MEDIATION
U.S. District Court Southern District of Ohio (Columbus) CIVIL DOCKET FOR CASE #: 2:20-cv-03707-ALM-EPD

Subramanya v. United States Citizenship and Immigration Services et al Assigned to: Chief Judge Algenon L. Marbley Referred to: Magistrate Judge Elizabeth Preston Deavers Demand: $0 Cause: 05:551 Administrative Procedure Act

Date Filed: 07/22/2020 Jury Demand: None Nature of Suit: 899 Other Statutes: Administrative Procedures Act/Review or Appeal of Agency Decision Jurisdiction: U.S. Government Defendant

Plaintiff
Ranjitha Subramanya individually and on behalf of a class of those similarly situated

represented by Robert Howard Cohen Porter, Wright, Morris & Arthur LLP 41 South High Street, Suite 3200 Columbus, OH 43215 614/227-2066 Fax: 614/227-2100 Email: rcohen@porterwright.com LEAD ATTORNEY ATTORNEY TO BE NOTICED

Ana P. Crawford Porter Wright Morris & Arthur - 3 PO Box 1805 One S Main Street Suite 1600 Dayton, OH 45401-1805 937-449-6726 Fax: 937-449-6820 Email: acrawford@porterwright.com ATTORNEY TO BE NOTICED

Caroline Gentry Porter Wright Morris & Arthur One Dayton Centre One South Main Street Suite 1600

Plaintiff
Carlos Francisco Rodriguez Martinez individually and on behalf of those similarly situated

Dayton, OH 45402-2028 937-449-6748 Email: cgentry@porterwright.com ATTORNEY TO BE NOTICED
David P Shouvlin Porter Wright Morris & Arthur - 2 41 S High Street Suite 2800 Columbus, OH 43215-6194 614-227-2000 Email: dshouvlin@porterwright.com ATTORNEY TO BE NOTICED
Kirsten R. Fraser Porter Wright Morris & Arthur LLP 41 South High Street 29th Floor Columbus, OH 43215 614-227-2014 Fax: 614-227-2100 Email: kfraser@porterwright.com ATTORNEY TO BE NOTICED
represented by Robert Howard Cohen (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Ana P. Crawford (See above for address) ATTORNEY TO BE NOTICED
Caroline Gentry (See above for address) ATTORNEY TO BE NOTICED
David P Shouvlin (See above for address) ATTORNEY TO BE NOTICED
Kirsten R. Fraser (See above for address) ATTORNEY TO BE NOTICED

Plaintiff Lucrecia Rosa Ramos individually and on behalf of those similarly situated
Plaintiff Kebin Palma Sanchez individually and on behalf of those similarly situated
Plaintiff

represented by Robert Howard Cohen (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Ana P. Crawford (See above for address) ATTORNEY TO BE NOTICED
Caroline Gentry (See above for address) ATTORNEY TO BE NOTICED
David P Shouvlin (See above for address) ATTORNEY TO BE NOTICED
Kirsten R. Fraser (See above for address) ATTORNEY TO BE NOTICED
represented by Robert Howard Cohen (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Ana P. Crawford (See above for address) ATTORNEY TO BE NOTICED
Caroline Gentry (See above for address) ATTORNEY TO BE NOTICED
David P Shouvlin (See above for address) ATTORNEY TO BE NOTICED
Kirsten R. Fraser (See above for address) ATTORNEY TO BE NOTICED

Rene Kejang Ngenkeng

represented by Caroline Gentry (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Ana P. Crawford (See above for address) ATTORNEY TO BE NOTICED

V. Defendant United States Citizenship and Immigration Services
Defendant Ken Cuccinelli in his official capacity as the Acting Director of U.S. Citizenship and Immigration Services Defendant Ernest Destefano in his official capacity as the Chief of the Office of Intake and Document Production, USCIS

represented by Christopher R Yates United States Attorney's Office - 2 303 Marconi Boulevard 2nd Floor Columbus, OH 43215 614-469-5715 Fax: 614-469-5240 Email: christopher.yates@usdoj.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Christopher R Yates (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Christopher R Yates (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Date Filed

#

07/22/2020 1

Docket Text
COMPLAINT against Ranjitha Subramanya ( Filing fee $ 400 paid - receipt number: 0648-7568329), filed by Ranjitha Subramanya. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4
Exhibit D) (Cohen, Robert) (Entered: 07/22/2020)

07/22/2020 2

MOTION for Temporary Restraining Order by Plaintiff Ranjitha
Subramanya. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D) (Cohen, Robert) (Entered: 07/22/2020)

07/22/2020

3 DECLARATION of Ranijitha Subramanya re Motion for Temporary Restraining Order by Plaintiff Ranjitha Subramanya. (Cohen, Robert) Modified text and termed Motion on 7/23/2020 (jlk). (Entered: 07/22/2020)

07/22/2020

4 DECLARATION of Catherine Kang in Support of 2 MOTION for Temporary Restraining Order by Plaintiff Ranjitha Subramanya. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C,

# 4 Exhibit D, # 5 Exhibit E) (Cohen, Robert) Modified text and termed Motion on 7/23/2020 (jlk). (Entered: 07/22/2020)

07/22/2020

5 DECLARATION of Andrea La Manna in Support of 2

MOTION for Temporary Restraining Order by Plaintiff Ranjitha Subramanya. (Cohen, Robert) Modified text and termed motion on 7/23/2020 (jlk). (Entered: 07/22/2020)

07/22/2020

6 REQUEST for Issuance of Summons. (Cohen, Robert) (Entered: 07/22/2020)

07/22/2020

7 REQUEST for Issuance of Summons. (Cohen, Robert) (Entered: 07/22/2020)

07/22/2020

8 REQUEST for Issuance of Summons. (Cohen, Robert) (Entered: 07/22/2020)

07/23/2020

9 NOTICE of Appearance by Caroline Gentry for Plaintiff Ranjitha Subramanya (Gentry, Caroline) (Entered: 07/23/2020)

07/23/2020 10

ORDER Setting 65.1 Virtual Conference on Motion 2
MOTION for Temporary Restraining Order : Motion Hearing set for 7/29/2020 03:00 PM Virtually before Chief Judge Algenon L. Marbley. Signed by Chief Judge Algenon L. Marbley on 07/23/2020. (cw) (Entered: 07/23/2020)

07/24/2020 11

NOTICE of Appearance by Christopher R Yates for Defendants Ken Cuccinelli, Ernest Destefano, United States Citizenship and Immigration Services (Yates, Christopher) (Entered: 07/24/2020)

07/24/2020

12 Summons Issued as to United States Citizenship and Immigration Services. (jlk) (Main Document 12 replaced on 7/24/2020) (jlk). (Entered: 07/24/2020)

07/24/2020

13 Summons Issued as to Ken Cuccinelli. (jlk) (Entered: 07/24/2020)

07/24/2020

14 Summons Issued as to Ernest Destefano. (jlk) (Entered: 07/24/2020)

07/24/2020 15

NOTICE by Plaintiff Ranjitha Subramanya /Civil Cover Sheet (Gentry, Caroline) (Entered: 07/24/2020)

07/27/2020

16 NOTICE of Appearance by Kirsten R. Fraser for Plaintiff Ranjitha Subramanya (Fraser, Kirsten) (Entered: 07/27/2020)

07/28/2020 18

NOTICE by Plaintiffs Lucrecia Rosa Ramos, Carlos Francisco Rodriguez Martinez, Kebin Palma Sanchez, Ranjitha Subramanya /Declaration of Wajdi M. Ammarah (Gentry, Caroline) (Entered: 07/28/2020)

07/28/2020

19 NOTICE by Plaintiffs Lucrecia Rosa Ramos, Carlos Francisco Rodriguez Martinez, Kebin Palma Sanchez, Ranjitha Subramanya /Declaration of Yoan Martinez Ayala (Gentry, Caroline) (Entered: 07/28/2020)

07/28/2020

20 NOTICE by Plaintiffs Lucrecia Rosa Ramos, Carlos Francisco Rodriguez Martinez, Kebin Palma Sanchez, Ranjitha Subramanya /Declaration of Sirelene Moura Da Costa; Norberto Bernardes Da Fonseca; and Samuel Moura Fonseca (Gentry, Caroline) (Entered: 07/28/2020)

07/28/2020

21 NOTICE by Plaintiffs Lucrecia Rosa Ramos, Carlos Francisco Rodriguez Martinez, Kebin Palma Sanchez, Ranjitha Subramanya /Declaration of Nicolas Joseph Bell Fabregat (Gentry, Caroline) (Entered: 07/28/2020)

07/28/2020

22 NOTICE by Plaintiffs Lucrecia Rosa Ramos, Carlos Francisco Rodriguez Martinez, Kebin Palma Sanchez, Ranjitha Subramanya /Declaration of Abraham Blay Gayetaye (Gentry, Caroline) (Entered: 07/28/2020)

07/28/2020

23 NOTICE by Plaintiffs Lucrecia Rosa Ramos, Carlos Francisco Rodriguez Martinez, Kebin Palma Sanchez, Ranjitha Subramanya /Declaration of Mohsen Haghighatpour (Gentry, Caroline) (Entered: 07/28/2020)

07/28/2020

24 NOTICE by Plaintiffs Lucrecia Rosa Ramos, Carlos Francisco Rodriguez Martinez, Kebin Palma Sanchez, Ranjitha

07/28/2020 07/28/2020 07/28/2020 07/28/2020 07/28/2020 07/28/2020 07/28/2020 07/28/2020 07/28/2020

Subramanya /Declaration of Syeda Fareeza Karimushan (Gentry, Caroline) (Entered: 07/28/2020)
25 NOTICE by Plaintiffs Lucrecia Rosa Ramos, Carlos Francisco Rodriguez Martinez, Kebin Palma Sanchez, Ranjitha Subramanya /Declaration of Meng Huan Lee (Gentry, Caroline) (Entered: 07/28/2020)
26 NOTICE by Plaintiffs Lucrecia Rosa Ramos, Carlos Francisco Rodriguez Martinez, Kebin Palma Sanchez, Ranjitha Subramanya /Declaration of Ching-Min Lin (Gentry, Caroline) (Entered: 07/28/2020)
27 NOTICE by Plaintiffs Lucrecia Rosa Ramos, Carlos Francisco Rodriguez Martinez, Kebin Palma Sanchez, Ranjitha Subramanya /Declaration of Carlos Francisco Rodriguez Martinez (Gentry, Caroline) (Entered: 07/28/2020)
28 NOTICE by Plaintiffs Lucrecia Rosa Ramos, Carlos Francisco Rodriguez Martinez, Kebin Palma Sanchez, Ranjitha Subramanya /Declaration of Richard Patrick McNulty (Gentry, Caroline) (Entered: 07/28/2020)
29 NOTICE by Plaintiffs Lucrecia Rosa Ramos, Carlos Francisco Rodriguez Martinez, Kebin Palma Sanchez, Ranjitha Subramanya /Declaration of Swetha Muralidhara (Gentry, Caroline) (Entered: 07/28/2020)
30 NOTICE by Plaintiffs Lucrecia Rosa Ramos, Carlos Francisco Rodriguez Martinez, Kebin Palma Sanchez, Ranjitha Subramanya /Declaration of Tania Patricia Carcamo Oseguera (Gentry, Caroline) (Entered: 07/28/2020)
31 NOTICE by Plaintiffs Lucrecia Rosa Ramos, Carlos Francisco Rodriguez Martinez, Kebin Palma Sanchez, Ranjitha Subramanya /Declaration of Michael Propper, Director, Chess NYC (Gentry, Caroline) (Entered: 07/28/2020)
32 NOTICE by Plaintiffs Lucrecia Rosa Ramos, Carlos Francisco Rodriguez Martinez, Kebin Palma Sanchez, Ranjitha Subramanya /Declaration of Lucrecia Rosa Ramos (Gentry, Caroline) (Entered: 07/28/2020)
33 NOTICE by Plaintiffs Lucrecia Rosa Ramos, Carlos Francisco Rodriguez Martinez, Kebin Palma Sanchez, Ranjitha Subramanya /Declaration of Kebin Antonio Palma Sanchez (Gentry, Caroline) (Entered: 07/28/2020)

07/28/2020

34 Amended MOTION for Temporary Restraining Order and Mandatory Injunction by Plaintiffs Lucrecia Rosa Ramos, Carlos Francisco Rodriguez Martinez, Kebin Palma Sanchez, Ranjitha Subramanya. (Gentry, Caroline) (Entered: 07/28/2020)

07/28/2020

35 MOTION to Dismiss for Lack of Jurisdiction PLAINTIFFS AMENDED COMPLAINT FOR TEMPORARY RESTRAINING ORDER, PRELIMINARY AND PERMANENT INJUNCTIVE RELIEF, DECLARATORY RELIEF AND WRIT OF MANDAMUS, AND OBJECTION TO CERTIFICATION AS A CLASS ACTION (ECF NOS. 1, 2, 5, 17, and 34) by Defendants Ken Cuccinelli, Ernest Destefano, United States Citizenship and Immigration

Services. (Attachments: # 1 Affidavit Goodwin, USCIS/DHS

Decl., # 2 Affidavit Troy, NBC/USCIS/DHS Decl.) (Yates, Christopher) (Entered: 07/28/2020)

07/28/2020

36 NOTICE by Plaintiffs Lucrecia Rosa Ramos, Carlos Francisco Rodriguez Martinez, Kebin Palma Sanchez, Ranjitha Subramanya /Declaration of Rene Kejang Ngenkeng (Gentry, Caroline) (Entered: 07/28/2020)

07/28/2020

37 NOTICE by Plaintiffs Lucrecia Rosa Ramos, Carlos Francisco Rodriguez Martinez, Kebin Palma Sanchez, Ranjitha Subramanya, Rene Kejang Ngenkeng /Notice of Adding Rene Kejang Ngenkeng as a Plaintiff and Class Representative (Gentry, Caroline) (Entered: 07/28/2020)

07/29/2020 38

Emergency MOTION to Certify Class by Plaintiffs Rene Kejang Ngenkeng, Lucrecia Rosa Ramos, Carlos Francisco Rodriguez Martinez, Kebin Palma Sanchez, Ranjitha Subramanya. (Gentry, Caroline) (Entered: 07/29/2020)

07/29/2020 39

NOTICE of Hearing:Preliminary Pretrial Conference set for 9/1/2020 11:00 AM in Teleconference before Magistrate Judge Elizabeth Preston Deavers. (sln) (Entered: 07/29/2020)

07/31/2020

40 NOTICE by Plaintiffs Rene Kejang Ngenkeng, Lucrecia Rosa Ramos, Carlos Francisco Rodriguez Martinez, Kebin Palma Sanchez, Ranjitha Subramanya /NOTICE OF FILING REDACTED FIRST AMENDED CLASS ACTION COMPLAINT (Attachments: # 1 Exhibit FIRST AMENDED CLASS ACTION COMPLAINT REDACTED) (Gentry, Caroline) (Entered: 07/31/2020)

08/03/2020

41 REDACTED Version of 17 Amended Complaint. (sln) (Entered: 08/03/2020)

08/03/2020 42

ORDER Setting Virtual Hearing on Motion 34 Mandatory Injunction : Motion Hearing set for 8/10/2020 09:30 AM in Virtual Courtroom 331 - Columbus before Chief Judge Algenon L. Marbley United States: +1 (646) 749-3112; Access Code: 347-407869; and DENYING 35 Defendants Motion to Dismiss.

GRANTING 2 34 Motion for Temporary Restraining Order. Signed by Chief Judge Algenon L. Marbley on 8/3/2020. (cw) (Entered: 08/03/2020)

08/04/2020

43 NOTICE of Appearance by Ana P. Crawford for Plaintiffs Rene Kejang Ngenkeng, Lucrecia Rosa Ramos, Carlos Francisco Rodriguez Martinez, Kebin Palma Sanchez, Ranjitha Subramanya (Crawford, Ana) (Entered: 08/04/2020)

08/04/2020

44 Transcript of Motion for Temporary Restraining Order Proceedings held on July 29, 2020, before Judge Algenon L. Marbley. Court Reporter/Transcriber Shawna J. Evans, Telephone number 614-7193316. 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 through PACER. <P>NOTICE RE: REDACTION OF TRANSCRIPTS: Within 5 business days of this filing, each party shall inform the Court, by filing a Notice of Redaction, of the party's intent to redact personal data identifiers from the electronic transcript of the court proceeding. The policy is located on our website at www.ohsd.uscourts.gov (Forms - Electronic Availability of Transcripts). Please read this policy carefully. <P> For a complete copy of a transcript, please contact the Court Reporter or the Clerk's Office. Redaction Request due 8/25/2020. Redacted Transcript Deadline set for 9/4/2020. Release of Transcript Restriction set for 11/2/2020. (Evans, Shawna) (Entered: 08/04/2020)

08/05/2020

45 Joint MOTION to Continue Preliminary Injunction Hearing and Associated Deadlines by Plaintiffs Rene Kejang Ngenkeng, Lucrecia Rosa Ramos, Carlos Francisco Rodriguez Martinez, Kebin Palma Sanchez, Ranjitha Subramanya. (Gentry, Caroline) (Entered: 08/05/2020)

08/06/2020 46

SCHEDULING ORDER AND ORDER granting 45 Motion to Continue; Preliminary Injunction Hearing reset for 8/24/2020 at 9:30 a.m. Signed by Chief Judge Algenon L. Marbley on 8/6/2020. (cw) (Entered: 08/06/2020)

08/10/2020 47

CONSENT to Mediation by Defendant United States Citizenship and Immigration Services (Yates, Christopher) (Entered: 08/10/2020)

08/11/2020 48

NOTICE of Hearing: Settlement Conference set for 8/12/2020 11:00 AM in Teleconference before Magistrate Judge Elizabeth Preston Deavers. (sln) (Entered: 08/11/2020)

08/11/2020

Minute Entry for proceedings held before Magistrate Judge Elizabeth Preston Deavers: Status Conference held on 8/11/2020. (sln) (Entered: 08/11/2020)

08/12/2020

49 Minute Entry for proceedings held before Magistrate Judge Elizabeth Preston Deavers: Settlement Conference held on 8/12/2020. Negotiations not at impasse. Parties continue to confer. (sln) (Entered: 08/14/2020)

08/13/2020

50 Minute Entry for proceedings held before Magistrate Judge Elizabeth Preston Deavers: Continued mediation held on 8/13/2020. Parties continuing to mediate. (sln) (Entered: 08/17/2020)

08/13/2020

51 NOTATION ORDER : Joint Status Report regarding status, but not substance of settlement negotiations due by 8/18/2020. By Magistrate Judge Elizabeth Preston Deavers on 8/13/2020. (sln) (Entered: 08/17/2020)

08/18/2020

52 NOTICE of Voluntary Dismissal by Plaintiff Carlos Francisco Rodriguez Martinez (Gentry, Caroline) (Entered: 08/18/2020)

08/18/2020 53

STATUS REPORT Joint Status Report RE: Parties' Proposed Consent Order, Pursuant to Notation Order ECF No. 51, to file Notice of/Proposed Consent Order 8-20-2020 by Defendant United States Citizenship and Immigration Services. (Yates, Christopher) (Entered: 08/18/2020)

08/19/2020

54 NOTICE by Defendant United States Citizenship and Immigration

Services re 53 Status Report, Joint Notice of Filing Proposed Consent Order (Attachments: # 1 Text of Proposed Order [Proposed] Consent Order) (Yates, Christopher) (Entered: 08/19/2020)

08/21/2020 55

CONSENT ORDER. Signed by Chief Judge Algenon L. Marbley on 8/21/2020. (cw) (Entered: 08/21/2020)

08/21/2020

56 STATUS REPORT Defendants' Report Pursuant to Consent Order (ECF No. 55), 08/21/2020 by Defendant United States Citizenship

and Immigration Services. (Yates, Christopher) (Entered: 08/21/2020)

08/24/2020

NOTICE : The PPTC set for 9/1/2020 at 11:00 AM is VACATED. (sln) (Entered: 08/24/2020)

09/09/2020 57

STATUS REPORT Defendants' Report Pursuant to Consent Order (ECF No. 55), 09/09/2020 by Defendant United States Citizenship and Immigration Services. (Yates, Christopher) (Entered: 09/09/2020)

09/30/2020 58

STATUS REPORT Defendants' Report Pursuant to Consent Order (ECF No. 55), 09/30/2020, with next report due 10/09/2020 Pursuant to Consent Order (ECF No. 55) by Defendant United States Citizenship and Immigration Services. (Yates, Christopher) (Entered: 09/30/2020)

10/09/2020

59 STATUS REPORT Defendants' Report Pursuant to Consent Order (ECF No. 55), 10/09/2020, with next report due 10/16/2020 Pursuant to Consent Order (ECF No. 55) by Defendant United States Citizenship and Immigration Services. (Yates, Christopher) (Entered: 10/09/2020)

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 Case: 2:20-cv-03707-ALM-EPD Doc #: 1 Filed: 07/22/20 Page: 1 of 20 PAGEID #: 1

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO EASTERN DIVISION

RANJITHA SUBRAMANYA, individually :

and on behalf of a class of those similarly

:

situated,

:

725 Mill Crossing Dr.

:

Westerville, Ohio 43082

:

:

Plaintiff,

:

:

v.

:

:

UNITED STATES CITIZENSHIP AND

:

IMMIGRATION SERVICES

:

20 Massachusetts Ave., NW

:

Washington, D.C. 20001

:

:

and

:

:

KEN CUCCINELLI, in his official capacity :

as the Acting Director of U.S. Citizenship

:

and Immigration Services

:

20 Massachusetts Ave., NW

:

Washington, D.C. 20001

:

:

and

:

:

ERNEST DESTEFANO, in his official

:

capacity as the Chief of the Office of Intake :

and Document Production, USCIS

:

20 Massachusetts Ave., NW

:

Washington, D.C. 20001

:

:

Defendants.

:

Case No. ________________
Judge ___________________
VERIFIED COMPLAINT FOR TEMPORARY RESTRAINING ORDER, PRELIMINARY AND PERMANENT INJUNCTIVE RELIEF, DECLARATORY RELIEF AND WRIT OF MANDAMUS

1. This putative class action Complaint seeks temporary, preliminary and permanent mandatory injunctive relief, declaratory relief, and a writ of mandamus to compel Defendants to perform their clear legal duty to issue Employment Authorization Documents (“EADs”) to Plaintiff and class members after approving their Applications for Employment Authorization.

Case: 2:20-cv-03707-ALM-EPD Doc #: 1 Filed: 07/22/20 Page: 2 of 20 PAGEID #: 2
Because USCIS has significantly slowed and/or stopped printing EADs, which are essential for Plaintiff and approximately 75,000 putative class members to obtain or keep their jobs, Plaintiff seeks emergency relief that requires Defendants to print and issue the EADs immediately, and in no event later than seven days from the date of the Court’s order.
2. Below are images of an exemplar EAD that is available on USCIS’s website:1
3. Section 274a.13(b) of Title 8 of the Code of Federal Regulations imposes a clear and non-discretionary legal duty on Defendant United States Citizenship and Immigration Services (USCIS) to issue an EAD to every successful applicant for employment authorization: “If the application is granted, the alien shall be notified of the decision and issued an employment authorization document valid for a specific period and subject to any terms and conditions as noted.” 8 C.F.R. § 274a.13(b) (emphasis added).
4. It is necessary for USCIS to issue EADs because its mere approval of Applications for Employment Authorization is legally insufficient to confer permission to work on Plaintiff and class members. Instead, aliens must provide employers with a valid and unexpired EAD issued by Defendants before they can be lawfully hired or allowed to continue their employment.
1 These images were downloaded from the following URL on July 21, 2020: https://www.uscis.gov/i-9central/form-i-9-acceptable-documents
2

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5. Historically, Defendants have printed and issued EADs promptly after approving an alien’s Application for Employment Authorization, typically within 48 hours after approval.
6. Recently, however, Defendants have significantly slowed and/or stopped issuing EADs, thereby causing irreparable injury to Plaintiff and class members.
7. For example, USCIS approved Plaintiff’s application to extend her H-4 status and employment authorization on April 7, 2020, but Defendants unlawfully failed to issue her an EAD after approving her application. As a result, Plaintiff was forced to stop working for her employer after her initial EAD expired on June 7, 2020. To date, she still has not received her EAD and she remains unable to work. Worse, her employer has notified her that she will lose her job if she does not provide proof of employment authorization by August 9, 2020.
8. Defendants reportedly have not provided Plaintiff and class members the EADs to which they are legally entitled because they terminated USCIS’s printing contract with a third party, without having any intention or plan to replace that printing contract with another contract or method that would allow Defendants to print and issue EADs in a timely manner.
9. Defendants’ deliberate and intentional decision to significantly slow or stop providing EADs to aliens after approving their Applications for Employment Authorization is arbitrary, capricious and in violation of the laws and Constitution of the United States.
10. This Court is authorized by the Administrative Procedure Act, 5 U.S.C. § 551 et seq. and the Mandamus Act, 28 U.S.C. § 1361, to issue an order compelling Defendants to issue EADs to Plaintiff and class members.
11. By delaying or refusing to provide EADs to Plaintiffs and class members, Defendants have abused their power in an egregious and outrageous manner, without any reasonable justification in the service of a legitimate governmental objective, and with either an
3

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intention to harm Plaintiff and class members or deliberate indifference. Defendants have thereby violated the guarantee of substantive due process inherent in the Due Process Clause of the Fifth Amendment to the United States Constitution.
12. Defendants’ actions and failures to act have intentionally, deliberately and/or willfully inflicted irreparable harm on Plaintiff and class members, who are unable to work despite having been granted employment authorization, solely because of the lack of an EAD.
13. Under the foregoing laws and the Constitution of the United States, this Court should issue a mandatory temporary restraining order, writ of mandamus, preliminary and permanent injunctive relief, and declaratory relief that compels Defendants to issue EADs to Plaintiff and class members immediately, and in no event later than seven calendar days after the date of the Court’s order.
PARTIES 14. Plaintiff incorporates the allegations in the foregoing paragraphs as if they were fully restated herein. 15. Plaintiff Ranjitha Subramanya is a native and citizen of India. Plaintiff was admitted to the United States as an H-1B nonimmigrant to work at Nationwide Insurance. Plaintiff applied for, and was granted a change of nonimmigrant status to H-4, a nonimmigrant dependent of Vinod Simha, her husband. Plaintiff’s husband is an employee of American Electric Power and the recipient of a lawfully-extended H-1B nonimmigrant petition. Both Plaintiff’s husband and Plaintiff are in valid H-1B and H-4 status, respectively. Their status is valid until June 7, 2023. 16. Defendant United States Citizenship and Immigration Services is charged with the statutory duty to adjudicate benefits pursuant to the Immigration and Nationality Act, 8 U.S.C. §1101 et. seq. This duty includes the clear and non-discretionary legal obligation to issue an
4

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Employment Authorization Document (EAD) following approval of an Application for Employment Authorization. 8 C.F.R. § 274a.13(b).
17. Defendant Ken Cuccinelli is the Acting Director for the United States Citizenship and Immigration Services and this action is brought against him in his official capacity. Defendant Cuccinelli is generally charged with the duty to oversee the operations of USCIS and is responsible for ensuring that USCIS fairly and reasonably adjudicates applications for benefits pursuant to the Immigration and Nationality Act. He is also responsible for ensuring that USCIS complies with all of its legal obligations, including its clear and non-discretionary duty to issue EADs after it approves Applications for Employment Authorization. 8 C.F.R. § 274a.13(b).
18. Ernest DeStefano, is the Chief of the Office of Intake and Document Production of USCIS, and has supervisory authority over the ministerial operations to produce and mail secure identity documents, such as Permanent Resident Cards and Employment Authorization Documents. This action is brought against him in his official capacity.
JURISDICTION 19. Plaintiff incorporates the allegations in the foregoing paragraphs as if they were fully restated herein. 20. This Court has subject-matter jurisdiction of this action under 5 U.S.C. § 702 and 28 U.S.C. §§ 1331, 1361, and 1651.
VENUE 21. Venue is proper in this district and division under 28 U.S.C. § 1391(e)(1).
5

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FACTUAL BACKGROUND 22. Plaintiff incorporates the allegations in the foregoing paragraphs as if they were fully restated herein. 23. Plaintiff timely applied for an extension of her H-4 nonimmigrant status and an extension of her employment authorization on December 23, 2019. True and accurate copies of the receipts for these applications are attached to this Complaint as Exhibit A. 24. Plaintiff received notice of an Application Support Center appointment on January 17, 2020 and appeared for this appointment to permit the USCIS to capture her biometric identifiers. A true and accurate copy of the Notice of Appointment is attached to this Complaint as Exhibit B. 25. Plaintiff’s applications to extend nonimmigrant H-4 status and Employment Authorization were approved by USCIS on April 7, 2020. The approval notices, true and accurate copies of which are attached to the Complaint as Exhibit C, extended Plaintiff’s H-4 status and work authorization until June 7, 2023. However, Defendants have failed and refused to issue the physical card, which is the only document sufficient to provide evidence of employment authorization to an employer. 26. Generally, the EAD is produced and sent to the applicant within 48 hours of the approval. It has been over 105 days since USCIS approved Plaintiff’s application and Defendant still has not printed and sent the EAD to Plaintiff. 27. On May 4, 2020, Plaintiff, through counsel, filed an inquiry regarding the nondelivery of the EAD through Defendants’ E-Request, an on-line inquiry system. The inquiry was assigned ID number SR11252000620NSC, and the automated response to counsel stated that a response would be issued by May 26, 2020.
6

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28. The promised response time, before May 26, 2020, was very close to the expiration of Plaintiff’s existing EAD on June 7, 2020. Plaintiff therefore called the USCIS Contact Center on May 14, 2020 to make a further inquiry and was told by the USCIS officer that she would receive the EAD before the end of May.
29. In the meantime, USCIS processed the inquiry from counsel submitted on May 4, 2020. On May 18, 2020, the inquiry was assigned to an officer and a response was forwarded to counsel. That response, a true and accurate copy of which is attached to the Complaint as Exhibit D, states that the matter was under review, and a minimum of 60 days was required for this review.
30. This unsatisfactory answer prompted Plaintiff to again contact USCIS on May 20, 2020. Plaintiff was told that the inquiry was recorded on May 18, 2020, and the application was being reviewed. Plaintiff was not informed of the expected delivery date of her EAD.
31. On May 28, 2020, Plaintiff again contacted USCIS to check the status of her EAD. Plaintiff was told that applicants are expected to allow a minimum of 60 days from the date USCIS responded to an inquiry to process/review the request. Plaintiff was told that agents are unable to escalate an inquiry until the 60 days has lapsed. Defendants, through their respective agents, have never provided any explanation for the delay in the creation of this EAD.
32. On June 1, 2020, Plaintiff’s counsel inquired of Senator Rob Portman’s office about the status of Plaintiff’s EAD.
33. On June 2, 2020, Senator Portman advised Plaintiff through her counsel that “[u]nfortunately, according to [USCIS] officials, while your I-765 was approved on April 7, 2020, there are significant delays at this time in card production. USCIS is unable to expedite the production of EAD cards.”
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Case: 2:20-cv-03707-ALM-EPD Doc #: 1 Filed: 07/22/20 Page: 8 of 20 PAGEID #: 8
34. Plaintiff’s existing EAD expired on June 7, 2020 and she became unable to provide the required evidence of her employment authorization, notwithstanding USCIS’s approval of her application for employment authorization on April 7, 2020.
35. Plaintiff’s employer has advised her that it will terminate her employment on August 9, 2020, if she has not produced valid proof of employment authorization by that time.
36. On June 10, 2020, Senator Rob Portman’s office submitted a follow-up inquiry on Plaintiff’s behalf to USCIS. On July 21, 2020, Senator Portman advised Plaintiff through her counsel that “[u]nfortunately, according to [USCIS] officials, they are far behind in card production. We are aware that your I-765 was approved on April 7, 2020, however, USCIS says that they are unable to expedite the printing of your card.”
37. On June 12, 2020, Plaintiff again contacted USCIS to check the status of her EAD. Plaintiff once again was told that applicants are expected to allow a minimum of 60 days from the date USCIS responded to an inquiry to process/review the request. Plaintiff was again told that agents are unable to escalate an inquiry until the 60-day period has lapsed.
38. Despite Plaintiff’s timely application for extension of employment authorization benefits and subsequent USCIS approval and extensive efforts to implore USCIS to issue the EAD, Plaintiff has not received either an explanation of why the EAD has not been issued or when she might expect it to be issued. Without a valid EAD, Plaintiff is unable to provide satisfactory evidence of her employment authorization to meet the I-9 requirements as set forth in 8 U.S.C. §1324a(b)(1)(C), and is in imminent jeopardy of losing her job.
39. Plaintiff has not had access to gainful employment since June 7, 2020, when her employment authorization expired. If Plaintiff’s EAD is promptly issued by order of this Court and received prior to August 9, 2020, Plaintiff will be eligible to return to work at her place of
8

Case: 2:20-cv-03707-ALM-EPD Doc #: 1 Filed: 07/22/20 Page: 9 of 20 PAGEID #: 9
previous employment as an H-4 nonimmigrant with employment authorization. If not, then Plaintiff will be irreparably harmed by the permanent loss of her employment.
CLASS ALLEGATIONS 40. Plaintiff incorporates the allegations in the foregoing paragraphs as if they were fully restated herein. 41. Pursuant to Rules 23(a) and 23(b)(2) of the Federal Rules of Civil Procedure, Plaintiff brings this action on behalf of herself and the following nationwide class:
All aliens who reside in the United States and have submitted an Application for Employment Authorization that has been approved by USCIS, but who have not received an EAD. 42. The proposed class is so numerous that joinder of all of its members is impracticable. On information and belief, USCIS reportedly has a backlog of at least 75,000 unprinted EADs. 43. There are numerous questions of law and fact that are common to the individual Plaintiff and class members, including: a. Whether Defendants have significantly slowed and/or stopped issuing
EADs after approving Applications for Employment Authorization; b. Whether Defendants failed to issue EADs to Plaintiff and class members
because they terminated USCIS’s printing contract with a third party, without having any intention or plan to replace that printing contract with another contract or method that would allow Defendants to print and issue EADs in a timely manner; c. Whether Defendants’ actions and failures to act have caused irreparable injury to Plaintiff and class members;
9

Case: 2:20-cv-03707-ALM-EPD Doc #: 1 Filed: 07/22/20 Page: 10 of 20 PAGEID #: 10

d. Whether Defendants’ failure to issue EADs to Plaintiff and class members

violates 8 C.F.R. § 274a.13(b);

e. Whether Defendants’ failure to issue EADs to Plaintiff and class members

violates 5 U.S.C. § 555(b);

f. Whether Defendants’ failure to issue EADs to Plaintiff and class members

constitutes final agency action;

g. Whether Defendants failed to take a discrete agency action that they are

required to take;

h. Whether Defendants’ failure to issue EADs to Plaintiff and class members

is arbitrary, capricious, an abuse of discretion, or otherwise not in

accordance with law;

i.

Whether Defendants’ failure to issue EADs to Plaintiff and class members

is contrary to a constitutional right, power, privilege, or immunity, including

the substantive due process guarantee inherent in the Due Process Clause of

the Fifth Amendment to the United States Constitution;

j.

Whether Defendants have abused their power in an egregious and

outrageous manner, without any reasonable justification in the service of a

legitimate governmental objective, and with either an intention to harm

Plaintiff and class members or deliberate indifference;

l.

Whether Defendants’ failure to issue EADs to Plaintiff and class members

is in excess of statutory jurisdiction, authority, or limitations, or short of

statutory right;

10

Case: 2:20-cv-03707-ALM-EPD Doc #: 1 Filed: 07/22/20 Page: 11 of 20 PAGEID #: 11
m. Whether this Court should compel Defendants to issue EADs, which action has been unlawfully withheld and/or unreasonably delayed;
n. Whether this Court should hold that Defendants acted unlawfully when they failed to issue EADs to Plaintiff and class members;
o. Whether Plaintiff and class members have a clear right to relief; p. Whether Defendants have a clear, non-discretionary, mandatory and
ministerial legal duty to issue EADs to Plaintiff and class members; q. Whether no other adequate remedy is available to Plaintiff and class
members; and r. Whether this Court should issue a mandatory temporary restraining order,
emergency writ of mandamus, preliminary and permanent injunctive relief, and/or declaratory relief requiring Defendants to issue EADs to Plaintiff and class members immediately, and in no event later than seven days after the Court’s order. 44. Plaintiff’s claims are typical of the claims asserted by the entire class. 45. Plaintiff will fairly and adequately protect the interests of the class. There is no actual or potential conflict between members of the class with respect to the relief sought in this lawsuit. Moreover, Plaintiff is represented by a law firm and attorneys who are well-experienced with class actions. 46. Defendants are acting or refusing to act on grounds generally applicable to the class, making appropriate temporary, mandamus, injunctive and corresponding declaratory relief with respect to the class as a whole.
11

Case: 2:20-cv-03707-ALM-EPD Doc #: 1 Filed: 07/22/20 Page: 12 of 20 PAGEID #: 12
COUNT ONE (Administrative Procedure Act, 5 U.S.C. § 706(1)) 47. Plaintiff incorporates the allegations in the foregoing paragraphs as if they were fully restated herein. 48. Pursuant to the Administrative Procedure Act, 5 U.S.C. § 706(1), this Court shall compel agency action that has been unlawfully withheld or unreasonably delayed. 49. Defendants are required to issue EADs to Plaintiff and class members after approving their Applications for Employment Authorization. 50. Until recently, Defendants issued EADs promptly after approving an alien’s Application for Employment Authorization, typically within 48 hours after that approval. 51. Recently, however, Defendants significantly slowed and/or stopped issuing EADs after approving Applications for Employment Authorization, thereby causing irreparable injury to Plaintiff and class members. 52. For example, USCIS approved Plaintiff’s application to extend her H-4 status and employment authorization on April 7, 2020, but Defendants did not issue her an EAD. As a result, Plaintiff was forced to stop working for her employer after her initial EAD expired on June 7, 2020. To date, she still has not received her EAD, she remains unable to work, and her employment will be terminated if she does not provide a valid EAD by August 9, 2020. 53. Defendants reportedly have not provided Plaintiff and class members the EADs to which they are legally entitled because they terminated USCIS’s printing contract with a third party, without having any intention or plan to replace that printing contract with another contract or method that would allow Defendants to print and issue EADs in a timely manner. 54. Defendants have failed to take a discrete and non-discretionary agency action that they are required to take.
12

Case: 2:20-cv-03707-ALM-EPD Doc #: 1 Filed: 07/22/20 Page: 13 of 20 PAGEID #: 13
55. Defendants’ failure to act constitutes final agency action because USCIS has concluded its decision-making process and its approval of Applications for Employment Authorization have determined the rights and obligations of Plaintiff and class members.
56. Plaintiff and class members have no other adequate remedy in court to redress Defendants’ refusal to issue and/or unreasonable delay in issuing their EADs.
57. Defendants’ failure to issue EADs has caused and will imminently cause substantial and concrete harm to Plaintiff and class members, who have lost or will lose the ability to work as a result of Defendants’ unlawful actions and/or failure to act.
58. Plaintiff seeks, on behalf of herself and the class, a mandatory temporary restraining order and preliminary and permanent injunctive relief that requires Defendants to issue EADs to Plaintiff and class members immediately, and in no event later than seven days after the date of the Court’s order.
59. Plaintiff further seeks a declaration that Defendants have violated their obligations to comply with 8 C.F.R. § 274a.13(b).
60. Plaintiff further seeks an award of reasonable attorneys’ fees and costs. COUNT TWO
(Writ of Mandamus, 28 U.S.C. § 1361) 61. Plaintiff incorporates the allegations in the foregoing paragraphs as if they were fully restated herein. 62. Pursuant to 28 U.S.C. § 1361, this Court has original jurisdiction of this action in the nature of mandamus to compel Defendants, who are an agency, officers or employees of the United States, to perform a duty owed to Plaintiff and class members. 63. Plaintiff has a clear legal right under 8 C.F.R. § 274a.13(b) to be issued an EAD valid for the period specified on Plaintiff’s I-797 after approval of the Application for Employment
13

Case: 2:20-cv-03707-ALM-EPD Doc #: 1 Filed: 07/22/20 Page: 14 of 20 PAGEID #: 14
Authorization has been granted. The regulation provides in relevant part: “If the application is granted, the alien shall be notified of the decision and issued an employment authorization document valid for a specific period…”
64. Class members have a clear legal right under 8 C.F.R. § 274a.13(b) to be issued an EAD valid for the applicable or specified period after approval of their Applications for Employment Authorization have been granted.
65. Defendants have a clear legal duty to conclude matters within a reasonable time under 5 U.S.C. § 555(b), which provides in relevant part: “With due regard for the convenience and necessity of the parties or their representatives and within a reasonable time, each agency shall proceed to conclude a matter presented to it.”
66. Defendants have a clear legal duty to complete proceedings within a reasonable time under 5 USC § 558(c), which provides in relevant part: “The agency, with due regard for the rights and privileges of all the interested parties and adversely affected persons and within a reasonable time, shall set and complete proceedings required to be conducted in accordance with sections 556 and 557 of this title or other proceedings required by law…” 5 U.S.C. § 558(c).
67. Plaintiff and class members have no other adequate remedy to redress Defendants’ refusal and/or unreasonable delay in issuing their EADs.
68. Defendants’ failure to issue EADs have caused and will imminently cause substantial and concrete harm to Plaintiff and class members, who have lost or will lose the ability to work as a result of Defendants’ unlawful actions and/or failure to act.
69. Plaintiff seeks, on behalf of herself and the class, a writ of mandamus that requires Defendants to issue EADs to Plaintiff and class members immediately, and in no event later than seven days after the date of the Court’s order.
14

Case: 2:20-cv-03707-ALM-EPD Doc #: 1 Filed: 07/22/20 Page: 15 of 20 PAGEID #: 15
70. Plaintiff further seeks an award of reasonable attorneys’ fees and costs. COUNT THREE
(Administrative Procedure Act, 5 U.S.C. § 706(2) and the Due Process Clause of the Fifth Amendment to the United States Constitution (Substantive Due Process))
71. Plaintiff incorporates the allegations in the foregoing paragraphs as if they were fully restated herein.
72. Pursuant to the Administrative Procedure Act, 5 U.S.C. § 706(2), this Court shall hold unlawful and set aside agency action, findings, and conclusions found to be (A) arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with law; (B) contrary to constitutional right, power, privilege, or immunity; or (C) in excess of statutory jurisdiction, authority, or limitations, or short of statutory right.
73. The Due Process Clause of the Fifth Amendment to the United States Constitution provides: “No person shall be … deprived of life, liberty, or property, without due process of law.” This Clause has been interpreted to include a right to substantive due process.
74. Plaintiff and class members have a liberty interest in the right to lawful employment.
75. Once their Applications for Employment Authorization have been approved by Defendants, Plaintiff and class members have a property interest in their EADs.
76. Defendants reportedly have not provided Plaintiff and class members the EADs to which they are legally entitled because they terminated USCIS’s printing contract with a third party, without having any intention or plan to replace that printing contract with another contract or method that would allow Defendants to print and issue EADs in a timely manner.
15

Case: 2:20-cv-03707-ALM-EPD Doc #: 1 Filed: 07/22/20 Page: 16 of 20 PAGEID #: 16
77. Defendants’ actions and failures to act have intentionally, deliberately and/or willfully inflicted irreparable harm on Plaintiff and class members, who are unable to work despite having been granted employment authorization, solely because of the lack of an EAD.
78. Defendants’ deliberate, willful and unlawful refusal to print and issue EADs has deprived Plaintiff and class members of their liberty interest in the right to lawful employment and their property interest in their EADs.
79. Defendants’ deliberate, willful and unlawful refusal to print and issue EADs to Plaintiff and class members, thereby depriving them of rights protected by the Fifth Amendment to the United States Constitution, constitutes an egregious and outrageous abuse of governmental power that shocks the conscience.
80. Defendants’ deliberate, willful and unlawful refusal to print and issue EADs is without any reasonable justification in the service of a legitimate governmental objective.
81. Defendants’ deliberate, willful and unlawful refusal to print and issue EADs is either motivated by an intention to harm Plaintiff and class members or constitutes deliberate indifference.
82. Defendants’ failure to issue EADs has caused and will imminently cause substantial and concrete harm to Plaintiff and class members, who have lost or will lose the ability to work as a result of Defendants’ unlawful actions and/or failure to act.
83. Plaintiff seeks, on behalf of herself and the class, a mandatory temporary restraining order and preliminary and permanent injunctive relief that requires Defendants to issue EADs to Plaintiff and class members immediately, and in no event later than seven days after the date of the Court’s order.
16

Case: 2:20-cv-03707-ALM-EPD Doc #: 1 Filed: 07/22/20 Page: 17 of 20 PAGEID #: 17
84. Plaintiff further seeks a declaration that Defendants have violated the guarantee of substantive due process inherent in the Due Process Clause of the Fifth Amendment to the United States Constitution.
85. Plaintiff further seeks an award of reasonable attorneys’ fees and costs. IRREPARABLE HARM / INADEQUATE REMEDY AT LAW
86. Plaintiff incorporates the allegations in the foregoing paragraphs as if they were fully restated herein.
87. Defendants’ refusal and/or failure to issue EADs to Plaintiff and class members have deprived and will deprive them of lawful employment and the benefits thereof, including but not limited to wages, income, health insurance, other benefits, and the ability to provide financial support for themselves and their families.
88. Plaintiff and class members have been and will be irreparably harmed because they cannot sue Defendants for monetary damages that would make them whole for lost employment opportunities and benefits.
89. Plaintiff and class members cannot be adequately compensated for these harms in an action at law for money damages.
WHEREFORE, Plaintiff respectfully prays as follows: a) The Court enter a mandatory temporary restraining order that requires Defendants to issue EADs to Plaintiff and class members immediately, and in no event later than seven days after the date of the Court’s order;
17

Case: 2:20-cv-03707-ALM-EPD Doc #: 1 Filed: 07/22/20 Page: 18 of 20 PAGEID #: 18
b) The Court issue a writ of mandamus that compels Defendants to issue EADs to Plaintiff and class members immediately, and in no event later than seven days after the date of the Court’s order;
c) The Court enter preliminary and permanent injunctions that require Defendants to issue EADs promptly after approving Applications for Employment Authorization, and in no event later than seven days after the date of such approval;
d) The Court issue a declaration that Defendants have violated their obligations under 8 C.F.R. § 274a.13(b) and the Due Process Clause of the Fifth Amendment to the United States Constitution;
e) Plaintiff and class members recover their reasonable attorneys’ fees and costs; and f) Plaintiff and class members have such other and further relief that the Court
deems just and equitable.
Respectfully submitted,
s/ Robert H. Cohen Robert H. Cohen, Trial Attorney (0009216) Caroline H. Gentry (0066138) David P. Shouvlin (0066154) Porter Wright Morris & Arthur LLP 41 South High Street, Suites 2800-3200 Columbus, OH 43215 Telephone: 614.227.2066 Email: rcohen@porterwright.com Counsel for the Plaintiff
18

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Case: 2:20-cv-03707-ALM-EPD Doc #: 1 Filed: 07/22/20 Page: 20 of 20 PAGEID #: 20

Exhibit A
B C
D

LIST OF ATTACHMENTS
Description of Exhibit
Form I-797C, Notice of Action: Receipts for Form I-539, Application to Extend Nonimmigrant Status and Form I-765, Application for Employment Authorization
Form I-797C, Notice of Action: Appointment Notice for Biometrics
Form I-797C, Notice of Action: Approval of Applications to Extend H-4 nonimmigrant status and Employment Authorization (April 7, 2020 and July 7, 2020)
Correspondence from USCIS in response to Counsel’s inquiry regarding nonissuance of EAD, May 18, 2020 and July 8, 2020

13438894v3
20

Case: 2:20-cv-03707-ALM-EPD Doc #: 1-1 Filed: 07/22/20 Page: 1 of 3 PAGEID #: 21

Department of Homeland Security U.S. Citizenship and Inmu~ration Services

Form I-7970, Notice ~f Action

THIS NOTICE DOES NQT GRANT ANY IMMIGRATION STATUS OR SENEFI'T.

Recciptl~um6cr

Receired Uale
13/23/2019
`lolice Date
12/23/2019

3'rioriiy Date
Page
1 0}' 1

Rr'1NJTTHA SUBRAI4~lANYA c/o CATHERINE C KANG POR"1'ER WRIGHT IviORRIS ARTHUR 41 SOUTH HIGH STREET FLR 3l CnLUMBUS OH X13215

CaseT~pe
1539 - AYPLiCA'f'ION "i"Q EXTEIeU/~IiANGE NOMMl~9(GRANT STATUS
Applicant
SUBFA1t4ANYA, RANl1THA
Aeneficiury
SUBRAMANS'A, RA1tiJ(THA
Notice Type: i2eccipt Notice /Amount received: 5455.00 U.S.

This notice confirms dial USC1S received your application or petition ,"this case") sis shown above. If' any pf the inf'ortnation in your notice is incorrect or you have any questions abnuE your case, you can ca~itect with the U5CiS Contact Center at wivw.useis.gc~v/coiitactcenter or ask xbc~ut your case online :it www.uscis.gov/e-request. You will need your Atizn Registration ti umbec (A-Number) and/or the receipt number shown above.
You can receive updates on ytturcase by visiking wu~H~:usc s.gov/casestatus to get the latest status or you can create an account at my.uscis.govtaccount ar~d receive email updates fir your case.

This noticz does not gram any immigration sratus or benefit, nor is ie e~~idence that this case is still fending. li Dilly shows ti~at the application or petition was receipled ~a the date shown,. Processing tint¢ -Processing times vary by forrti type.
Visit tivww.wcis.govlproccssingtimes Co see the cwrt:~t processing times by fottn type a~~d field office of service c~nte~•. • Ii you do not n:ceive an initial decision or update within our current processing time, you can try oat online tools availaUle at www.uscis.govhoals or ask
about your cast online at tivwlr.uscis.oav/e-request. When we make a dx.cision ~n your case ~r il'we need something from pou, we will notify you by mail and update our systems.
[f your address claangcs - If you mc7ve N~hile your case is pending, please visit www.uscis.go+~/addressebanxe for inf'ormauon on hew to update yowaddress. Remember to update your address fur all your receipt numbers.

Return of Original Documents -Use Form G-884, Request for the Return of Original nocuments, to request the return of original documents submitted to establish eligibility for an irnmigruiun or citizenship benefit, Xou only need to submit one Form G88a if you are requesting multiple documents c€~ntained in a single USC15 fle. however, if th4 rcc~ucsted docurncntation is in more than one USCIS Cite, you must submit a separate request for each file. (For esam~le: If you wish ro obtain your mother's birth certificate and your parents' marriage cert ificate, both of which are in the iJSCIS titz that pertains to her, submit one Forna G-884 with you+ mother's information.]
l~(31'IC:k:: Under the [u~migration <md Nat oa~ality Act (IN.4}, the inforn~aticm ~~ou provide nn and in support oF:ipplicatioi~s and petirions is submitted under the penalty of perjury. USCIS and the U.S. Department ofHomeiand Security r~scrve the right ro verify this inforrnalion txforc andlor ai'ter ;~ilkin~ a decision on your czse so we can ensure that you have complied with applicable laws, rules, regulations, and other 1ega1 authorities. We may review public information anJ records, contact others by ir~ail, the Internet ur pfione, canduet site inspections of businesses and residences, or use gthar methods of verification. We will use the information obtained io determine whether you are eligible for the benetit you seek. if we find any derogatory information, we wilt follov.~ the law in determining whether to provide you (and the legal representative listed on }'our Forni G-28, if you submitted cane) an opportunity to addres=, that inionnation before tive makf a formal decision nn your case or start proceedings.

Bekieficiaiy!iesa: Name Sti$RAMA\YA. RANJi'fHA

UOB

COB

Clan

Ott iNUI.A

_.._.___ ___...~. . .___._.._____._....__._._.._____.. ......

_M_.__W_.___._..

Yleuse gee the aJditional iaif~r~raution an ilta b~c~.. You will be notified se{rufately about a3ty other cases you filed.

yehraskn Service Center U. S. CfT1LENSHiP & [MMIGKA'1"10N 5VC p.Q. 8ox 82621 t,incoln NE 68?01-221
USC;IS Contact Center: svww.uscis.gov/contactcenter

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Exhibit A

If this is an interview or biometrics appointment notice, please see

octant information.

Form I-7970 04/01/19

Case: 2:20-cv-03707-ALM-EPD Doc #: 1-1 Filed: 07/22/20 Page: 2 of 3 PAGEID #: 22

Department of Homeland Security U.S. Citizenship and Immigration Services

Form I-747C, Notice of Action

THIS NE)TICE DOES NOT GRANT ANY IMMIGRATION STATUS OR BENEFIT.

Receipt Numt~cr

~

LI-1

Rcceicet4 Orate
121~31'2(~!9

Nuu&~e Date
12/23/2019

Prinrit} Dale
rave
7 ~~f 2.

xANrr7~Ha sUF3xaMt1NYA clo CATN:ERCNI C' KANCs PrJ~"1'rR WR€GHT MORRIS Ak2THiJR 4l SOU'I'H H. ICiH S'1~REE'T' FIR 3 2 C{7LU~iBUS (~~H 43215

___-.~..,.-..,.e Case T7~pc
t7b5 - APPI.1CATlON FOR L:N1~'C.UYn9ENT AUT3I012SLA7't0l~
Applicant
SU33RAIv1A;~;YA, S~At3J1THR
13ene6dary
SUBRAiYtANYA, Rr1N7ITHA
l~iocice Type: k~~~zpr Not;~e A.mni~nt received: $41fJ.{~0 U.S. Class requested: C'26

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~~'e have received tlae aPplicatiaz~ or netitian ("your case") listed above. 'This nonce anly shows that yos~r cstge ~-as filed oa the "Received IAate" listed above. it does i*!QT ~;ra~~t you airy imrnigr~atiori statx~s er im~~sigrutiuii benefit, ~xt~cl it is not evidence ilaat your cis€: is still p~;nding. We ~vi13 ~~c~tify you in tivri~ing 4ui~en we make a decision ~n ynur case ar if we, zjee~' acldiiional infcrn~ation.
Ple~e save this and :u7y utlier rotices about your case for your recards. You should als~s keep copies of aaythiFig you send os, a~ well :~ prue~f q(dalivery. }{aye these records available rvhen you contact us abo~zt your c~;e.
If say of the information in yoa~r naLice is iacarrect or you have az~y giasstit~r~~ about yflur case, you can canned wills the tF5C15 Cpntsact Cz~Cer at
WWK'.11$ClS. y~-.',CJ w'fi:()Ill'u1C:1CY.tIl:;I"Of uS~C d~lUlit yCiL1 t' C<i5C C3fl~t tlC c{[ W WW.iISCi S. ~,{7 V~C-CC(}11E.;5f. ~Qlt WI~1 SlCY(~ ~'7UI' f~~IP.tI ~'~~aS(i'~Ci6(i t~t~(I]~yE[ {,~1-~U[l7~'fPP~ BIIC~~~C ~ I~IL' TLCCI~t 17UI71Il£f SIlO Vilt iA~7CV~.

SOU riitl I'CC~1VC i1 ~7(~J.i~S G77 YOUf Cu~G b}' ViSy[t0~ lV'1vW.USCIS.~;OY/C3SCSYiYlt15 LO ~C[ i~1C ~diCSt SlatU UT YOU s:~llt G3'Eal~ 1331 aCL'Oit ti( dl I~tY. u.iCIS.nOVJ~,CCDUi)I c~liF~
rcc,^,ive i:mail upclales fir your case.

?~'UY~YIHFI ~7C' ~g{~ ljdY ~d83]7~U}'311CItt t~.U~}iOP{'[.E1g10iA ~UCUP11CI1$ (F..4aQ~ r,'.X~I:l75iflil - T}lPS i10fiCF„ ~JY IISCjf, :~6CS I1UC ~fiATIT i3~Ay' i9i1i111,QaCIIh Oft J1ilf LIS U7 ~Ct1C~11~,
~i OC i~ It eVN3~.Rt.'[; 1~1a1 [h1G C SC iS Sll~~ PG~Rd71iF~,. NpWCV~I', 1~:
Yau lave tirt~i:ly filed to ra nesv your 4un~ant Form I-765 FALL; :end Ye.ir N:Af7 ren:oval is under a cate~;~ry that is eligible f'or an automatic 18~ day extension {see ~vGy~w.i~seis,~ov11-765 fc~r a list of categaries7; and • Ti:4 category t7n your current E.h[7 s7~atches ttie "Class Requested" listed orr this Notice of Action {Nola: if you are a Temporary Proi~cte:9 Status beneticiary or applicant, your F,AD and this Notice roust contain either the A f 2 or Cl9 etas,. buk they dc~ no; need t« match each ether.) rind • Yau clo oat re~Giva ~ourrenewat ~:~U bei~ai~e you7' cuarcnz EAl? ::x~irts: • Ti en this Notice of Action autoinatic~lly extends the validity of your ~;.An fix ts~ to t&~ days from the. expir~tinn date printed nn fhe~ ~aee of the card. 71' all of the at~ove eonditior~s a~~lv with respect i't~ your EAU ;en~cvul a~rplicuuon, you rzaay pry scat this ~loticc. oC r'~cti~n with your expireri LA13 io yoi.ir employ~e~r For cmplayme~~t tiligibiiity verification (Form f-4) pur}mses. If yaw• renewal appGe~tian is ~Icnie~i, thz. automatic exteosioi~ immediately terminates. and you may not provide this Notice ofActicsn with yo~ir expirzd EAD for Form 1-9 ~urp~ses. tf your t'Al~ is a combo acrd, the ~etc~rn.itic exte~isian c3aa:s net apply [~ actv~ncc parole. Fur ir~iorc inCc~rrs~ati~n, please visst our w~bsize at www.us«;is.gov/t-765.

d'rt~cessiu~ time -Processing f'srraes vary by 4"orrn t}~pe.
Visit 1vwa~.usc9s.govlprocessingtisnes to see i.he current Pr~cassin~ times ~y forni type and field of~ice ~r service center. • 1Fy~o~ do not i~eccive ~n initial decision os• u}~date within oar cun~ne processing ti~i~., You can dry our online tc~o15 available at ww~w.uscis.gc>vltools
or ask shout your case online at u-wK~.uscis.Eovle-ref,~uest. • Wl~i~;n we rsiake a Jeciaion on y~~x~r case or iPw~ need so~~eth4ng from youe we will i~otifv you by mail and updaic our s~~stems.

Yot~ can receive update; on yatir ca~c.
• Visit tl~e Case Statics Qnli~~c u~~bsste at w~~w,uscis.g4vlcasestaEu~. Pravidc your recent nun;ber~ and ~~t the latest update un youraase. • Create an accaani a, n~iy.ascis.gc~vlau:aunt an~f mceive email updates on your case.
~3io~32frics - ~Ve rcgi,t~e biarnetrics (fin~erpnnis. a pJ~oto, and a si~;n~ti.re) for some types ~C cases. !f we need biametri~s from yogi, v,~c will send you a St;YI~fZAT~ azppointrn~rt nutice with a Speei~c cake, tirr~e and pta~e fa3' you to a to ~ USC15 A~rplica;ion Support Center (ASG') kot~ biometrics processiu~. You must wait f~r'shaY separate appoint~rtient notice ~tnd take ~t {NCJT ~l~is receipt notice} to you€ ASC' appointanani alori;; with your ~I~oCo identificatioi5, Acce}~table kirzr~s ~f ~~lxatia ideniific~tior; 4nt:

A passpo~# or national photo IiJ issued b}' ~oi~r cai~ratr}~.

Ple:~se see the additional information o~ the hack. You tiviil be notified separately ahouc any other c ices you filed.

Nebraska S~:rvice; Center U. 5 ClTI7EiVSF1lP A; #M~1IGRATION S`'C P.(~ f3c~x 825? t Lincoln TdF, fiS501 2?~ I
tJSCIS C'cY:ztuct Cenker: ww w.uscss.#;avlcnntucfcc

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Zf this is an interview or Uipmetrics appointment

information.

Fonn I-797C 04/D1/]9

Case: 2:20-cv-03707-ALM-EPD Doc #: 1-1 Filed: 07/22/20 Page: 3 of 3 PAGEID #: 23

Department of Homeland Security U.S. Citizenship and Inmugration Services

Form I-79~C, Notice of Action

THIS NOTICE D(JE5 NOT GRAM ANY IMMIGRATION STATUS OR BENEFIT.

RCCCipi Number
J_-

Reccie'ed Qale..
i2i23/2019

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Yrioriiy Dntc
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Notirn Date
~zi231ryoi9 • z'tver s leeense. • .~ military plaoro ilk. or Astate-issued ~~~hoto iL~ wrd.

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±765 -APPLICATION F'OR Eiv9f'LC1Z`1vtF,NT AtiTHURt7,ATlC~N

Applfcnnt
SUBRAMA1vY,~, R,~N.IITHA

Reneti~daty
st;BRAea,wYA, xANJt`r'HA

(f you receive mire than one ASC ~ppointmenr notice fe,~en for ditferent c:a6es), ta}:e ih~m heath tc~ the first appointment date.

If your address changes - If you mnvc while yoa~r case: is pending, pfeas<: aisit ~ ww.uscis.go~/addresscl~ar~~e fc~r inf~cmaUon ~i~ ho;v to tEpdate your ~ addtcss, Rerriernbc;r fo update your address for a3f your ir~ipt oua~i~rs.

Ttci.arn of (}ri~inal Docun2ent5 - Llse Firm G-884, Regt~esC fpr the. R.efurn of (7riQiiFa1 Sigcumer~tF, to request the retua~n of o~i,g<nal dcxumei3ts su!?~nitt~~ to establish eiigi~ifity Pot ~.n irorr~igration or' citizenship b~ne~t. You only need to subrt3it oiie F"orm G-An4 if yon ace s~equestipg multiple ds7curnerzis corrCained in a fiing1~ L`SC~tS fi le. Ho~n~ever, if the requested aoci~~meaitation is in ~noro than one USCIS fiic, yoga mu,t submit a sc~~arate requcct for e.:~ch fic. tTor ex~mp3e: !f y«i~ wish iu ol7tairr v~our mother's birti7 ce~tzficatc and youe~ parents' m~nia~e certificate, both of~v}aiciy acre irz the U$C'IS file that pertains to hat,
svt~+nic anc Parj2z G-8R4 with your mother's inPorniation-)

NQ'TIt:~: Undcz'thc Insanigration mid Natit~nality Act (lNAi, the inft~rm22ioi~ voG~ provide on and in su~~poii of <~p~tilications ~t~3c3 petitia~is is submitted ender the ~:rialty of pe{jury. USCir, znci Use fJ.S. i~e~artment of homeland Security reserve the right to verify this information before andJor after making a cleaision on your cure so i~~e c:an e~~sure lIY~~Y pt~u have con7plierJ spith ~~;~iicabte In;vs, ri~Ies, r~~utarions, aa~d tatirer legal authorities. ~W~; rraay reeic~y public information rind records, cr~ntsict othe~~rs by n,~il, the interact or phone, condaci sits; inspeetio»s of businesses and residences, or~ use o~kter ruethods' c>f verification. VVe wit! rise rlae information otstai~~ed to detem~ine whether you arc eEigible for the benefit you seek_ If we f~n~ any der~gaco~y ~nfc~rmation, we ~viIl fr+llov+ the law in defcr~i,rining v✓hcti~er to provide you (arid the le~~l representative lise~:tl cn your Fof'rri G-25, iP you si~brzutied cane) ~u3 c~pportur~iC;< Sa address that Utfarmatiowz be€arc. we make ~ 4"o€ma] clecisior~ on yc>c~r case oa~ start proceedings,

Pie~se see the addiri~nal inFormacion an the back. You will bc. notified separttely about any {xher cases you tiled.

Nebiasl,a Service Cen1~r U,S CITTZP..'*7SHIPRt 1MMIfiRAT1~N,SVC I'.O i3aX825'?1 Lincoln Nr 68>01:'521
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if khis is ao interview or biometrics appointment nucice, please see the back of thfs notice for important information.

Form I-7970 0=1i0Ui9

Case: 2:20-cv-03707-ALM-EPD Doc #: 1-2 Filed: 07/22/20 Page: 1 of 1 PAGEID #: 24

Department of Homeland Securit~r tJ.S. Citizenship and Imnugration Services

Farm I-7970, Notice of Action

THIS NOTICE DOES NOT GRANT ANY IMMIGRATION STATUS OR BENEFIT.

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,,.~ I'Yease r~sclicdnle m} a~7pufnhiaectL On4:u li$CIS re~:ci~es ti our r~equr~.~, vvi~ still t~: rent to a4~u ap~uinhncnt ni~ticc. ~i.ak~ ~3 c.~p+; «f Shia nE~Ci~~° i'~r yuGfr rr~oed.,. then r~~..iil the ~~riginaf Stith 5~uur rcgneci tai 13P1.~. ,~1lciandria >~S~'. Stiiic itt(3. R~,SO Ia'i,~ht~tiar3tt Nwi. Alra~mdn.t, t'4 "_~it'~-l~Rb

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IC)'nu hr~vc xn~' gacrtson~ regarding this notice, piea~e ccac~tac# fh~s C!S['T ('untacf ['enter sat i-$i(}$1-:i75-S2ti3.
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iFthis is an Interview or biometrics appointment notice, please see the back oFthis notice for important inforroatFon.

F~rcn I-747C' U4f01l19

Case: 2:20-cv-03707-ALM-EPD Doc #: 1-3 Filed: 07/22/20 Page: 1 of 3 PAGEID #: 25

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Plc:us,; mad tl~ tsac:k r~A't~ais Bonn curcfuifp for s~orc i~~formaticza.

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iV~TICE: ,4lthoug# thl~ nfpiiC~tton nr petition has ~:n ~provecl. CiSCIS and cfic I1.S. Ih;pnrtmant nat' Homct~:9r? Security r~~rre the righH tc~ rcr~fy this infiumatic~n }aefoa., emiior after staking a decisic*a on yrxir case so we can cuaur~ that you nave ~anp~ieci wia}~ ryrpliceb[e s`aws, zutcs, regulstiors, ant4 other legs# authorities. We mscy revizw ~~rblic inform+tlion and :ecnrds, contactothcrs Du Ainii, the intemet or ~fione. c~aduct site inspections of bv4inessrs and residences, err uFe niher methotEs of verification, lie will u;e the iofnrrru~tiun obinined eta cks.r~tiizie wlxihtr yew uie eligi6Je foe the hene6t you k. it we t3ut1 any derogs~Lory irzfc~rrtastiucs, wo wi19 fcriluw rlic law in dei~rninrn~ wtret3~er to ~irovide yr>u tend the fegpt rcpresentedve listed un yous Form G-28, if }'au submitted ~n~) an ~ppcartiinity to z~ddress thnc information txfare we make a formal
cic~isirm tin your east err suu2 prcDceeclings.

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FORM 1-797A [REl6.081ai/16]

Case: 2:20-cv-03707-ALM-EPD Doc #: 1-3 Filed: 07/22/20 Page: 2 of 3 PAGEID #: 26

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Receipt Number
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Received llate
1J2312019
Notice Date
04/07/2020

USCIS Accaum Number Priorih Dale

Case Type
I765 -APPLICATION FOR EMPLOYMF,NT AUTHORI7,ATiON
Applicant

Page
1 of 1

RAN717NA SURRAMANI'A

RANJITHA SUBRAMANYA c/o CATHERINE C KANG PORTER WRIGHT MORRIS ARTHUR 41 SOUTH HIGH STREET FLR 31 COLUMBUS OH 43215

Notice Type: Approval Notice Class: C26 Valid from 04/07/2020 to 06/07/2023

We have approved your application for employment authorization. We will send your Employment Authorization Document (EAD) (also known as an EAD :.a;d ar:crm :-766) tc you scFarat;,;y.
Your EAD card is proof that you are allowed to work in the United States. Show the cazd to your employer to verify your authorization to work during the dates on the cazd. You cannot use this approval notice as proof of your employment authorization.
When you receive your EAD card, please check that all the information on the card is correct. If you need to change any information nn the card, please mail all of the following to the office listed below:
• A letter explaining what information needs to be corrected, • Your EAD card, • A photocopy of this notice, and • Evidence to show what the correct information should be. For example, if you need to correct your name, submit a copy of your birth certificate or
official name change.
If You Nave_a Pending Form1.485
]f you have a pending or approved Form I-140 and a pending Form 1-485, you may request to change employers if your Form I-485 has been pending for at least 180 days. In order to do so, you need to submit documentation about your new job offer. For more information on how to request a change of employers and what information you must submit, please visit the USCIS website at www.uscis.gov.
1f your EAD card expires before we make a final decision on your Form I-485, you may apply for a new EAD cazd.
TH1S FORM IS NOT A VISA AND MAY NUT BE USED IN PLACE OF A VISA OR EVIDENCE OF EMPLOYMENT AL,'THORIZATION.
NOTICE: Although this application or petition has been approved, USCIS and the U.S. Department of Homeland Security reserve the right to verify this information before and/or after making a decision on your case so we can ensure that you have complied with applicable laws, rules, regulations, and other legal authorities. We may review public information and records, wntact others by mail, the intemet or phone, conduct site inspections of businesses and residences, or use other methods of verification. We will use the information obtained to determine whether you are eligible for the benefit you seek. If we find any derogatory info nation, we will follow the law in determining whether to provide you (and the legal representative listed on your Form G-28, if you submitted one) an opportunity to address that information before we make a formal decision on your case or start proceedings.

Please see the additional information on the back. You will be notified separately about any other cases you filed.

Vermont Service Center U. S. CITILEI~iSHIP & IMMIGRA?ION SVC
SaintAlbans~VT 054790001

~ i ~~

~ ~

~ ~'

y

~ s

USCIS Contact Center: www.uscis.gov/co ctcenter

Exhibit C

Case: 2:20-cv-03707-ALM-EPD Doc #: 1-3 Filed: 07/22/20 Page: 3 of 3 PAGEID #: 27

,.5. tNi1 t t

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~~~'✓w ( • ~`~'~~~^~ ~~T~ • ~~~ I U.:a"~~C!TZ£N5N1P 0.MD ~~'lMtCRATtON~SE.'RVICFS

KCCCI li ~IIMhC1"
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Rrccivtd Dalc
12/23,'?Q 19
e/~nti)nceCDa/rr /~
U 7(\/\Il7\~?\l

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R:\~J~T41:\ Sl'f3R:1~L~~'\',\.

RE~NJITHA SUBRANIANYA ct'o CA'J~HEFtINE L Kr1NG PORTER WRIGHI' N10RRIS ARTHUR 41 SOUTI i I-iIGI-3 S'1'RLET FI_R ;1 COLUh'[BUS OH 43? l:i

~totiec Type: Appro~~al Notice Class: C26 Valid from 0=1!07%2020 to Q6:'07-?023

~i'e ba~•c approved }'our application for cmpioymeni authorization. ~1'c ~~~ill scnd }'our [:mpto~ ment .luthoriration Document (L-'AU) (al>o kni~~cn a~ an
r:,nG~~ ~~r~ ~~ roan c-~~,~,~ ~o ,:t,~ s~n~<<u~i~.
four L-.AD rard is prncaf that ~~ou sue :il)ut+cd to aurk in the l;nited Statcs. 5ho~v the card to }our emplu~cr to ~•crifv your authonration tt~ ~~ork during the dzites nn the card. Yau cannot use this approval notice as ~raofof ti~c~ur empin~ meat authorization.
~~'hen ~•ou recei~~c dour E:AD card. plLase check that alI the informaticm on the card is ciirzect. If~ou need to chvi_c an} inionnatic~n on the card, pleaise m:sit all oCthe follo~~•ine to the t>(Ticc listed Mclut~'
• A Ieuer es}alaining n-hat intormatiian needs to he currcctcd, four EAD card.
• A photocopy ul this notice, and • [ videnec to show .chat the correct in~ormatian should be. 1'or eaant~rle, if you need to corrccl ~~aur n.ime, submit 7 copy of}'ow birth certificate e7r
o(Tcial name ch~mee.
~,f _~_QU._~~~if~l 8 ~t'lldllla {'C1ff11,~~K$
lfyou ha~~e a pending arappro~•cd 1~urrn t-140 and a pending Pomi I-4fii, ~'ou may requ~~t to ch~rrge employers if}uur farm t-48~ has been pending f'or at Ieast I S(.) da}s. In order to do ;o. 1ou need to submit docunyematian about }'our new,job o17er. Fur more infomiaticm m7 ho~v to request a chan;e of empleycr and ghat information you must submit, plcsuc visit the USA1S H~ebsite at ~~~i~~~~~.uscis:_ov.
tf~rour F..AD card expires before ~~~e make a final decision un your Form 1.48 , yciu ma}~ apply fer a n~~ti EAD card.
THIS FOftAJ 15 NO'T A 1'lS:1 ~'~\D i►G11'' \OT t3E USED 1ti PLAC:f: OF A ~'IS:~ OR EVIDENCE OF E':1fNI.01'\[ENT AL`THORI/,:l"('IOV.
10TIC'E: Althnugh this application or petition has been apprv~~ed, USCI5 and the U.S. Department of Homeland Security reserve the right to ~-crify this information 6eforc anchor alter makim~ a d~cisiun un yi.~ur case so ~+'c can ensure thrt you have complied tivith applicable la~~~s. rules, rceula~inns, :aid other legal authorities. 41~`c may reti•ie~~~ public inti~rm~Uan and records. contact others by mail. the intcmet or phone, conduct site inspections of businesses and residences, or use other methods c~('~~crificatinn. We gilt use the infi~rmation obtained to determine whether }~ou are cligihl4 ibr the brnetit you seek. ifwc lin~1 any dercie!atory inii>rmaN~~n, u~c t~~ilt ["t~llo~e the tau in detcrminin~ whother to provide yt~u (and tltc legal rcpres'entativetisted cfn ~~our Form G-?&. if~y~~u submiucd one) an opportunity [o address that inliirmation before gee mail:e a formal decisi~~n on }our case or strut procecdu~gs

Please sec the additional inJorniation on the hack. You ~~ill be notilicd separately about am other cases you ailed.

Vermont Sen~ice C'cnter

U. S. CITIZ[TvSI i1P & 11~1?~11CiRATiOP' SVC

f~

Saint Alba~cV1 T OS~t79t0001

~

l',S('IS Contact Center. K~ti'n.uscis.~;ovlcontact enter

Exhibit C

1
F(JRM S-7`"37 3_r~~V.CIal01/3CiI

Case: 2:20-cv-03707-ALM-EPD Doc #: 1-4 Filed: 07/22/20 Page: 1 of 4 PAGEID #: 28

11~Y1111U8~'. wily ] ~..:~~~}
KA'~G, c~~isxr~ti~v~ r~rtT~r~ ti~~~r~~c~~~i~ ~rc~a~~ttts ~r~7~t ~~~1~~ ~:~.~>
a i S HIGI i ST FL 31

'~°`~~`.;r'_ ~~~

U.S, Depmrtment of 8omeland Security \'I:R~lON7' SI:R1~'tCF~ ~i\1'f 12 731.011'F~ft 117:LnG\ STRF3[:7" 5,=11N'I° ALI~:1N5,~'"1' U~~7~)
L'.S. Citizenship and ~~Y~rnigration Services

ATTORNEY COPY IL~l~~Ji'I~It,~1 SUf~RA~1~\Y~

OH =i3~!!!!!

t7rar Ita~~jitha ~abr~tmanya; C7n U~i~~r20?Q, yoti car tl~c cicsignatc~i re~u-~scnt~iti~=c sht7~vn befo~ti•, coi~t~~ctcc~ us ~bcxat your case. Sc~mc or the kcy ii~t'c~rr~tati~~r~ ~i~~en tea t~s .~t that time c~R;~s th4 ic~llai~~i~~g:

Person who contacted us: Caller indicated they are. Attorney Name: Case type.
F~IIA~ CIAfB:
Receipt #: Referral ID: BeneSciary (if you filed fos someone eise): Your USCIS Account Number {A-number): 'Type of service requested:

Kc~n~, Catlerinc Attorney car Ai~tlrr~rizccl IZe~resc~at;~ti~x
17~i5 1 ~?;%23r'2U i 9 I_I \~ Slt 1 # 2i?~}QOCi2U'~SC. lnformati~n not a~~aitablc Inti7rmation nut avaikubic iti'on-I~cli~-ery of I3~~~ploym~i~t ~uth~riz~ti~n Caryl

'1'Ia4 stixti~s crYtlai service t~ec~u:;st .s:

~~4 ~►r~ senctin~ yvur case fur rcvie~~~. It is not nccrssary t~ ~iib«iit m~tltiplc t•e~lu~sis fnr carrcctivc ,~ctic~tt, Your rc~lucst fc~r a revic~~~ c>f thi,~ rtj~~alicatit>nlp~titic>n tivill ta,~ cc~m~alcteci .~s c~uickfy ~~s c~nr resa~u-~cs ailc~n~. I~'1c~sc nllt~~v a ~I~inniinum cif G(1 da~~s ft~r ~Itis oCfitc to recauest, rccriv~ and revic~+~ the tile.

{7nlinc; Services `I'o stay current on your case w>e l~~vc traui~ to Iycl~.~ >'ou <zt ~+=ti~1ti°.~r ;~ is.gc~~~lti~n~s .u~d m}.~iscis.~~a~, i~tcluc~i~rg: Sign up for aur~>matic case: updates in niyl~SC.tS: iny.uscis.~r~~k,"account
~S~QIU` V1I'fUc~~ 2Stilti'IU11t ~111111A: til'VV1V,LISGIti.f'(a1~e"C111T1]:t
Check Xacu~ case status: ~~~~ti~~v.uscs.gov/casestatus (.;heck groccssing tiilic : ~v~~~~~F.uscis.~cavtprc~ccssingiimcs :1cldress C'hans~es: If y~7u m~,v~, please ~risit u~~~~~v.uscis.~o~~.'addresschan~,e f'or information on hUw to ttpciate your ~~ciclress. (2en~ember tea update va«r address fcrr all ~~our receipt ni~mbcrs. It~you Ir} ot~r t~ttlinc tnn14 ~i~ci still ~u;~~! hcl~i, a~lCaai call the CJ~C:;IS Ca~7t~ict C~.nt~r t ~,U(1-37~-~2~43 ar 500-767-15'~~ ("1'C?l~ 1'i~r the
Exhibit D
u~s. cis -c,~_~~=zc~~a ~~~:-~r, nti1~ cur • ~.~~-zo-~~~ a-spar,►

Case: 2:20-cv-03707-ALM-EPD Doc #: 1-4 Filed: 07/22/20 Page: 2 of 4 PAGEID #: 29
lticaring impairccl), 7'h~~nk you fir your n~gttiry. We ~p~reciate your continual ~a~iticncc.
. Exhibit D U.S. GS - t)5- I ~+-"?03f) ~S:;b ~~~1 C7:)7' - L.IU-2D•0i0-?

Case: 2:20-cv-03707-ALM-EPD Doc #: 1-4 Filed: 07/22/20 Page: 3 of 4 PAGEID #: 30

Kang, Catherine C.
From: Sent: To: Subject:

USCIS <USCIS-CaseStatus@dhs.gov> Wednesday, July 8, 2020 9:48 AM Kang, Catherine C. #EXT# Your recent inquiry (receipt #LIN-20--1) (Attorney/paralegal copy of customer communication)

#External Email#

U.S. Department of Homeland Security VERMONT SERVICE CENTER 75 LOWER WELDEN STREET SAINT ALBANS,VT 05479

U.S. Citizenship and Immigration Services Wednesday, July 8, 2020

Emailed to ckang@porterwright.com

Dear Ranjitha Subramanya:

On 06/26/2020, you or the designated representative shown below, contacted us about your case. Some of the key information given to us at that time was the following:

Person who contacted us: -- Kang, Catherine

Caller indicated they are: -- Attorney or Authorized Representative

Attorney Name: -- KANG, CATHERINE

Case type: -- 1765

Filing date: -- 12/23/2019

Receipt #: "LIN--
Re

Beneficiary (if you filed for someone else): -- Information not available

Your USCIS Account Number (A-number):
1

Exhibit D

Case: 2:20-cv-03707-ALM-EPD Doc #: 1-4 Filed: 07/22/20 Page: 4 of 4 PAGEID #: 31
-- Information not available Type of service requested: -- Non-Delivery of Employment Authorization Card
The status of this service request is: A review of U.S. Citizenship and Immigration Services (USCIS) records indicates your Form I-765, Application for Employment Authorization, was re-approved on July 6, 2020. As of the date of this letter, your Employment Authorization Document was in production. If you do not receive your card within 30 days, please contact the USCIS Contact Center at 1-800-375-5383. We hope this information is helpful to you. ----------------------------------Online Services To stay current on your case, we have tools to help you at www.uscis.gov/tools and my.uscis.gov, including: Sign up for automatic case updates in myUSCIS: my.uscis.gov/account Ask our virtual assistant Emma: www.uscis.gov/emma Check your case status: www.uscis.gov/casestatus Check processing times: www.uscis.gov/processingtimes Address Changes: If you move, please visit www.uscis.gov/addresschange for information on how to update your address. Remember to update your address for all your receipt numbers. If you try our online tools and still need help, please call USCIS Contact Center at 800-375-5283 or 800-767-1833 (TDD for the hearing impaired). Thank you for your inquiry. We appreciate your continued patience.
Exhibit D

ClassAction.org
This complaint is part of ClassAction.org's searchable class action lawsuit database and can be found in this post: USCIS Faces Class Action Over Months-Long Work Permit Printing Delays

 
 Case: 2:20-cv-03707-ALM-EPD Doc #: 53 Filed: 08/18/20 Page: 1 of 3 PAGEID #: 429

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO
EASTERN DIVISION

RANJITHA SUBRAMANYA, individually :

and on behalf of a class of those similarly

: Case No. 2:20-CV-3707

situated, et al.,

:

: Chief Judge Algenon L. Marbley

Plaintiffs,

:

: Magistrate Judge Deavers

vs.

:

:

UNITED STATES CITIZENSHIP AND

: JOINT STATUS REPORT REGARDING

IMMIGRATION SERVICES, et al.,

: PARTIES’ PROPOSED CONSENT

: ORDER, PURSUANT TO NOTATION

Defendants.

: ORDER (ECF NO. 51)

On August 5, 2020, counsel for Plaintiffs and Defendants filed a request to continue the preliminary injunction hearing scheduled for August 10, 2020 until August 24, 2020 so that the parties will have time to negotiate a consent order to resolve the claims at issue in Plaintiffs’ complaint. ECF No. 45. On August 6, 2020, this Court granted the Parties’ motion to continue. ECF No. 46.
On August 10, 2020 counsel for Plaintiffs and Defendants filed a “Joint Motion for Magistrate Judge Mediated Negotiations for Consent Order,” “so that the parties will have time to negotiate a consent decree to resolve the claims at issue in Plaintiffs’ complaint.” ECF No. 47.
On or about August 11, 2020 a settlement conference began before Chief Magistrate Judge Elizabeth A. Preston Deavers, by phone, pursuant to “Notice of Hearing.” ECF No. 48; see also ECF No. 49, “Minute Entry for proceedings held before Magistrate Judge Elizabeth Preston Deavers: Settlement Conference held on 8/12/2020. Negotiations not at impasse. Parties continue to confer.”; ECF No. 50, “Minute Entry for proceedings held before Magistrate Judge Elizabeth Preston Deavers: Continued mediation held on 8/13/2020. Parties continuing to mediate.”

1

Case: 2:20-cv-03707-ALM-EPD Doc #: 53 Filed: 08/18/20 Page: 2 of 3 PAGEID #: 430

On August 17, 2020, this Court issued the following “Notation Order”: Joint Status Report regarding status, but not substance of settlement negotiations due by 8/18/2020. By Magistrate Judge Elizabeth Preston Deavers on 8/13/2020. ECF No. 51. Counsel for Plaintiffs and Defendants report that they have come to agreement in principle upon material terms comprising a full resolution of Plaintiffs’ claims. The Parties respectfully request of this Court the opportunity to finalize a “proposed consent order,” for this Court’s consideration, review, and order, not later than 5:00p.m., Thursday, August 20, 2020. This extension of the opportunity to negotiate full resolution will not alter or delay the timeline and associated deadlines adopted by this Court pursuant to Order, but, rather, is intended to serve the interest of all parties, conserve the resources of this Court, and advance judicial economy by obviating the need for the Preliminary Injunction Hearing and/or hearing on the merits, and order upon same. ECF No. 46.

Respectfully submitted,
DAVID M. DEVILLERS United States Attorney
s/Christopher R. Yates CHRISTOPHER R. YATES (0064776) Assistant United States Attorney 303 Marconi Boulevard, Suite 200 Columbus, Ohio 43215 E-mail: christopher.yates@usdoj.gov
Attorney for Defendants

s/Caroline H. Gentry__________________ CAROLINE H. GENTRY (0066136) Porter Wright Morris & Arthur LLP One South Main Street, Suite 1600 Dayton, Ohio 45402 E-mail: cgentry@porterwright.com
and
Robert H. Cohen (0009216) David P. Shouvlin (0066154) Kirsten R. Fraser (0093951) Porter Wright Morris & Arthur LLP 41 South High Street, Suites 2800-3200 Columbus, Ohio 43215 E-mail: rcohen@porterwright.com E-mail: dshouvlin@porterwright.com
2

Case: 2:20-cv-03707-ALM-EPD Doc #: 53 Filed: 08/18/20 Page: 3 of 3 PAGEID #: 431 E-mail: kfraser@porterwright.com and Ana P. Crawford (0090581) Porter Wright Morris & Arthur LLP 250 East Fifth Street, Suite 2200 Cincinnati, Ohio 45202 Email: acrawford@porterwright.com Attorneys for Plaintiffs
3

 
 Case: 2:20-cv-03707-ALM-EPD Doc #: 55 Filed: 08/21/20 Page: 1 of 17 PAGEID #: 451

Case: 2:20-cv-03707-ALM-EPD Doc #: 55 Filed: 08/21/20 Page: 2 of 17 PAGEID #: 452

Case: 2:20-cv-03707-ALM-EPD Doc #: 55 Filed: 08/21/20 Page: 3 of 17 PAGEID #: 453

Case: 2:20-cv-03707-ALM-EPD Doc #: 55 Filed: 08/21/20 Page: 4 of 17 PAGEID #: 454

Case: 2:20-cv-03707-ALM-EPD Doc #: 55 Filed: 08/21/20 Page: 5 of 17 PAGEID #: 455

Case: 2:20-cv-03707-ALM-EPD Doc #: 55 Filed: 08/21/20 Page: 6 of 17 PAGEID #: 456

Case: 2:20-cv-03707-ALM-EPD Doc #: 55 Filed: 08/21/20 Page: 7 of 17 PAGEID #: 457

Case: 2:20-cv-03707-ALM-EPD Doc #: 55 Filed: 08/21/20 Page: 8 of 17 PAGEID #: 458

Case: 2:20-cv-03707-ALM-EPD Doc #: 55 Filed: 08/21/20 Page: 9 of 17 PAGEID #: 459

Case: 2:20-cv-03707-ALM-EPD Doc #: 55 Filed: 08/21/20 Page: 10 of 17 PAGEID #: 460

Case: 2:20-cv-03707-ALM-EPD Doc #: 55 Filed: 08/21/20 Page: 11 of 17 PAGEID #: 461

Case: 2:20-cv-03707-ALM-EPD Doc #: 55 Filed: 08/21/20 Page: 12 of 17 PAGEID #: 462

Case: 2:20-cv-03707-ALM-EPD Doc #: 55 Filed: 08/21/20 Page: 13 of 17 PAGEID #: 463

Case: 2:20-cv-03707-ALM-EPD Doc #: 55 Filed: 08/21/20 Page: 14 of 17 PAGEID #: 464

Case: 2:20-cv-03707-ALM-EPD Doc #: 55 Filed: 08/21/20 Page: 15 of 17 PAGEID #: 465

Case: 2:20-cv-03707-ALM-EPD Doc #: 55 Filed: 08/21/20 Page: 16 of 17 PAGEID #: 466

Case: 2:20-cv-03707-ALM-EPD Doc #: 55 Filed: 08/21/20 Page: 17 of 17 PAGEID #: 467

 
 Case: 2:20-cv-03707-ALM-EPD Doc #: 57 Filed: 09/09/20 Page: 1 of 3 PAGEID #: 471

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO
EASTERN DIVISION

RANJITHA SUBRAMANYA, individually :

and on behalf of a class of those similarly

: Case No. 2:20-CV-3707

situated, et al.,

:

: Chief Judge Algenon L. Marbley

Plaintiffs,

:

: Magistrate Judge Deavers

vs.

:

:

UNITED STATES CITIZENSHIP AND

: DEFENDANTS’ REPORT PURSUANT

IMMIGRATION SERVICES, et al.,

: TO CONSENT ORDER (ECF No. 55),

: SEPTEMBER 9, 2020

Defendants.

:

In accordance with the Consent Order, proposed by the Parties, signed and entered by this
Court, (ECF No. 54, filed 8/19/2020; ECF No. 55, filed 8/21/2020), Defendants submit the
following Report for September 9, 2020, as described at Section IV. AGREED UPON TIMELINE,
of that Consent Order1:
10. Subject to Section VI. 16. and 18., Defendants agree to comply with the following Benchmarks: a. By August 21, 2020, Defendants will provide Plaintiffs’ Counsel and will file the aggregate data for the Putative Class Members. This data will include the aggregate number of Putative Class Members who are seeking an EAD based on a (c)(8) classification in Subclass 2. Defendants will provide Plaintiffs’ Counsel and will file updated aggregate data on September 9, 2020 and September 30, 2020.

1 All capitalized terms not defined herein are accorded the meanings ascribed to them in the Consent Order. ECF No. 55.
1

Case: 2:20-cv-03707-ALM-EPD Doc #: 57 Filed: 09/09/20 Page: 2 of 3 PAGEID #: 472

Aggregate Data for Putative Class Members Reporting of September 9, 2020

Total Putative Class Members

On August 20, 2020, USCIS created the Putative Class List which it will use to provide the reports required under Section V of the Consent Order. On that date, there were a total of 45,5652 receipt
numbers meeting the definition of the two subclasses, as further identified below.

EADs Not Yet Produced

Date August 20, 2020

Subclass 1 27,829

Subclass 2 All Categories
17,736

Subclass 2 (C08 Only)
4,102

EADs Produced3
Date August 20, 2020 September 9, 2020

Subclass 1
0 27,8294

Subclass 2 All Categories
0 12,7175

Subclass 2 (C08 Only)
0
2,4286

2 This number represents the total number of receipt numbers meeting the definition of Putative Class Member. There could be more than one receipt number associated with an individual Putative Class Member.
3 The term Putative Class Member means an alien who resides in the United States, who has submitted a Form I-765 to USCIS, whose Form I-765 USCIS was approved on or after December 1, 2019, and whose Employment Authorization Document has not been Produced at the time the Putative Class List was generated. Accordingly, at the time the Putative Class List was generated on August 20, 2020, USCIS had not yet produced any EADs for the Putative Class Members. Importantly, by August 20, 2020, USCIS had Produced EADs for all Plaintiffs.
4 USCIS produced all Subclass 1 EADs within 7 business days of the execution of the Consent Order by Defendants’ Counsel and Plaintiffs’ Counsel. Initially, there were 131 EADs that did not meet the USCIS quality assurance standards for card production (e.g., photo too light, photo too dark). See Consent Order Section IV.11.a. Since that time, USCIS has been working to correct the defects identified for these EADs. As of September 9, 2020, the defect in all but 6 of these EADs have been corrected and the EADs were Produced.
5 Of the 12,717 Subclass 2 EADs produced, more than 98 percent were produced within 7 business days of biometric capture. As of September 9, 2020, 102 of the produced EADs do not meet the USCIS quality assurance standards for card production (e.g., photo too light, photo too dark). See Consent Order Section IV.11.a. USCIS is working to correct these defects.
6 Of the 2,428 Subclass 2 C08 EADs produced, more than 99 percent were produced within 7 business days of biometric capture. As of September 9, 2020, 18 of the produced EADs do not meet the USCIS quality assurance standards for card production (e.g., photo too light, photo too dark). See Consent Order Section IV.11.a. USCIS is working to correct these defects.
2

Case: 2:20-cv-03707-ALM-EPD Doc #: 57 Filed: 09/09/20 Page: 3 of 3 PAGEID #: 473
Respectfully submitted, DAVID M. DEVILLERS United States Attorney s/Christopher R. Yates CHRISTOPHER R. YATES (0064776) Assistant United States Attorney 303 Marconi Boulevard, Suite 200 Columbus, Ohio 43215 E-mail: christopher.yates@usdoj.gov Attorney for Defendants
CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing was filed on the 9th day of September 2020, using the Court’s CM/ECF system, which will notify all counsel of record.
s/Christopher R. Yates CHRISTOPHER R. YATES (0064776) Assistant United States Attorney
3

 
 Case: 2:20-cv-03707-ALM-EPD Doc #: 58 Filed: 09/30/20 Page: 1 of 3 PAGEID #: 474

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO
EASTERN DIVISION

RANJITHA SUBRAMANYA, individually :

and on behalf of a class of those similarly

: Case No. 2:20-CV-3707

situated, et al.,

:

: Chief Judge Algenon L. Marbley

Plaintiffs,

:

: Magistrate Judge Deavers

vs.

:

:

UNITED STATES CITIZENSHIP AND

: DEFENDANTS’ REPORT PURSUANT

IMMIGRATION SERVICES, et al.,

: TO CONSENT ORDER (ECF No. 55),

: SEPTEMBER 30, 2020

Defendants.

:

In accordance with the Consent Order, proposed by the Parties, signed and entered by this
Court, (ECF No. 54, filed 8/19/2020; ECF No. 55, filed 8/21/2020), Defendants submit the
following Report for September 30, 2020, as described at Section IV. AGREED UPON
TIMELINE, of that Consent Order1:
10. Subject to Section VI. 16. and 18., Defendants agree to comply with the following Benchmarks: a. By August 21, 2020, Defendants will provide Plaintiffs’ Counsel and will file the aggregate data for the Putative Class Members. This data will include the aggregate number of Putative Class Members who are seeking an EAD based on a (c)(8) classification in Subclass 2. Defendants will provide Plaintiffs’ Counsel and will file updated aggregate data on September 9, 2020 and September 30, 2020. Pursuant to Section V. REPORTING, 13. and 14. of the Consent Order, and the results of the
following Report for September 30, 2020, Defendants “will file a Report on October 9, 2020 and
every 7 days thereafter until Defendants have Produced and Mailed EADs for all individuals on
the Putative Class List.” See ECF No. 55, PAGEID #: 460.

1 All capitalized terms not defined herein are accorded the meanings ascribed to them in the Consent Order. ECF No. 55. 1

Case: 2:20-cv-03707-ALM-EPD Doc #: 58 Filed: 09/30/20 Page: 2 of 3 PAGEID #: 475

Aggregate Data for Putative Class Members Reporting of September 30, 2020

Total Putative Class Members

On August 20, 2020, USCIS created the Putative Class List which it will use to provide the reports required under Section V of the Consent Order. On that date, there were a total of 45,5652 receipt
numbers meeting the definition of the two subclasses, as further identified below.

EADs Not Yet Produced

Date August 20, 2020

Subclass 1 27,829

Subclass 2 All Categories
17,736

Subclass 2 (C08 Only)
4,102

EADs Produced3
Date August 20, 2020 September 9, 2020 September 30, 2020

Subclass 1
0 27,829 27,8294

Subclass 2 All Categories
0 12,717 15,1775

Subclass 2 (C08 Only)
0
2,428 3,7566

2 This number represents the total number of receipt numbers meeting the definition of Putative Class Member. There could be more than one receipt number associated with an individual Putative Class Member.
3 The term Putative Class Member means an alien who resides in the United States, who has submitted a Form I-765 to USCIS, whose Form I-765 USCIS approved on or after December 1, 2019, and whose Employment Authorization Document has not been Produced at the time the Putative Class List was generated. Accordingly, at the time the Putative Class List was generated on August 20, 2020, USCIS had not yet produced any EADs for the Putative Class Members. Importantly, by August 20, 2020, USCIS had Produced EADs for all Plaintiffs.
4 USCIS produced all Subclass 1 EADs within 7 business days of the execution of the Consent Order by Defendants’ Counsel and Plaintiffs’ Counsel. Initially, there were 131 EADs that did not meet the USCIS quality assurance standards for card production (e.g., photo too light, photo too dark). See Consent Order Section IV.11.a. Since that time, USCIS has been working to correct the defects identified for these EADs. As of September 30, 2020, the defect in all but 4 of these EADs have been corrected and the EADs were Produced.
5 Of the 15,177 Subclass 2 EADs produced, more than 98 percent were produced within 7 business days of biometric capture. As of September 30, 2020, 15 of the produced EADs do not meet the USCIS quality assurance standards for card production (e.g., photo too light, photo too dark). See Consent Order Section IV.11.a. USCIS is working to correct these defects.
6 Of the 3,756 Subclass 2 C08 EADs produced, more than 99 percent were produced within 7 business days of biometric capture. As of September 30, 2020, 6 of the produced EADs do not meet the USCIS quality assurance standards for card production (e.g., photo too light, photo too dark). See Consent Order Section IV.11.a. USCIS is working to correct these defects.
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Case: 2:20-cv-03707-ALM-EPD Doc #: 58 Filed: 09/30/20 Page: 3 of 3 PAGEID #: 476
Respectfully submitted, DAVID M. DEVILLERS United States Attorney s/Christopher R. Yates CHRISTOPHER R. YATES (0064776) Assistant United States Attorney 303 Marconi Boulevard, Suite 200 Columbus, Ohio 43215 E-mail: christopher.yates@usdoj.gov Attorney for Defendants
CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing was filed on the 30th day of September 2020, using the Court’s CM/ECF system, which will notify all counsel of record.
s/Christopher R. Yates CHRISTOPHER R. YATES (0064776) Assistant United States Attorney
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