MEMORANDUM IN SUPPORT OF PLAINTIFFS’ RULE 60(B)(2) MOTION FOR RELIEF FROM FINAL JUDGMENT & REQUEST FOR INDICATIVE RULING UNDER RULE 62.1(A)

This motion seeks relief under Fed. R. Civ. P. 60(b)(2) based on newly discovered evidence of discriminatory animus and unconstitutional intent by Secretary Ross and the political appointees and operatives involved in adding a citizenship question to the 2020 Census. This evidence provides the link between the explicitly discriminatory purpose behind the citizenship question and the Commerce Department’s actions, a link that this Court found wanting in the record and thus prevented it from ruling in Plaintiffs’ favor on their claims under the Equal Protection Clause (Kravitz and LUPE Plaintiffs) and 42 U.S.C. § 1985(3) (LUPE Plaintiffs only).