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`Case No. 1:25-cv-469-CJN
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF COLUMBIA
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`___________________________________
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`PERSONAL SERVICES
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`CONTRACTOR ASSOCIATION,
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`Plaintiff,
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`v.
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`DONALD TRUMP, et al.,
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`Defendants.
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`___________________________________ )
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`PLAINTIFF PSC ASSOCIATION’S
`MOTION FOR PRELIMINARY INJUNCTION
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`Plaintiff PSC Association moves for a preliminary injunction ordering Defendants, their
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`agents, and those acting in concert with them to:
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`(a) Refrain from taking any steps to abolish USAID, including to suspend, eliminate,
`consolidate, reorganize, or downsize: (i) USAID, (ii) its workforce, or (iii) USAID
`contracts, grants, awards, programs, projects, or activities.
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`(b) Refrain from any steps to transfer, integrate, or subsume USAID, its workforce, or its
`contracts, grants, awards, programs, projects, or activities to other parts of the federal
`government.
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`(c) Apportion to USAID the full amount of funds that Congress appropriated to USAID and
`maintain that apportionment to USAID—so that USAID can obligate those funds for: (i) its
`operations and (ii) contracts, grants, awards, and projects overseen by USAID, per
`Congress’s SFOPS 2024 and 2025 and additional budgetary appropriations to USAID.
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`(d) Operate, maintain, and restore public online access to apportionment data, with the
`associated footnotes and written explanations, including by restoring the Public
`Apportionments Database, enabling the public to confirm OMB’s apportionments of
`appropriated funds to USAID.
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`Case 1:25-cv-00469-CJN Document 39 Filed 04/23/25 Page 2 of 3
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`(e) Develop and file a plan showing how they will: (i) timely obligate the full amount of
`SFOPS Title II and III and all other funds that Congress has appropriated to USAID; and
`(ii) maintain staffing at USAID at levels adequate to obligate all funds appropriated by
`Congress to USAID, to oversee and administer all USAID awards, and to carry out all
`other statutorily mandated USAID activities, including meeting all reporting requirements.
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`(f) Until complying with paragraph (e) above, refrain from: (i) enforcing or giving effect to
`termination notices sent to USAID personal services contractors (USPSCs) on or after
`January 20, 2025; or (ii) taking any steps to close USAID missions or other USAID
`facilities overseas or to involuntarily repatriate USAID personnel or their families from
`overseas.
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`(g) Restore the website usaid.gov and public and employee access to it, as they were on
`January 19, 2025.
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`(h) Cease disclosing USPSCs’ personal identifying information on, and remove that
`information from, all DOGE websites.
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`(i) File biweekly status reports documenting and confirming compliance with this order.
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`This motion is based on Fed. R. Civ. Proc. 65, Plaintiff’s accompanying memorandum of
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`law in support of this motion, and the exhibits to that memorandum of law, filed concurrently
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`with this motion. Pursuant to Local Civil Rule 7(m), Plaintiff’s counsel conferred with opposing
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`counsel, and this motion is opposed.
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`Respectfully submitted,
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` /s/
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`Joshua Karsh
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`Dated: April 23, 2025
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`Carolyn E. Shapiro
`Schnapper-Casteras PLLC
`200 E. Randolph St., Ste 5100
`Chicago, IL 60601
`cshapiro@schnappercasteras.com
`312-520-7533
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`Marni Willenson
`D.C. USDC Bar No.
`IL0011
`Illinois Bar No. 6238365
`Willenson Law, LLC
`3420 W. Armitage Ave.,
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`Joshua Karsh
`Mehri & Skalet PLLC
`1237 Judson Ave.
`Evanston, IL 60202
`jkarsh@findjustice.com
`773-505-7533
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`2
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`Case 1:25-cv-00469-CJN Document 39 Filed 04/23/25 Page 3 of 3
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`Member of the Illinois bar with a
`D.C. practice limited to federal
`litigation. Not a member of the
`District of Columbia bar.
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`Ste 200
`Chicago, IL 60647
`marni@willensonlaw.com
`312-546-4910
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`Member of the Illinois
`bar with a D.C. practice
`limited to federal
`litigation. Not a member
`of the District of
`Columbia bar.
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`3
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