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)

Case 1:20-cv-02262-EGS Document 14 Filed 08/20/20 Page 1 of 2

UNITED STATES DISTRICT COURT
DISTRICT OF COLUMBIA
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- - - - - - - RICHARDSON, CHRISTOPHER CARROLL,
TERESA :
GINA ARFI, and AIDA ZYGAS,
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Case No. 20-cv-02262 (EGS)
Plaintiffs,
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-against:
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DONALD J. TRUMP, in his official capacity as President of :
the United States,
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LOUIS DEJOY, in his official capacity as Postmaster
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General of the United States, and
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UNITED STATES POSTAL SERVICE,
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Defendants.
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PLAINTIFFS’ APPLICATION FOR A PRELIMINARY INJUNCTION
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Plaintiffs Teresa Richardson, Christopher Carroll, Gina Arfi, and Aida Zygas (collectively
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“Plaintiffs”), by and through their undersigned counsel, hereby move this Court, pursuant to Rule 65 of
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the Federal Rules of Civil Procedure and Local Rule 65.1, for a preliminary injunction.
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For the reasons stated in Plaintiffs’ accompanying Memorandum of Points and Authorities and
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the declarations and exhibits attached thereto (filed concurrently herewith), Plaintiffs respectfully request
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that this Court enter an Order directing Defendants Donald J. Trump, Louis DeJoy, and the United States
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Postal Service (“USPS”) to: (1) return postal operations and restore postal service to that in place
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on January 1, 2020; (2) replace or restore the removed the high-speed sorting machines and
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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: [phone]
Attorneys for Plaintiffs
OF COUNSEL:
Kathryn Page Berg
120 West 45th Street, 38th Floor
New York, NY 10036
(pro hac vice forthcoming)
Tel: [phone]

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