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Docket Number: 8:25-cv-00951
Citation:Abrego Garcia v. Noem, 8:25-cv-00951, (D. Maryland Apr 14, 2025) ECF No. 66
Date Filed: April 14th, 2025
Uploaded: July 14th, 2025, 11:41 a.m. EDT
NOTICE OF FILING OF OFFICIAL TRANSCRIPT of Proceedings - Status Conference - held on 4/11/2025, before Judge Paula Xinis. Court Reporter/Transcriber Paula Leeper, Telephone number (301)344-3229. Total number of pages filed: 28. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained from the Court Reporter or through PACER. Redaction Request due 5/5/2025. Redacted Transcript Deadline set for 5/15/2025. Release of Transcript Restriction set for 7/14/2025.(pl, Court Reporter) (Entered: 04/14/2025)
1 Case 8:25-cv-00951-PX Document 66 Filed 04/14/25 Page 1 of 28 1 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND 2 GREENBELT DIVISION 3 ____________________________________ ) 4 KILMAR ARMANDO ABREGO GARCIA, ) et al., ) 5 ) Plaintiff, ) 6 )Docket Number vs. )8:25-cv-00951-PX 7 ) KRISTI NOEM, et al, ) 8 ) Defendant. ) 9 ____________________________________)10 TRANSCRIPT OF STATUS CONFERENCE BEFORE THE HONORABLE PAULA XINIS11 UNITED STATES DISTRICT COURT JUDGE FRIDAY, APRIL 11, 2025, AT 1:00 P.M.12 APPEARANCES:13 On Behalf of the Plaintiff: BY: SIMON SANDOVAL-MOSHENBERG, ESQUIRE14 MURRAY OSORIO 4103 Chain Bridge Road, Suite 30015 Fairfax, VA 22030 (703)352-239916 BY: JONATHAN COOPER, ESQUIRE17 OLIVIA HORTON, ESQUIRE QUINN, EMANUEL, URQUHART & SULLIVAN, LLP18 1300 I Street NW Suite 90019 Washington, DC 20005 (202)538-800020 (Appearances continued)2122 ***COMPUTER-AIDED TRANSCRIPTION OF STENOTYPED NOTES***232425 Paula J. Leeper, Federal Official Reporter - USDC 6500 Cherrywood Lane, Suite 200 Greenbelt, Maryland 20770 2 Case 8:25-cv-00951-PX Document 66 Filed 04/14/25 Page 2 of 28 1 On Behalf of the Defendants: 2 BY: DREW ENSIGN, ESQUIRE DEPUTY ASSISTANT ATTORNEY GENERAL 3 CIVIL DIVISION, DEPARTMENT OF JUSTICE 950 Pennsylvania Avenue NW 4 Washington, DC 20530 (202)514-2000 5 ALSO PRESENT: Jennifer Vasquez Sura, Plaintiff 6 Michelle Latour, Esquire, DOJ Ernest Molina, Esquire, DOJ 7 8 910111213141516171819202122232425 Paula J. Leeper, Federal Official Reporter - USDC 6500 Cherrywood Lane, Suite 200 Greenbelt, Maryland 20770 3 Case 8:25-cv-00951-PX Document 66 Filed 04/14/25 Page 3 of 28 1 P R O C E E D I N G S 2 (Court called to order.) 3 DEPUTY CLERK: All rise. The United States District 4 Court for the District of Maryland is now in session. The 5 Honorable Paula Xinis presiding. 6 THE COURT: Good afternoon, everyone. 7 (ALL COUNSEL: Good afternoon, Your Honor.) 8 THE COURT: You all can have a seat. 9 Mr. Ulander?10 DEPUTY CLERK: Yes, Your Honor. The matter now11 pending before the Court is Civil Action Number 25-951, Kilmar12 Armando Abrego Garcia, et al. v. Kristi Noem, et al. The13 matter comes before this Court for a status conference.14 Counsel, please identify yourselves for the record.15 MR. SANDOVAL-MOSHENBERG: Good afternoon, Your Honor.16 Simon Sandoval-Moshenberg of Murray Osorio, LLC, and with me is17 Jonathan Cooper of Quinn, Emanuel, Urquhart & Sullivan.18 Thank you, Your Honor.19 THE COURT: And who else is at counsel table?20 Ms. Horton and Mrs. Vasquez Sura; is that right?21 MS. HORTON: That is correct.22 THE COURT: And we're all going to try our best to23 slow down for the court reporter's sake. Okay.24 All right. For the government?25 MR. ENSIGN: Good afternoon, Your Honor. Drew Ensign Paula J. Leeper, Federal Official Reporter - USDC 6500 Cherrywood Lane, Suite 200 Greenbelt, Maryland 20770 4 Case 8:25-cv-00951-PX Document 66 Filed 04/14/25 Page 4 of 28 1 for defendants. With me is Michelle Latour and Ernest Molina. 2 THE COURT: I'm sorry, I didn't catch the last name, 3 Mr. Molina? 4 MR. MOLINA: Yes, Your Honor. 5 THE COURT: Okay. Thank you all. 6 So we're here today, because as you all know, last night 7 the United States Supreme Court issued its decision. It 8 vacated the administrative stay that has been in place since 9 Monday morning-ish until last night at 6:30. The order from10 the Court affirmed all aspects of my decision and prior orders,11 save for requiring clarification on remand.12 The Court noted that my prior order properly required the13 government to facilitate Abrego Garcia's release from custody14 in El Salvador, and I'm quoting directly from the Supreme15 Court, and to ensure that his case is handled as it would have16 been had, had he not been improperly sent to El Salvador.17 The Court went on to say the intended scope of the term18 "effectuate" in this District Court's order, however, is19 unclear and may exceed the District Court's authority.20 So last night, in short order, this Court amended its21 prior order and made clear what the government must do22 consistent with the Supreme Court's directive. And that is23 found at ECF 51, where I said "to this end," and that end was24 to clarify the term, "the Court hereby amends the order to25 direct the defendants take all available steps to facilitate Paula J. Leeper, Federal Official Reporter - USDC 6500 Cherrywood Lane, Suite 200 Greenbelt, Maryland 20770 5 Case 8:25-cv-00951-PX Document 66 Filed 04/14/25 Page 5 of 28 1 the return of Abrego Garcia to the United States as soon as 2 possible." 3 So contrary to what the government has put and the 4 defendants have put in their pleadings today asking for more 5 time, there is no need for further briefing on this. My words 6 are clear. 7 The next question becomes, is the -- are the defendants 8 able to answer the three questions and willing to answer the 9 three questions that I've put to them for today.10 And I'm going to take each one, Mr. Ensign, in order,11 because your pleadings, since last night, seem to really only12 focus on the third bucket of information that I've asked. So I13 want to go one by one and get your views on each of them, and14 then I'll turn to the plaintiffs.15 So the three areas are, first -- and I asked today for a16 supplemental declaration. I did not get it, I got two pages17 that said you're not able yet to answer any of these questions18 and you cannot comply with my order.19 So the order was, one, the current physical location and20 custodial status of Mr. Abrego Garcia; two, what steps, if any,21 defendants have taken to facilitate Abrego Garcia's immediate22 return to the United States; and three, what additional steps23 defendants will take and when to facilitate his return.24 So, let's start with number one.25 Why did -- why did the defendants not comply with the Paula J. Leeper, Federal Official Reporter - USDC 6500 Cherrywood Lane, Suite 200 Greenbelt, Maryland 20770 6 Case 8:25-cv-00951-PX Document 66 Filed 04/14/25 Page 6 of 28 1 order and give me someone with personal knowledge to tell me 2 Mr. Abrego Garcia's current physical location and custodial 3 status? 4 MR. ENSIGN: Your Honor, as we explained in the 5 filing about an hour ago, we are still internally reviewing the 6 Supreme Court's decision and vetting what we can say to this 7 Court that is being actively considered right now. 8 THE COURT: What do you mean "what you can say"? 9 This is a very direct question. Where is he? And under whose10 authority?11 MR. ENSIGN: Your Honor, plaintiffs have represented12 that he is in El Salvador.13 THE COURT: No, I'm asking from the government's14 perspective, what information do you have about where he is and15 under whose authority?16 MR. ENSIGN: Your Honor, I do not have that17 information. I do not have any information that would18 contradict plaintiffs' assertion that he is in El Salvador19 under the -- in the custody of the El Salvadoran government.20 THE COURT: So the United States is going on record21 as saying you have no evidence as to where he is today and22 under whose authority? I just want to understand it.23 MR. ENSIGN: That's not the position of the United24 States specifically. I do not have that knowledge, and,25 therefore, I cannot relay that knowledge to the Court. Paula J. Leeper, Federal Official Reporter - USDC 6500 Cherrywood Lane, Suite 200 Greenbelt, Maryland 20770 7 Case 8:25-cv-00951-PX Document 66 Filed 04/14/25 Page 7 of 28 1 THE COURT: Okay. As an officer of the court, you're 2 saying your clients have not told you, as of today, the status 3 of Mr. Abrego Garcia, where he's located, and under whose 4 authority? 5 MR. ENSIGN: They have not provided that confirmation 6 to me before this hearing today. 7 THE COURT: Even though I directed that that 8 information be shared? It's quite basic. I'm not asking for 9 State secrets. I'm asking where one man, who was wrongly and10 illegally deported, removed from this country -- I don't want11 to use that word, because, frankly, that implies compliance12 with the INA, so I am not even sure what word to use. But all13 I know is, he's not here. The government was prohibited from14 sending him to El Salvador.15 And now I'm asking just a very simple question: Where is16 he?17 MR. ENSIGN: Your Honor, I do not have the -- that18 information provided to me that I can provide to you, for the19 reasons explained in the filing about an hour ago.20 THE COURT: Okay. And the filing about an hour ago21 talks about prospective information. You talk about how I22 haven't given you enough time to facilitate or to think about23 what you're doing next, and I'm invading the province of the24 Executive Branch because I have asked for answers that have25 been delayed for quite some time. Paula J. Leeper, Federal Official Reporter - USDC 6500 Cherrywood Lane, Suite 200 Greenbelt, Maryland 20770 8 Case 8:25-cv-00951-PX Document 66 Filed 04/14/25 Page 8 of 28 1 So this question is not about prospective. It's not -- I 2 am not asking about who you're talking to when. I'm asking a 3 very simple question: Where is he? 4 MR. ENSIGN: Your Honor, I don't have the information 5 to provide to you definitively as to where he is. I do not 6 have any information that would contradict plaintiffs' 7 assertions that he is in El Salvador in the custody of 8 government of El Salvador. 9 THE COURT: And you do not disagree that the last10 hands on Mr. Abrego Garcia were not the plaintiffs' hands, they11 were the government's hands? That's clear.12 So what I'm hearing from the government is there's no13 evidence before me as to where Mr. Abrego Garcia is currently,14 from the government's perspective?15 MR. ENSIGN: Not exactly, Your Honor. The plaintiffs16 have submitted evidence that that's where he is, and at17 present, the government has not submitted any evidence that18 would contradict that.19 THE COURT: I understand that. But the plaintiffs20 don't have any evidence for today, because unless they are21 going to correct me that they have actually spoken to22 Mr. Abrego Garcia or gotten some contemporary evidence as to23 where he is, there's no evidence today as to where he is today.24 Plaintiffs, will you have some evidence for me as to where25 he is today? Paula J. Leeper, Federal Official Reporter - USDC 6500 Cherrywood Lane, Suite 200 Greenbelt, Maryland 20770 9 Case 8:25-cv-00951-PX Document 66 Filed 04/14/25 Page 9 of 28 1 MR. SANDOVAL-MOSHENBERG: No, Your Honor. We have 2 not been able to speak to Mr. Abrego Garcia, notwithstanding 3 the family hiring a lawyer in El Salvador to try to make 4 contact. 5 THE COURT: Okay. So then there is no evidence as to 6 where he is today, and that is extremely troubling. 7 But I'm going to move to the second question, because I 8 think if I keep, you know -- I don't want you to have to keep 9 saying the same thing over and over again to my question.10 So the next one is: What steps, if any, defendants have11 taken to facilitate Abrego Garcia's immediate return to the12 United States?13 And the way I look at this, is -- to be sure, there was a14 period of time where the Supreme Court stayed my order, but15 there was also a period of time where that order was in full16 force and effect. And that was from Friday, April 4th, until17 Monday, when the Supreme Court, April 7, sometime in the18 morning, when they stayed it, and then it was lifted last19 night.20 So there are days in which if the defendants had done21 anything, I want to know what they have done.22 What have the defendants done to facilitate23 Mr. Abrego Garcia's return?24 MR. ENSIGN: Your Honor, again, for the reasons25 explained in our filing about an hour ago, the defendants are Paula J. Leeper, Federal Official Reporter - USDC 6500 Cherrywood Lane, Suite 200 Greenbelt, Maryland 20770 10 Case 8:25-cv-00951-PX Document 66 Filed 04/14/25 Page 10 of 28 1 not yet prepared to share that information. They are actively 2 evaluating both the Supreme Court decision and what they can 3 share with this Court. 4 But at this particular moment, they are not prepared to 5 share that information, which is currently -- 6 THE COURT: Have they done anything? 7 MR. ENSIGN: Your Honor, I don't have personal 8 knowledge of what steps were taken to comply. 9 THE COURT: Okay. So that means they have done10 nothing. I don't -- this is a yes-or-no question, and I don't11 mean to -- to direct, you know, all of my frustration at you,12 Mr. Ensign, because you're new, at least in this court, and so13 take this for what it is. It is a direct question that, in my14 view, is a yes or no. And that doesn't -- that doesn't invade15 any province of the Executive Branch, because I'm not asking16 what yet. I'm just asking was there anything.17 Was there anything done while this order was in full force18 and effect to facilitate the return of Mr. Abrego Garcia?19 MR. ENSIGN: Your Honor, I do not have that20 information. I -- I'm unable to answer that question because I21 don't have knowledge of that.22 THE COURT: Well, then, it is important, it behooves,23 I believe, this case and how the system of justice works, that24 the following be communicated to your clients:25 You are the officer of the court, you are the instrument Paula J. Leeper, Federal Official Reporter - USDC 6500 Cherrywood Lane, Suite 200 Greenbelt, Maryland 20770 11 Case 8:25-cv-00951-PX Document 66 Filed 04/14/25 Page 11 of 28 1 to represent them. If they do not give you the information and 2 there is no information before the Court, if there is no 3 information or evidence before the Court, then there is no 4 evidence. 5 So the record, as it stands, is despite this Court's clear 6 directive, your clients have done nothing to facilitate the 7 return of Mr. Abrego Garcia. There's an easy way to combat 8 that, and that's just to tell me whether you've done anything, 9 and if so, what?10 If you believe there's some reason why you can't, then you11 have to put that in writing, but you haven't yet.12 And to say to me that you don't have personal knowledge13 means that you don't have, like, full and effective contact14 with your clients. I mean, that's just not adding up to me, so15 maybe you can explain what you mean.16 How do you not have personal knowledge of this very basic17 question?18 MR. ENSIGN: Well, Your Honor, we are -- as the19 government has explained, it is actively evaluating what it can20 share with the Court and, you know, intends to comply with the21 Supreme Court's order and this Court's order. It is actively22 evaluating what can be shared.23 THE COURT: Okay.24 MR. ENSIGN: It is not yet prepared to resolve that25 question and has not, therefore, provided the answers that Paula J. Leeper, Federal Official Reporter - USDC 6500 Cherrywood Lane, Suite 200 Greenbelt, Maryland 20770 12 Case 8:25-cv-00951-PX Document 66 Filed 04/14/25 Page 12 of 28 1 could be shared with this Court. 2 THE COURT: What further evaluation, in your view, 3 does the administration or your defendants, your clients, need 4 to do to answer whether anything was done? That yes-or-no 5 question, what evaluation exactly needs to be done to answer 6 historically, what the Supreme Court said in its order, you 7 must be prepared to do? I -- and I'm just -- again, real 8 basic, yes or no. 9 And you're saying you're not yet prepared to answer that10 question despite the fact that this case has gone on for quite11 so many days.12 Am I getting that right?13 MR. ENSIGN: That is correct, Your Honor. For the14 reasons we explained in the filing previously, we are not yet15 prepared to share that information. We are actively16 considering what could be done.17 This is a case that involves three different cabinet18 departments, and there is a lot of interagency process that19 attends to these things.20 THE COURT: And while -- while you do that, given21 that the Supreme Court has said that my decision and all22 aspects of my order, save for a narrow clarification, is in23 full force and effect, the irreparable harm continues.24 Is anybody moving with any sort of speed on your end to25 get to the bottom of this so that I can get an answer? And I Paula J. Leeper, Federal Official Reporter - USDC 6500 Cherrywood Lane, Suite 200 Greenbelt, Maryland 20770 13 Case 8:25-cv-00951-PX Document 66 Filed 04/14/25 Page 13 of 28 1 don't mean to be flip about it, I'm just -- I'm not sure what 2 to take from the fact that the Supreme Court has spoken quite 3 clearly and yet I can't get an answer today about what you've 4 done, if anything, in the past, which means, again, the record, 5 as it stands, is that nothing has done -- been done in the 6 past. 7 When do you expect that, according to your clients, we 8 might get some answers to these questions? 9 MR. ENSIGN: Your Honor, we did move for an extension10 of the deadline and requested Tuesday at close of business; we11 would certainly be prepared to address the Court's questions by12 then. We could potentially do so on a faster basis, but we13 were not able to do so by 11:30 today, as the Court's order.14 That was not practical under the circumstances. We --15 THE COURT: No, you called it unreasonable. Despite16 the fact that this case has been going on for weeks, you called17 it unreasonable. And in light of the Supreme Court's18 directive, I respectfully disagree. I don't think it's19 unreasonable at all to ask very basic, historical questions.20 But be that as it may, you are going on record as saying21 by Tuesday of next week, you will have answers, meaning22 individuals with personal knowledge who can declare, under23 penalties of perjury, that's usually what's expected of a24 declaration, answers to these questions?25 MR. ENSIGN: Your Honor, we are prepared to provide Paula J. Leeper, Federal Official Reporter - USDC 6500 Cherrywood Lane, Suite 200 Greenbelt, Maryland 20770 14 Case 8:25-cv-00951-PX Document 66 Filed 04/14/25 Page 14 of 28 1 the government's responses that may include assertions of 2 privilege. I don't know. There are active discussions, you 3 know, ongoing. 4 I know, however, that because we moved to continue until 5 that time, we were certainly prepared to file something by that 6 time. We were not proposing a deadline that we were unwilling 7 to -- to meet. 8 THE COURT: Okay. You have anything to add before I 9 turn to the plaintiffs?10 MR. ENSIGN: Yes, Your Honor.11 I -- I think we disagree fundamentally with the current12 status of the Court's order. You know, as the Supreme Court13 said, I guess, two important things.14 One is that it said the -- that, quote, the deadline in15 the challenged order is no longer effective.16 THE COURT: Do you know why, though? I mean, that's17 because the administrative stay stayed the case past the18 effective deadline. And that's just common sense, right?19 The -- the deadline can't be in place if the stay blew past the20 deadline.21 So now you have a new amended order, incorporates22 everything else that the Supreme Court permitted, and then made23 clear that you are to take all available steps to facilitate24 the return of Abrego Garcia to the United States as soon as25 possible. That's the new deadline. Paula J. Leeper, Federal Official Reporter - USDC 6500 Cherrywood Lane, Suite 200 Greenbelt, Maryland 20770 15 Case 8:25-cv-00951-PX Document 66 Filed 04/14/25 Page 15 of 28 1 You can't have a historic deadline. It's over. So what's 2 the point? 3 MR. ENSIGN: Your Honor, as a second part of that, 4 the Supreme Court went on to explain the District Court should 5 clarify its directive with due regard to the deference owed to 6 the Executive Branch and the conduct of foreign affairs. 7 THE COURT: And I did that in the order. It's at 8 ECF 51. I quoted that very directive, and then I said "to this 9 end," and the rest follows.10 So you have the clarification, so I don't see what you're11 fundamentally disagreeing with.12 MR. ENSIGN: Your Honor, respectfully, the -- it is13 that due regard for the deference owed to the Executive Branch14 and the conduct of foreign affairs. At a bare minimum, we15 believe that you were required to hear from the Executive16 Branch what its position was as to clarification in a written17 brief before any order could become effective again.18 THE COURT: No, I disagree. You don't get that19 unless I say I need it, and I didn't need it. And now you20 don't get to brief what is now in the past.21 I have amended the order. That's what the Supreme Court22 told me to do. I did it. Everything else is in full force and23 effect. We do not get to relitigate the past in that respect.24 Now, going forward, you make your arguments as to what you25 think I'm entitled to and why, or not entitled to, and we go Paula J. Leeper, Federal Official Reporter - USDC 6500 Cherrywood Lane, Suite 200 Greenbelt, Maryland 20770 16 Case 8:25-cv-00951-PX Document 66 Filed 04/14/25 Page 16 of 28 1 from there. But we're not going to slow walk this. 2 So you will have a full and fair opportunity to be heard. 3 It -- but we're not relitigating what the Supreme Court has 4 already put to bed. And I don't believe I need help in 5 clarifying the order. I clarified the order. 6 So now with the order as it is, if you believe there is 7 some reason why you can't comply, then that is what you will 8 put in writing to me. 9 Does that make sense?10 MR. ENSIGN: Your Honor, we understand the Court's11 position on this. We -- we object to it, and we read the12 Supreme Court's order differently. We do not -- we believe13 that you were -- that the due regard for the deference owed to14 the Executive Branch required the Court to hear from us before15 any clarification it issued.16 THE COURT: It did not say that. And it made clear17 that when I said "facilitate," I was on all fours with the law.18 So now, my order reads, "take all available steps to facilitate19 the return as soon as possible."20 It -- it's just -- it's as plain as that.21 So -- so I hear you. You've made your record. I disagree22 with you.23 Next thing before I turn to the plaintiffs? Anything24 else?25 MR. ENSIGN: No, Your Honor. Paula J. Leeper, Federal Official Reporter - USDC 6500 Cherrywood Lane, Suite 200 Greenbelt, Maryland 20770 17 Case 8:25-cv-00951-PX Document 66 Filed 04/14/25 Page 17 of 28 1 THE COURT: Okay. All right. Mr. Moshenberg or 2 Mr. Cooper? Who is arguing? 3 MR. SANDOVAL-MOSHENBERG: Your Honor, just with 4 regard to steps one and two. 5 THE COURT: Yep. 6 MR. SANDOVAL-MOSHENBERG: The Court's order was 7 sufficiently clear. It asked for information that they should 8 have been doing already. They clearly didn't comply. What 9 remedy there is we leave to the sound discretion of the Court.10 THE COURT: Well, I need you to tell me what you11 believe is legal, proper, warranted going forward. You know,12 leaving it to the discretion of the Court is not --13 MR. SANDOVAL-MOSHENBERG: Okay.14 THE COURT: I need your argument.15 MR. SANDOVAL-MOSHENBERG: Yes, Your Honor.16 Your Honor, it's quite clear that the government, and I17 hate to use these words, but is playing a game with their own18 lawyers.19 This is now a second time we are before this Court with20 lawyers saying "I haven't been provided this information," "I21 haven't been provided any documentation," "I don't know."22 I think it's quite clear, at this point, that the Court23 needs to order that individuals with personal knowledge be24 brought before this Court.25 THE COURT: All right. Well -- Paula J. Leeper, Federal Official Reporter - USDC 6500 Cherrywood Lane, Suite 200 Greenbelt, Maryland 20770 18 Case 8:25-cv-00951-PX Document 66 Filed 04/14/25 Page 18 of 28 1 MR. SANDOVAL-MOSHENBERG: That's our position, Your 2 Honor. 3 THE COURT: Okay. I think - I think we need some -- 4 listen, I'm not interested in delaying this at all. Right? 5 But at the same time, there has to be some considered judgment 6 of how and under what authority I do or do not do something. 7 MR. SANDOVAL-MOSHENBERG: Yes, Your Honor. 8 THE COURT: So I think we can accomplish both at the 9 same time.10 I want to take a moment where you all will press pause,11 unless there's something more that you want to say about,12 practically, how you would like to see the next several steps13 roll out.14 Mr. Moshenberg, do you have any recommendations?15 MR. SANDOVAL-MOSHENBERG: Well, I mean Your Honor has16 really hit the nail on the head with regards to the17 enforceability of the order with regards to effectuating the18 return of Mr. Abrego Garcia being full effect and with regards19 to the irreparable harm.20 We understand the order to provide a declaration as being21 essentially with regards to compliance with the thrust of the22 order, which is that they take all reasonably available steps23 to effectuate his return -- to facilitate his return.24 THE COURT: Well, what do I do with the government25 saying "we can't do this until Tuesday"? Paula J. Leeper, Federal Official Reporter - USDC 6500 Cherrywood Lane, Suite 200 Greenbelt, Maryland 20770 19 Case 8:25-cv-00951-PX Document 66 Filed 04/14/25 Page 19 of 28 1 MR. SANDOVAL-MOSHENBERG: Your Honor, I don't think 2 the government laid an actual, factual foundation. When a 3 party comes before a court saying that something is impossible, 4 they need to lay a factual foundation by means of declarations, 5 not just arguments of counsel, especially where those 6 counsel -- that counsel is being told, "Actually, I don't know 7 what's going on." 8 But even regardless of that, there's just simply no 9 declaration here.10 THE COURT: Okay. And are you -- well, I'm not going11 to -- I'm not going to ask you right now to address the relief12 you seek for whatever violation you see.13 What I am contemplating is a very quick briefing order, as14 well as an order of compliance.15 And what I mean by that is, government, just so we're16 clear, there are no business hours in this court. There's --17 all hours are hours spent on all cases, including this one. So18 there's no nine to five.19 And what that means, is from now until compliance of this20 order, I'm going to require daily statuses, daily updates. You21 can tell me what you can, what you can't, why. But we're going22 to make a record of what, if anything, the government is doing23 or not doing.24 And, plaintiff, you are -- it's your case, so you have to25 put before me the -- the harms you see, the violations you see, Paula J. Leeper, Federal Official Reporter - USDC 6500 Cherrywood Lane, Suite 200 Greenbelt, Maryland 20770 20 Case 8:25-cv-00951-PX Document 66 Filed 04/14/25 Page 20 of 28 1 and the remedy you think you're entitled to, give the 2 government an opportunity to respond, and then I'll rule as 3 quickly as I can. 4 Any -- any input or thoughts about that? And I'll turn to 5 both of you. 6 MR. SANDOVAL-MOSHENBERG: No, Your Honor, that's very 7 appropriate. We think daily status updates is very 8 appropriate. And we'll be able to respond to each of those 9 status updates very promptly after they come in, both on the10 merits and also as an evidentiary matter we think that the11 status update is too vague, generic or being provided by a12 person without personal knowledge.13 THE COURT: Okay.14 MR. SANDOVAL-MOSHENBERG: Thank you, Your Honor.15 THE COURT: Government, anything to add to this?16 MR. ENSIGN: Your Honor, the United States intends to17 comply with the Supreme Court's order. We are actively taking18 steps to do so. We are not able meet the Court's deadlines19 because they are impracticable, but we intend to comply with20 the Supreme Court's order.21 THE COURT: Well, then every day you can say that to22 the public and to me. You can say that, every day, you can't23 comply with one, two and three of this order, you're just24 unable to.25 And if you can comply, because, frankly, I see one and two Paula J. Leeper, Federal Official Reporter - USDC 6500 Cherrywood Lane, Suite 200 Greenbelt, Maryland 20770 21 Case 8:25-cv-00951-PX Document 66 Filed 04/14/25 Page 21 of 28 1 as relatively straightforward and basic, or if you comply 2 partially, if you can give a little bit of insight, if you can 3 provide some information, then do it. If not, then the -- then 4 the defendants go on record as saying they are unable to 5 provide any information, and the record will stand as no 6 information and no steps and no evidence as to where Mr. Abrego 7 Garcia is. That's just the way it works in a court. 8 So I -- I hope -- I hope so. I hope you will. I hope you 9 will, in good faith, comply.10 And if it -- we'll just take it from there. I mean, I11 can't call it right now because I don't have briefing on it,12 but I do know that I want daily updates until this matter is13 resolved.14 So we will -- we will get working on a written order that15 memorializes all of this.16 Do you have any alternative suggestions for me,17 Mr. Ensign?18 MR. ENSIGN: Your Honor, this is actively being19 discussed. And, you know, as I said, we were prepared to20 address this by Tuesday close of business. You know, perhaps a21 report or a declaration by Monday close of business is22 something we could accomplish as an alternative to daily. I23 know that there are active, you know -- you know, active --24 THE COURT: Okay. I understand where you think25 you're going to land, and my order is daily updates. If your Paula J. Leeper, Federal Official Reporter - USDC 6500 Cherrywood Lane, Suite 200 Greenbelt, Maryland 20770 22 Case 8:25-cv-00951-PX Document 66 Filed 04/14/25 Page 22 of 28 1 daily update is zero, then that's what it will be. But -- but, 2 you know, there is -- there is -- it's fundamentally -- it's 3 important to go on record in a case of this nature where the 4 Supreme Court has affirmed all but a very narrow clarification, 5 which I've given you, as to why you are not -- what you're 6 doing or not doing. 7 So I -- I guess my message, for what it's worth, is if you 8 can do it tomorrow, do it tomorrow. I don't understand why you 9 can't do it tomorrow. I don't understand why one and two10 cannot be answered today. So maybe you can answer that for me11 between now and 5:00 tomorrow.12 Anyway, unless there are any other thoughts or comments,13 what I will do is issue an order that compels a daily update14 from a person with personal knowledge on one, two, and three.15 I will -- I think what we will also do is we'll set in a16 follow-up hearing for the day after, Mr. Ensign, when you say17 you believe you can get me the declaration that we wish to have18 today, that I ordered to have today. We'll just set in another19 hearing after that.20 And, plaintiff, it will be up to you, if you wish to ask21 for any further relief, to put it in writing. And I'll set a22 briefing schedule that's relatively expeditious for that.23 Okay?24 MR. SANDOVAL-MOSHENBERG: We understand. Thank you,25 Your Honor. Paula J. Leeper, Federal Official Reporter - USDC 6500 Cherrywood Lane, Suite 200 Greenbelt, Maryland 20770 23 Case 8:25-cv-00951-PX Document 66 Filed 04/14/25 Page 23 of 28 1 THE COURT: Okay. Government, is there anything else 2 you wish for me to consider? 3 MR. ENSIGN: Your Honor, again, we just object on the 4 basis that we think that the Supreme Court's order required the 5 Court to consider the government's view before entering a 6 clarification of the order, that that's what the due 7 requirement -- 8 THE COURT: Okay. Your objection is noted. If there 9 is anything else that you wish to be heard on as to the next10 steps, I'm inviting that. But your objection is noted.11 MR. ENSIGN: Thank you, Your Honor.12 And, again, as we have expressed in our filing about an13 hour ago, we simply believe that the Court's deadlines are14 impracticable, but that is not to say that the government is15 not intending to comply with the Supreme Court's order.16 THE COURT: Okay. Very well. I appreciate that.17 Mr. Moshenberg?18 MR. SANDOVAL-MOSHENBERG: Your Honor, I don't know19 if -- Your Honor, just now, the issue of who the government20 will be required to bring to the following hearing, or if you21 prefer to address that in briefing on the papers?22 THE COURT: Well, you -- right, you need to brief it.23 MR. SANDOVAL-MOSHENBERG: Thank you, Your Honor.24 THE COURT: Exactly. What remedy -- what violations25 you see, what remedy you're seeking. And in the interim, I Paula J. Leeper, Federal Official Reporter - USDC 6500 Cherrywood Lane, Suite 200 Greenbelt, Maryland 20770 24 Case 8:25-cv-00951-PX Document 66 Filed 04/14/25 Page 24 of 28 1 will require daily updates from the government, again, with a 2 declaration from someone with personal knowledge. And the 3 government will give me what they give me and we'll go from 4 there. 5 MR. SANDOVAL-MOSHENBERG: Very good, Your Honor. 6 Thank you. 7 THE COURT: All right. Anything else? 8 MR. SANDOVAL-MOSHENBERG: Nothing from plaintiffs. 9 THE COURT: All right. Thank you all.10 DEPUTY CLERK: All rise. This Honorable Court now11 stands adjourned.12 (Proceedings were concluded at 1:26 p.m.)13141516171819202122232425 Paula J. Leeper, Federal Official Reporter - USDC 6500 Cherrywood Lane, Suite 200 Greenbelt, Maryland 20770 Case 8:25-cv-00951-PX Document 66 Filed 04/14/25 Page 25 of 28 1 CERTIFICATE OF OFFICIAL REPORTER 2 3 4 I, Paula J. Leeper, Federal Official Court Reporter, in 5 and for the United States District Court for the District of 6 Maryland, do hereby certify, pursuant to 28 U.S.C. § 753, that 7 the foregoing is a true and correct transcript of the 8 stenographically-reported proceedings held in the 9 above-entitled matter and the transcript page format is in10 conformance with the regulations of the Judicial Conference of11 the United States.12 Dated this 11th day of April 2025.131415 /S/ Paula J. Leeper ____________________16 Paula J. Leeper, RPR, CRR17 Federal Official Reporter1819202122232425 Paula J. Leeper, Federal Official Reporter - USDC 6500 Cherrywood Lane, Suite 200 Greenbelt, Maryland 20770 14/8 16/23 19/22 20/15 23/1 23/9 24/7 contradict [3] 6/18 8/6 8/18 Anyway [1] 22/12 contrary [1] 5/3DEPUTY CLERK: [3] 3/3 3/10 24/10 APPEARANCES [2] 1/12 1/20 COOPER [3] 1/16 3/17 17/2MR. ENSIGN: [26] Case 8:25-cv-00951-PXMR. MOLINA: [1] 4/4 Document 66 appreciate [1] 23/16 Filed 04/14/25 Page 26 of 28 correct [4] 3/21 8/21 12/13 25/7 appropriate [2] 20/7 20/8 counsel [6] 3/7 3/14 3/19 19/5 19/6 19/6MR. SANDOVAL-MOSHENBERG: [17] 3/15 9/1 17/3 17/6 APRIL [4] 1/11 9/16 9/17 25/12 country [1] 7/10 17/13 17/15 18/1 18/7 18/15 19/1 20/6 20/14 22/24 April 4th [1] 9/16 court [50] 23/18 23/23 24/5 24/8 April 7 [1] 9/17 Court's [20] 4/18 4/19 4/22 6/6 11/5 11/21 11/21MS. HORTON: [1] 3/21 areas [1] 5/15 13/11 13/13 13/17 14/12 16/10 16/12 17/6 20/17THE COURT: [47] arguing [1] 17/2 20/18 20/20 23/4 23/13 23/15 argument [1] 17/14 CRR [1] 25/16/ arguments [2] 15/24 19/5 current [3] 5/19 6/2 14/11/S [1] 25/15 ARMANDO [2] 1/4 3/12 currently [2] 8/13 10/5 ask [3] 13/19 19/11 22/20 custodial [2] 5/20 6/21 asked [4] 5/12 5/15 7/24 17/7 custody [3] 4/13 6/19 8/711 [1] 1/11 asking [9] 5/4 6/13 7/8 7/9 7/15 8/2 8/2 10/15 cv [1] 1/611:30 [1] 13/13 10/1611th [1] 25/12 aspects [2] 4/10 12/22 D1300 [1] 1/18 assertion [1] 6/18 daily [9] 19/20 19/20 20/7 21/12 21/22 21/25 22/11:00 [1] 1/11 assertions [2] 8/7 14/1 22/13 24/11:26 [1] 24/12 ASSISTANT [1] 2/2 Dated [1] 25/12 attends [1] 12/19 day [4] 20/21 20/22 22/16 25/122 ATTORNEY [1] 2/2 days [2] 9/20 12/11 authority [6] 4/19 6/10 6/15 6/22 7/4 18/6 DC [2] 1/19 2/42000 [1] 2/4 available [4] 4/25 14/23 16/18 18/2220005 [1] 1/19 deadline [8] 13/10 14/6 14/14 14/18 14/19 14/20 Avenue [1] 2/3 14/25 15/1202 [2] 1/19 2/42025 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18/18 privilege [1] 14/2 18/4 19/10 19/11 19/20 23/10 21/6 21/17 22/16 23/17 proceedings [2] 24/12 25/8I've [3] 5/9 5/12 22/5 Mr. Abrego [11] 5/20 6/2 7/3 8/10 8/13 8/22 9/2 process [1] 12/18identify [1] 3/14 10/18 11/7 18/18 21/6 prohibited [1] 7/13illegally [1] 7/10 Mr. Abrego Garcia's [1] 9/23 promptly [1] 20/9immediate [2] 5/21 9/11 Mr. Cooper [1] 17/2 proper [1] 17/11implies [1] 7/11 Mr. Ensign [4] 5/10 10/12 21/17 22/16 properly [1] 4/12important [3] 10/22 14/13 22/3 Mr. Molina [1] 4/3 proposing [1] 14/6impossible [1] 19/3 Mr. Moshenberg [3] 17/1 18/14 23/17 prospective [2] 7/21 8/1impracticable [2] 20/19 23/14 Mr. Ulander [1] 3/9 provide [6] 7/18 8/5 13/25 18/20 21/3 21/5improperly [1] 4/16 Mrs. [1] 3/20 provided [6] 7/5 7/18 11/25 17/20 17/21 20/11INA [1] 7/12 Mrs. Vasquez [1] 3/20 province [2] 7/23 10/15include [1] 14/1 Ms. [1] 3/20 public [1] 20/22including [1] 19/17 Ms. Horton [1] 3/20 pursuant [1] 25/6incorporates [1] 14/21 MURRAY [2] 1/14 3/16 put [8] 5/3 5/4 5/9 11/11 16/4 16/8 19/25 22/21individuals [2] 13/22 17/23 must [2] 4/21 12/7 PX [1] 1/6information [21] 5/12 6/14 6/17 6/17 7/8 7/18 7/21 8/4 8/6 10/1 10/5 10/20 11/1 11/2 11/3 12/15 17/7 N Q 17/20 21/3 21/5 21/6 nail [1] 18/16 question [14] 5/7 6/9 7/15 8/1 8/3 9/7 9/9 10/10input [1] 20/4 name [1] 4/2 10/13 10/20 11/17 11/25 12/5 12/10insight [1] 21/2 narrow [2] 12/22 22/4 questions [7] 5/8 5/9 5/17 13/8 13/11 13/19 13/24instrument [1] 10/25 Q STATES [13] 1/1 1/11 3/3 4/7 5/1 5/22 6/20 6/24 whatever [1] 19/12 9/12 14/24 20/16 25/5 25/11 whether [2] 11/8 12/4quick [1] 19/13 status [9] 1/10 3/13 5/20 6/3 7/2 14/12 20/7 20/9 while [3] 10/17 12/20 12/20quickly [1] 20/3Case 8:25-cv-00951-PXQUINN [2] 1/17 3/17 Document 66 20/11 Filed 04/14/25 Page 28 of 28 whose [4] 6/9 6/15 6/22 7/3 statuses [1] 19/20 willing [1] 5/8quite [6] 7/8 7/25 12/10 13/2 17/16 17/22 stay [3] 4/8 14/17 14/19 wish [4] 22/17 22/20 23/2 23/9quote [1] 14/14 stayed [3] 9/14 9/18 14/17 without [1] 20/12quoted [1] 15/8 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18/16 18/17 18/18 18/21 16/3 16/12 20/17 20/20 22/4 23/4 23/15 18/7regulations [1] 25/10 Sura [2] 2/5 3/20 yet [8] 5/17 10/1 10/16 11/11 11/24 12/9 12/14relatively [2] 21/1 22/22 system [1] 10/23 13/3relay [1] 6/25 yourselves [1] 3/14release [1] 4/13 Trelief [2] 19/11 22/21 Z table [1] 3/19relitigate [1] 15/23 taken [3] 5/21 9/11 10/8 zero [1] 22/1relitigating [1] 16/3 taking [1] 20/17remand [1] 4/11 talk [1] 7/21remedy [4] 17/9 20/1 23/24 23/25 talking [1] 8/2removed [1] 7/10 talks [1] 7/21report [1] 21/21 tell [4] 6/1 11/8 17/10 19/21reported [1] 25/8 term [2] 4/17 4/24REPORTER [3] 25/1 25/4 25/17 therefore [2] 6/25 11/25reporter's [1] 3/23 thing [2] 9/9 16/23represent [1] 11/1 things [2] 12/19 14/13represented [1] 6/11 think [16] 7/22 9/8 13/18 14/11 15/25 17/22 18/3requested [1] 13/10 18/3 18/8 19/1 20/1 20/7 20/10 21/24 22/15 23/4require [2] 19/20 24/1 third [1] 5/12required [5] 4/12 15/15 16/14 23/4 23/20 though [2] 7/7 14/16requirement [1] 23/7 thoughts [2] 20/4 22/12requiring [1] 4/11 three [7] 5/8 5/9 5/15 5/22 12/17 20/23 22/14resolve [1] 11/24 thrust [1] 18/21resolved [1] 21/13 time [10] 5/5 7/22 7/25 9/14 9/15 14/5 14/6 17/19respect [1] 15/23 18/5 18/9respectfully [2] 13/18 15/12 today [17] 4/6 5/4 5/9 5/15 6/21 7/2 7/6 8/20 8/23respond [2] 20/2 20/8 8/23 8/25 9/6 13/3 13/13 22/10 22/18 22/18responses [1] 14/1 told [3] 7/2 15/22 19/6rest [1] 15/9 tomorrow [4] 22/8 22/8 22/9 22/11return [12] 5/1 5/22 5/23 9/11 9/23 10/18 11/7 transcript [3] 1/10 25/7 25/9 14/24 16/19 18/18 18/23 18/23 TRANSCRIPTION [1] 1/22reviewing [1] 6/5 troubling [1] 9/6right [13] 3/20 3/24 6/7 12/12 14/18 17/1 17/25 true [1] 25/7 18/4 19/11 21/11 23/22 24/7 24/9 try [2] 3/22 9/3rise [2] 3/3 24/10 Tuesday [4] 13/10 13/21 18/25 21/20Road [1] 1/14 turn [4] 5/14 14/9 16/23 20/4roll [1] 18/13 two [8] 5/16 5/20 14/13 17/4 20/23 20/25 22/9RPR [1] 25/16 22/14rule [1] 20/2 US U.S.C [1] 25/6sake [1] 3/23 Ulander [1] 3/9Salvador [8] 4/14 4/16 6/12 6/18 7/14 8/7 8/8 9/3 unable [3] 10/20 20/24 21/4Salvadoran [1] 6/19 unclear [1] 4/19same [3] 9/9 18/5 18/9 under [8] 6/9 6/15 6/19 6/22 7/3 13/14 13/22 18/6SANDOVAL [2] 1/13 3/16 understand [8] 6/22 8/19 16/10 18/20 21/24 22/8SANDOVAL-MOSHENBERG [2] 1/13 3/16 22/9 22/24save [2] 4/11 12/22 UNITED [13] 1/1 1/11 3/3 4/7 5/1 5/22 6/20 6/23saying [9] 6/21 7/2 9/9 12/9 13/20 17/20 18/25 9/12 14/24 20/16 25/5 25/11 19/3 21/4 unless [4] 8/20 15/19 18/11 22/12schedule [1] 22/22 unreasonable [3] 13/15 13/17 13/19scope [1] 4/17 until [6] 4/9 9/16 14/4 18/25 19/19 21/12seat [1] 3/8 unwilling [1] 14/6second [3] 9/7 15/3 17/19 up [3] 11/14 22/16 22/20secrets [1] 7/9 update [3] 20/11 22/1 22/13see [7] 15/10 18/12 19/12 19/25 19/25 20/25 23/25 updates [6] 19/20 20/7 20/9 21/12 21/25 24/1seek [1] 19/12 URQUHART [2] 1/17 3/17seeking [1] 23/25 use [3] 7/11 7/12 17/17seem [1] 5/11 usually [1] 13/23sending [1] 7/14sense [2] 14/18 16/9 Vsent [1] 4/16session [1] 3/4 v. [1] 3/12set [3] 22/15 22/18 22/21 VA [1] 1/15several [1] 18/12 vacated [1] 4/8share [5] 10/1 10/3 10/5 11/20 12/15 vague [1] 20/11shared [3] 7/8 11/22 12/1 Vasquez [2] 2/5 3/20short [1] 4/20 very [13] 6/9 7/15 8/3 11/16 13/19 15/8 19/13 20/6SIMON [2] 1/13 3/16 20/7 20/9 22/4 23/16 24/5simple [2] 7/15 8/3 vetting [1] 6/6simply [2] 19/8 23/13 view [3] 10/14 12/2 23/5since [2] 4/8 5/11 views [1] 5/13slow [2] 3/23 16/1 violation [1] 19/12so [42] violations [2] 19/25 23/24someone [2] 6/1 24/2 vs [1] 1/6something [5] 14/5 18/6 18/11 19/3 21/22sometime [1] 9/17 Wsoon [3] 5/1 14/24 16/19 walk [1] 16/1sorry [1] 4/2 want [8] 5/13 6/22 7/10 9/8 9/21 18/10 18/11 21/12sort [1] 12/24 warranted [1] 17/11sound [1] 17/9 was [17] 4/23 5/19 7/9 7/13 9/13 9/15 9/15 9/16speak [1] 9/2 9/18 10/16 10/17 10/17 12/4 13/14 15/16 16/17 17/6specifically [1] 6/24 Washington [2] 1/19 2/4speed [1] 12/24 way [3] 9/13 11/7 21/7spent [1] 19/17 we'll [5] 20/8 21/10 22/15 22/18 24/3spoken [2] 8/21 13/2 week [1] 13/21stand [1] 21/5 weeks [1] 13/16stands [3] 11/5 13/5 24/11 well [11] 10/22 11/18 17/10 17/25 18/15 18/24start [1] 5/24 19/10 19/14 20/21 23/16 23/22State [1] 7/9 went [2] 4/17 15/4
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