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Defendant.
Pursuant to Federal Rule of Civil Procedure 23(a), (b)(2), and (g), Plaintiffs Mark
Tassinari, Richard Espinosa, and Joseph Almeida (“Plaintiffs”), hereby move this Court for an
order:
o All individuals with opioid use disorder (OUD) who are excluded from
of their use or desire to use any form of medication for opioid use disorder
individuals with OUD who are denied access to, or are impeded from
2. Naming Plaintiffs Mark Tassinari, Richard Espinosa, and Joseph Almeida as class
representatives; and
3. Appointing Plaintiffs’ counsel as class counsel.
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Case 1:21-cv-10806-LTS Document 139 Filed 05/05/23 Page 2 of 2
Authorities in Support of Plaintiffs’ Motion for a Preliminary Injunction and Plaintiffs’ Motion
for Provisional Class Certification, the accompanying Declarations of Dr. Claudia Rodriguez,
Mark Tassinari, Richard Espinosa, Joseph Almeida, Shawn Arcidiacono, Christine M. Salazar,
Maria Wenzell, Matthew J. Murray, and Lucy B. Bansal and exhibits thereto, the complete files
and records of this action, and such other matters as the Court may properly consider in ruling on
the motion.
Counsel for Plaintiffs, Matthew J. Murray, hereby certifies that counsel have conferred
and have attempted in good faith to resolve or narrow the issues subject to this motion.
Respectfully submitted,