NATIONAL ASSOCIATION FOR THE ADVANCEMENT OF COLORED PEOPLE v. UNITED STATES POSTAL SERVICE et al

Filing 8

MOTION for Preliminary Injunction by NATIONAL ASSOCIATION FOR THE ADVANCEMENT OF COLORED PEOPLE (Attachments: #1 Memorandum in Support, #2 Declaration Declaration of Carmen Watkins, #3 Declaration Declaration of Earl Graham, #4 Text of Proposed Order, #5 Certificate of Service)(Zieve, Allison)

Case 1:20-cv-02295-TSC Document 8 Filed 09/01/20 Page 1 of 2

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
NATIONAL ASSOCIATION FOR THE
ADVANCEMENT OF COLORED
PEOPLE,
Plaintiff,
v.
UNITED STATES POSTAL SERVICE,
et al.,
Defendants.

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Civil Action No. 20-cv-2295 (TSC)

PLAINITFF’S MOTION FOR A PRELIMINARY INJUNCTON
Pursuant to Rule 65(a) of the Federal Rules of Civil Procedure and Local Rule 65.1(c),
plaintiff National Association for the Advancement of Colored People hereby moves for a
preliminary injunction requiring defendants United States Postal Service and Louis DeJoy to
rescind changes to postal service announced in the July 10, 2020, “PMG Expectations and Plan”
and “Pivot.” Defendants’ counsel has been consulted and advises that Defendants do not consent
to this relief.
In support of this motion, Plaintiff submits the accompanying (1) memorandum of law,
(2) Declarations of Carmen Watkins and Earl Graham, and (3) a proposed order.
Dated: September 1, 2020

Respectfully submitted,

Samuel Spital (D.D.C. Bar No. SS4839)
Rachel Kleinman (NY Bar No. 4417903)
Monique Lin-Luse (NY Bar No. 5671920)
J. Zachery Morris (NY Bar No. 5392196)
John S. Cusick (NY Bar No. 5585245)
NAACP LEGAL DEFENSE &
EDUCATIONAL FUND, INC.

/s/ Allison M. Zieve
Allison M. Zieve (DC Bar No. 424786)
Matthew A. Seligman (DC Bar No. 1018889)
PUBLIC CITIZEN LITIGATION GROUP
1600 20th Street NW
Washington, DC 20009
[phone]

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Case 1:20-cv-02295-TSC Document 8 Filed 09/01/20 Page 2 of 2

40 Rector Street, 5th Floor
New York, NY 10006
[phone]
Counsel for Plaintiff NAACP

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