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)

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
NATIONAL ASSOCIATION FOR THE
ADVANCEMENT OF COLORED
PEOPLE,
4805 Mount Hope Drive
Baltimore, MD 21215,

Plaintiff,
v.
Case No. 1:20-cv-02295-TSC
UNITED STATES POSTAL SERVICE,
475 L’Enfant Plaza SW
Room 4012
Washington, DC 20260-2200,
and
LOUIS DEJOY, in his official capacity
as Postmaster General of the United
States Postal Service,
U.S. Postal Service Office
475 L’Enfant Plaza SW
Room 4012
Washington, DC 20260-2200,
Defendants.
DECLARATION OF EARL GRAHAM
My name is Earl Graham and I am over the age of 18 and fully competent to make this
declaration. Under penalty of perjury, I declare the following:
1. I am a 62-year-old African American man and father.
2. I was born in Newark, New Jersey and live in Blythewood, South Carolina.
3. I am disabled veteran.
4. I am a member of the NAACP.

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5. I rely on the USPS for important mail, including for mail-order medications to treat
backpain, headaches, arthritis, sciatica, and cholesterol.
6. Before this summer, my mail-order medications would arrive generally a few days after
my doctor approved any prescription. Since mid-July, however, my medications have taken
much longer to arrive, including sometimes arriving one week or longer after my doctor
has approved prescriptions. Two weeks ago I reached out to the U.S. Department of
Veterans Affairs (“VA”) to inquiry about these delays. After a VA representative spoke
with my prescription provider, the representative informed me that the delays were due to
mail service delays.
7. For more than three decades, I have always voted in person for federal and state elections.
But for the upcoming 2020 November general election, I will vote by mail for the first time
because I am concerned about social distancing at polling locations and exposure to the
virus, especially as someone at higher risk for severe illness. I am also concerned my ballot
will not arrive in time to be counted because of the recent mail delays and reliability of
mail services.

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