Honorable Jean P. Rosenbluth United States Magistrate Judge Complaint Filed: April 16, 2020 1 Pursuant to Federal Rule of Civil Procedure 25(d), Defendants Mayorkas and Johnson are automatically substituted for their predecessors

Discovery in this action is likely to involve production of confidential, proprietary, and/or private information for which special protection from public disclosure and from use for any purpose other than prosecuting this litigation may be warranted.

2.14 Professional Vendors: persons or entities that provide litigation support services (e.g., photocopying, videotaping, translating, preparing exhibits or demonstrations, and organizing, storing, or retrieving data in any form or medium) and their employees and subcontractors.

With the exception of the attorneys who entered appearances in this litigation, each individual identified under section 7.3(a) must execute the “Acknowledgment and Agreement to be Bound” (Exhibit A) prior to obtaining access to any information designated as “CONFIDENTIAL-ATTORNEYS’ EYES ONLY”]]; (b) Experts (as defined in this Order) of the Receiving Party to whom disclosure is reasonably necessary for this Action and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); (c) the court and its personnel; (d) court reporters and their staff; (e) interpreters; (f) professional jury or trial consultants, mock jurors, and Professional Vendors to whom disclosure is reasonably necessary for this Action.

In accordance with this Court’s October 5, 2020 Order (see ECF No. 37), the identities of the ICE employees sued in their individual capacity shall be disclosed only to Plaintiffs’ Outside Counsel of Record, including support staff to whom disclosure is reasonably necessary for this Action.

A. RULE 12(b)(1) ARGUMENTS – SUBJECT-MATTER JURISDICTION Defendants offer three reasons for finding that the Court lacks subject-matter jurisdiction, none of which are convincing.

) The Court need not take judicial notice of these documents but may consider them nonetheless, as they are incorporated by reference in the FAC.