Plaintiffs California, Massachusetts, Nevada, Washington, Arizona, Colorado,
Connecticut, Delaware, the District of Columbia, Hawai'i, Illinois, Maine, Maryland, Michigan,
Minnesota, New Jersey, New Mexico, New York, North Carolina, Oregon, Rhode Island,
Vermont, Virginia, Wisconsin, and Josh Shapiro, in his official capacity as Governor of the
Commonwealth of Pennsylvania ("Plaintiff States"), hereby respectfully move, pursuant to
Federal Rule of Civil Procedure 65, 5 U.S.C. § 705, and Local Rule 7.1, for:
1. an immediate temporary restraining order and emergency stay of the United States
Postal Service's ("USPS) final rule Ballot Mail for Federal Elections, 91 Fed. Reg.
54,966 (published Aug. 26, 2026) (codified at 39 C.F.R. pt. 111) ("Rule"); and
2. expedited briefing on a preliminary injunction and § 705 stay, followed by entry of the
requested preliminary injunction and stay to restrain Defendants' from implementing
or enforcing the Rule pending resolution of this case.