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The trial court wrote the decision using only points that back the state’s argument, without addressing the facts and the law argued by the plaintiffs in their briefs. Some of the main points that can be argued on appeal include: Standing: The trial court agreed with the defendants that the plaintiffs failed to allege facts establishing standing in the individual capacities or to assert claims on behalf of their businesses. On appeal, we will argue that the plaintiffs did allege sufficient harm from the loss of their personal income due to the actions of the defendants, and that they had authority under existing law to bring the claim as members of limited liability companies for damages suffered by their businesses. The court ignored the fact that the defendants did not raise any claim that the plaintiffs, as individuals, did not have standing; and the court ignored the State Supreme Court precedent of Saunders v. Briner, which allows members of closely held LLCs to bring derivative actions on behalf to their businesses. As to Senator Sampson, the plaintiffs will argue that they did allege specific harm to his ability to participate in the rule-making process, as found by other courts for legislators in similar circumstances. The court also ignored the specific harm alleged regarding the violation of the Connecticut Constitution by the defendants in ignoring the provision to provide proposed rules to the General Assembly for approval. Basically, the court could not refute the arguments made by the plaintiffs in their objection to the Motion to Dismiss, and, thus, ignored those facts, law, and arguments. Mootness and Equal Protection: The plaintiffs will argue that the court was wrong in claiming that the plaintiffs did not include “any information explaining how they were treated differently” or how the different treatment was arbitrary. The plaintiffs specified in their complaint that the Executive Orders and Rules required them to close their businesses and lose their income, while allowing others to keep their businesses open and their income intact. They also will argue that their claims were not rendered moot by the Executive Orders and Rules allowing the businesses to “re-open”; in fact, their income remained substantially harmed when the “re-opening” was only partial and temporary. Takings Clause: The plaintiffs will argue that they demonstrated that the defendants’ actions constituted a taking. The property interest affected was their income and livelihood; each of the plaintiffs’ businesses was required to close and to change its way of operating, causing harm to their personal income, and that their right to due process was affected by the Executive Orders and Rules, particularly when they were issued unconstitutionally. Assembly: The plaintiffs will argue that they provided sufficient facts to confer standing regarding the violation of their First Amendment right of assembly, and that the trial court did not present any relevant legal precedents to refute the plaintiffs’ claims. Relief: The plaintiffs will argue that the court could provide practical relief by issuing a declaratory ruling and injunctive relief, since the harm continued even after the initial “re-opening” of the businesses, due to the issuance of additional Orders and Rules. Sovereign immunity: The plaintiffs will argue that the doctrine of sovereign immunity is not available to the defendants as a matter of law under the Connecticut Constitution, since the State acted unconstitutionally. Writ of Mandamus: The plaintiffs will argue that the claims are ripe and the court can grant the writ.