Case 5:16-cv-00257-OLG Document 106 Filed 05/17/18 Page 1 of 4

IN THE UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF TEXAS
SAN ANTONIO DIVISION

JARROD STRINGER, et. al, §

§
Plaintiffs, §
§
v. §
§
ROLANDO PABLOS, IN HIS OFFICIAL § Civil Action No. 5:16-cv-00257-OLG
CAPACITY AS THE TEXAS SECRETARY §
OF STATE and STEVEN C. McCRAW, IN §
HIS OFFICIAL CAPACITY AS THE §
DIRECTOR OF THE TEXAS §
DEPARTMENT OF PUBLIC SAFETY §
§
Defendants. §

PLAINTIFFS’ NOTICE OF FILING PROPOSED FORM OF JUDGMENT

Plaintiffs file this Notice along with their Proposed Form of Judgment, which is

submitted as Exhibit A. The Court’s May 10, 2018 Order requires the Parties to submit a

proposed form of judgment setting forth the necessary declaratory and injunctive relief,

consistent with the Court's findings, on or before May 17, 2018. Order, Dkt. 105 at 60-61.

On May 14, 2018, Plaintiffs’ counsel emailed their proposed form of judgment to

Defendants’ counsel. See Ex. A; Ex. B. On May 15, 2018, Plaintiffs’ counsel requested a

meeting with Defendants’ counsel to discuss the proposed form of judgment. See Ex. C.

Defendants’ counsel agreed to confer via telephone call at 8:30 a.m. the next day. During the

conference on May 16, 2018, Defendants’ counsel notified Plaintiffs’ counsel that they generally

do not agree with the monitoring and public education provisions in Plaintiffs’ proposed form of

judgment and recommended that the Parties submit separate filings in response to the Court’s

May 10th Order. During the call on May 16th and in an email sent on the morning of May 17,

2018, Plaintiffs’ counsel requested that Defendants’ counsel send a draft of Defendants’

1
 Case 5:16-cv-00257-OLG Document 106 Filed 05/17/18 Page 2 of 4

proposed form of judgment—or specify Defendants’ objections to Plaintiffs’ proposed form of

judgment and provide the details of Defendants’ proposal. See Ex. D. Defendants’ counsel did

not respond to this email with specific objections to Plaintiffs’ proposed form of judgment or

specific proposals from Defendants. Instead, Defendants’ counsel stated, in part, that Defendants

“were unable to reconcile [Plaintiffs’] proposal with the requirement that injunctive relief be

narrowly tailored to address the particular legal violation the Court found, as required by Rule

65.” See Ex. E.

As a result, if necessary, Plaintiffs request the Court allow them the opportunity to

respond to Defendants’ proposed form of judgment, any specific objections made by Defendants

to Plaintiffs’ proposed form of judgment, and/or any specific proposals from Defendants.

Dated: May 17, 2017 Respectfully submitted,

By: /s/ Hani Mirza

Peter A. Kraus (pro hac vice)
Texas Bar No. 11712980
kraus@waterskraus.com
Charles S. Siegel
Texas Bar No. 18341875
siegel@waterskraus.com
Caitlyn E. Silhan
Texas Bar No. 24072879
csilhan@waterskraus.com
Rachel A. Gross (pro hac vice)
Texas Bar No. 24073608
rgross@waterskraus.com

WATERS & KRAUS, LLP

3141 Hood Street, Suite 700
Dallas, Texas 75219
214-357-6244 (Telephone)
214-871-2263 (Facsimile)

Mimi M.D. Marziani

Texas Bar No. 24091906
mimi@texascivilrightsproject.org
Rebecca Harrison Stevens
Texas Bar No. 24065381

2
Case 5:16-cv-00257-OLG Document 106 Filed 05/17/18 Page 3 of 4

beth@texascivilrightsproject.org
Hani Mirza
Texas Bar No. 24083512
hani@texascivilrightsproject.org

TEXAS CIVIL RIGHTS PROJECT

1405 Montopolis Drive
Austin, Texas 78741
512-474-5073 (Telephone)
512-474-0726 (Facsimile)

ATTORNEYS FOR PLAINTIFFS

3
 Case 5:16-cv-00257-OLG Document 106 Filed 05/17/18 Page 4 of 4

CERTIFICATE OF SERVICE
I hereby certify that on May 17, 2018, a true and correct copy of this Notice and

Plaintiffs’ Proposed Form of Judgment was served upon counsel of record via the Court’s ECF

system.

/s/ Hani Mirza

CERTIFICATE OF CONFERENCE
I hereby certify that on May 16 and 17, 2018, Plaintiffs’ counsel conferred with

Defendants’ counsel, Anna Mackin and Esteban Soto, and Defendants’ counsel are opposed to

Plaintiffs’ Proposed Form of Judgment, which is submitted with this Notice as Exhibit A.

/s/ Hani Mirza

4
Case 5:16-cv-00257-OLG Document 106-1 Filed 05/17/18 Page 1 of 8

Exhibit A
 Case 5:16-cv-00257-OLG Document 106-1 Filed 05/17/18 Page 2 of 8

IN THE UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF TEXAS
SAN ANTONIO DIVISION

JARROD STRINGER, et. al, §

§
Plaintiffs, §
§
v. §
§
ROLANDO PABLOS, IN HIS OFFICIAL § Civil Action No. 5:16-cv-00257-OLG
CAPACITY AS THE TEXAS SECRETARY §
OF STATE and STEVEN C. McCRAW, IN §
HIS OFFICIAL CAPACITY AS THE §
DIRECTOR OF THE TEXAS §
DEPARTMENT OF PUBLIC SAFETY §
§
Defendants. §

[PROPOSED FORM OF] JUDGMENT

The Court, having considered the parties’ motions for summary judgment and ordered

entry of judgment in favor of Plaintiffs (Dkt. 105), now therefore:

1. FINDS AND DECLARES, pursuant to 28 U.S.C. § 2201 and 52 U.S.C.

§ 20510(b)(2), that Defendants have violated the NVRA, 52 U.S.C. §§ 20503(a)(1), 20504(a),

(c), (d), and (e), and 20507(a)(1)(A), and the Equal Protection Clause, U.S. Const. amend. XIV,

§ 1, by failing to permit simultaneous voter registration with online driver’s license renewal and

change-of-address transactions;

2. PERMANENTLY ENJOINS Defendants, their agents and successors in office,

and all persons working in concert with them, from continuing to violate the NVRA and Equal

Protection Clause by:

(a) failing to establish procedures to register to vote in elections for Federal office for

driver’s license customers who renew or change their address online;

1
Case 5:16-cv-00257-OLG Document 106-1 Filed 05/17/18 Page 3 of 8

(b) refusing to treat each online driver’s license renewal or change-of-address application

as an application for voter registration with respect to elections for Federal office;

(c) refusing to include a voter registration application form for elections for Federal

office as part of each online driver’s license renewal or change-of-address

application;

(d) requiring online driver’s license renewal and change-of-address customers who wish

to register to vote or update their voter registration to complete an entirely separate,

duplicative voter registration application with the Secretary of State’s office;

(e) refusing to make the voter registration portion of each online driver’s license renewal

or change-of-address application available to the Secretary of State’s office;

(f) refusing to treat the customer’s online driver’s license change-of-address application

as a notification of change of address for voter registration with respect to elections

for Federal office, unless the customer indicates that the change of address is not for

voter registration purposes;

(g) refusing to transmit voter registration information submitted in connection with

online driver’s license renewal and change-of-address transactions to the appropriate

State election official within the statutorily required timeframe, 52 U.S.C. § 20504(e);

(h) refusing, in the case of registration with an online driver’s license renewal or change-

of-address application, to ensure that any eligible online driver’s license customer is

registered to vote in an election, if the valid voter registration form of the customer is

submitted to the Department of Public Safety (DPS) not later than the lesser of 30

days, or the period provided by state law, before the date of the election;

2
 Case 5:16-cv-00257-OLG Document 106-1 Filed 05/17/18 Page 4 of 8

(i) refusing to accept and use online driver’s license customers’ previously-captured

electronic signatures for voter registration purposes; and

(j) failing to record and use an online driver’s license renewal or change-of-address

customer’s response to the voter registration portion of the application.

3. PERMANENTLY ENJOINS Defendants, their agents and successors in office,

and all persons working in concert with them, from implementing practices and procedures that

otherwise violate the NVRA;

4. DIRECTS Defendant DPS, no later than 45 days 1 from the date of this Judgment,

to:

(a) permit simultaneous voter registration with online driver’s license renewal and

change-of-address transactions so that in order to register to vote or update voter

registration information, the online driver’s license renewal or change-of-address

customer only needs to respond to the following:

1. Would you like to register to vote? No additional information

is required.

○ Yes, Register Me to Vote

○ No, Do Not Register Me to Vote

2. If you are already registered, this application will be used to

update your voter registration address, unless you opt out.
Would you like to opt out of updating your address for voter
registration purposes?

○ Update My Voter Registration

○ Opt Out: DO NOT Update My Voter Registration

(Your new address will not be submitted to the Texas
Secretary of State’s office for voter registration purposes).

1
This shortened timeline compared to the initially requested relief of 90-day implementation is (1) justified
considering the simplicity of implementation evidenced by the record, and (2) necessary because of the imminent
election in November 2018.

3
 Case 5:16-cv-00257-OLG Document 106-1 Filed 05/17/18 Page 5 of 8

(hereinafter “the voter registration questions”);

(b) register to vote or update voter registration information for online driver’s license

customers who select “Yes” in response to the question, “Would you like to register

to vote?”

(c) register to vote or update voter registration information for online driver’s license

customers who select “Update My Voter Registration” in response to the question,

“Would you like to opt out of updating your address for voter registration purposes?”

(d) register to vote or update voter registration information for online driver’s license

customers who select both "No” in response to the question, “Would you like to

register to vote?” and “Update My Voter Registration” in response to the question,

“Would you like to opt out of updating your address for voter registration purposes?”

(e) track, record, and retain each online driver’s license renewal or change-of-address

customer’s response to the voter registration questions; and

(f) transmit the voter registration information for each online driver’s license renewal or

change-of-address customer to the Secretary of State’s office, including the

customer’s response to the voter registration questions and the customer’s electronic

signature file collected during the customer’s last in-person transaction;

5. DIRECTS Defendant the Secretary of State, upon receipt from DPS of each

online driver’s license renewal or change-of-address customer’s voter registration information

and signature file, to transmit this data in the normal course of business to local voter registrars

who are responsible for completing the voter registration process, in a manner substantially

similar to the process for transmitting voter registration information after an in-person

4
 Case 5:16-cv-00257-OLG Document 106-1 Filed 05/17/18 Page 6 of 8

transaction; and ensure that local voter registrars register to vote or update the voter registration

information of these customers;

6. DIRECTS Defendants, within 14 days from the date of this Judgment, to submit

to Plaintiffs’ counsel a broad-based public education plan for approval that details the use of all

media venues, including but not limited to television, radio, internet social media, Texas.gov,

and the Secretary of State’s website https://www.sos.state.tx.us, to inform and educate the public

on how this Judgment changes the voter registration process for online driver’s license renewal

and change-of-address applications; include in this public education plan steps to incorporate for

two years the promotion of voter registration through online driver’s license renewal and change-

of-address applications into the Texas.gov marketing program, the Texas.gov/driver marketing

campaign, and all DPS, Secretary of State, and their vendors’ marketing campaigns related to

online driver’s license renewal and change-of-address applications; and, once the public

education plan is approved by Plaintiffs, implement such plan no later than 45 days from the

date of this Judgment. 2

7. DIRECTS Defendants to:

(a) submit to this Court notice of compliance with this Judgment no later than 45 days

from the date of this Judgment, with affidavits from the Director of DPS and the

Secretary of State attached confirming compliance with this Judgment;

(b) submit to Plaintiffs’ counsel on or before January 15th of every year for the next three

years through January 15, 2021, a report that includes, for the previous calendar year:

2
Should the Parties be incapable of agreeing on an appropriate public education plan, the Parties will submit their
proposals to the Court no later than 25 days from the date of this Judgment, and the Court will order the
implementation of a plan that takes reasonable steps to inform the public about this Judgment as described in
Paragraph 6.

5
Case 5:16-cv-00257-OLG Document 106-1 Filed 05/17/18 Page 7 of 8

(i) a general summary of compliance efforts detailing all steps taken to implement

each of the provisions and requirements of this Judgment, including any

significant implementation problems, staff training needs, and recommendations

for improvement;

(ii) the number of online driver’s license renewal and change-of-address applications

and the number of voter registrations arising from these applications;

(iii)copies of all NVRA procedures and educational and training materials related to

online driver’s license renewal or change-of-address transactions both used in the

preceding year and expected to be used in the future;

(iv) any investigations or corrective actions at DPS or the Secretary of State’s office

related to voter registrations through online driver’s license renewal or change-of-

address applications;

(v) any implemented or revised policies or procedures at DPS or the Secretary of

State’s office related to voter registrations through online driver's license renewal

or change-of-address applications; and

(vi) all customer complaints related to voter registration through an online driver’s

license renewal or change-of-address application, and all subsequent

correspondence and action taken related to each customer complaint; and

(c) conduct monthly quality control tests until May 2019 to ensure that the online

driver’s license renewal and change-of-address process complies with this Judgment,

and report to Plaintiffs’ counsel every three months the results of completed quality

control tests;

6
 Case 5:16-cv-00257-OLG Document 106-1 Filed 05/17/18 Page 8 of 8

8. RETAINS jurisdiction over this action until two years after the date of this

Judgment to ensure that Defendants continue to comply with their obligations under the NVRA,

the Equal Protection Clause, and this Judgment, and, if Defendants fail to comply with this

Judgment at any time after the two-year deadline, permits Plaintiffs to initiate an enforcement

action against Defendants in this Court;

9. ORDERS that Defendants shall pay to Plaintiffs their reasonable attorney’s fees,

including litigation expenses, and costs as will be determined by the Court in a post-judgment

Order upon submission by the Plaintiffs.

SIGNED this ____ day of ________, 2018.

___________________________________
ORLANDO L. GARCIA
CHIEF U.S. DISTRICT JUDGE

7
Case 5:16-cv-00257-OLG Document 106-2 Filed 05/17/18 Page 1 of 3

Exhibit B
5/17/2018 Case 5:16-cv-00257-OLGTexasDocument
Civil Rights Project
106-2 Mail - Fwd:
FiledStringer v. Pablos Page 2 of 3
05/17/18

Hani Mirza <hani@texascivilrightsproject.org>

Fwd: Stringer v. Pablos

Hani Mirza <hani@texascivilrightsproject.org> Mon, May 14, 2018 at 8:02 PM
To: "Mackin, Anna" <Anna.Mackin@oag.texas.gov>
Cc: Caitlyn Silhan <csilhan@waterskraus.com>, Beth Stevens <beth@texascivilrightsproject.org>,
Caroline.Taylor@oag.texas.gov, Kelly.Gall@oag.texas.gov, Mimi Marziani <mimi@texascivilrightsproject.org>, Ryan Cox
<ryan@texascivilrightsproject.org>

Dear Counsel,

Please see the attached word version of the Proposed Form of Judgment.

Thank you,

Hani Mirza

---------- Forwarded message ----------

From: Mackin, Anna <Anna.Mackin@oag.texas.gov>
Date: Fri, May 11, 2018 at 1:32 PM
Subject: Stringer v. Pablos
To: Caitlyn Silhan <csilhan@waterskraus.com>, "beth@texascivilrightsproject.org" <beth@texascivilrightsproject.org>
Cc: "Taylor, Caroline" <Caroline.Taylor@oag.texas.gov>, "Gall, Kelly" <Kelly.Gall@oag.texas.gov>

Dear Counsel,

In view of the Court’s order received today, do you have a proposal for what your desired injunction would look
like?

Thanks,

Anna

Anna Mackin | Assistant Attorney General

Texas Office of the Attorney General

512.475.4074 | anna.mackin@oag.texas.gov

--
Hani Mirza
Senior Attorney
Texas Civil Rights Project
O: (972) 333-9200 ext. 171
https://mail.google.com/mail/u/0/?ui=2&ik=fd92fad4ed&jsver=awrWbfDFcFs.en.&cbl=gmail_fe_180429.15_p3&view=pt&msg=16361525f9daae16&search=inbox&siml
5/17/2018 Case 5:16-cv-00257-OLGTexasDocument
Civil Rights Project
106-2 Mail - Fwd:
FiledStringer v. Pablos Page 3 of 3
05/17/18
www.texascivilrightsproject.org
Facebook | Twitter | Instagram

Donate Now!

This email and any files attached are privileged and confidential, and is/are intended only for the individual named. If you are not the intended recipient or
otherwise have reason to believe that you have received this message in error, please notify the sender by email and delete this message immediately from your
computer. Any other use, retention, dissemination, forwarding, printing, or copying of this message and any attachments is strictly prohibited.

Proposed Form of Judgment.docx

36K

https://mail.google.com/mail/u/0/?ui=2&ik=fd92fad4ed&jsver=awrWbfDFcFs.en.&cbl=gmail_fe_180429.15_p3&view=pt&msg=16361525f9daae16&search=inbox&siml
Case 5:16-cv-00257-OLG Document 106-3 Filed 05/17/18 Page 1 of 3

Exhibit C
5/17/2018 Case 5:16-cv-00257-OLGTexasDocument
Civil Rights Project
106-3 Mail - Fwd:
FiledStringer v. Pablos Page 2 of 3
05/17/18

Hani Mirza <hani@texascivilrightsproject.org>

Fwd: Stringer v. Pablos

Caitlyn Silhan <csilhan@waterskraus.com> Tue, May 15, 2018 at 7:37 AM
To: "Mackin, Anna" <Anna.Mackin@oag.texas.gov>
Cc: Beth Stevens <beth@texascivilrightsproject.org>, Caroline.Taylor@oag.texas.gov, Kelly.Gall@oag.texas.gov, Hani Mirza
<hani@texascivilrightsproject.org>, Mimi Marziani <mimi@texascivilrightsproject.org>, Ryan Cox
<ryan@texascivilrightsproject.org>

Anna, are you available to discuss this today at 3:30? Please let us know. Thanks.

Caitlyn Silhan | Attorney

Waters & Kraus

*sent from my iPhone, so please excuse any errors.

On May 14, 2018, at 8:03 PM, Hani Mirza <hani@texascivilrightsproject.org> wrote:

Dear Counsel,

Please see the attached word version of the Proposed Form of Judgment.

Thank you,

Hani Mirza

---------- Forwarded message ----------

From: Mackin, Anna <Anna.Mackin@oag.texas.gov>
Date: Fri, May 11, 2018 at 1:32 PM
Subject: Stringer v. Pablos
To: Caitlyn Silhan <csilhan@waterskraus.com>, "beth@texascivilrightsproject.org"
<beth@texascivilrightsproject.org>
Cc: "Taylor, Caroline" <Caroline.Taylor@oag.texas.gov>, "Gall, Kelly" <Kelly.Gall@oag.texas.gov>

Dear Counsel,

In view of the Court’s order received today, do you have a proposal for what your desired injunction
would look like?

Thanks,

Anna

Anna Mackin | Assistant Attorney General

Texas Office of the Attorney General

512.475.4074 | anna.mackin@oag.texas.gov

https://mail.google.com/mail/u/0/?ui=2&ik=fd92fad4ed&jsver=awrWbfDFcFs.en.&cbl=gmail_fe_180429.15_p3&view=pt&msg=16363ce60ab59891&search=inbox&dsq
5/17/2018 Case 5:16-cv-00257-OLGTexasDocument
Civil Rights Project
106-3 Mail - Fwd:
FiledStringer v. Pablos Page 3 of 3
05/17/18

--
Hani Mirza
Senior Attorney
Texas Civil Rights Project
O: (972) 333-9200 ext. 171
www.texascivilrightsproject.org
Facebook | Twitter | Instagram

Donate Now!

This email and any files attached are privileged and confidential, and is/are intended only for the individual named. If you are not the
intended recipient or otherwise have reason to believe that you have received this message in error, please notify the sender by email and
delete this message immediately from your computer. Any other use, retention, dissemination, forwarding, printing, or copying of this
message and any attachments is strictly prohibited.

<Proposed Form of Judgment.docx>

This electronic message contains information from WATERS & KRAUS, LLP that may be privileged and confidential
attorney work product or attorney/client communication. The information is intended to be for the use of the addressee
only. If you are not the addressee, note that any disclosure, copying, distribution or use of the contents of this message is
prohibited. If you received this message in error, please notify the sender immediately.

https://mail.google.com/mail/u/0/?ui=2&ik=fd92fad4ed&jsver=awrWbfDFcFs.en.&cbl=gmail_fe_180429.15_p3&view=pt&msg=16363ce60ab59891&search=inbox&dsq
Case 5:16-cv-00257-OLG Document 106-4 Filed 05/17/18 Page 1 of 2

Exhibit D
5/17/2018 Case 5:16-cv-00257-OLGTexasDocument
Civil Rights Project
106-4 Mail - Fwd:
FiledStringer v. Pablos Page 2 of 2
05/17/18

Hani Mirza <hani@texascivilrightsproject.org>

Fwd: Stringer v. Pablos

Caitlyn Silhan <csilhan@waterskraus.com> Thu, May 17, 2018 at 9:06 AM
To: "Soto, Esteban" <Esteban.Soto@oag.texas.gov>, Anna Mackin <Anna.Mackin@oag.texas.gov>
Cc: Beth Stevens <beth@texascivilrightsproject.org>, "Taylor, Caroline" <Caroline.Taylor@oag.texas.gov>, Hani Mirza
<hani@texascivilrightsproject.org>, "Gall, Kelly" <Kelly.Gall@oag.texas.gov>, "mimi@texascivilrightsproject.org"
<mimi@texascivilrightsproject.org>, "ryan@texascivilrightsproject.org" <ryan@texascivilrightsproject.org>

Anna and Esteban,

Following up on our call yesterday, we plan to file our proposed form of judgment by COB today, and would like the
opportunity to review and potentially address any specific counter-proposals and objections you have to our draft before
filing. To that end, and as we requested yesterday, would you please send us a draft of your proposed form of judgment—
or specify your objections to our draft and provide the details of your proposal—by noon today?

Thank you,

Caitlyn

Caitlyn Silhan | Attorney

Waters & Kraus

*sent from a mobile device, so please excuse any errors.

On May 15, 2018, at 1:26 PM, Soto, Esteban <Esteban.Soto@oag.texas.gov> wrote:

[Quoted text hidden]

<ATT00001.jpg>

<ATT00002.jpg>

This electronic message contains information from WATERS & KRAUS, LLP that may be privileged and confidential
attorney work product or attorney/client communication. The information is intended to be for the use of the addressee
only. If you are not the addressee, note that any disclosure, copying, distribution or use of the contents of this message is
prohibited. If you received this message in error, please notify the sender immediately.

https://mail.google.com/mail/u/0/?ui=2&ik=fd92fad4ed&jsver=awrWbfDFcFs.en.&cbl=gmail_fe_180429.15_p3&view=pt&msg=1636e6c717421909&search=inbox&sim
Case 5:16-cv-00257-OLG Document 106-5 Filed 05/17/18 Page 1 of 2

Exhibit E
5/17/2018 Case 5:16-cv-00257-OLGTexas Civil Rights Project
Document 106-5 Mail Filed
- Today’s05/17/18
Submission Page 2 of 2

Hani Mirza <hani@texascivilrightsproject.org>

Today’s Submission
Mackin, Anna <Anna.Mackin@oag.texas.gov> Thu, May 17, 2018 at 1:23 PM
To: caitlyn silhan <csilhan@waterskraus.com>, Beth Stevens <beth@texascivilrightsproject.org>, Hani Mirza
<hani@texascivilrightsproject.org>, Mimi Marziani <mimi@texascivilrightsproject.org>, Ryan Cox
<ryan@texascivilrightsproject.org>
Cc: "Soto, Esteban" <Esteban.Soto@oag.texas.gov>, "Hendrix, Laura" <Laura.Hendrix@oag.texas.gov>, "Taylor, Caroline"
<Caroline.Taylor@oag.texas.gov>, "Gall, Kelly" <Kelly.Gall@oag.texas.gov>

All,

Thank you for providing us with a copy of the proposed judgment you intend to submit to the Court. As we indicated on
the call on Wednesday, we continue to dispute liability, and we also object to the scope of the relief you proposed. The
court found that Defendants’ current processing of online driver license renewals and changes of address violates the
NVRA by failing “to permit a simultaneous voter registration application with every transaction[.]” Doc 105 at 60. The
Court stated that “[a]sking motor voters whether they are interested in voter registration and sending them to SOS for an
entirely separate application process is not enough [to comply with the NVRA’s motor voter requirements.]” Doc. 105 at
60. We were unable to reconcile your proposal with the requirement that injunctive relief be narrowly tailored to address
the particular legal violation the Court found, as required by Rule 65. We therefore object to its terms.

Anna

https://mail.google.com/mail/u/0/?ui=2&ik=fd92fad4ed&jsver=awrWbfDFcFs.en.&cbl=gmail_fe_180429.15_p3&view=pt&msg=1636f57dd59915d7&search=inbox&siml