Discovery Documents in NEH Lawsuit

Exhibits related to the motion for summary judgment filed by the MLA, ACLS, and AHA in our lawsuit to restore the NEH are linked below.

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Exhibits

Exhibit 1: Transcript of video-recorded deposition of Justin Fox, January 28, 2026
Exhibit 2: Transcript of video-recorded deposition of Nathan Cavanaugh, January 23, 2026
Exhibit 3: Transcript of video-recorded deposition of Michael McDonald, January 30, 2026
Exhibit 4: February 7 email, subject: “NEH EO Award Review Spreadsheet”
Exhibit 5: April 1 email correspondence, subject: “RE: NEH Grants Termination”
Exhibit 6: Spreadsheet with NEH staff annotations
Exhibit 7: A list of ACLS Plaintiffs’ and their members’ grants that were terminated
Exhibit 8: March 13 email, subject: “historical review of grants”
Exhibit 9: “Detection List” created by DOGE's Justin Fox with keywords like “gay,” “BIPOC (Black, Indigenous, People of Color),” “indigenous,” “tribal,” “melting pot,” “equality,” and similar terms, to identify grants that he dubbed the “Craziest Grants” and “Other Bad Grants.”
Exhibit 10: April 3 email, subject: “Crazy grants”
Exhibit 11: Spreadsheet (AR_000024) compiled by Justin Fox. He submitted the description of 1,162 grants in the NEH database to ChatGPT with the following prompt: “Does the following relate at all to DEI? Respond factually in less than 120 characters. Begin with ‘Yes.’ or ‘No.’ followed by a brief explanation. Do not use ‘this initiative‘ or ‘this description’ in your response.”
Exhibit 12: Spreadsheet compiled by Justin Fox including ”DEI Rationale” from ChatGPT. Fox designated grants as ”NEH identified DEI involvement” based on Exhibit 6, in which NEH staff annotated grants as low/medium/high or N/A for ”DEI Involvement.”
Exhibit 13: March 13 email, subject: ”NEH Grants”
Exhibit 14: Spreadsheet compiled by Michael McDonald and Adam Wolfson recommending ”grants to keep”
Exhibit 15: March email correspondence, subject: ”Re: TO REVIEW Active Grants”
Exhibit 16: March email correspondence, subject: ”Re: TO REVIEW Active Grants”
Exhibit 17: March email correspondence, subject: ”Re: TO REVIEW Active Grants”
Exhibit 18: Email from NEH Chief Information Officer to Dartmouth-affiliated grantees: ”I'm terribly sorry to tell you that DOGE did indeed cancel your award. NEH staff, like myself, didn't realize it was happening.”
Exhibit 19: Email from NEH Director of the Division of Research Programs: “[...] we have not been able to reinstate the five NEH-JUSFC fellowships terminated by DOGE (per Acting Chairman Michael McDonald).”
Exhibit 20: NEH termination notice
Exhibit 21: Spreadsheet is taken from AR_000024, with some non-pertinent columns hidden for readability purposes.
Exhibit 22: April 3 email, subject: ”Terminated Grants”
Exhibit 23: April email correspondence, subject: ”RE: NEH Grants Termination”
Exhibit 24: Grants Implicated by Equal Protection Claim
Exhibit 25: List of terminated grants
Exhibit 26: Transcript of video-recorded deposition of Adam Wolfson, January 29, 2026
Exhibit 27: March 12 email, subject: ”NEH | Biden Grants”
Exhibit 28: Spreadsheet titled ”Biden Grants”
Exhibit 29: ”Talking Points for 4/9/25 NCH [National Council on the Humanities] Meeting”
Exhibit 30: March 17 email, subject: ”NEH Review”
Exhibit 31: This spreadsheet is taken from US-000061583, with some non-pertinent columns hidden for readability purposes.
Exhibit 32: Spreadsheet containing a compiled list of all grants “to cancel” and all grants “to keep.”
Exhibit 33: Defendants’ Responses and Objections to Plaintiffs’ First Set of Requests for Admissions
Exhibit 34: Text messages between Adam Wolfson and Michael McDonald
Exhibit 35: Termination grant notice
Exhibit 36: Spreadsheet, ”Contracts and Grants: Terminations”
Exhibit 37: Notice of Grant Termination document
Exhibit 38: Notice of Grant Termination document
Exhibit 39: Spreadsheet, ”NEH Grants - To Cancel: Organizations (4/1/2025 action date)”

Deposition Videos

As part of the lawsuit brought by the MLA, ACLS, and AHA, two key members of the DOGE team, Justin Fox (senior advisor to Stephen Ehikian, Acting Administrator and Deputy Administrator of the General Services Administration) and Nathan Cavanaugh (a political appointee at the General Services Administration), as well as Adam Wolfson (NEH Assistant Chair for Programs) and Michael McDonald (NEH General Counsel and Acting Chair of the NEH from March 2025 to January 2026) were deposed about their roles in the termination of NEH grants.

Deposition of Michael McDonald (taken 30 January 2026)

Deposition of Adam Wolfson (taken 29 January 2026)

Deposition of Nathan Cavanaugh (taken 23 January 2026)

Deposition of Justin Fox (taken 28 January 2026)

Discovery Documents in NEH Lawsuit

Exhibits

Deposition Videos

Documents and Declarations