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Tyler McBrien

@tylermcbrien.com

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Managing Editor at Lawfare @lawfaremedia.org Signal - tylermcbrien.97 Writing in the New York Times, The Atlantic, Washington Post, Slate, Mother Jones, Foreign Policy, The New Republic, the Los Angeles Review of Books, and more: www.tylermcbrien.com

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Tyler McBrien·Jul 2

NEW: Kilmar Abrego Garcia’s lawyers seek permission to file an amended complaint in his civil case in Maryland. Among other things, the amended complaint “includes Abrego Garcia's first-hand account of torture and mistreatment at CECOT…”

Case 8:25-cv-00951-PX
Document 211
Filed 07/02/25 Page 2 of 5
3. The proposed Amended Complaint details the Government's defiance of court
orders after this Court granted preliminary injunctive relief. The Amended Complaint includes
allegations that the Government made decisions to defy judicial mandates. These allegations are
new to the Complaint, but have been cited in various filings in this Court as the case has developed.
They are directly relevant to Plaintiffs' constitutional claims and outstanding requests for
declaratory and prospective injunctive relief.
4. Plaintiffs also seek to incorporate evidence that emerged in a June 2025
whistleblower disclosure from former DOJ official Erez Reuveni, who was previously counsel for
the Government in this case. The new allegations include government officials internally
acknowledging that Abrego Garcia's removal was an "administrative error" while simultaneously
working to prevent his return and to make post-hoc justifications. These revelations provide
evidence of deliberate misconduct that was unavailable when the original Complaint was filed and
directly support Plaintiffs' claims.
5. The proposed Amended Complaint also Includes Abrego Garcia's first-hand
account of torture and mistreatment at CECOT, as well as developments regarding his return to the United States and the Government's stated plan to remove him again. These allegations identify
the severe harm actually suffered and the threat of repeated unlawful removal that supports
Plaintiffs' request for prospective injunctive relief. The inclusion of these facts, which could not
have been pleaded at the time of the original filing, is essential to present a complete picture of the
violations and ensure adequate relief.
6. Plaintiffs also propose to clarify that the relief sought includes restoring the status
quo ante, which requires (among other things) the Government to return Abrego Garcia to
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Tyler McBrien·Jun 27

Wow was that fast--an immigrant advocate group already filed an amended complaint seeking class action relief in its birthright citizenship case in federal court in Maryland

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Tyler McBrien·Jul 15

Lawyers for ICE are increasingly hiding their identities in court. This is completely unprecedented. “We’re not really doing names publicly,” said Judge ShaSha Xu — after stating her own name and those of the immigrants and their lawyers. theintercept.com/2025/07/15/i...

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