Professional Documents
Culture Documents
US CCB Motion For PI
US CCB Motion For PI
US CCB Motion For PI
No. 2:24-cv-691
UNITED STATES CONFERENCE OF
CATHOLIC BISHOPS, et al.,
Plaintiffs,
Defendants.
Pursuant to Federal Rule of Civil Procedure 65 and Local Rule 65.1, Plaintiffs the United States
Conference of Catholic Bishops, the Society of the Roman Catholic Church of the Diocese of Lake
Charles, the Society of the Roman Catholic Church of the Diocese of Lafayette, and The Catholic
University of America (collectively, “Plaintiffs”) move for a preliminary injunction on Counts I,
III, V, and Count VI set out in their Complaint (ECF No. 1) against Defendants Equal Employment
Plaintiffs ask this Court to stay the effective date of the Final Rule, Implementation of Pregnant
Workers Fairness Act, 89 Fed. Reg. 29,096 (Apr. 19, 2024), pending judicial review, see 5 U.S.C.
§ 705, and to preliminary enjoin Defendants from enforcing the Final Rule, the Pregnant Workers
Fairness Act, 42 U.S.C. § 2000gg, et seq., and Title VII, 42 U.S.C. § 2000e, et seq., as it concerns
the inclusion of abortion in the Final Rule, including any aspect of the Final Rule or its enforcement
pursuant to statute that would compel or pressure Plaintiffs to abandon employment policies and
practices embodying their sincere religious beliefs against abortion. The grounds for this Motion
1
Case 2:24-cv-00691-DCJ-TPL Document 11 Filed 05/22/24 Page 2 of 3 PageID #: 414
Respectfully submitted,
2
Case 2:24-cv-00691-DCJ-TPL Document 11 Filed 05/22/24 Page 3 of 3 PageID #: 415
CERTIFICATE OF SERVICE
I hereby certify that on May 22, 2024, the foregoing was electronically filed using the CM/ECF
system. A copy of the foregoing will also be promptly served upon Defendants pursuant to Fed. R.
Civ. P. 5(b) and emailed to counsel for EEOC at the email addresses below:
Daniel Schwei, Esq. (daniel.s.schwei@usdoj.gov)
s/ Daniel H. Blomberg
Daniel H. Blomberg*
Trial Attorney
s/ Michael J. O’Brien
Michael J. O’Brien
(LA Bar No. 38852)
*Application for admission pro hac vice
forthcoming