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[116] On the video made as a documentary source for the story, which is publicly available, Ferguson is heard to say, "500,000 when you can, to me, open doors"

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and Santa Fe is in compliance with the [Memorandum of] Agreement. Given the ongoing challenge to the MOA, defendants promise to remove the terms was only a promise, and they didnt carry the formidable burden of showing that it is absolutely clear the allegedly wrongful behavior could not reasonably be expected to recur. So injunctive relief claims could proceed.