Case 1:25-cv-00166-JMC Document 1 Filed 01/20/25 Page 1 of 30
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`UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF COLUMBIA
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`JERALD LENTINI,
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`and
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`Civil Action No. 1:25-cv-00166
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`JOSHUA ERLICH,
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`NATIONAL SECURITY COUNSELORS, *
`INC.,
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`1451 Rockville Pike
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`Suite 250
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`Rockville, MD 20852
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`Plaintiffs,
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`DEPARTMENT OF GOVERNMENT
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`EFFICIENCY, an advisory committee
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`utilized by the Office of Management and *
`Budget, the Office of Personnel
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`Management, and the Executive Office of *
`the President
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`1155 F Street, NW
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`Washington, DC 20004,
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`OFFICE OF MANAGEMENT AND
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`BUDGET
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`725 17th Street, NW
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`Washington, DC 20503,
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`OFFICE OF PERSONNEL
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`MANAGEMENT
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`1900 E Street, NW
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`Washington, DC 20415,
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`Case 1:25-cv-00166-JMC Document 1 Filed 01/20/25 Page 2 of 30
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`EXECUTIVE OFFICE OF THE
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`PRESIDENT
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`1600 Pennsylvania Avenue, NW
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`Washington, DC 20500,
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`ELON MUSK, in his official capacity as
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`Co-Chair of the Department of
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`Government Efficiency
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`1155 F Street, NW
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`Washington, DC 20004,
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`VIVEK RAMASWAMY, in his official
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`Capacity as Co-Chair of the Department
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`of Government Efficiency
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`1155 F Street, NW
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`Washington, DC 20004,
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`RUSSELL VOUGHT, in his official
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`capacity as Director of the Office of
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`Management and Budget
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`725 17th Street, NW
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`Washington, DC 20503,
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`SCOTT KUPOR, in his official capacity
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`as Director of the Office of Personnel
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`Management
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`1900 E Street, NW
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`Washington, DC 20415,
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`and
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`DONALD TRUMP, in his official capacity *
`as President of the United States
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`1600 Pennsylvania Avenue, NW
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`Washington, DC 20500,
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`Defendants.
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`Case 1:25-cv-00166-JMC Document 1 Filed 01/20/25 Page 3 of 30
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`COMPLAINT
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`Plaintiffs Jerald Lentini, Joshua Erlich, and National Security Counselors, Inc., bring this
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`action against Defendants pursuant to the Federal Advisory Committee Act (“FACA”), 5 U.S.C.
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`app. 2 §§ 1-16, the Administrative Procedure Act (“APA”), 5 U.S.C. § 701, et seq., the
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`Mandamus Act, 28 U.S.C. § 1361, the Federal Declaratory Judgment Act, 28 U.S.C. § 2201, and
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`the All Writs Act, 28 U.S.C. § 1651. Plaintiffs seek mandamus relief compelling Defendants to
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`comply with the nondiscretionary requirements of FACA, a declaration that Defendants have
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`violated FACA, and other declaratory and injunctive relief which would have the effect of
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`prohibiting Defendant Department of Government Efficiency (“DOGE”) from operating
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`further—and prohibit Defendants Office of Management and Budget, Office of Personnel
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`Management, and Executive Office of the President from interacting with DOGE—until DOGE
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`has complied with FACA.
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`JURISDICTION
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`1.
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`This Court has both subject matter jurisdiction over this action and personal
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`jurisdiction over Defendants pursuant to 5 U.S.C. § 704 and 28 U.S.C. §§ 1331, 1361.
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`VENUE
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`2.
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`Venue is appropriate under 28 U.S.C. § 1391.
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`PARTIES
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`3.
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`Plaintiff Jerald Lentini (“Lentini”) is a U.S. citizen and a resident of the state of
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`Connecticut.
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`4.
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`Plaintiff Joshua Erlich (“Erlich”) is a U.S. citizen and a resident of the
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`Commonwealth of Virginia.
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`3
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`Case 1:25-cv-00166-JMC Document 1 Filed 01/20/25 Page 4 of 30
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`5.
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`Plaintiff National Security Counselors, Inc. (“NSC”) is a non-profit public interest
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`law firm incorporated in 2010 in the Commonwealth of Virginia as a tax-exempt charitable
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`organization. Since 2009, NSC has represented federal employees (including national security
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`employees) in administrative and litigation matters, as well as engaging in litigation and public
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`advocacy related to national security, accountability, and transparency.
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`6.
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`Lentini, Erlich, and NSC have a direct interest in the integrity, balance, and
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`legitimacy of DOGE, and in preventing the proposal or enactment of any policies that would
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`adversely affect federal employees (including national security employees), unions, government
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`accountability, or transparency.
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`7.
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`DOGE is an advisory committee established by Defendants Elon Musk (“Musk”),
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`Vivek Ramaswamy (“Ramaswamy”), and President-Elect Donald Trump on 12 November 2024
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`and subsequently and continuingly utilized by Defendants Office of Management and Budget
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`(“OMB”), Office of Personnel Management (“OPM”), and Executive Office of the President
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`(“EOP”) beginning at 12:00 PM on 20 January 2025.
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`8.
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`Defendant OMB is a federal agency which utilizes DOGE. DOGE is subject to
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`oversight by OMB employees, who exercise decisionmaking authority over matters related to
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`DOGE’s work.
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`9.
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`Defendant OPM is a federal agency which utilizes DOGE. DOGE is subject to
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`oversight by OPM employees, who exercise decisionmaking authority over matters related to
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`DOGE’s work.
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`10.
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`Defendant EOP is a Federal Government office which utilizes DOGE. DOGE is
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`subject to oversight by EOP employees, who exercise decisionmaking authority over matters
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`related to DOGE’s work.
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`4
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`Case 1:25-cv-00166-JMC Document 1 Filed 01/20/25 Page 5 of 30
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`11.
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`Defendant Musk is Co-Chair of DOGE. He is being sued in his official capacity
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`only.
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`12.
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`Defendant Ramaswamy is Co-Chair of DOGE. He is being sued in his official
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`capacity only.
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`13.
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`Defendant Russell Vought (“Vought”) is, as of this writing, President Trump’s
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`nominee to be Director of OMB. Once he is confirmed by the Senate, Vought will exercise
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`decisionmaking authority over matters related to DOGE’s work. He is being sued in his official
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`capacity only.
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`14.
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`Defendant Scott Kupor (“Kupor”) is, as of this writing, President Trump’s
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`nominee to be Director of OPM. Once he is confirmed by the Senate, Kupor will exercise
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`decisionmaking authority over matters related to DOGE’s work. He is being sued in his official
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`capacity only.
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`15.
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`Defendant Trump is the President of the United States. As head of the Executive
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`Office of the President and the Executive Branch, Trump will exercise decisionmaking authority
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`over matters related to DOGE’s work. He is being sued in his official capacity only.
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`BACKGROUND
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`PART I: STATUTORY AND REGULATORY FRAMEWORK
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`16.
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`FACA was intended to address congressional concerns with the growing number
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`and use of advisory committees. Congress found, among other things, that committees “should
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`be established only when they are determined to be essential” and that “Congress and the public”
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`should be kept abreast of their activities. “FACA’s principal purpose was to establish procedures
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`aimed at enhancing public accountability of federal advisory committees.”
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`Case 1:25-cv-00166-JMC Document 1 Filed 01/20/25 Page 6 of 30
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`17.
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`FACA applies to “any committee, board, commission, council, conference, panel,
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`task force, or other similar group, or any subcommittee or other subgroup thereof . . . established
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`or utilized by one or more agencies . . . in the interest of obtaining advice or recommendations
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`for the President or one or more agencies or officers of the Federal Government,” denominating
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`such groups as “advisory committees.”
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`18.
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`Only those committees which are “composed wholly of full-time, or permanent
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`part-time, officers or employees of the Federal Government” or “created by the National
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`Academy of Sciences or the National Academy of Public Administration” fall outside the
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`definition of “advisory committee” under the Act.
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`19.
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`All of the provisions of FACA apply to advisory committees except when an “Act
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`of Congress establishing any such advisory committee specifically provides otherwise.”
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`20.
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`FACA requires “the membership of the advisory committee to be fairly balanced
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`in terms of the points of view represented and the functions to be performed by the advisory
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`committee” and “that the advice and recommendations of the advisory committee will not be
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`inappropriately influenced by the appointing authority or by any special interest, but will instead
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`be the result of the advisory committee’s independent judgment.”
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`21.
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`FACA’s implementing regulations, promulgated by the General Services
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`Administration (“GSA”), require each advisory committee to have a plan to attain fairly balanced
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`membership. The plan must “ensure that, in the selection of members for the advisory committee,
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`the agency will consider a cross-section of those directly affected, interested, and qualified, as
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`appropriate to the nature and functions of the advisory committee. Advisory committees requiring
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`technical expertise should include persons with demonstrated professional or personal
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`qualifications and experience relevant to the functions and tasks to be performed.”
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`Case 1:25-cv-00166-JMC Document 1 Filed 01/20/25 Page 7 of 30
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`22.
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`The charter of each advisory committee must be filed by the “Committee
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`Management Officer designated in accordance with section 8(b) of the Act, or . . . another agency
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`official designated by the agency head.”
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`23.
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`No advisory committee “shall meet or take any action until an advisory committee
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`charter has been filed with . . . the head of the agency to whom any advisory committee reports
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`and with the standing committees of the Senate and of the House of Representatives having
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`legislative jurisdiction of such agency.” The advisory committee charter must also be filed with
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`the Library of Congress and the GSA Committee Management Secretariat.
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`24.
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`Each advisory committee must also have a Designated Federal Officer (“DFO”)
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`designated by the agency head. A committee’s DFO is responsible for calling meetings of the
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`committee, approving the agenda for all committee meetings, attending meetings, adjourning any
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`meeting when they determine it to be “in the public interest,” and chairing the meeting when
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`directed by the agency head.
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`25.
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`FACA demands transparency in the procedures and meetings of advisory
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`committees. All advisory committee meetings must be open to the public and must be timely
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`noticed in the Federal Register. Meetings must be noticed in the Federal Register at least fifteen
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`days before the meeting is to be held.
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`26.
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`Interested members of the public must “be permitted to attend, appear before, or
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`file statements with any advisory committee,” subject only to “reasonable” regulations set by the
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`Administrator of General Services. Although portions of meetings may be closed where the
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`President determines that closure is provided for pursuant to 5 U.S.C. § 552b(c) (the federal
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`Open Meetings statute), any such determination must be made in a writing that sets forth the
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`reasons for the conclusion.
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`7
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`Case 1:25-cv-00166-JMC Document 1 Filed 01/20/25 Page 8 of 30
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`27.
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`Each advisory committee meeting must be “held at a reasonable time and in a
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`manner or place reasonably accessible to the public,” and in a place sufficient to accommodate “a
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`reasonable number of interested members of the public.” If an advisory committee meeting is
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`held via teleconference, videoconference, or other electronic medium, it still must be made
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`accessible to the public.
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`28.
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`Subject to the provisions of the Freedom of Information Act, 5 U.S.C. § 552, “the
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`records, reports, transcripts, minutes, appendixes, working papers, drafts, studies, agenda, or other
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`documents which were made available to or prepared for or by each advisory committee shall be
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`available for public inspection and copying at a single location in the offices of the advisory
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`committee or the agency to which the advisory committee reports.”
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`29.
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`FACA mandates that “[d]etailed minutes of each meeting of each advisory
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`committee shall be kept and shall contain a record of the persons present, a complete and accurate
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`description of matters discussed and conclusions reached, and copies of all reports received,
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`issued, or approved by the advisory committee. The accuracy of all minutes shall be certified to
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`by the chairman of the advisory committee.” Advisory committees must make available copies
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`of transcripts of advisory committee meetings to “any person” at only the “actual cost of
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`duplication.”
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`30.
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`These requirements reflect FACA’s goal of ensuring that “agencies should seek to
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`be as inclusive as possible.”
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`31.
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`Each of the requirements of FACA is mandatory on the officials utilizing the
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`advisory committee—in this case Vought, Kupor, and Trump—and on the advisory committee
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`itself.
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`8
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`Case 1:25-cv-00166-JMC Document 1 Filed 01/20/25 Page 9 of 30
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`PART II: DOGE’S ESTABLISHMENT AND ADVISORY ROLE
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`32.
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`On 19 August 2024, after a campaign event in Pennsylvania, Candidate Trump
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`was asked if would consider an administration position for Musk if elected. Candidate Trump
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`replied, “I certainly would, if he would do it, I certainly would. He’s a brilliant guy.” That
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`evening, Musk replied from a personal social media account, “I am willing to serve,” along with
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`an Artificial Intelligence-generated image of himself standing at a lectern labeled “D.O.G.E.
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`Department of Government Efficiency.” This image is the earliest known use of “D.O.G.E.” or
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`reference to the “Department of Government Efficiency.” The DOGE acronym is a tongue-in-
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`cheek reference to Dogecoin, a cryptocurrency in which Musk has personally invested and which
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`he regularly promoted on social media.
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`33.
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`On 12 November 2024, following his election victory, President-Elect Trump
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`announced in a statement from his transition team, published on social media, that he intended to
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`appoint Musk and former presidential candidate Vivek Ramaswamy to “lead the Department of
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`Government Efficiency (‘DOGE’),” which he described as a new entity that would “provide
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`advice and guidance from outside of Government” and would “partner with the White House and
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`Office of Management & Budget to drive large scale structural reform, and create an
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`entrepreneurial approach to Government never seen before.” He further stated that he “look[ed]
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`forward to Elon and Vivek making changes to the Federal Bureaucracy,” and set a termination
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`date of 4 July 2026 for this new advisory committee.
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`34.
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`On 14 November 2024, the @DOGE account posted a call on x.com for
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`individuals to apply for membership in DOGE by sending a direct message to that account.
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`35.
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`On 17 November 2024, Ramaswamy appeared on the Fox Business Channel show
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`Sunday Morning Futures and outlined the agenda for DOGE:
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`Case 1:25-cv-00166-JMC Document 1 Filed 01/20/25 Page 10 of 30
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`First is, we want to go right in through executive action, to do the failures of the
`Executive Branch that need to be addressed. Because the dirty little secret right
`now, Maria, is the people we elect to run the Government, they’re not the ones who
`actually run the Government. It’s the unelected bureaucrats in the administrative
`state. That was created through executive action; it’s going to be fixed through
`executive action . . . . We’re not going to be cutting ribbons, we’re going to be
`cutting costs. So [our] recommendations are going to be on a real-time basis . . . .
`Part of this is exposing for the public the extent of that rot and waste, but then to
`take steps, first, through executive action, and then laying the groundwork for
`broader change through legislation as well . . . . Historically, it’s been the view of
`many scholars to say that those [Government employees] cannot even be fired. Now
`we take a different view with the environment the Supreme Court has given us in
`recent years, and we’re going to use that in a pretty extensive way, Maria, to move
`quickly.
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`36.
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`On 20 November 2024, Musk and Ramaswamy authored an opinion editorial in
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`the Wall Street Journal in which they stated that “President Trump has asked the two of us to
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`lead a newly formed Department of Government Efficiency, or DOGE, to cut the Federal
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`Government down to size.”
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`37.
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`Notwithstanding their claim that DOGE would be “[u]nlike government
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`commissions or advisory committees”—demonstrating that they did not intend for DOGE to be
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`governed by FACA—Musk and Ramaswamy further stated, “This team will work in the new
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`administration closely with the White House Office of Management and Budget.”
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`38. Musk and Ramaswamy added, “DOGE will work with legal experts embedded in
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`government agencies, aided by advanced technology, to apply [recent Supreme Court] rulings to
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`federal regulations enacted by such agencies. DOGE will present this list of regulations to
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`President Trump, who can, by executive action, immediately pause the enforcement of those
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`regulations and initiate the process for review and rescission.”
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`39. Most relevant for this litigation, Musk and Ramaswamy then stated their intention
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`to, through DOGE, effect “mass head-count reductions across the federal bureaucracy” through
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`executive action:
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`Case 1:25-cv-00166-JMC Document 1 Filed 01/20/25 Page 11 of 30
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`DOGE intends to work with embedded appointees in agencies to identify the
`minimum number of employees required at an agency for it to perform its
`constitutionally permissible and statutorily mandated functions. The number of
`federal employees to cut should be at least proportionate to the number of federal
`regulations that are nullified: Not only are fewer employees required to enforce
`fewer regulations, but the agency would produce fewer regulations once its scope
`of authority is properly limited. Employees whose positions are eliminated deserve
`to be treated with respect, and DOGE’s goal is to help support their transition into
`the private sector. The president can use existing laws to give them incentives for
`early retirement and to make voluntary severance payments to facilitate a graceful
`exit.
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`Conventional wisdom holds that statutory civil-service protections stop the
`president or even his political appointees from firing federal workers. The purpose
`of these protections is to protect employees from political retaliation. But the statute
`allows for “reductions in force” that don’t target specific employees. The statute
`further empowers the president to “prescribe rules governing the competitive
`service.” That power is broad. Previous presidents have used it to amend the civil
`service rules by executive order, and the Supreme Court has held—in Franklin v.
`Massachusetts (1992) and Collins v. Yellen (2021) that they weren’t constrained by
`the Administrative Procedures [sic] Act when they did so. With this authority, Mr.
`Trump can implement any number of “rules governing the competitive service”
`that would curtail administrative overgrowth, from large-scale firings to relocation
`of federal agencies out of the Washington area. Requiring federal employees to
`come to the office five days a week would result in a wave of voluntary terminations
`that we welcome: If federal employees don’t want to show up, American taxpayers
`shouldn’t pay them for the Covid-era privilege of staying home.
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`40.
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`Other key political figures soon began supporting this new advisory committee.
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`Speaker of the House Mike Johnson brought Musk and Ramaswamy to address a gathering of
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`representatives at the Capitol on 5 December 2024, including members of the newly formed
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`“DOGE Caucus,” about their plans, posting on social media that “@HouseGOP is excited to
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`work with @ElonMusk, @VivekGRamaswamy and @DOGE for a leaner, more efficient
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`government.” Musk and Ramaswamy held additional meetings on 5 December, including with
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`Senator Marsha Blackburn, who posted on her social media account that they had discussed
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`“how @DOGE will get its arms around our bloated federal government.”
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`Case 1:25-cv-00166-JMC Document 1 Filed 01/20/25 Page 12 of 30
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`41.
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`Outside of Government, venture capitalists affiliated with the tech industry were
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`brought into DOGE to assist with ramping up operations. In November 2024, Marc Andreessen
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`(“Andreessen”), a venture capitalist and major donor to the Trump campaign, was brought on
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`board to identify possible members.
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`42.
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`On 4 December 2024, President-Elect Trump posted on social media that he had
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`personally “asked William Joseph McGinley to serve as Counsel to the Department of
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`Government Efficiency (“DOGE”), something he is very passionate about.” Trump added, “Bill
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`will work with Elon Musk, Vivek Ramaswamy, and their team of incredible pioneers at DOGE,
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`to rebuild a U.S. Government that truly serves the People. . . . He will partner with the White
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`House and the Office of Management and Budget to provide advice and guidance to end the
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`bloated Federal Bureaucracy.”
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`43.
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`Incoming Executive Branch personnel have also been keen to highlight their
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`ideological affinity with DOGE. On 9 December 2024, after being announced by President-Elect
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`Trump as his choice to serve as OMB General Counsel, Mark Paoletta posted on social media
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`about how excited he was to help implement Trump’s agenda, “including working w/ @DOGE
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`to cut wasteful government spending!” Ramaswamy reposted Paoletta’s comments an hour later,
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`adding, “@MarkPaoletta will be a great partner to @DOGE within OMB.”
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`44.
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`On 14 January 2025, Andreessen sat for an interview with a podcaster from the
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`Hoover Institution, a right-wing think tank at Stanford University. In this interview, during a
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`discussion of areas of federal employment practices—like telework and collective bargaining
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`agreements—in which DOGE would be making recommendations, Andreessen acknowledged
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`the advisory structure of DOGE:
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`Andreessen: [D]oes the President of the United States have the legal authority to
`order people back to work? Does it count to be an employee of the Federal
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`Case 1:25-cv-00166-JMC Document 1 Filed 01/20/25 Page 13 of 30
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`Government if you’re not in the office? So there’s a ton of threads like that that
`they’re going to plan to . . . pull.
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`Interviewer: All this is just beautiful, really, truly beautiful. However, DOGE is an
`advisory commission.
`
`Andreessen: Sure.
`
`Interviewer: I believe this is the way the President has set it up, as an advisory
`commission. It has its sunset date.
`
`Andreessen: Yes.
`
`Interviewer: It ends on July, or goes out of business on July 4, 2026.
`
`Andreessen: That’s right.
`
`After a brief tangential discussion regarding impoundment, Andreessen concluded:
`
`
`Vivek and Elon are running it, and . . . it itself is not getting set up as a permanent
`agency. It doesn’t have the authority to execute on everything that we’re talking
`about, but the White House does, the Executive Branch does, and the President
`does. And it will be . . . , as it should be, it will be a decision of the President on
`what he wants to do with these recommendations. Um, you know, the people being
`staffed into the positions, . . . so the new head of OMB, is very, you know, has
`talked about being very aligned with this, The new head of OPM is actually a
`partner of ours who’s going in there, he’s very aligned with this.
`
`45.
`
`On 10 January 2025, the Washington Post reported, citing “people familiar with
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`the matter,” “In recent days, aides with the nongovernmental ‘Department of Government
`
`Efficiency’ tied to President-elect Donald Trump’s transition team have spoken with staffers at
`
`more than a dozen federal agencies . . . . The agencies include the Treasury Department, the
`
`Internal Revenue Service and the departments of Homeland Security, Veterans Affairs, and
`
`Health and Human Services.”
`
`46.
`
`On 12 January 2025, the New York Times reported, citing “people who have
`
`insight into DOGE’s operations,” “The goal is for most major agencies to eventually have two
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`DOGE representatives.” This report added that “the minority of people not detailed to agencies
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`
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`would be housed within the Executive Office of the President at the U.S. Digital Service” and
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`that “DOGE is also expected to have an office in the Office of Management and Budget.”
`
`47.
`
`This report also noted, “People involved in the operation say that secrecy and
`
`avoiding leaks is paramount, and much of its communication is conducted on Signal, the
`
`encrypted messaging app.”
`
`48.
`
`This claim is supported by a public blog post by Vinay Hiremath, who worked
`
`with DOGE for four weeks in November and December:
`
`After 8 calls with people who all talked fast and sounded very . . . smart, I was
`added to a number of Signal groups and immediately put to work. . . . Within 2
`minutes of talking to the final interviewer for DOGE, he asked me if I wanted to
`join. I said “yes”’. Then he said “cool” and I was in multiple Signal groups. I was
`immediately acquainted with the software, HR, and legal teams and went from 0 to
`100 taking meetings and getting shit done. This was the day before Thanksgiving.
`
`The next 4 weeks of my life consisted of 100s of calls recruiting the smartest people
`I’ve ever talked to, working on various projects I’m definitely not able to talk about,
`and learning how completely dysfunctional the government was.
`
`49.
`
`On 13 January 2025, the New York Times reported that Musk was likely to occupy
`
`an office in the Eisenhower Executive Office Building, part of the White House Complex.
`
`PART III: DEMOGRAPHICS OF DOGE’S MEMBERSHIP
`
`50.
`
`Due to DOGE’s lack of transparency, little is publicly known about its structure
`
`or membership.
`
`51.
`
`From the outset, Musk and Ramaswamy have stated their intentions to only select
`
`DOGE members who adhere to a particular philosophy, and the known members all share
`
`similar characteristics which reflect a particular background.
`
`52.
`
`The 14 November 2024 social media post from @DOGE specifically stated, “We
`
`need super high-IQ small-government revolutionaries willing to work 80+ hours per week on
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`unglamorous cost-cutting.”
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`53. Musk and Ramaswamy’s 20 November 2024 opinion editorial stated, “We are
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`assisting the Trump transition team to identify and hire a lean team of small-government
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`crusaders, including some of the sharpest technical and legal minds in America.”
`
`54.
`
`The 12 January 2025 New York Times report revealed, “Many of the executives
`
`involved are expecting to do six-month voluntary stints inside the federal government before
`
`returning to their high-paying jobs.”
`
`55.
`
`This report also revealed details about the distinctly arbitrary selection process:
`
`Mr. Musk’s friends have been intimately involved in choosing people who are set
`to be deployed to various agencies. Those who have conducted interviews for
`DOGE include the Silicon Valley investors Marc Andreessen, Shaun Maguire,
`Baris Akis and others who have a personal connection to Mr. Musk. Some who
`have received the Thiel Fellowship, a prestigious grant funded by Mr. Thiel given
`to those who promise to skip or drop out of college to become entrepreneurs, are
`involved with programming and operations for DOGE. Brokering an introduction
`to Mr. Musk or Mr. Ramaswamy, or their inner circles, has been a key way for
`leaders to be picked for deployment.
`
`56.
`
`As revealed in the 10 January 2025 Washington Post report revealed, DOGE is
`
`continuing to select members through an opaque and arbitrary process:
`
`Musk and Ramaswamy have significantly stepped up hiring for their new entity,
`with more than 50 staffers already working out of the offices of SpaceX, Musk’s
`rocket-building company, in downtown Washington, two of the people said. DOGE
`aims to have a staff of close to 100 people in place by Trump’s inauguration on Jan.
`20, they said.
`
`57.
`
`Through various reports, it is possible to identify seventeen individuals in addition
`
`to Musk and Ramaswamy who have been affiliated with DOGE in some fashion: Baris Akis,
`
`Andreessen, Steve Davis, James Fishback, Chris Gober, Antonio Gracias, Vinay Hiremath,
`
`Travis Kalanick, Joseph Lonsdale, Matt Luby, Shaun Maguire, William McGinley, Emil
`
`Michael, Katie Miller, Rachel Riley, Steve Roberts, Brad Smith, and Joanna Wischer.
`
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`58.
`
`Of these seventeen DOGE associates, ten are or have been senior corporate
`
`executives or venture capitalists affiliated with the tech industry: Akis, Andreessen, Davis,
`
`Fishback, Gracias, Hiremath, Kalanick, Lonsdale, Maguire, and Michael. Seven were affiliated
`
`with the previous Trump administration or the Trump campaign: Andreessen, Maguire,
`
`McGinley, Michael, Miller, Smith, and Wischer. Four have a personal relationship with Musk or
`
`Ramaswamy: Davis, Gober, Luby, and Roberts.
`
`59.
`
`The only known DOGE associate who does not fit into one of these categories is
`
`Rachel Riley, who describes herself thusly: “I am a Partner in McKinsey’s Public Sector and
`
`People/Organizational Performance practice, where I lead teams to advise state and federal
`
`government clients on questions of organizational transformation and organizational design for
`
`efficiency and speed.” The nature of Riley’s involvement with DOGE is unknown.
`
`PART IV: DOGE’S LACK OF REPRESENTATION
`
`60.
`
`Upon information and belief, not a single member of DOGE is a federal employee
`
`or represents the perspective of federal employees, despite the evidence that DOGE intends to
`
`provide recommendations regarding federal employment practices and ways to reduce the size of
`
`the federal workforce.
`
`61.
`
`Upon information and belief, not a single member of DOGE is a member of a
`
`union or represents the perspective of unions, despite the evidence that DOGE will be evaluating
`
`collective bargaining agreements.
`
`62.
`
`Upon information and belief, not a single member of DOGE has experience
`
`working on matters of national security or representing people who do, despite the evidence that
`
`DOGE intends to provide recommendations to agencies in this field.
`
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`63.
`
`Upon information and belief, not a single member of DOGE has experience
`
`advocating for greater accountability and transparency in the Federal Government, despite the
`
`evidence that DOGE intends to keep its deliberations and activities secret.
`
`64.
`
`65.
`
`To remedy this imbalance, Lentini and Erlich requested appointment to DOGE.
`
`Lentini has been a lawyer for thirteen years. He holds a bachelor’s degree from
`
`New College of Florida, a Master of Business Administration from Louisiana State University
`
`Shreveport, and a law degree from Georgetown University.
`
`66.
`
`Since graduating from law school, Lentini has worked in various capacities for a
`
`wide array of employers, including the AFL-CIO, the Connecticut state government, and NSC.
`
`He is a local elected official in Manchester, CT, a community of 60,000 residents.
`
`67.
`
`In his application to DOGE, Lentini stated that he was applying for membership
`
`“in the hopes that true governmental waste may be cut without sacrificing the dedicated and
`
`competent federal workers who spend every day serving their country.” He added, “I am deeply
`
`concerned that the D.O.G.E. may be bereft of staff—and leadership—who understand and
`
`prioritize the considerations of the civil servants whose lives will be most directly impacted by
`
`proposed reforms. As a proud member of AFSCME Local 2663, I hope to ensure that these
`
`workers’ livelihoods are not capriciously upended by those whose expertise and sympathies lie
`
`elsewhere.”
`
`68.
`
`Lentini’s application emphasized his experience working for a state government
`
`agency “help