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Memorandum of law submitted by NYSNA in response to suit

Attached is the memorandum of law submitted by NYSNA in response to the suit filed in federal court seeking an injunction in order to stop NYSNA members from voting on a bylaws proposal at its annual meeting on September 24, 2011.


The New York State Nurses Association is the voice for nursing in the Empire State. With more than 37,000 members, it is New York’s largest professional association and union for registered nurses. The association represents registered nurses, and some all-professional bargaining units, in New York and New Jersey. It supports nurses and nursing practice through education, research, legislative advocacy, and collective bargaining.