MEMORANDUM IN SUPPORT OF MOTION FOR PRELIMINARY INJUNCTION
The Plaintiffs, by their counsel van der Veen, Hartshorn and Levin, through Bruce L. Castor, Jr., are seeking injunctive relief from state actors against the illegal mandate affecting their union members.
Resulting from the unlawful vaccine mandate instituted by Defendants, millions of federal employees are facing adverse and unjust punishment for holding honest, constitutionally protected beliefs in opposition to the COVID-19 vaccines. Such forced ingestion of treatment, and Plaintiffs’ members’ reactions thereto, will lead to and threaten the integrity of crucial government operations and violates Plaintiffs’ members constitutional rights.