***UPDATE*** Final version completed, filed, and attached.
Much of the work in a federal lawsuit is not in the courtroom, but rather in written arguments. Right now, a motion for a preliminary injunction is in front of the court, and the US replied in opposition (naturally — see previous post on blog). I’ve spent much of this week preparing a reply to their opposition, and I think I’ve produced a quality argument.
Let’s make it even better. Some of you may have legal experience, many likely do not, but it doesn’t require a law degree to make a coherent argument. So, I open the floor to you for your review, thoughts, ideas, and suggestions. Anything from a comma out of place to a great piece of case law you read that you think might fit.
My draft document is attached. Some rules:
1) The document gets filed on Monday, so the earlier you reply, the better. The latest reply that I can look at before filing is Monday at 9:00 AM.
2) This is essentially a reply to the government’s reply. Please read the government’s reply first (previous post). As background information, the motion at hand is a motion for preliminary injunction against the TSA using nude body scanners on me or “touching my junk.” (Preliminary injunctions are supposed to be narrow in scope, which is why the motion only relates to me, however if the motion is granted, the door is open for anyone to sue to get relief, not to mention the TSA will be forced re-look at their actions!)
3) You can post your thoughts in the comments or e-mail me directly -> jon at fourtentech.com.
4) Nothing will be construed as “legal advice.” You are either not a lawyer or are a lawyer giving a personal, non-professional opinion only. No attorney-client relationship created, and no compensation due.
Thanks for helping! I know that we all wish that there were something we could do to make this better, and hopefully this is a step in that direction. Together we can beat them!
Reply to Opp to TRO (.pdf) (FINAL VERSION)