Case 1:20-cv-03325-AT Document 43 Filed 05/05/20 Page 15 of 30 deprivation of a constitutional right, no separate showing of irreparable harm is necessary.”); Jolly v. Coughlin, 76 F.3d 468, 482 (2d Cir. 1996) (clarifying that “it is the alleged violation of a constitutional right that triggers a finding of irreparable harm” and a substantial likelihood of success on the merits of a constitutional violation is not necessary). Courts in this circuit have consistently found irreparable injury in matters where voters have alleged constitutional violations of their right to vote. See, e.g., Green Party of New York State, 267 F. Supp. 2d at 351 (“The plaintiffs have satisfied the [irreparable harm] prong of the test by alleging” that certain aspects of New York’s voter enrollment scheme violated “their First and Fourteenth Amendment rights to express their political beliefs, to associate with one another as a political party, and to equal protection of the law.”); Credico v. New York State Bd. of Elections, 751 F. Supp. 2d 417, 420 (E.D.N.Y. 2010) (finding irreparable injury where plaintiffs alleged that the [BOE’s] refusal to place a candidate’s name on the ballot violated plaintiffs’ First and Fourteenth Amendment rights to “fully express their political association with the parties or candidates of their choice”); Dillon v. New York State Bd. of Elections, No. 05 Civ. 4766, 2005 WL 2847465, at *3 (E.D.N.Y. Oct. 31, 2005) (finding irreparable harm where “plaintiffs allege[d] violations of their First and Fourteenth Amendment rights of expression and association and equal protection of the law”). Moreover, Plaintiffs and Plaintiff-Intervenors can clearly establish irreparable injury because, without Court intervention, the presidential primary will not take place, Plaintiffs, Plaintiff-Intervenors, and the candidates to whom they are pledged will not appear on the ballot, and—along with other New York Democratic voters—they will be deprived of the right to cast a vote for an otherwise qualified candidate and the political views expressed by that candidate. See Amarasinghe v. Quinn, 148 F. Supp. 2d 630, 634 (E.D. Va. 2001) (“It is clear that the 15

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