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Case 2:21-cv-05172-HB AMERICAN FEDERATION OF GOVERNMENT EMPLOYEES COUNCIL OF PRISON LOCALS 33 et al v. AHUJA et al Motion for Preliminary Injunction

January 25, 2022

By van der Veen, Hartshorn, Levin & Lindheim

MOTION FOR PRELIMINARY INJUNCTION

Plaintiffs respectfully move this Court for an order under Rule 65 of the Federal Rules of Civil Procedure granting a preliminary injunction, with expedited consideration, in their favor against the named Defendants in their official capacities. As explained in the Complaint and attached Memorandum supporting this motion, Defendants have acted without statutory authority, violated the Civil Service Reform Act of 1978, and the Constitution of the United States, by promulgating and implementing an overly broad and illegal vaccine mandate through Executive Order 14043.

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