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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.

[36] [37] In addition, Franz Maciejewski presents as evidence of the affair the discovery of a Swiss hotel guest book entry for 13 August 1898, signed by Freud "Dr