the categorical exclusion of transgender

people from military service;
3.

Issue a permanent injunction prohibiting the categorical exclusion of transgender

people from military service;
14

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4.

Award Plaintiffs their reasonable costs and attorneys’ fees;

5.

Issue any other relief the Court deems appropriate.

August 9, 2017

Claire Laporte (pro hac vice forthcoming)
Matthew E. Miller (pro hac vice forthcoming)
Daniel McFadden (pro hac vice forthcoming)
Rachel C. Hutchinson (pro hac vice
forthcoming)
FOLEY HOAG LLP
155 Seaport Blvd.
Boston, Massachusetts 02210
Telephone: 617-832-1000
Fax: 617-832-7000
Jennifer Levi (pro hac vice forthcoming)
GLBTQ LEGAL ADVOCATES & DEFENDERS
30 Winter St., Ste. 800
Boston, Massachusetts 02108
Telephone: 617-426-1350
Fax: 617-426-3594
Shannon P. Minter (pro hac vice
forthcoming)
Amy Whelan (pro hac vice forthcoming)
NATIONAL CENTER FOR LESBIAN RIGHTS
870 Market St., Ste. 370
San Francisco, California 94102
Telephone: 415-392-6257
Fax: 415-392-8442

Respectfully submitted,
/s/ Paul R.Q. Wolfson
Paul R.Q. Wolfson (D.C. Bar No. 414759)
WILMER CUTLER PICKERING HALE & DORR
LLP
1875 Pennsylvania Ave. N.W.
Washington, D.C. 20006
Telephone: 202-663-6000
Fax: 202-663-6363
Alan E. Schoenfeld (pro hac vice
forthcoming)
WILMER CUTLER PICKERING
HALE & DORR LLP
7 World Trade Center
250 Greenwich St.
New York, New York 10007
Telephone: 212-230-8800
Fax: 212-230-8888
Adam M. Cambier (pro hac vice forthcoming)
WILMER CUTLER PICKERING
HALE & DORR LLP
60 State Street
Boston, Massachusetts 02109
Telephone: 617-526-6000
Fax: 617-526-5000
Attorneys for Plaintiffs

15

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CIVIL COVER SHEET
JS-44 (Rev. 6/17 DC)

I. (a) PLAINTIFFS

DEFENDANTS

JANE DOE 1, JANE DOE 2, JANE DOE 3, JANE DOE 4,
and JANE DOE 5

DONALD J. TRUMP, in his official capacity as President of
the United States, et al.
(see addendum for complete list of defendants)

88888

COUNTY OF RESIDENCE OF FIRST LISTED DEFENDANT _____________________
(IN U.S. PLAINTIFF CASES ONLY)

(b) COUNTY OF RESIDENCE OF FIRST LISTED PLAINTIFF _____________________
(EXCEPT IN U.S. PLAINTIFF CASES)
(c) ATTORNEYS (FIRM NAME, ADDRESS, AND TELEPHONE NUMBER)

Paul Wolfson, Alan Schoenfeld, Adam Cambier (WilmerHale);
Claire Laporte, Matthew Miller, Daniel McFadden, Rachel
Hutchinson (Foley Hoag); Jennifer Levi (GLAD); Shannon
Minter, Amy Whelan (NCLR)

WILMER CUTLER PICKERING HALE & DORR LLP
1875 Pennsylvania Ave. N.W.
Washington, D.C. 20006
Telephone: 202-663-6000
II. BASIS OF JURISDICTION

III. CITIZENSHIP OF PRINCIPAL PARTIES (PLACE AN x IN ONE BOX FOR

(PLACE AN x IN ONE BOX ONLY)

o
o

1 U.S. Government
Plaintiff

o

2 U.S. Government
Defendant

o

NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF THE TRACT OF LAND INVOLVED

ATTORNEYS (IF KNOWN)

3 Federal Question
(U.S. Government Not a Party)
4 Diversity
(Indicate Citizenship of
Parties in item III)

PLAINTIFF AND ONE BOX FOR DEFENDANT) FOR DIVERSITY CASES ONLY!
PTF
DFT

Citizen of this State
Citizen of Another State
Citizen or Subject of a
Foreign Country

o1 o1
o2 o2
o3 o3

Incorporated or Principal Place
of Business in This State
Incorporated and Principal Place
of Business in Another State
Foreign Nation

PTF

DFT

o4 o4
o5 o5
o6 o6

IV. CASE ASSIGNMENT AND NATURE OF SUIT
(Place an X in one category, A-N, that best represents your Cause of Action and one in a corresponding Nature of Suit)

o

A. Antitrust
410 Antitrust

o

o

o

B. Personal Injury/
Malpractice
310 Airplane
315 Airplane Product Liability
320 Assault, Libel & Slander
330 Federal Employers Liability
340 Marine
345 Marine Product Liability
350 Motor Vehicle
355 Motor Vehicle Product Liability
360 Other Personal Injury
362 Medical Malpractice
365 Product Liability
367 Health Care/Pharmaceutical
Personal Injury Product Liability
368 Asbestos Product Liability

E. General Civil (Other)

Real Property
210 Land Condemnation
220 Foreclosure
230 Rent, Lease & Ejectment
240 Torts to Land
245 Tort Product Liability
290 All Other Real Property
Personal Property
370 Other Fraud
371 Truth in Lending
380 Other Personal Property
Damage
385 Property Damage
Product Liability

C. Administrative Agency
Review
151 Medicare Act

Social Security
861 HIA (1395ff)
862 Black Lung (923)
863 DIWC/DIWW (405(g))
864 SSID Title XVI
865 RSI (405(g))
Other Statutes
891 Agricultural Acts
893 Environmental Matters
890 Other Statutory Actions (If
Administrative Agency is
Involved)

OR
Bankruptcy
422 Appeal 27 USC 158
423 Withdrawal 28 USC 157
Prisoner Petitions
535 Death Penalty
540 Mandamus & Other
550 Civil Rights
555 Prison Conditions
560 Civil Detainee – Conditions
of Confinement
Property Rights
820 Copyrights
830 Patent
835 Patent – Abbreviated New
Drug Application
840 Trademark

o

o

D. Temporary Restraining
Order/Preliminary
Injunction

Any nature of suit from any category
may be selected for this category of
case assignment.
*(If Antitrust, then A governs)*

F. Pro Se General Civil
Federal Tax Suits
870 Taxes (US plaintiff or
defendant)
871 IRS-Third Party 26 USC
7609
Forfeiture/Penalty
625 Drug Related Seizure of
Property 21 USC 881
690 Other
Other Statutes
375 False Claims Act
376 Qui Tam (31 USC
3729(a))
400 State Reapportionment
430 Banks & Banking
450 Commerce/ICC
Rates/etc.
460 Deportation

462 Naturalization
Application
465 Other Immigration
Actions
470 Racketeer Influenced
& Corrupt Organization
480 Consumer Credit
490 Cable/Satellite TV
850 Securities/Commodities/
Exchange
896 Arbitration
899 Administrative Procedure
Act/Review or Appeal of
Agency Decision
950 Constitutionality of State
Statutes
890 Other Statutory Actions
(if not administrative agency
review or Privacy Act)

 Case 1:17-cv-01597 Document 1-1 Filed 08/09/17 Page 2 of 3

o

G. Habeas Corpus/
2255

o

K. Labor/ERISA
(non-employment)
710 Fair Labor Standards Act
720 Labor/Mgmt. Relations
740 Labor Railway Act
751 Family and Medical
Leave Act
790 Other Labor Litigation
791 Empl. Ret. Inc. Security Act

*(If pro se, select this deck)*

*(If pro se, select this deck)*

o

o

L. Other Civil Rights
(non-employment)
441 Voting (if not Voting Rights
Act)
443 Housing/Accommodations
440 Other Civil Rights
445 Americans w/Disabilities –
Employment
446 Americans w/Disabilities –
Other
448 Education

o

I. FOIA/Privacy Act
895 Freedom of Information Act
890 Other Statutory Actions
(if Privacy Act)

442 Civil Rights – Employment
(criteria: race, gender/sex,
national origin,
discrimination, disability, age,
religion, retaliation)

530 Habeas Corpus – General
510 Motion/Vacate Sentence
463 Habeas Corpus – Alien
Detainee

o

o

H. Employment
Discrimination

152 Recovery of Defaulted
Student Loan
(excluding veterans)

o

M. Contract
110 Insurance
120 Marine
130 Miller Act
140 Negotiable Instrument
150 Recovery of Overpayment
& Enforcement of
Judgment
153 Recovery of Overpayment
of Veteran’s Benefits
160 Stockholder’s Suits
190 Other Contracts
195 Contract Product Liability
196 Franchise

J. Student Loan

N. Three-Judge
Court
441 Civil Rights – Voting
(if Voting Rights Act)

V. ORIGIN

o 1 Original o 2 Removed o 3 Remanded
Proceeding

from State
Court

from Appellate
Court

o 4 Reinstated o 5 Transferred o 6 Multi-district o 7 Appeal to
or Reopened

from another
district (specify)

Litigation

District Judge
from Mag.
Judge

o 8 Multi-district
Litigation –
Direct File

VI. CAUSE OF ACTION (CITE THE U.S. CIVIL STATUTE UNDER WHICH YOU ARE FILING AND WRITE A BRIEF STATEMENT OF CAUSE.)

42 U.S.C. s 1983. Suit alleging estoppel and violations of the Due Process Clause and the Equal Protection component of
VII. REQUESTED IN
COMPLAINT

CHECK IF THIS IS A CLASS
ACTION UNDER F.R.C.P. 23

DEMAND $
JURY DEMAND:

Check YES only if demanded in complaint

VIII. RELATED CASE(S)
IF ANY

(See instruction)

YES

If yes, please complete related case form

August 09, 2017
DATE: _________________________

NO

YES

NO

s/ Paul R.Q. Wolfson
SIGNATURE OF ATTORNEY OF RECORD _________________________________________________________
INSTRUCTIONS FOR COMPLETING CIVIL COVER SHEET JS-44
Authority for Civil Cover Sheet

The JS-44 civil cover sheet and the information contained herein neither replaces nor supplements the filings and services of pleadings or other papers as required
by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the
Clerk of Court for the purpose of initiating the civil docket sheet. Consequently, a civil cover sheet is submitted to the Clerk of Court for each civil complaint filed.
Listed below are tips for completing the civil cover sheet. These tips coincide with the Roman Numerals on the cover sheet.
I.

COUNTY OF RESIDENCE OF FIRST LISTED PLAINTIFF/DEFENDANT (b) County of residence: Use 11001 to indicate plaintiff if resident
of Washington, DC, 88888 if plaintiff is resident of United States but not Washington, DC, and 99999 if plaintiff is outside the United States.

III.

CITIZENSHIP OF PRINCIPAL PARTIES: This section is completed only if diversity of citizenship was selected as the Basis of Jurisdiction
under Section II.

IV.

CASE ASSIGNMENT AND NATURE OF SUIT: The assignment of a judge to your case will depend on the category you select that best
represents the primary cause of action found in your complaint. You may select only one category. You must also select one corresponding
nature of suit found under the category of the case.

VI.

CAUSE OF ACTION: Cite the U.S. Civil Statute under which you are filing and write a brief statement of the primary cause.

VIII.

RELATED CASE(S), IF ANY: If you indicated that there is a related case, you must complete a related case form, which may be obtained from
the Clerk’s Office.

Because of the need for accurate and complete information, you should ensure the accuracy of the information provided prior to signing the form.

 Case 1:17-cv-01597 Document 1-1 Filed 08/09/17 Page 3 of 3

ADDENDUM – LIST OF DEFENDANTS
x

DONALD J. TRUMP, in his official capacity as President of the United States;

x

JAMES N. MATTIS, in his official capacity as Secretary of Defense;

x

JOSEPH F. DUNFORD, JR., in his official capacity as Chairman of the Joint Chiefs of
Staff;

x

the UNITED STATES DEPARTMENT OF THE ARMY;

x

RYAN D. MCCARTHY, in his official capacity as Secretary of the Army;

x

the UNITED STATES DEPARTMENT OF THE AIR FORCE;

x

HEATHER A. WILSON, in her official capacity as Secretary of the Air Force;

x

the UNITED STATES COAST GUARD;

x

ELAINE C. DUKE, in her official capacity as Secretary of Homeland Security; and

x

the UNITED STATES OF AMERICA.

 Case 1:17-cv-01597 Document 1-2 Filed 08/09/17 Page 1 of 3
AO 440 (Rev. 06/12) Summons in a Civil Action

UNITED STATES DISTRICT COURT
for the

District
of Columbia
__________
District
of __________
JANE DOE 1, JANE DOE 2, JANE DOE 3, JANE
DOE 4, and JANE DOE 5

Plaintiff(s)

v.
DONALD J. TRUMP, in his official capacity as
President of the United States, et al.
(see addendum for additional defendants)
Defendant(s)

)
)
)
)
)
)
)
)
)
)
)
)

Civil Action No.

SUMMONS IN A CIVIL ACTION
To: (Defendant’s name and address) DONALD J. TRUMP
The White House
1600 Pennsylvania Ave. NW, 1st Floor, West Wing
Washington, D.C. 20500
Telephone: 202-456-1414

A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are: Paul R.Q. Wolfson, D.C. Bar No. 414759
Wilmer Cutler Pickering Hale & Dorr LLP
1875 Pennsylvania Ave. N.W.
Washington, D.C. 20006
Telephone: 202-663-6000
Fax: 202-663-6363

If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.

CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk

 Case 1:17-cv-01597 Document 1-2 Filed 08/09/17 Page 2 of 3
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)

Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for (name of individual and title, if any)
was received by me on (date)

.

u I personally served the summons on the individual at (place)
on (date)

; or

u I left the summons at the individual’s residence or usual place of abode with (name)
, a person of suitable age and discretion who resides there,
on (date)

, and mailed a copy to the individual’s last known address; or
, who is

u I served the summons on (name of individual)
designated by law to accept service of process on behalf of (name of organization)
on (date)

; or

u I returned the summons unexecuted because

; or

u Other (specify):
.
My fees are $

for travel and $

for services, for a total of $

I declare under penalty of perjury that this information is true.

Date:
Server’s signature

Printed name and title

Server’s address

Additional information regarding attempted service, etc:

0.00

.

 Case 1:17-cv-01597 Document 1-2 Filed 08/09/17 Page 3 of 3

ADDENDUM – LIST OF DEFENDANTS
x

DONALD J. TRUMP, in his official capacity as President of the United States;

x

JAMES N. MATTIS, in his official capacity as Secretary of Defense;

x

JOSEPH F. DUNFORD, JR., in his official capacity as Chairman of the Joint Chiefs of
Staff;

x

the UNITED STATES DEPARTMENT OF THE ARMY;

x

RYAN D. MCCARTHY, in his official capacity as Secretary of the Army;

x

the UNITED STATES DEPARTMENT OF THE AIR FORCE;

x

HEATHER A. WILSON, in her official capacity as Secretary of the Air Force;

x

the UNITED STATES COAST GUARD;

x

ELAINE C. DUKE, in her official capacity as Secretary of Homeland Security; and

x

the UNITED STATES OF AMERICA.

 Case 1:17-cv-01597 Document 1-3 Filed 08/09/17 Page 1 of 3
AO 440 (Rev. 06/12) Summons in a Civil Action

UNITED STATES DISTRICT COURT
for the

District
of Columbia
__________
District
of __________
JANE DOE 1, JANE DOE 2, JANE DOE 3, JANE
DOE 4, and JANE DOE 5

Plaintiff(s)

v.
DONALD J. TRUMP, in his official capacity as
President of the United States, et al.
(see addendum for additional defendants)
Defendant(s)

)
)
)
)
)
)
)
)
)
)
)
)

Civil Action No.

SUMMONS IN A CIVIL ACTION
To: (Defendant’s name and address) JAMES N. MATTIS
1000 Defense Pentagon, Room 3E880
Washington, D.C. 20301
Telephone: 703-692-7100

A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are: Paul R.Q. Wolfson, D.C. Bar No. 414759
Wilmer Cutler Pickering Hale & Dorr LLP
1875 Pennsylvania Ave. N.W.
Washington, D.C. 20006
Telephone: 202-663-6000
Fax: 202-663-6363

If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.

CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk

 Case 1:17-cv-01597 Document 1-3 Filed 08/09/17 Page 2 of 3
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)

Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for (name of individual and title, if any)
was received by me on (date)

.

u I personally served the summons on the individual at (place)
on (date)

; or

u I left the summons at the individual’s residence or usual place of abode with (name)
, a person of suitable age and discretion who resides there,
on (date)

, and mailed a copy to the individual’s last known address; or
, who is

u I served the summons on (name of individual)
designated by law to accept service of process on behalf of (name of organization)
on (date)

; or

u I returned the summons unexecuted because

; or

u Other (specify):
.
My fees are $

for travel and $

for services, for a total of $

I declare under penalty of perjury that this information is true.

Date:
Server’s signature

Printed name and title

Server’s address

Additional information regarding attempted service, etc:

0.00

.

 Case 1:17-cv-01597 Document 1-3 Filed 08/09/17 Page 3 of 3

ADDENDUM – LIST OF DEFENDANTS
x

DONALD J. TRUMP, in his official capacity as President of the United States;

x

JAMES N. MATTIS, in his official capacity as Secretary of Defense;

x

JOSEPH F. DUNFORD, JR., in his official capacity as Chairman of the Joint Chiefs of
Staff;

x

the UNITED STATES DEPARTMENT OF THE ARMY;

x

RYAN D. MCCARTHY, in his official capacity as Secretary of the Army;

x

the UNITED STATES DEPARTMENT OF THE AIR FORCE;

x

HEATHER A. WILSON, in her official capacity as Secretary of the Air Force;

x

the UNITED STATES COAST GUARD;

x

ELAINE C. DUKE, in her official capacity as Secretary of Homeland Security; and

x

the UNITED STATES OF AMERICA.

 Case 1:17-cv-01597 Document 1-4 Filed 08/09/17 Page 1 of 3
AO 440 (Rev. 06/12) Summons in a Civil Action

UNITED STATES DISTRICT COURT
for the

District
of Columbia
__________
District
of __________
JANE DOE 1, JANE DOE 2, JANE DOE 3, JANE
DOE 4, and JANE DOE 5

Plaintiff(s)

v.
DONALD J. TRUMP, in his official capacity as
President of the United States, et al.
(see addendum for additional defendants)
Defendant(s)

)
)
)
)
)
)
)
)
)
)
)
)

Civil Action No.

SUMMONS IN A CIVIL ACTION
To: (Defendant’s name and address) JOSEPH F. DUNFORD, JR.
9999 Joint Chiefs of Staff Pentagon
Washington, D.C. 20318
Telephone: 703-697-9121

A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are: Paul R.Q. Wolfson, D.C. Bar No. 414759
Wilmer Cutler Pickering Hale & Dorr LLP
1875 Pennsylvania Ave. N.W.
Washington, D.C. 20006
Telephone: 202-663-6000
Fax: 202-663-6363

If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.

CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk

 Case 1:17-cv-01597 Document 1-4 Filed 08/09/17 Page 2 of 3
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)

Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for (name of individual and title, if any)
was received by me on (date)

.

u I personally served the summons on the individual at (place)
on (date)

; or

u I left the summons at the individual’s residence or usual place of abode with (name)
, a person of suitable age and discretion who resides there,
on (date)

, and mailed a copy to the individual’s last known address; or
, who is

u I served the summons on (name of individual)
designated by law to accept service of process on behalf of (name of organization)
on (date)

; or

u I returned the summons unexecuted because

; or

u Other (specify):
.
My fees are $

for travel and $

for services, for a total of $

I declare under penalty of perjury that this information is true.

Date:
Server’s signature

Printed name and title

Server’s address

Additional information regarding attempted service, etc:

0.00

.

 Case 1:17-cv-01597 Document 1-4 Filed 08/09/17 Page 3 of 3

ADDENDUM – LIST OF DEFENDANTS
x

DONALD J. TRUMP, in his official capacity as President of the United States;

x

JAMES N. MATTIS, in his official capacity as Secretary of Defense;

x

JOSEPH F. DUNFORD, JR., in his official capacity as Chairman of the Joint Chiefs of
Staff;

x

the UNITED STATES DEPARTMENT OF THE ARMY;

x

RYAN D. MCCARTHY, in his official capacity as Secretary of the Army;

x

the UNITED STATES DEPARTMENT OF THE AIR FORCE;

x

HEATHER A. WILSON, in her official capacity as Secretary of the Air Force;

x

the UNITED STATES COAST GUARD;

x

ELAINE C. DUKE, in her official capacity as Secretary of Homeland Security; and

x

the UNITED STATES OF AMERICA.

 Case 1:17-cv-01597 Document 1-5 Filed 08/09/17 Page 1 of 3
AO 440 (Rev. 06/12) Summons in a Civil Action

UNITED STATES DISTRICT COURT
for the

District
of Columbia
__________
District
of __________
JANE DOE 1, JANE DOE 2, JANE DOE 3, JANE
DOE 4, and JANE DOE 5

Plaintiff(s)

v.
DONALD J. TRUMP, in his official capacity as
President of the United States, et al.
(see addendum for additional defendants)
Defendant(s)

)
)
)
)
)
)
)
)
)
)
)
)

Civil Action No.

SUMMONS IN A CIVIL ACTION
To: (Defendant’s name and address) UNITED STATES DEPARTMENT OF THE ARMY
Office of the Secretary of the Army
101 Army Pentagon
Washington, D.C. 20310

A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are: Paul R.Q. Wolfson, D.C. Bar No. 414759
Wilmer Cutler Pickering Hale & Dorr LLP
1875 Pennsylvania Ave. N.W.
Washington, D.C. 20006
Telephone: 202-663-6000
Fax: 202-663-6363

If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.

CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk

 Case 1:17-cv-01597 Document 1-5 Filed 08/09/17 Page 2 of 3
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)

Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for (name of individual and title, if any)
was received by me on (date)

.

u I personally served the summons on the individual at (place)
on (date)

; or

u I left the summons at the individual’s residence or usual place of abode with (name)
, a person of suitable age and discretion who resides there,
on (date)

, and mailed a copy to the individual’s last known address; or
, who is

u I served the summons on (name of individual)
designated by law to accept service of process on behalf of (name of organization)
on (date)

; or

u I returned the summons unexecuted because

; or

u Other (specify):
.
My fees are $

for travel and $

for services, for a total of $

I declare under penalty of perjury that this information is true.

Date:
Server’s signature

Printed name and title

Server’s address

Additional information regarding attempted service, etc:

0.00

.

 Case 1:17-cv-01597 Document 1-5 Filed 08/09/17 Page 3 of 3

ADDENDUM – LIST OF DEFENDANTS
x

DONALD J. TRUMP, in his official capacity as President of the United States;

x

JAMES N. MATTIS, in his official capacity as Secretary of Defense;

x

JOSEPH F. DUNFORD, JR., in his official capacity as Chairman of the Joint Chiefs of
Staff;

x

the UNITED STATES DEPARTMENT OF THE ARMY;

x

RYAN D. MCCARTHY, in his official capacity as Secretary of the Army;

x

the UNITED STATES DEPARTMENT OF THE AIR FORCE;

x

HEATHER A. WILSON, in her official capacity as Secretary of the Air Force;

x

the UNITED STATES COAST GUARD;

x

ELAINE C. DUKE, in her official capacity as Secretary of Homeland Security; and

x

the UNITED STATES OF AMERICA.

 Case 1:17-cv-01597 Document 1-6 Filed 08/09/17 Page 1 of 3
AO 440 (Rev. 06/12) Summons in a Civil Action

UNITED STATES DISTRICT COURT
for the

District
of Columbia
__________
District
of __________
JANE DOE 1, JANE DOE 2, JANE DOE 3, JANE
DOE 4, and JANE DOE 5

Plaintiff(s)

v.
DONALD J. TRUMP, in his official capacity as
President of the United States, et al.
(see addendum for additional defendants)
Defendant(s)

)
)
)
)
)
)
)
)
)
)
)
)

Civil Action No.

SUMMONS IN A CIVIL ACTION
To: (Defendant’s name and address) RYAN D. MCCARTHY
102 Army Pentagon, Room 3E700
Washington, D.C. 20310
Telephone: 703-695-4311

A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are: Paul R.Q. Wolfson, D.C. Bar No. 414759
Wilmer Cutler Pickering Hale & Dorr LLP
1875 Pennsylvania Ave. N.W.
Washington, D.C. 20006
Telephone: 202-663-6000
Fax: 202-663-6363

If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.

CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk

 Case 1:17-cv-01597 Document 1-6 Filed 08/09/17 Page 2 of 3
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)

Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for (name of individual and title, if any)
was received by me on (date)

.

u I personally served the summons on the individual at (place)
on (date)

; or

u I left the summons at the individual’s residence or usual place of abode with (name)
, a person of suitable age and discretion who resides there,
on (date)

, and mailed a copy to the individual’s last known address; or
, who is

u I served the summons on (name of individual)
designated by law to accept service of process on behalf of (name of organization)
on (date)

; or

u I returned the summons unexecuted because

; or

u Other (specify):
.
My fees are $

for travel and $

for services, for a total of $

I declare under penalty of perjury that this information is true.

Date:
Server’s signature

Printed name and title

Server’s address

Additional information regarding attempted service, etc:

0.00

.

 Case 1:17-cv-01597 Document 1-6 Filed 08/09/17 Page 3 of 3

ADDENDUM – LIST OF DEFENDANTS
x

DONALD J. TRUMP, in his official capacity as President of the United States;

x

JAMES N. MATTIS, in his official capacity as Secretary of Defense;

x

JOSEPH F. DUNFORD, JR., in his official capacity as Chairman of the Joint Chiefs of
Staff;

x

the UNITED STATES DEPARTMENT OF THE ARMY;

x

RYAN D. MCCARTHY, in his official capacity as Secretary of the Army;

x

the UNITED STATES DEPARTMENT OF THE AIR FORCE;

x

HEATHER A. WILSON, in her official capacity as Secretary of the Air Force;

x

the UNITED STATES COAST GUARD;

x

ELAINE C. DUKE, in her official capacity as Secretary of Homeland Security; and

x

the UNITED STATES OF AMERICA.

 Case 1:17-cv-01597 Document 1-7 Filed 08/09/17 Page 1 of 3
AO 440 (Rev. 06/12) Summons in a Civil Action

UNITED STATES DISTRICT COURT
for the

District
of Columbia
__________
District
of __________
JANE DOE 1, JANE DOE 2, JANE DOE 3, JANE
DOE 4, and JANE DOE 5

Plaintiff(s)

v.
DONALD J. TRUMP, in his official capacity as
President of the United States, et al.
(see addendum for additional defendants)
Defendant(s)

)
)
)
)
)
)
)
)
)
)
)
)

Civil Action No.

SUMMONS IN A CIVIL ACTION
To: (Defendant’s name and address) UNITED STATES DEPARTMENT OF THE AIR FORCE
1670 Air Force Pentagon
Washington, D.C. 20330
Telephone: 703-697-6061

A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are: Paul R.Q. Wolfson, D.C. Bar No. 414759
Wilmer Cutler Pickering Hale & Dorr LLP
1875 Pennsylvania Ave. N.W.
Washington, D.C. 20006
Telephone: 202-663-6000
Fax: 202-663-6363

If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.

CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk

 Case 1:17-cv-01597 Document 1-7 Filed 08/09/17 Page 2 of 3
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)

Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for (name of individual and title, if any)
was received by me on (date)

.

u I personally served the summons on the individual at (place)
on (date)

; or

u I left the summons at the individual’s residence or usual place of abode with (name)
, a person of suitable age and discretion who resides there,
on (date)

, and mailed a copy to the individual’s last known address; or
, who is

u I served the summons on (name of individual)
designated by law to accept service of process on behalf of (name of organization)
on (date)

; or

u I returned the summons unexecuted because

; or

u Other (specify):
.
My fees are $

for travel and $

for services, for a total of $

I declare under penalty of perjury that this information is true.

Date:
Server’s signature

Printed name and title

Server’s address

Additional information regarding attempted service, etc:

0.00

.

 Case 1:17-cv-01597 Document 1-7 Filed 08/09/17 Page 3 of 3

ADDENDUM – LIST OF DEFENDANTS
x

DONALD J. TRUMP, in his official capacity as President of the United States;

x

JAMES N. MATTIS, in his official capacity as Secretary of Defense;

x

JOSEPH F. DUNFORD, JR., in his official capacity as Chairman of the Joint Chiefs of
Staff;

x

the UNITED STATES DEPARTMENT OF THE ARMY;

x

RYAN D. MCCARTHY, in his official capacity as Secretary of the Army;

x

the UNITED STATES DEPARTMENT OF THE AIR FORCE;

x

HEATHER A. WILSON, in her official capacity as Secretary of the Air Force;

x

the UNITED STATES COAST GUARD;

x

ELAINE C. DUKE, in her official capacity as Secretary of Homeland Security; and

x

the UNITED STATES OF AMERICA.

 Case 1:17-cv-01597 Document 1-8 Filed 08/09/17 Page 1 of 3
AO 440 (Rev. 06/12) Summons in a Civil Action

UNITED STATES DISTRICT COURT
for the

District
of Columbia
__________
District
of __________
JANE DOE 1, JANE DOE 2, JANE DOE 3, JANE
DOE 4, and JANE DOE 5

Plaintiff(s)

v.
DONALD J. TRUMP, in his official capacity as
President of the United States, et al.
(see addendum for additional defendants)
Defendant(s)

)
)
)
)
)
)
)
)
)
)
)
)

Civil Action No.

SUMMONS IN A CIVIL ACTION
To: (Defendant’s name and address) HEATHER A. WILSON
1670 Air Force Pentagon
Washington, D.C. 20330
Telephone: 703-697-7376

A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are: Paul R.Q. Wolfson, D.C. Bar No. 414759
Wilmer Cutler Pickering Hale & Dorr LLP
1875 Pennsylvania Ave. N.W.
Washington, D.C. 20006
Telephone: 202-663-6000
Fax: 202-663-6363

If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.

CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk

 Case 1:17-cv-01597 Document 1-8 Filed 08/09/17 Page 2 of 3
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)

Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for (name of individual and title, if any)
was received by me on (date)

.

u I personally served the summons on the individual at (place)
on (date)

; or

u I left the summons at the individual’s residence or usual place of abode with (name)
, a person of suitable age and discretion who resides there,
on (date)

, and mailed a copy to the individual’s last known address; or
, who is

u I served the summons on (name of individual)
designated by law to accept service of process on behalf of (name of organization)
on (date)

; or

u I returned the summons unexecuted because

; or

u Other (specify):
.
My fees are $

for travel and $

for services, for a total of $

I declare under penalty of perjury that this information is true.

Date:
Server’s signature

Printed name and title

Server’s address

Additional information regarding attempted service, etc:

0.00

.

 Case 1:17-cv-01597 Document 1-8 Filed 08/09/17 Page 3 of 3

ADDENDUM – LIST OF DEFENDANTS
x

DONALD J. TRUMP, in his official capacity as President of the United States;

x

JAMES N. MATTIS, in his official capacity as Secretary of Defense;

x

JOSEPH F. DUNFORD, JR., in his official capacity as Chairman of the Joint Chiefs of
Staff;

x

the UNITED STATES DEPARTMENT OF THE ARMY;

x

RYAN D. MCCARTHY, in his official capacity as Secretary of the Army;

x

the UNITED STATES DEPARTMENT OF THE AIR FORCE;

x

HEATHER A. WILSON, in her official capacity as Secretary of the Air Force;

x

the UNITED STATES COAST GUARD;

x

ELAINE C. DUKE, in her official capacity as Secretary of Homeland Security; and

x

the UNITED STATES OF AMERICA.

 Case 1:17-cv-01597 Document 1-9 Filed 08/09/17 Page 1 of 3
AO 440 (Rev. 06/12) Summons in a Civil Action

UNITED STATES DISTRICT COURT
for the

District
of Columbia
__________
District
of __________
JANE DOE 1, JANE DOE 2, JANE DOE 3, JANE
DOE 4, and JANE DOE 5

Plaintiff(s)

v.
DONALD J. TRUMP, in his official capacity as
President of the United States, et al.
(see addendum for additional defendants)
Defendant(s)

)
)
)
)
)
)
)
)
)
)
)
)

Civil Action No.

SUMMONS IN A CIVIL ACTION
To: (Defendant’s name and address) UNITED STATES COAST GUARD
2703 Martin Luthre King Jr. Ave. SE
Washington, D.C. 20593

A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are: Paul R.Q. Wolfson, D.C. Bar No. 414759
Wilmer Cutler Pickering Hale & Dorr LLP
1875 Pennsylvania Ave. N.W.
Washington, D.C. 20006
Telephone: 202-663-6000
Fax: 202-663-6363

If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.

CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk

 Case 1:17-cv-01597 Document 1-9 Filed 08/09/17 Page 2 of 3
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)

Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for (name of individual and title, if any)
was received by me on (date)

.

u I personally served the summons on the individual at (place)
on (date)

; or

u I left the summons at the individual’s residence or usual place of abode with (name)
, a person of suitable age and discretion who resides there,
on (date)

, and mailed a copy to the individual’s last known address; or
, who is

u I served the summons on (name of individual)
designated by law to accept service of process on behalf of (name of organization)
on (date)

; or

u I returned the summons unexecuted because

; or

u Other (specify):
.
My fees are $

for travel and $

for services, for a total of $

I declare under penalty of perjury that this information is true.

Date:
Server’s signature

Printed name and title

Server’s address

Additional information regarding attempted service, etc:

0.00

.

 Case 1:17-cv-01597 Document 1-9 Filed 08/09/17 Page 3 of 3

ADDENDUM – LIST OF DEFENDANTS
x

DONALD J. TRUMP, in his official capacity as President of the United States;

x

JAMES N. MATTIS, in his official capacity as Secretary of Defense;

x

JOSEPH F. DUNFORD, JR., in his official capacity as Chairman of the Joint Chiefs of
Staff;

x

the UNITED STATES DEPARTMENT OF THE ARMY;

x

RYAN D. MCCARTHY, in his official capacity as Secretary of the Army;

x

the UNITED STATES DEPARTMENT OF THE AIR FORCE;

x

HEATHER A. WILSON, in her official capacity as Secretary of the Air Force;

x

the UNITED STATES COAST GUARD;

x

ELAINE C. DUKE, in her official capacity as Secretary of Homeland Security; and

x

the UNITED STATES OF AMERICA.

 Case 1:17-cv-01597 Document 1-10 Filed 08/09/17 Page 1 of 3
AO 440 (Rev. 06/12) Summons in a Civil Action

UNITED STATES DISTRICT COURT
for the

District
of Columbia
__________
District
of __________
JANE DOE 1, JANE DOE 2, JANE DOE 3, JANE
DOE 4, and JANE DOE 5

Plaintiff(s)

v.
DONALD J. TRUMP, in his official capacity as
President of the United States, et al.
(see addendum for additional defendants)
Defendant(s)

)
)
)
)
)
)
)
)
)
)
)
)

Civil Action No.

SUMMONS IN A CIVIL ACTION
To: (Defendant’s name and address) ELAINE C. DUKE
Department of Homeland Security
245 Murray Lane SW, Building 410
Washington, D.C. 20528
Telephone: 202-282-8000

A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are: Paul R.Q. Wolfson, D.C. Bar No. 414759
Wilmer Cutler Pickering Hale & Dorr LLP
1875 Pennsylvania Ave. N.W.
Washington, D.C. 20006
Telephone: 202-663-6000
Fax: 202-663-6363

If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.

CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk

 Case 1:17-cv-01597 Document 1-10 Filed 08/09/17 Page 2 of 3
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)

Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for (name of individual and title, if any)
was received by me on (date)

.

u I personally served the summons on the individual at (place)
on (date)

; or

u I left the summons at the individual’s residence or usual place of abode with (name)
, a person of suitable age and discretion who resides there,
on (date)

, and mailed a copy to the individual’s last known address; or
, who is

u I served the summons on (name of individual)
designated by law to accept service of process on behalf of (name of organization)
on (date)

; or

u I returned the summons unexecuted because

; or

u Other (specify):
.
My fees are $

for travel and $

for services, for a total of $

I declare under penalty of perjury that this information is true.

Date:
Server’s signature

Printed name and title

Server’s address

Additional information regarding attempted service, etc:

0.00

.

 Case 1:17-cv-01597 Document 1-10 Filed 08/09/17 Page 3 of 3

ADDENDUM – LIST OF DEFENDANTS
x

DONALD J. TRUMP, in his official capacity as President of the United States;

x

JAMES N. MATTIS, in his official capacity as Secretary of Defense;

x

JOSEPH F. DUNFORD, JR., in his official capacity as Chairman of the Joint Chiefs of
Staff;

x

the UNITED STATES DEPARTMENT OF THE ARMY;

x

RYAN D. MCCARTHY, in his official capacity as Secretary of the Army;

x

the UNITED STATES DEPARTMENT OF THE AIR FORCE;

x

HEATHER A. WILSON, in her official capacity as Secretary of the Air Force;

x

the UNITED STATES COAST GUARD;

x

ELAINE C. DUKE, in her official capacity as Secretary of Homeland Security; and

x

the UNITED STATES OF AMERICA.

 Case 1:17-cv-01597 Document 1-11 Filed 08/09/17 Page 1 of 3
AO 440 (Rev. 06/12) Summons in a Civil Action

UNITED STATES DISTRICT COURT
for the

District
of Columbia
__________
District
of __________
JANE DOE 1, JANE DOE 2, JANE DOE 3, JANE
DOE 4, and JANE DOE 5

Plaintiff(s)

v.
DONALD J. TRUMP, in his official capacity as
President of the United States, et al.
(see addendum for additional defendants)
Defendant(s)

)
)
)
)
)
)
)
)
)
)
)
)

Civil Action No.

SUMMONS IN A CIVIL ACTION
To: (Defendant’s name and address) UNITED STATES OF AMERICA
Via Department of Justice
950 Pennsylvania Ave. NW
Washington, D.C. 20530

A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are: Paul R.Q. Wolfson, D.C. Bar No. 414759
Wilmer Cutler Pickering Hale & Dorr LLP
1875 Pennsylvania Ave. N.W.
Washington, D.C. 20006
Telephone: 202-663-6000
Fax: 202-663-6363

If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.

CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk

 Case 1:17-cv-01597 Document 1-11 Filed 08/09/17 Page 2 of 3
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)

Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for (name of individual and title, if any)
was received by me on (date)

.

u I personally served the summons on the individual at (place)
on (date)

; or

u I left the summons at the individual’s residence or usual place of abode with (name)
, a person of suitable age and discretion who resides there,
on (date)

, and mailed a copy to the individual’s last known address; or
, who is

u I served the summons on (name of individual)
designated by law to accept service of process on behalf of (name of organization)
on (date)

; or

u I returned the summons unexecuted because

; or

u Other (specify):
.
My fees are $

for travel and $

for services, for a total of $

I declare under penalty of perjury that this information is true.

Date:
Server’s signature

Printed name and title

Server’s address

Additional information regarding attempted service, etc:

0.00

.

 Case 1:17-cv-01597 Document 1-11 Filed 08/09/17 Page 3 of 3

ADDENDUM – LIST OF DEFENDANTS
x

DONALD J. TRUMP, in his official capacity as President of the United States;

x

JAMES N. MATTIS, in his official capacity as Secretary of Defense;

x

JOSEPH F. DUNFORD, JR., in his official capacity as Chairman of the Joint Chiefs of
Staff;

x

the UNITED STATES DEPARTMENT OF THE ARMY;

x

RYAN D. MCCARTHY, in his official capacity as Secretary of the Army;

x

the UNITED STATES DEPARTMENT OF THE AIR FORCE;

x

HEATHER A. WILSON, in her official capacity as Secretary of the Air Force;

x

the UNITED STATES COAST GUARD;

x

ELAINE C. DUKE, in her official capacity as Secretary of Homeland Security; and

x

the UNITED STATES OF AMERICA.