DIY Obama Ballot Challenge - Motion For Temporary Restraining Order in KY

IN THE COMMONWEALTH OF KENTUCKY

FRANKLIN CIRCUIT COURT

48TH JUDICIAL CIRCUIT

CIVIL ACTION NO. __________________[leave blank until assigned]

[substitute the applicable heading for your state and county court name above]

…, Plaintiff; [if original suit is brought by more than one plaintiff, change to plural, and do so throughout this complaint form, as applicable] vs. Barack Obama, Democratic National Committee, Secretary of State, and State Board of Elections, Defendants.	MOTION FOR TEMPORARY RESTRAINING ORDER

Plaintiff requests that the court issue a temporary restraining order (“TRO”) restraining the Secretary of State from printing ballots with the name of defendant Obama on them as a candidate for President of the United States until the final resolution of this case, as follows:

Necessity of TRO

As shown below, the TRO is necessary because, without it, there is a high likelihood that defendants Obama and DNC will resist discovery and delay this case, perhaps beyond the November election. On the other hand, once the TRO in place, defendants Obama and DNC will be more likely to cooperate with the discovery needed to resolve the factual questions necessary to the proper resolution of this case.