Case: Vote Forward v. DeJoy

Vote Forward v. Dejoy

Vote Forward v. Dejoy

National Redistricting Foundation

Stanford-MIT Healthy Elections Project

COMPLAINT against All Defendants (Filing fee $ 400) filed by VOTE FORWARD, COLORADO ORGANIZATION FOR LATINA OPPORTUNITY AND REPRODUCTIVE RIGHTS, VOCES UNIDAS DE LAS MONTANAS, AARON CARREL, PADRES & JOVENES UNIDOS. (Attachments: # 1 Exhibit 1 - USPS Mandatory Stand-Up Talk, # 2 Exhibit 2 - Chart of States Where Voters Mail-in Ballots Are Impacted By Defendants Delays, # 3 Exhibit 3 - USPS Letter to PA Election Officials, # 4 Civil Cover Sheet, # 5 Summons - L. DeJoy, # 6 Summons - USPS, # 7 Summons - W. Barr, # 8 Summons - M. Sherwin, # 9 Notice to Counsel/Party Regarding Related Cases)(Duraiswamy, Shankar) (Entered: 08/28/2020)

1 Exhibit 1 - USPS Mandatory Stand-Up Talk

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2 Exhibit 2 - Chart of States Where Voters Mail-in Ballots Are Impacted By Defenda

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3 Exhibit 3 - USPS Letter to PA Election Officials

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4 Civil Cover Sheet

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5 Summons - L. DeJoy

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6 Summons - USPS

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7 Summons - W. Barr

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8 Summons - M. Sherwin

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9 Notice to Counsel/Party Regarding Related Cases

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COMPLAINT against All Defendants (Filing fee $ 400) filed by VOTE FORWARD, COLORADO ORGANIZATION FOR LATINA OPPORTUNITY AND REPRODUCTIVE RIGHTS, VOCES UNIDAS DE LAS MONTANAS, AARON CARREL, PADRES & JOVENES UNIDOS. (Attachments: # 1 Exhibit 1 - USPS Mandatory Stand-Up Talk, # 2 Exhibit 2 - Chart of States Where Voters Mail-in Ballots Are Impacted By Defendants Delays, # 3 Exhibit 3 - USPS Letter to PA Election Officials, # 4 Civil Cover Sheet, # 5 Summons - L. DeJoy, # 6 Summons - USPS, # 7 Summons - W. Barr, # 8 Summons - M. Sherwin, # 9 Notice to Counsel/Party Regarding Related Cases)(Duraiswamy, Shankar) (Entered: 08/28/2020)

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- John W. Fraser, Filing fee $ 100. Fee Status: Fee Paid. by AARON CARREL, COLORADO ORGANIZATION FOR LATINA OPPORTUNITY AND REPRODUCTIVE RIGHTS, PADRES & JOVENES UNIDOS, VOCES UNIDAS DE LAS MONTANAS, VOTE FORWARD (Attachments: # 1 Declaration of John W. Fraser, # 2 Proposed Order)(Duraiswamy, Shankar) (Entered: 08/28/2020)

1 Declaration of John W. Fraser

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2 Proposed Order

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MOTION for Leave to Appear Pro Hac Vice :Attorney Name- John W. Fraser, Filing fee $ 100. Fee Status: Fee Paid. by AARON CARREL, COLORADO ORGANIZATION FOR LATINA OPPORTUNITY AND REPRODUCTIVE RIGHTS, PADRES & JOVENES UNIDOS, VOCES UNIDAS DE LAS MONTANAS, VOTE FORWARD (Attachments: # 1 Declaration of John W. Fraser, # 2 Proposed Order)(Duraiswamy, Shankar) (Entered: 08/28/2020)

LCvR 26.1 CERTIFICATE OF DISCLOSURE of Corporate Affiliations and Financial Interests by VOTE FORWARD (Duraiswamy, Shankar) (Entered: 08/28/2020)

LCvR 26.1 CERTIFICATE OF DISCLOSURE of Corporate Affiliations and Financial Interests by VOTE FORWARD (Duraiswamy, Shankar) (Entered: 08/28/2020)

LCvR 26.1 CERTIFICATE OF DISCLOSURE of Corporate Affiliations and Financial Interests by VOCES UNIDAS DE LAS MONTANAS (Duraiswamy, Shankar) (Entered: 08/28/2020)

LCvR 26.1 CERTIFICATE OF DISCLOSURE of Corporate Affiliations and Financial Interests by VOCES UNIDAS DE LAS MONTANAS (Duraiswamy, Shankar) (Entered: 08/28/2020)

LCvR 26.1 CERTIFICATE OF DISCLOSURE of Corporate Affiliations and Financial Interests by COLORADO ORGANIZATION FOR LATINA OPPORTUNITY AND REPRODUCTIVE RIGHTS (Duraiswamy, Shankar) (Entered: 08/28/2020)

LCvR 26.1 CERTIFICATE OF DISCLOSURE of Corporate Affiliations and Financial Interests by COLORADO ORGANIZATION FOR LATINA OPPORTUNITY AND REPRODUCTIVE RIGHTS (Duraiswamy, Shankar) (Entered: 08/28/2020)

LCvR 26.1 CERTIFICATE OF DISCLOSURE of Corporate Affiliations and Financial Interests by PADRES & JOVENES UNIDOS (Duraiswamy, Shankar) (Entered: 08/28/2020)

LCvR 26.1 CERTIFICATE OF DISCLOSURE of Corporate Affiliations and Financial Interests by PADRES & JOVENES UNIDOS (Duraiswamy, Shankar) (Entered: 08/28/2020)

NOTICE OF RELATED CASE by AARON CARREL, COLORADO ORGANIZATION FOR LATINA OPPORTUNITY AND REPRODUCTIVE RIGHTS, PADRES & JOVENES UNIDOS, VOCES UNIDAS DE LAS MONTANAS, VOTE FORWARD. Case related to Case No. 20-2340. (adh, ) (Entered: 08/28/2020)

NOTICE OF RELATED CASE by AARON CARREL, COLORADO ORGANIZATION FOR LATINA OPPORTUNITY AND REPRODUCTIVE RIGHTS, PADRES & JOVENES UNIDOS, VOCES UNIDAS DE LAS MONTANAS, VOTE FORWARD. Case related to Case No. 20-2340. (adh, ) (Entered: 08/28/2020)

SUMMONS (4) Issued Electronically as to LOUIS DEJOY, UNITED STATES POSTAL SERVICE, U.S. Attorney and U.S. Attorney General (Attachment: # 1 Notice and Consent)(adh, ) (Entered: 08/28/2020)

1 Notice and Consent

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SUMMONS (4) Issued Electronically as to LOUIS DEJOY, UNITED STATES POSTAL SERVICE, U.S. Attorney and U.S. Attorney General (Attachment: # 1 Notice and Consent)(adh, ) (Entered: 08/28/2020)

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Robert D. Fram, Filing fee $ 100. Fee Status: Fee Paid. by AARON CARREL, COLORADO ORGANIZATION FOR LATINA OPPORTUNITY AND REPRODUCTIVE RIGHTS, PADRES & JOVENES UNIDOS, VOCES UNIDAS DE LAS MONTANAS, VOTE FORWARD (Attachments: # 1 Declaration Declaration of Robert D. Fram, # 2 Proposed Order)(Duraiswamy, Shankar) (Entered: 08/28/2020)

1 Declaration Declaration of Robert D. Fram

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2 Proposed Order

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MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Robert D. Fram, Filing fee $ 100. Fee Status: Fee Paid. by AARON CARREL, COLORADO ORGANIZATION FOR LATINA OPPORTUNITY AND REPRODUCTIVE RIGHTS, PADRES & JOVENES UNIDOS, VOCES UNIDAS DE LAS MONTANAS, VOTE FORWARD (Attachments: # 1 Declaration Declaration of Robert D. Fram, # 2 Proposed Order)(Duraiswamy, Shankar) (Entered: 08/28/2020)

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Diane Ramirez, Filing fee $ 100. Fee Status: Fee Paid. by AARON CARREL, COLORADO ORGANIZATION FOR LATINA OPPORTUNITY AND REPRODUCTIVE RIGHTS, PADRES & JOVENES UNIDOS, VOCES UNIDAS DE LAS MONTANAS, VOTE FORWARD (Attachments: # 1 Declaration of Diane Ramirez, # 2 Proposed Order)(Duraiswamy, Shankar) (Entered: 08/28/2020)

1 Declaration of Diane Ramirez

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2 Proposed Order

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MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Diane Ramirez, Filing fee $ 100. Fee Status: Fee Paid. by AARON CARREL, COLORADO ORGANIZATION FOR LATINA OPPORTUNITY AND REPRODUCTIVE RIGHTS, PADRES & JOVENES UNIDOS, VOCES UNIDAS DE LAS MONTANAS, VOTE FORWARD (Attachments: # 1 Declaration of Diane Ramirez, # 2 Proposed Order)(Duraiswamy, Shankar) (Entered: 08/28/2020)

Case Assigned to Judge Emmet G. Sullivan. (adh, )

Case Assigned to Judge Emmet G. Sullivan. (adh, )

MINUTE ORDER granting 8 motion for leave to appear pro hac vice. Robert D. Fram is hereby admitted pro hac vice in this action. Counsel should register for e-filing via PACER and file a notice of appearance pursuant to LCvR 83.6(a). Click for instructions. Signed by Judge Emmet G. Sullivan on 8/28/2020. (lcegs2)

MINUTE ORDER granting 8 motion for leave to appear pro hac vice. Robert D. Fram is hereby admitted pro hac vice in this action. Counsel should register for e-filing via PACER and file a notice of appearance pursuant to LCvR 83.6(a). Click for instructions. Signed by Judge Emmet G. Sullivan on 8/28/2020. (lcegs2)

MINUTE ORDER granting 9 motion for leave to appear pro hac vice. Diane Ramirez is hereby admitted pro hac vice in this action. Counsel should register for e-filing via PACER and file a notice of appearance pursuant to LCvR 83.6(a). Click for instructions. Signed by Judge Emmet G. Sullivan on 8/28/2020. (lcegs2)

MINUTE ORDER granting 9 motion for leave to appear pro hac vice. Diane Ramirez is hereby admitted pro hac vice in this action. Counsel should register for e-filing via PACER and file a notice of appearance pursuant to LCvR 83.6(a). Click for instructions. Signed by Judge Emmet G. Sullivan on 8/28/2020. (lcegs2)

MINUTE ORDER granting 10 motion for leave to appear pro hac vice. John W. Fraser is hereby admitted pro hac vice in this action. Counsel should register for e-filing via PACER and file a notice of appearance pursuant to LCvR 83.6(a). Click for instructions. Signed by Judge Emmet G. Sullivan on 8/28/2020. (lcegs2)

MINUTE ORDER granting 10 motion for leave to appear pro hac vice. John W. Fraser is hereby admitted pro hac vice in this action. Counsel should register for e-filing via PACER and file a notice of appearance pursuant to LCvR 83.6(a). Click for instructions. Signed by Judge Emmet G. Sullivan on 8/28/2020. (lcegs2)

MINUTE ORDER. The Court, sua sponte, directs the Plaintiff to show cause why this action should not be consolidated as related with National Association for the Advancement of Colored People v. U.S. Postal Service, 20-2295; Richardson v. Trump, 20-2262; and State of New York v. Trump, 20-2340 by no later than September 4, 2020 at 12:00 PM. See Fed. R. Civ. P. 42(a) (permitting the court to consolidate actions "involv[ing] a common question of law or fact"); Local Civ. R. 40.5(a)(3) (defining related civil actions). Signed by Judge Emmet G. Sullivan on 9/1/2020. (lcegs3)

MINUTE ORDER. The Court, sua sponte, directs the Plaintiff to show cause why this action should not be consolidated as related with National Association for the Advancement of Colored People v. U.S. Postal Service, 20-2295; Richardson v. Trump, 20-2262; and State of New York v. Trump, 20-2340 by no later than September 4, 2020 at 12:00 PM. See Fed. R. Civ. P. 42(a) (permitting the court to consolidate actions "involv[ing] a common question of law or fact"); Local Civ. R. 40.5(a)(3) (defining related civil actions). Signed by Judge Emmet G. Sullivan on 9/1/2020. (lcegs3)

Set/Reset Deadlines: Plaintiff Show Cause due no later than 12:00PM on 9/4/2020. (mac)

Set/Reset Deadlines: Plaintiff Show Cause due no later than 12:00PM on 9/4/2020. (mac)

.Order

RESPONSE TO ORDER TO SHOW CAUSE re Minute Order entered on 09/01/2020 by AARON CARREL, COLORADO ORGANIZATION FOR LATINA OPPORTUNITY AND REPRODUCTIVE RIGHTS, PADRES & JOVENES UNIDOS, VOCES UNIDAS DE LAS MONTANAS, VOTE FORWARD. (Duraiswamy, Shankar) Modified on 9/6/2020 to correct docket text (zjf). (Entered: 09/04/2020)

RESPONSE TO ORDER TO SHOW CAUSE re Minute Order entered on 09/01/2020 by AARON CARREL, COLORADO ORGANIZATION FOR LATINA OPPORTUNITY AND REPRODUCTIVE RIGHTS, PADRES & JOVENES UNIDOS, VOCES UNIDAS DE LAS MONTANAS, VOTE FORWARD. (Duraiswamy, Shankar) Modified on 9/6/2020 to correct docket text (zjf). (Entered: 09/04/2020)

STANDING ORDER: The parties are directed to read the attached Standing Order Governing Civil Cases Before Judge Emmet G. Sullivan in its entirety upon receipt. The parties are hereby ORDERED to comply with the directives in the attached Standing Order. Signed by Judge Emmet G. Sullivan on 09/04/20. (Attachment: # 1 Exhibit 1) (mac) (Entered: 09/04/2020)

1 Exhibit 1

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STANDING ORDER: The parties are directed to read the attached Standing Order Governing Civil Cases Before Judge Emmet G. Sullivan in its entirety upon receipt. The parties are hereby ORDERED to comply with the directives in the attached Standing Order. Signed by Judge Emmet G. Sullivan on 09/04/20. (Attachment: # 1 Exhibit 1) (mac) (Entered: 09/04/2020)

MINUTE ORDER. In view of 11 response to order to show cause, as well as the responses from parties in Richardson v. Trump, 20-2262; National Association for the Advancement of Colored People v. U.S. Postal Service, 20-2295; and State of New York v. Trump, 20-2340, the Court shall not consolidate the cases as related pursuant to Federal Rule of Civil Procedure 42(a) and Local Civil Rule 40.5(a)(3). It is ORDERED that the parties shall coordinate schedules for discovery purposes to the extent possible. Signed by Judge Emmet G. Sullivan on 9/5/2020. (lcegs3)

MINUTE ORDER. In view of 11 response to order to show cause, as well as the responses from parties in Richardson v. Trump, 20-2262; National Association for the Advancement of Colored People v. U.S. Postal Service, 20-2295; and State of New York v. Trump, 20-2340, the Court shall not consolidate the cases as related pursuant to Federal Rule of Civil Procedure 42(a) and Local Civil Rule 40.5(a)(3). It is ORDERED that the parties shall coordinate schedules for discovery purposes to the extent possible. Signed by Judge Emmet G. Sullivan on 9/5/2020. (lcegs3)

.Order

NOTICE of Appearance by Kuntal Virendra Cholera on behalf of All Defendants (Cholera, Kuntal) (Entered: 09/08/2020)

NOTICE of Appearance by Kuntal Virendra Cholera on behalf of All Defendants (Cholera, Kuntal) (Entered: 09/08/2020)

Joint MOTION for Protective Order by LOUIS DEJOY, UNITED STATES POSTAL SERVICE (Cholera, Kuntal) (Entered: 09/08/2020)

Joint MOTION for Protective Order by LOUIS DEJOY, UNITED STATES POSTAL SERVICE (Cholera, Kuntal) (Entered: 09/08/2020)

AMENDED COMPLAINT against LOUIS DEJOY, UNITED STATES POSTAL SERVICE filed by AARON CARREL, VOTE FORWARD, VOCES UNIDAS DE LAS MONTANAS, COLORADO ORGANIZATION FOR LATINA OPPORTUNITY AND REPRODUCTIVE RIGHTS, PADRES & JOVENES UNIDOS, PAUL HUNTER, INDERBIR SINGH DATTA, GARY YOUNG, DANTE FLORES-DEMARCHI, SEBASTIAN IMMONEN, LINDA ROBERSON, MARTHA THOMPSON, SEAN MORRISON, AMY BOLAN, KATHRYN MONTGOMERY. (Attachments: # 1 Exhibit 1 - USPS Mandatory Stand Up Talk, # 2 Exhibit 2 - States Where Voters' Mail-in Ballots Are Impacted By Defendants' Delays, # 3 Exhibit 3 - USPS Letter to PA Election Officials, # 4 Exhibit 4 - Redline from Original Complaint)(Duraiswamy, Shankar) (Entered: 09/08/2020)

1 Exhibit 1 - USPS Mandatory Stand Up Talk

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2 Exhibit 2 - States Where Voters' Mail-in Ballots Are Impacted By Defendants

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3 Exhibit 3 - USPS Letter to PA Election Officials

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4 Exhibit 4 - Redline from Original Complaint

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AMENDED COMPLAINT against LOUIS DEJOY, UNITED STATES POSTAL SERVICE filed by AARON CARREL, VOTE FORWARD, VOCES UNIDAS DE LAS MONTANAS, COLORADO ORGANIZATION FOR LATINA OPPORTUNITY AND REPRODUCTIVE RIGHTS, PADRES & JOVENES UNIDOS, PAUL HUNTER, INDERBIR SINGH DATTA, GARY YOUNG, DANTE FLORES-DEMARCHI, SEBASTIAN IMMONEN, LINDA ROBERSON, MARTHA THOMPSON, SEAN MORRISON, AMY BOLAN, KATHRYN MONTGOMERY. (Attachments: # 1 Exhibit 1 - USPS Mandatory Stand Up Talk, # 2 Exhibit 2 - States Where Voters' Mail-in Ballots Are Impacted By Defendants' Delays, # 3 Exhibit 3 - USPS Letter to PA Election Officials, # 4 Exhibit 4 - Redline from Original Complaint)(Duraiswamy, Shankar) (Entered: 09/08/2020)

MOTION for Preliminary Injunction by AMY BOLAN, AARON CARREL, COLORADO ORGANIZATION FOR LATINA OPPORTUNITY AND REPRODUCTIVE RIGHTS, INDERBIR SINGH DATTA, DANTE FLORES-DEMARCHI, PAUL HUNTER, SEBASTIAN IMMONEN, KATHRYN MONTGOMERY, SEAN MORRISON, PADRES & JOVENES UNIDOS, LINDA ROBERSON, MARTHA THOMPSON, VOCES UNIDAS DE LAS MONTANAS, VOTE FORWARD, GARY YOUNG (Attachments: # 1 Memorandum in Support, # 2 Exhibit Index, # 3 Exhibit USPS OIG Report (Aug. 2020), # 4 Exhibit USPS, Postal Operations Manual (Excerpts), # 5 Exhibit USPS OIG Report (May 2020), # 6 Exhibit USPS, Mandatory Stand-Up Talk: All Employees, # 7 Exhibit Leaked USPS Powerpoint, # 8 Exhibit DeJoy Testimony - House Oversight Hearing (Aug. 24, 2020), # 9 Exhibit DeJoy Testimony - Senate Hearing (Aug. 21, 2020), # 10 Exhibit Statement of DeJoy - House Oversight Comm. (Aug. 24, 2020), # 11 Declaration Professor Justin Grimmer, # 12 Exhibit USPS, Congressional Briefing (Aug. 31, 2020), # 13 Exhibit Chart of States Where Voters' Mail-In Ballots Are Impacted By Defendants' Delays, # 14 Exhibit USPS Letter to Pa. (July 29, 2020), # 15 Declaration Eitran D. Hersh, # 16 Exhibit House Oversight Hearing on USPS Operations - Transcript (Aug. 24, 2020), # 17 Exhibit Senate HSGAC Hearing on USPS Operations - Transcript (Aug. 21, 2020), # 18 Declaration Aaron Carrel, # 19 Declaration Martha Thompson, # 20 Declaration Kathryn Montgomery, # 21 Declaration Sebastian Immonen, # 22 Declaration Amy Bolan, # 23 Declaration Inderbir Singh Datta, # 24 Declaration Scott J. Forman of Vote Forward, # 25 Declaration Alex Sanchez of Voces Unidas De Las Montanas, # 26 Text of Proposed Order)(Duraiswamy, Shankar) (Entered: 09/08/2020)

1 Memorandum in Support

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2 Exhibit Index

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3 Exhibit USPS OIG Report (Aug. 2020)

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4 Exhibit USPS, Postal Operations Manual (Excerpts)

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5 Exhibit USPS OIG Report (May 2020)

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6 Exhibit USPS, Mandatory Stand-Up Talk: All Employees

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7 Exhibit Leaked USPS Powerpoint

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8 Exhibit DeJoy Testimony - House Oversight Hearing (Aug. 24, 2020)

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9 Exhibit DeJoy Testimony - Senate Hearing (Aug. 21, 2020)

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10 Exhibit Statement of DeJoy - House Oversight Comm. (Aug. 24, 2020)

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11 Declaration Professor Justin Grimmer

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12 Exhibit USPS, Congressional Briefing (Aug. 31, 2020)

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13 Exhibit Chart of States Where Voters' Mail-In Ballots Are Impacted By Defen

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14 Exhibit USPS Letter to Pa. (July 29, 2020)

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15 Declaration Eitran D. Hersh

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16 Exhibit House Oversight Hearing on USPS Operations - Transcript (Aug. 24, 2020)

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17 Exhibit Senate HSGAC Hearing on USPS Operations - Transcript (Aug. 21, 2020)

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18 Declaration Aaron Carrel

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19 Declaration Martha Thompson

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20 Declaration Kathryn Montgomery

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21 Declaration Sebastian Immonen

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22 Declaration Amy Bolan

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23 Declaration Inderbir Singh Datta

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24 Declaration Scott J. Forman of Vote Forward

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25 Declaration Alex Sanchez of Voces Unidas De Las Montanas

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26 Text of Proposed Order

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MOTION for Preliminary Injunction by AMY BOLAN, AARON CARREL, COLORADO ORGANIZATION FOR LATINA OPPORTUNITY AND REPRODUCTIVE RIGHTS, INDERBIR SINGH DATTA, DANTE FLORES-DEMARCHI, PAUL HUNTER, SEBASTIAN IMMONEN, KATHRYN MONTGOMERY, SEAN MORRISON, PADRES & JOVENES UNIDOS, LINDA ROBERSON, MARTHA THOMPSON, VOCES UNIDAS DE LAS MONTANAS, VOTE FORWARD, GARY YOUNG (Attachments: # 1 Memorandum in Support, # 2 Exhibit Index, # 3 Exhibit USPS OIG Report (Aug. 2020), # 4 Exhibit USPS, Postal Operations Manual (Excerpts), # 5 Exhibit USPS OIG Report (May 2020), # 6 Exhibit USPS, Mandatory Stand-Up Talk: All Employees, # 7 Exhibit Leaked USPS Powerpoint, # 8 Exhibit DeJoy Testimony - House Oversight Hearing (Aug. 24, 2020), # 9 Exhibit DeJoy Testimony - Senate Hearing (Aug. 21, 2020), # 10 Exhibit Statement of DeJoy - House Oversight Comm. (Aug. 24, 2020), # 11 Declaration Professor Justin Grimmer, # 12 Exhibit USPS, Congressional Briefing (Aug. 31, 2020), # 13 Exhibit Chart of States Where Voters' Mail-In Ballots Are Impacted By Defendants' Delays, # 14 Exhibit USPS Letter to Pa. (July 29, 2020), # 15 Declaration Eitran D. Hersh, # 16 Exhibit House Oversight Hearing on USPS Operations - Transcript (Aug. 24, 2020), # 17 Exhibit Senate HSGAC Hearing on USPS Operations - Transcript (Aug. 21, 2020), # 18 Declaration Aaron Carrel, # 19 Declaration Martha Thompson, # 20 Declaration Kathryn Montgomery, # 21 Declaration Sebastian Immonen, # 22 Declaration Amy Bolan, # 23 Declaration Inderbir Singh Datta, # 24 Declaration Scott J. Forman of Vote Forward, # 25 Declaration Alex Sanchez of Voces Unidas De Las Montanas, # 26 Text of Proposed Order)(Duraiswamy, Shankar) (Entered: 09/08/2020)

MINUTE ORDER granting 14 joint motion for protective order. Signed by Judge Emmet G. Sullivan on 9/9/2020. (lcegs3) (Entered: 09/09/2020)

MINUTE ORDER granting 14 joint motion for protective order. Signed by Judge Emmet G. Sullivan on 9/9/2020. (lcegs3) (Entered: 09/09/2020)

MINUTE ORDER. In view of 16 Plaintiffs' motion for preliminary injunction, the parties shall adhere to the following briefing schedule: (1) Defendants shall file their opposition by no later than September 15, 2020, see L. Civ. R. 65.1(c); and (2) Plaintiffs shall file their reply by no later than September 20, 2020. Signed by Judge Emmet G. Sullivan on 9/9/2020. (lcegs3)

MINUTE ORDER. In view of 16 Plaintiffs' motion for preliminary injunction, the parties shall adhere to the following briefing schedule: (1) Defendants shall file their opposition by no later than September 15, 2020, see L. Civ. R. 65.1(c); and (2) Plaintiffs shall file their reply by no later than September 20, 2020. Signed by Judge Emmet G. Sullivan on 9/9/2020. (lcegs3)

.Order

Set/Reset Deadlines: Defendants Opposition due by 9/15/2020. Plaintiffs Reply due by 9/20/2020. (mac)

Set/Reset Deadlines: Defendants Opposition due by 9/15/2020. Plaintiffs Reply due by 9/20/2020. (mac)

NOTICE of Appearance by Douglas N. Letter on behalf of UNITED STATES HOUSE OF REPRESENTATIVES (Letter, Douglas) (Entered: 09/11/2020)

NOTICE of Appearance by Douglas N. Letter on behalf of UNITED STATES HOUSE OF REPRESENTATIVES (Letter, Douglas) (Entered: 09/11/2020)

Unopposed MOTION for Leave to File Amicus Curiae Brief in Support of Plaintiffs by UNITED STATES HOUSE OF REPRESENTATIVES (Attachments: # 1 Exhibit Proposed Brief of U.S. House of Representatives as Amicus Curiae in Support of Plaintiffs, # 2 Text of Proposed Order)(Letter, Douglas) (Entered: 09/11/2020)

1 Exhibit Proposed Brief of U.S. House of Representatives as Amicus Curiae in Supp

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2 Text of Proposed Order

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Unopposed MOTION for Leave to File Amicus Curiae Brief in Support of Plaintiffs by UNITED STATES HOUSE OF REPRESENTATIVES (Attachments: # 1 Exhibit Proposed Brief of U.S. House of Representatives as Amicus Curiae in Support of Plaintiffs, # 2 Text of Proposed Order)(Letter, Douglas) (Entered: 09/11/2020)

MOTION to Expedite Discovery by AMY BOLAN, AARON CARREL, COLORADO ORGANIZATION FOR LATINA OPPORTUNITY AND REPRODUCTIVE RIGHTS, INDERBIR SINGH DATTA, DANTE FLORES-DEMARCHI, PAUL HUNTER, SEBASTIAN IMMONEN, KATHRYN MONTGOMERY, SEAN MORRISON, PADRES & JOVENES UNIDOS, LINDA ROBERSON, MARTHA THOMPSON, VOCES UNIDAS DE LAS MONTANAS, VOTE FORWARD, GARY YOUNG (Attachments: # 1 Text of Proposed Order, # 2 Exhibit Index, # 3 Exhibit A - Plaintiffs First Request for Production of Documents, # 4 Exhibit B - Plaintiffs First Set of Interrogatories, # 5 Exhibit C - Plaintiffs First Request for Admissions, # 6 Exhibit D - Plaintiffs Notice of 30(b)(6) Deposition on Impact of Policy, # 7 Exhibit E - Plaintiffs Notice of 30(b)(6) Deposition on Cost Savings Justification, # 8 Exhibit F - Plaintiffs Notice of 30(b)(1) Deposition of Curtis, # 9 Exhibit G - Plaintiffs Notice of 30(b)(1) Deposition of Glass, # 10 Exhibit H - Plaintiffs Notice of 30(b)(1) Deposition o Cintron, # 11 Exhibit I - Guidelines (as filed in SDNY), # 12 Exhibit J - Guidelines Spreadsheet (as produced in EDWA), # 13 Exhibit K - Transmittal Email (as produced in EDWA), # 14 Exhibit L - USPS Publication 632, # 15 Exhibit M - June 2020 OIG Audit, # 16 Exhibit N - July 2020 Mandatory Stand-Up Talk, # 17 Exhibit O - July 2020 PMG Expectations, # 18 Exhibit P - July 2020 USPS Letter to PA Election Officials, # 19 Exhibit Q - August 2020 DeJoy Memo, # 20 Exhibit R - August 2020 OIG Auditi, # 21 Exhibit S - August 2020 USPS Congressional Briefing PowerPoint, # 22 Exhibit T - Cintron Declaration (as filed in SDNY), # 23 Exhibit U - Curtis Declaration (as filed in SDNY), # 24 Exhibit V - Glass Declaration (as filed in SDNY))(Duraiswamy, Shankar) (Entered: 09/14/2020)

1 Text of Proposed Order

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2 Exhibit Index

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3 Exhibit A - Plaintiffs First Request for Production of Documents

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4 Exhibit B - Plaintiffs First Set of Interrogatories

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5 Exhibit C - Plaintiffs First Request for Admissions

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6 Exhibit D - Plaintiffs Notice of 30(b)(6) Deposition on Impact of Policy

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7 Exhibit E - Plaintiffs Notice of 30(b)(6) Deposition on Cost Savings Justificati

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8 Exhibit F - Plaintiffs Notice of 30(b)(1) Deposition of Curtis

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9 Exhibit G - Plaintiffs Notice of 30(b)(1) Deposition of Glass

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10 Exhibit H - Plaintiffs Notice of 30(b)(1) Deposition o Cintron

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11 Exhibit I - Guidelines (as filed in SDNY)

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12 Exhibit J - Guidelines Spreadsheet (as produced in EDWA)

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13 Exhibit K - Transmittal Email (as produced in EDWA)

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14 Exhibit L - USPS Publication 632

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15 Exhibit M - June 2020 OIG Audit

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16 Exhibit N - July 2020 Mandatory Stand-Up Talk

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17 Exhibit O - July 2020 PMG Expectations

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18 Exhibit P - July 2020 USPS Letter to PA Election Officials

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19 Exhibit Q - August 2020 DeJoy Memo

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20 Exhibit R - August 2020 OIG Auditi

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21 Exhibit S - August 2020 USPS Congressional Briefing PowerPoint

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22 Exhibit T - Cintron Declaration (as filed in SDNY)

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23 Exhibit U - Curtis Declaration (as filed in SDNY)

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24 Exhibit V - Glass Declaration (as filed in SDNY)

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MOTION to Expedite Discovery by AMY BOLAN, AARON CARREL, COLORADO ORGANIZATION FOR LATINA OPPORTUNITY AND REPRODUCTIVE RIGHTS, INDERBIR SINGH DATTA, DANTE FLORES-DEMARCHI, PAUL HUNTER, SEBASTIAN IMMONEN, KATHRYN MONTGOMERY, SEAN MORRISON, PADRES & JOVENES UNIDOS, LINDA ROBERSON, MARTHA THOMPSON, VOCES UNIDAS DE LAS MONTANAS, VOTE FORWARD, GARY YOUNG (Attachments: # 1 Text of Proposed Order, # 2 Exhibit Index, # 3 Exhibit A - Plaintiffs First Request for Production of Documents, # 4 Exhibit B - Plaintiffs First Set of Interrogatories, # 5 Exhibit C - Plaintiffs First Request for Admissions, # 6 Exhibit D - Plaintiffs Notice of 30(b)(6) Deposition on Impact of Policy, # 7 Exhibit E - Plaintiffs Notice of 30(b)(6) Deposition on Cost Savings Justification, # 8 Exhibit F - Plaintiffs Notice of 30(b)(1) Deposition of Curtis, # 9 Exhibit G - Plaintiffs Notice of 30(b)(1) Deposition of Glass, # 10 Exhibit H - Plaintiffs Notice of 30(b)(1) Deposition o Cintron, # 11 Exhibit I - Guidelines (as filed in SDNY), # 12 Exhibit J - Guidelines Spreadsheet (as produced in EDWA), # 13 Exhibit K - Transmittal Email (as produced in EDWA), # 14 Exhibit L - USPS Publication 632, # 15 Exhibit M - June 2020 OIG Audit, # 16 Exhibit N - July 2020 Mandatory Stand-Up Talk, # 17 Exhibit O - July 2020 PMG Expectations, # 18 Exhibit P - July 2020 USPS Letter to PA Election Officials, # 19 Exhibit Q - August 2020 DeJoy Memo, # 20 Exhibit R - August 2020 OIG Auditi, # 21 Exhibit S - August 2020 USPS Congressional Briefing PowerPoint, # 22 Exhibit T - Cintron Declaration (as filed in SDNY), # 23 Exhibit U - Curtis Declaration (as filed in SDNY), # 24 Exhibit V - Glass Declaration (as filed in SDNY))(Duraiswamy, Shankar) (Entered: 09/14/2020)

RESPONSE re 16 MOTION for Preliminary Injunction filed by LOUIS DEJOY, UNITED STATES POSTAL SERVICE. (Attachments: # 1 Declaration Barber, Cintron, Curtis, # 2 Declaration Colin, Couch, DeChambeau, Glass, Prokity, Vo, # 3 Declaration Supplemental Cintron, Curtis, # 4 Exhibit 1-15)(Cholera, Kuntal) (Entered: 09/15/2020)

1 Declaration Barber, Cintron, Curtis

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2 Declaration Colin, Couch, DeChambeau, Glass, Prokity, Vo

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3 Declaration Supplemental Cintron, Curtis

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4 Exhibit 1-15

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RESPONSE re 16 MOTION for Preliminary Injunction filed by LOUIS DEJOY, UNITED STATES POSTAL SERVICE. (Attachments: # 1 Declaration Barber, Cintron, Curtis, # 2 Declaration Colin, Couch, DeChambeau, Glass, Prokity, Vo, # 3 Declaration Supplemental Cintron, Curtis, # 4 Exhibit 1-15)(Cholera, Kuntal) (Entered: 09/15/2020)

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Lawrence A. Hobel, Filing fee $ 100. Fee Status: Fee Paid. by AMY BOLAN, AARON CARREL, COLORADO ORGANIZATION FOR LATINA OPPORTUNITY AND REPRODUCTIVE RIGHTS, INDERBIR SINGH DATTA, DANTE FLORES-DEMARCHI, PAUL HUNTER, SEBASTIAN IMMONEN, KATHRYN MONTGOMERY, SEAN MORRISON, PADRES & JOVENES UNIDOS, LINDA ROBERSON, MARTHA THOMPSON, VOCES UNIDAS DE LAS MONTANAS, VOTE FORWARD, GARY YOUNG (Attachments: # 1 Declaration Declaration of L. Hobel, # 2 Text of Proposed Order Proposed Order)(Duraiswamy, Shankar) (Entered: 09/16/2020)

1 Declaration Declaration of L. Hobel

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2 Text of Proposed Order Proposed Order

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MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Lawrence A. Hobel, Filing fee $ 100. Fee Status: Fee Paid. by AMY BOLAN, AARON CARREL, COLORADO ORGANIZATION FOR LATINA OPPORTUNITY AND REPRODUCTIVE RIGHTS, INDERBIR SINGH DATTA, DANTE FLORES-DEMARCHI, PAUL HUNTER, SEBASTIAN IMMONEN, KATHRYN MONTGOMERY, SEAN MORRISON, PADRES & JOVENES UNIDOS, LINDA ROBERSON, MARTHA THOMPSON, VOCES UNIDAS DE LAS MONTANAS, VOTE FORWARD, GARY YOUNG (Attachments: # 1 Declaration Declaration of L. Hobel, # 2 Text of Proposed Order Proposed Order)(Duraiswamy, Shankar) (Entered: 09/16/2020)

MINUTE ORDER granting 22 motion for leave to appear pro hac vice. Lawrence A. Hobel is hereby admitted pro hac vice in this action. Counsel should register for e-filing via PACER and file a notice of appearance pursuant to LCvR 83.6(a). Click for instructions. Signed by Judge Emmet G. Sullivan on 9/16/2020. (lcegs3)

MINUTE ORDER granting 22 motion for leave to appear pro hac vice. Lawrence A. Hobel is hereby admitted pro hac vice in this action. Counsel should register for e-filing via PACER and file a notice of appearance pursuant to LCvR 83.6(a). Click for instructions. Signed by Judge Emmet G. Sullivan on 9/16/2020. (lcegs3)

RESPONSE re 20 MOTION to Expedite Discovery filed by LOUIS DEJOY, UNITED STATES POSTAL SERVICE. (Attachments: # 1 Exhibit A, # 2 Exhibit B)(Cholera, Kuntal) (Entered: 09/18/2020)

1 Exhibit A

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2 Exhibit B

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RESPONSE re 20 MOTION to Expedite Discovery filed by LOUIS DEJOY, UNITED STATES POSTAL SERVICE. (Attachments: # 1 Exhibit A, # 2 Exhibit B)(Cholera, Kuntal) (Entered: 09/18/2020)

REPLY to opposition to motion re 16 MOTION for Preliminary Injunction filed by AMY BOLAN, AARON CARREL, COLORADO ORGANIZATION FOR LATINA OPPORTUNITY AND REPRODUCTIVE RIGHTS, INDERBIR SINGH DATTA, DANTE FLORES-DEMARCHI, PAUL HUNTER, SEBASTIAN IMMONEN, KATHRYN MONTGOMERY, SEAN MORRISON, PADRES & JOVENES UNIDOS, LINDA ROBERSON, MARTHA THOMPSON, VOCES UNIDAS DE LAS MONTANAS, VOTE FORWARD, GARY YOUNG. (Attachments: # 1 Exhibit Index, # 2 Declaration of Justin Grimmer, # 3 Declaration of Ruth Goldway)(Duraiswamy, Shankar) (Entered: 09/20/2020)

1 Exhibit Index

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2 Declaration of Justin Grimmer

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3 Declaration of Ruth Goldway

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REPLY to opposition to motion re 16 MOTION for Preliminary Injunction filed by AMY BOLAN, AARON CARREL, COLORADO ORGANIZATION FOR LATINA OPPORTUNITY AND REPRODUCTIVE RIGHTS, INDERBIR SINGH DATTA, DANTE FLORES-DEMARCHI, PAUL HUNTER, SEBASTIAN IMMONEN, KATHRYN MONTGOMERY, SEAN MORRISON, PADRES & JOVENES UNIDOS, LINDA ROBERSON, MARTHA THOMPSON, VOCES UNIDAS DE LAS MONTANAS, VOTE FORWARD, GARY YOUNG. (Attachments: # 1 Exhibit Index, # 2 Declaration of Justin Grimmer, # 3 Declaration of Ruth Goldway)(Duraiswamy, Shankar) (Entered: 09/20/2020)

Unopposed MOTION for Leave to File Supplemental Declarations in Support of Motion for Preliminary Injunction by AMY BOLAN, AARON CARREL, COLORADO ORGANIZATION FOR LATINA OPPORTUNITY AND REPRODUCTIVE RIGHTS, INDERBIR SINGH DATTA, DANTE FLORES-DEMARCHI, PAUL HUNTER, SEBASTIAN IMMONEN, KATHRYN MONTGOMERY, SEAN MORRISON, PADRES & JOVENES UNIDOS, LINDA ROBERSON, MARTHA THOMPSON, VOCES UNIDAS DE LAS MONTANAS, VOTE FORWARD, GARY YOUNG (Attachments: # 1 Declaration of Justin Grimmer, # 2 Declaration of Ruth Goldway, # 3 Text of Proposed Order)(Duraiswamy, Shankar) (Entered: 09/22/2020)

1 Declaration of Justin Grimmer

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2 Declaration of Ruth Goldway

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3 Text of Proposed Order

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Unopposed MOTION for Leave to File Supplemental Declarations in Support of Motion for Preliminary Injunction by AMY BOLAN, AARON CARREL, COLORADO ORGANIZATION FOR LATINA OPPORTUNITY AND REPRODUCTIVE RIGHTS, INDERBIR SINGH DATTA, DANTE FLORES-DEMARCHI, PAUL HUNTER, SEBASTIAN IMMONEN, KATHRYN MONTGOMERY, SEAN MORRISON, PADRES & JOVENES UNIDOS, LINDA ROBERSON, MARTHA THOMPSON, VOCES UNIDAS DE LAS MONTANAS, VOTE FORWARD, GARY YOUNG (Attachments: # 1 Declaration of Justin Grimmer, # 2 Declaration of Ruth Goldway, # 3 Text of Proposed Order)(Duraiswamy, Shankar) (Entered: 09/22/2020)

Joint MOTION for Protective Order (502(D) Order) by LOUIS DEJOY, UNITED STATES POSTAL SERVICE (Cholera, Kuntal) (Entered: 09/22/2020)

Joint MOTION for Protective Order (502(D) Order) by LOUIS DEJOY, UNITED STATES POSTAL SERVICE (Cholera, Kuntal) (Entered: 09/22/2020)

AMICUS BRIEF by UNITED STATES HOUSE OF REPRESENTATIVES. (zjf) (Entered: 09/23/2020)

AMICUS BRIEF by UNITED STATES HOUSE OF REPRESENTATIVES. (zjf) (Entered: 09/23/2020)

MINUTE ORDER granting 19 motion for leave to file amicus curiae brief in support of Plaintiffs by UNITED STATES HOUSE OF REPRESENTATIVES. Signed by Judge Emmet G. Sullivan on 9/22/2020. (lcegs3)

MINUTE ORDER granting 19 motion for leave to file amicus curiae brief in support of Plaintiffs by UNITED STATES HOUSE OF REPRESENTATIVES. Signed by Judge Emmet G. Sullivan on 9/22/2020. (lcegs3)

REPLY to opposition to motion re 20 MOTION to Expedite Discovery -- Reply In Support of Plaintiffs' Motion for Expedited Discovery and Case Schedule filed by AMY BOLAN, AARON CARREL, COLORADO ORGANIZATION FOR LATINA OPPORTUNITY AND REPRODUCTIVE RIGHTS, INDERBIR SINGH DATTA, DANTE FLORES-DEMARCHI, PAUL HUNTER, SEBASTIAN IMMONEN, KATHRYN MONTGOMERY, SEAN MORRISON, PADRES & JOVENES UNIDOS, LINDA ROBERSON, MARTHA THOMPSON, VOCES UNIDAS DE LAS MONTANAS, VOTE FORWARD, GARY YOUNG. (Attachments: # 1 Exhibit Index, # 2 Exhibit 1 - Plaintiff States First Interrogatories and Requests for Production (as filed in E.D. Wash.), # 3 Exhibit 2 - Plaintiffs First Request for Production of Documents (as filed in E.D. Pa.), # 4 Exhibit 3 - Order Granting Plaintiffs' Motion for Expedited Discovery (as filed in E.D. Wash.), # 5 Exhibit 4 - Order Granting Expedited Discovery (as filed in E.D. Pa.), # 6 Exhibit 5 - Revised Proposed Order)(Duraiswamy, Shankar) (Entered: 09/23/2020)

1 Exhibit Index

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2 Exhibit 1 - Plaintiff States First Interrogatories and Requests for Production (

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3 Exhibit 2 - Plaintiffs First Request for Production of Documents (as filed in E.

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4 Exhibit 3 - Order Granting Plaintiffs' Motion for Expedited Discovery (as f

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5 Exhibit 4 - Order Granting Expedited Discovery (as filed in E.D. Pa.)

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6 Exhibit 5 - Revised Proposed Order

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REPLY to opposition to motion re 20 MOTION to Expedite Discovery -- Reply In Support of Plaintiffs' Motion for Expedited Discovery and Case Schedule filed by AMY BOLAN, AARON CARREL, COLORADO ORGANIZATION FOR LATINA OPPORTUNITY AND REPRODUCTIVE RIGHTS, INDERBIR SINGH DATTA, DANTE FLORES-DEMARCHI, PAUL HUNTER, SEBASTIAN IMMONEN, KATHRYN MONTGOMERY, SEAN MORRISON, PADRES & JOVENES UNIDOS, LINDA ROBERSON, MARTHA THOMPSON, VOCES UNIDAS DE LAS MONTANAS, VOTE FORWARD, GARY YOUNG. (Attachments: # 1 Exhibit Index, # 2 Exhibit 1 - Plaintiff States First Interrogatories and Requests for Production (as filed in E.D. Wash.), # 3 Exhibit 2 - Plaintiffs First Request for Production of Documents (as filed in E.D. Pa.), # 4 Exhibit 3 - Order Granting Plaintiffs' Motion for Expedited Discovery (as filed in E.D. Wash.), # 5 Exhibit 4 - Order Granting Expedited Discovery (as filed in E.D. Pa.), # 6 Exhibit 5 - Revised Proposed Order)(Duraiswamy, Shankar) (Entered: 09/23/2020)

ORDER granting 26 joint motion for protective order. Signed by Judge Emmet G. Sullivan on 9/25/2020. (lcegs3) Modified to remove "minute" on 9/29/2020 (znmw). (Entered: 09/25/2020)

ORDER granting 26 joint motion for protective order. Signed by Judge Emmet G. Sullivan on 9/25/2020. (lcegs3) Modified to remove "minute" on 9/29/2020 (znmw). (Entered: 09/25/2020)

NOTICE of Supplemental Materials by LOUIS DEJOY, UNITED STATES POSTAL SERVICE (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C)(Cholera, Kuntal) (Entered: 09/25/2020)

1 Exhibit A

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2 Exhibit B

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3 Exhibit C

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NOTICE of Supplemental Materials by LOUIS DEJOY, UNITED STATES POSTAL SERVICE (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C)(Cholera, Kuntal) (Entered: 09/25/2020)

MINUTE ORDER granting 25 unopposed motion to file supplemental declarations. Signed by Judge Emmet G. Sullivan on 9/25/2020. (lcegs3)

MINUTE ORDER granting 25 unopposed motion to file supplemental declarations. Signed by Judge Emmet G. Sullivan on 9/25/2020. (lcegs3)

ORDER granting 16 Motion for Preliminary Injunction. Signed by Judge Emmet G. Sullivan on 9/28/2020. (lcegs3) (Entered: 09/28/2020)

ORDER granting 16 Motion for Preliminary Injunction. Signed by Judge Emmet G. Sullivan on 9/28/2020. (lcegs3) (Entered: 09/28/2020)

MEMORANDUM OPINION. Signed by Judge Emmet G. Sullivan on 9/28/2020. (lcegs3) (Entered: 09/28/2020)

MEMORANDUM OPINION. Signed by Judge Emmet G. Sullivan on 9/28/2020. (lcegs3) (Entered: 09/28/2020)

MINUTE ORDER granting 20 Motion for Expedited Discovery. Federal Rule of Civil Procedure 26 "vests the trial judge with broad discretion to tailor discovery narrowly and to dictate the sequence of discovery." Watts v. SEC, 483 F.3d 501, 507 (D.C. Cir. 2007) (quoting Crawford-El v. Britton, 523 U.S. 574, 598 (1998)). Courts typically consider five factors when evaluating a motion for expedited discovery under the good-cause standard: "(1) whether a preliminary injunction is pending; (2) the breadth of the discovery requests; (3) the purpose for requesting the expedited discovery; (4) the burden on the defendants to comply with the requests; and (5) how far in advance of the typical discovery process the request was made." Guttenberg v. Emery, 26 F. Supp. 3d 88, 98 (D.D.C. 2014) (quoting In re Fannie Mae Derivative Litig., 227 F.R.D. 142, 14243 (D.D.C. 2005)). Courts are not limited to these factors, but the factors provide "guidelines for the exercise of the Court's discretion." Id. The Court finds that the good-cause standard is met here. As an initial matter, the Court notes that plaintiffs' motion for preliminary injunction has been granted. See Order, ECF No. 31. Second, the Court has reviewed the discovery requests and has determined that they are narrow and carefully targeted to discover the facts necessary for plaintiffs to establish their claims and rebut anticipated defenses. Plaintiffs shall ensure that they do not request discovery that has already been provided by the defendants in similar actions, specifically Pennsylvania v. DeJoy, No. 20-cv-4096 (E.D. Pa.) and Washington v. Trump, No. 20-cv-3127 (E.D. Wash.). Third, the purpose for requesting the expedited discovery supports granting plaintiffs' motion given the imminence of the election and the claim for which plaintiffs did not seek a preliminary injunction. Fourth, while defendants contend that it will be burdensome on them to comply, they mostly contend that the requests are duplicative and overlapping, or potentially overlapping. However, the Court has directed plaintiffs to ensure they do not request duplicative discovery. Fifth, while the discovery requests here are being made in advance of the typical discovery process, expedited resolution is appropriate given the imminence of the election. Accordingly, it is HEREBY ORDERED that defendants shall serve any objections to plaintiffs' discovery requests by no later than October 7, 2020; and it is FURTHER ORDERED that defendants shall serve their written responses and shall produce all documents responsive to plaintiffs' discovery requests by no later than October 13, 2020; and it is FURTHER ORDERED that depositions shall be taken by no later than October 16, 2020. The parties shall coordinate with the plaintiffs in State of New York v. Trump, 20-cv-2405, with regard to the taking of the depositions. Signed by Judge Emmet G. Sullivan on 10/2/2020. (lcegs3)

MINUTE ORDER granting 20 Motion for Expedited Discovery. Federal Rule of Civil Procedure 26 "vests the trial judge with broad discretion to tailor discovery narrowly and to dictate the sequence of discovery." Watts v. SEC, 483 F.3d 501, 507 (D.C. Cir. 2007) (quoting Crawford-El v. Britton, 523 U.S. 574, 598 (1998)). Courts typically consider five factors when evaluating a motion for expedited discovery under the good-cause standard: "(1) whether a preliminary injunction is pending; (2) the breadth of the discovery requests; (3) the purpose for requesting the expedited discovery; (4) the burden on the defendants to comply with the requests; and (5) how far in advance of the typical discovery process the request was made." Guttenberg v. Emery, 26 F. Supp. 3d 88, 98 (D.D.C. 2014) (quoting In re Fannie Mae Derivative Litig., 227 F.R.D. 142, 14243 (D.D.C. 2005)). Courts are not limited to these factors, but the factors provide "guidelines for the exercise of the Court's discretion." Id. The Court finds that the good-cause standard is met here. As an initial matter, the Court notes that plaintiffs' motion for preliminary injunction has been granted. See Order, ECF No. 31. Second, the Court has reviewed the discovery requests and has determined that they are narrow and carefully targeted to discover the facts necessary for plaintiffs to establish their claims and rebut anticipated defenses. Plaintiffs shall ensure that they do not request discovery that has already been provided by the defendants in similar actions, specifically Pennsylvania v. DeJoy, No. 20-cv-4096 (E.D. Pa.) and Washington v. Trump, No. 20-cv-3127 (E.D. Wash.). Third, the purpose for requesting the expedited discovery supports granting plaintiffs' motion given the imminence of the election and the claim for which plaintiffs did not seek a preliminary injunction. Fourth, while defendants contend that it will be burdensome on them to comply, they mostly contend that the requests are duplicative and overlapping, or potentially overlapping. However, the Court has directed plaintiffs to ensure they do not request duplicative discovery. Fifth, while the discovery requests here are being made in advance of the typical discovery process, expedited resolution is appropriate given the imminence of the election. Accordingly, it is HEREBY ORDERED that defendants shall serve any objections to plaintiffs' discovery requests by no later than October 7, 2020; and it is FURTHER ORDERED that defendants shall serve their written responses and shall produce all documents responsive to plaintiffs' discovery requests by no later than October 13, 2020; and it is FURTHER ORDERED that depositions shall be taken by no later than October 16, 2020. The parties shall coordinate with the plaintiffs in State of New York v. Trump, 20-cv-2405, with regard to the taking of the depositions. Signed by Judge Emmet G. Sullivan on 10/2/2020. (lcegs3)

.Order

Emergency MOTION to Enforce and Monitor Compliance with Preliminary Injunction, Emergency MOTION for Hearing and Briefing by AMY BOLAN, AARON CARREL, COLORADO ORGANIZATION FOR LATINA OPPORTUNITY AND REPRODUCTIVE RIGHTS, INDERBIR SINGH DATTA, DANTE FLORES-DEMARCHI, PAUL HUNTER, SEBASTIAN IMMONEN, KATHRYN MONTGOMERY, SEAN MORRISON, PADRES & JOVENES UNIDOS, LINDA ROBERSON, MARTHA THOMPSON, VOCES UNIDAS DE LAS MONTANAS, VOTE FORWARD, GARY YOUNG (Attachments: # 1 Memorandum in Support of Plaintiffs' Emergency Motion to Enforce and Monitor Compliance with Preliminary Injunction and Request for Expedited Briefing and Hearing, # 2 Exhibit Index, # 3 Exhibit A - Postmaster General DeJoy Testimony Tr. Aug. 24: House Oversight Hearing, # 4 Exhibit B - Tr. of Deposition of Robert Cintron, NY v. Trump, # 5 Exhibit C - USPS Service Score Data, # 6 Exhibit D - Supp. Grimmer Decl., NY v. Trump, # 7 Exhibit E - USPS Mar. 1 - Oct. 11, 2020 Extra Trips Data, # 8 Exhibit F - USPS Mar. 1 - Oct. 11, 2020 Late Trips Data, # 9 Exhibit G - USPS Daily Late and Extra Trips from Oct. 1 through Oct. 15, 2020, # 10 Exhibit H - Decl. of Joshua Colin, Pa. v. DeJoy, # 11 Exhibit I - Mem. from Kristin A. Seaver & David E. Williams to Officers, # 12 Exhibit J - Tr. of Deposition of Robert Justin Glass, NY v. Trump, # 13 Exhibit K - Supp. Grimmer Decl., Vote Forward v. DeJoy, # 14 Text of Proposed Order)(Duraiswamy, Shankar) (Entered: 10/22/2020)

1 Memorandum in Support of Plaintiffs' Emergency Motion to Enforce and Monito

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2 Exhibit Index

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3 Exhibit A - Postmaster General DeJoy Testimony Tr. Aug. 24: House Oversight Hear

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4 Exhibit B - Tr. of Deposition of Robert Cintron, NY v. Trump

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5 Exhibit C - USPS Service Score Data

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6 Exhibit D - Supp. Grimmer Decl., NY v. Trump

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7 Exhibit E - USPS Mar. 1 - Oct. 11, 2020 Extra Trips Data

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8 Exhibit F - USPS Mar. 1 - Oct. 11, 2020 Late Trips Data

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9 Exhibit G - USPS Daily Late and Extra Trips from Oct. 1 through Oct. 15, 2020

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10 Exhibit H - Decl. of Joshua Colin, Pa. v. DeJoy

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11 Exhibit I - Mem. from Kristin A. Seaver & David E. Williams to Officers

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12 Exhibit J - Tr. of Deposition of Robert Justin Glass, NY v. Trump

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13 Exhibit K - Supp. Grimmer Decl., Vote Forward v. DeJoy

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14 Text of Proposed Order

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Emergency MOTION to Enforce and Monitor Compliance with Preliminary Injunction, Emergency MOTION for Hearing and Briefing by AMY BOLAN, AARON CARREL, COLORADO ORGANIZATION FOR LATINA OPPORTUNITY AND REPRODUCTIVE RIGHTS, INDERBIR SINGH DATTA, DANTE FLORES-DEMARCHI, PAUL HUNTER, SEBASTIAN IMMONEN, KATHRYN MONTGOMERY, SEAN MORRISON, PADRES & JOVENES UNIDOS, LINDA ROBERSON, MARTHA THOMPSON, VOCES UNIDAS DE LAS MONTANAS, VOTE FORWARD, GARY YOUNG (Attachments: # 1 Memorandum in Support of Plaintiffs' Emergency Motion to Enforce and Monitor Compliance with Preliminary Injunction and Request for Expedited Briefing and Hearing, # 2 Exhibit Index, # 3 Exhibit A - Postmaster General DeJoy Testimony Tr. Aug. 24: House Oversight Hearing, # 4 Exhibit B - Tr. of Deposition of Robert Cintron, NY v. Trump, # 5 Exhibit C - USPS Service Score Data, # 6 Exhibit D - Supp. Grimmer Decl., NY v. Trump, # 7 Exhibit E - USPS Mar. 1 - Oct. 11, 2020 Extra Trips Data, # 8 Exhibit F - USPS Mar. 1 - Oct. 11, 2020 Late Trips Data, # 9 Exhibit G - USPS Daily Late and Extra Trips from Oct. 1 through Oct. 15, 2020, # 10 Exhibit H - Decl. of Joshua Colin, Pa. v. DeJoy, # 11 Exhibit I - Mem. from Kristin A. Seaver & David E. Williams to Officers, # 12 Exhibit J - Tr. of Deposition of Robert Justin Glass, NY v. Trump, # 13 Exhibit K - Supp. Grimmer Decl., Vote Forward v. DeJoy, # 14 Text of Proposed Order)(Duraiswamy, Shankar) (Entered: 10/22/2020)

NOTICE of Appearance by John Robinson on behalf of All Defendants (Robinson, John) (Entered: 10/22/2020)

NOTICE of Appearance by John Robinson on behalf of All Defendants (Robinson, John) (Entered: 10/22/2020)

Unopposed MOTION for Extension of Time to File Answer by LOUIS DEJOY, UNITED STATES POSTAL SERVICE (Attachments: # 1 Text of Proposed Order)(Robinson, John) (Entered: 10/22/2020)

Unopposed MOTION for Extension of Time to File Answer by LOUIS DEJOY, UNITED STATES POSTAL SERVICE (Attachments: # 1 Text of Proposed Order)(Robinson, John) (Entered: 10/22/2020)