RICHARDSON et al v. TRUMP et al

Filing 14

MOTION for Preliminary Injunction by GINA ARFI, CHRISTOPHER CARROLL, TERESA RICHARDSON, AIDA ZARGAS (Attachments: # 1 Text of Proposed Order)(Androphy, Joel)

Download PDF
Case 1:20-cv-02262-EGS Document 14 Filed 08/20/20 Page 1 of 2 UNITED STATES DISTRICT COURT DISTRICT OF COLUMBIA ------------------------------------------ x - - - - - - - RICHARDSON, CHRISTOPHER CARROLL, TERESA : GINA ARFI, and AIDA ZYGAS, : : Case No. 20-cv-02262 (EGS) Plaintiffs, : -against: : DONALD J. TRUMP, in his official capacity as President of : the United States, : : LOUIS DEJOY, in his official capacity as Postmaster : General of the United States, and : : UNITED STATES POSTAL SERVICE, : : Defendants. : - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - :x : : PLAINTIFFS’ APPLICATION FOR A PRELIMINARY INJUNCTION : : Plaintiffs Teresa Richardson, Christopher Carroll, Gina Arfi, and Aida Zygas (collectively : : “Plaintiffs”), by and through their undersigned counsel, hereby move this Court, pursuant to Rule 65 of : the Federal Rules of Civil Procedure and Local Rule 65.1, for a preliminary injunction. : : For the reasons stated in Plaintiffs’ accompanying Memorandum of Points and Authorities and : : the declarations and exhibits attached thereto (filed concurrently herewith), Plaintiffs respectfully request : : that this Court enter an Order directing Defendants Donald J. Trump, Louis DeJoy, and the United States : : Postal Service (“USPS”) to: (1) return postal operations and restore postal service to that in place : : on January 1, 2020; (2) replace or restore the removed the high-speed sorting machines and : : mailboxes that have been taken out of service and put them back into operation; (3) restore overtime pay and lift the hiring freeze so that USPS can hire additional employees when and where necessary to ensure the timely processing and delivery of mail-in ballots; (4) make all late mail deliveries instead of letting mail be delayed or go undelivered; (5) restore seasoned employees to their former positions, including the employees who were reassigned or displaced Case 1:20-cv-02262-EGS Document 14 Filed 08/20/20 Page 2 of 2 in the recent USPS reorganization; and (6) refrain from any and all other conduct that is intended to interfere and/or interferes with Plaintiffs’ fundamental right to vote in United States elections, including but not limited to the 2020 presidential election. Plaintiffs further respectfully request that this Court appoint a special master to oversee compliance with the Order. A proposed Order is filed concurrently herewith. Dated: Washington, D.C. August 20, 2020 Respectfully submitted, BERG & ANDROPHY /s/ David H. Berg David H. Berg (pro hac vice forthcoming) /s/ Joel M. Androphy Joel M. Androphy D.D.C. Bar No. 999769 James W. Quinn (pro hac vice forthcoming) 120 West 45th Street, 38th Floor New York, NY 10036 Tel: (646) 766-0073 Attorneys for Plaintiffs OF COUNSEL: Kathryn Page Berg 120 West 45th Street, 38th Floor New York, NY 10036 (pro hac vice forthcoming) Tel: (646) 766-0073 2

Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.


Why Is My Information Online?