Today we filed a Combined Brief in Response to the Defendants' Motion to Dismiss and Reply to Defendants' Opposition to Plaintiffs' Motion for Preliminary Injunction. Here is a short portion of the brief: Plaintiffs are entitled to due process and did not receive it because of the Defendants’ ultra vires construction of the justifiable need standard and the foregone conclusion by the Defendants that they would not issue a permit even when Plaintiffs met justifiable need as s