Sent: Tuesday, June 23, 2026 at 10:06:46 AM EDT
Subject: Fw: DC Joint Status Report
One must draw their own conclusions as to what this all means.
L. Lucas
----- Forwarded Message -----
From: Corey lea <cowtownfoundation@gmail.com>
Sent: Tuesday, June 23, 2026 at 07:18:03 AM EDT
Subject: DC Joint Status Report
--
Corey Lea
Executive Director
TheCowtownF
oundation.org.
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
CHARLES DENNARD, et al.,
Plaintiff,
v.
BROOKE ROLLINS, Secretary of
Agriculture, et al.,
Defendants.
Civil Action No. 25-0879 (ACR)
WHEREAS, on May 13, 2026, the Court directed the parties, during the remote joint
status conference, to file a joint status report, on or before June 22, 2026, updating the Court on
the status of proceedings. Accordingly, the parties submit the following joint status report.
1. Charles Dennard and Corey Lea (“Plaintiffs”) filed an amended complaint on June
12, 2026 following this Court’s March 23, 2026 Order on Motions requiring in part amended
pleadings for the matter to proceed against defendants Brooke Rollins, in her official capacity as
Secretary of Agriculture, The United States Department of Agriculture, Windsor Group LLC, The
Midtown Group, and Analytic Acquisition (“Defendants”) (collectively “the Parties”).
2. The Plaintiffs wish to be provided leave to amend their complaint again, with
permission of the Court to add Plaintiffs One Georgia Inc, and Corey Lea, Inc. The Plaintiffs also
wish to add FB Financial Corporation a/ka/ FIRSTBANK, Larry Hinton, American Bankers
Association, Independent Community Bankers Of America, and National Rural Lenders to the
already named defendants.
3. The present parties agree that the current outstanding discovery can be held in
abeyance, of the Second Amended Complaint, pending an Answer from the current Defendants.
Case 1:25-cv-00879-ACR Document 50 Filed 06/22/26 Page 1 of 3
2
Plaintiff’s Statement
4. An Answer should be filed within the period specified by Federal and Local rules of
service of the Second Amended Complaint, for the respective parties; or a responsive pleading at a
time specified by the pre-motion conference in accordance with Section 7(f) of the Court’s standing
order (ECF. No. 3).
Defendant’s Statement
5. Defendant the Secretary of Agriculture does not oppose Plaintiff filing a second
amended complaint. That said, Defendant cannot determine whether a motion to dismiss, in full
or in part, is warranted until Defendant sees the amended complaint. Defendant proposes that if
she determines a motion to dismiss is warranted that she will file a notice requesting a pre-motion
conference in accordance with Section 7(f) of the Court’s standing order (ECF No. 3) no more
than 30 days after Plaintiffs file their second amended complaint.
Dated: June 22, 2026
Washington, DC
Respectfully submitted,
JEANINE FERRIS PIRRO
United States Attorney
By: /s/ Ryan L. Jones
RYAN L. JONES LAW, LLC
Ryan L. Jones D.C. Bar #1015309
1776 I Street, NW, Suite 325
Washington, DC 20006
(202) 329-8959
Attorneys for Plaintiffs
By: /s/ John J. Bardo
JOHN J. BARDO, D.C. Bar #1655534
Assistant United States Attorney
601 D Street, NW
Washington, DC 20530
(202) 870-6770
Attorneys for the United States of America
Case 1:25-cv-00879-ACR Document 50 Filed 06/22/26 Page 2 of 3
3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on June 22, 2026, the foregoing Joint Status Report was filed
via the electronic filing system (CM-ECF), on all parties and counsel of record.
/s/_Ryan L. Jones
Ryan L. Jones
Attorney for Plaintiffs
Charles Dennard and Corey Lea
