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RIDGEWAY SUPERIOR COURT
FOR THE COUNTY OF RIDGEWAY
aspenfun,
Plaintiff,
v.
SolomonNomikos,
Defendant.
MOTION FOR TEMPORARY
RESTRAINING ORDER AND
PRELIMINARY INJUNCTION
INTRODUCTION
Mr. aspenfun (“Plaintiff”), by and through the undersigned counsel, pursuant to
Rid. R. Civ. P. 47(a), respectfully moves the court to issue a Temporary Restraining Order
against SolomonNomikos (“Defendant”), for 14 days, and, following a hearing, a
Preliminary Injunction against Defendant, pursuant to Rid. R. Civ. P. 47(b). In support
thereof, the Plaintiff states the following:
FACTUAL BACKGROUND
1. Plaintiff is a resident and citizen of the State of Ridgeway, and is employed
by the Ridgeway County Transit Authority as a Supervisor.
2. Defendant is a resident and citizen of the State of Ridgeway.
3. Plaintiff seeks protection from repeated acts of violence and harassment
perpetrated by Defendant.
4. On multiple occasions, Defendant has approached and physically assaulted
Plaintiff without provocation. These incidents have caused Plaintiff to fear
for their safety and believe that the behaviour will continue unless
restrained by order of this Court.
5. On one occasion, Defedant told Plaintiff that their “sole purpose in this
game will be to ruin your towing experience”. There have been more
incidents of promised targeting by the Defendant, said directly to the
Plaintiff.
6. On or about the 13th of July, 2025, Defendant intentionally shot Plaintiff as
they were towing an abandoned car in Palmer. On the same day, Defendant
followed Plaintiff around in Sterling Heights, causing them to call the
police. On this specific event, Defendant made threatening comments
towards Plaintiff.
7. Plaintiff has filed a sworn affidavit, detailing these events and
demonstrating that they are at risk of immediate and irreparable harm in the
absence of Court-ordered protection.
LEGAL STANDARD
1. Under the Ridgeway Rules of Civil Procedure, a TRO may be issued without prior
notice to the adverse party if it appears from specific facts set forth in an affidavit
or verified complaint that immediate and irreparable injury, loss, or damage will
result before the adverse party can be heard.1
2. Plaintiff meets this standard, as the pattern of targeted incidents of assaults and
harassment creates a substantial and imminent risk of further harm that cannot be
depressed by monetary damages alone.2
REQUEST FOR RELIEF
Accordingly, the Plaintiff respectfully requests that this Court:
A. Issue a Temporary Restraining Order prohibiting the Defendant from;
a. Coming within fifteen (15) studs of Plaintiff
b. Contacting, messaging, threatening, or harassing Plaintiff directly or
indirectly by any means;
c. Appearing at or near locations where Plaintiff is employed or otherwise
lawfully present;
B. Schedule a hearing on the matter of a Preliminary Injunction;
2 Plaintiff does not intend on suing the Defendant, nor do they intend on seeking monetary relief. The application for
a TRO is simply to ensure their physical safety and wellbeing, as they carry out the duties of an RCTA tow operator.
1 Rid. R. Civ. P. 47(a)
a. Waive the requirement of a bond or other security, pursuant to the Rules, as
there is no risk of harm to Defendant by requiring them to refrain from
unlawful conduct;
b. Grant such further relief as this Court deems just and proper.
Dated: July 16th, 2025
Palmer, Ridgeway County Respectfully submitted,
Detachment_Result
Detachment_Result (State Bar No. 11103)
Counsel of Record
Nicklaus, Popplewell & Associates LLP
Lander Civic Center, Suite 324
Lander, Mayflower 19000
Tel: (212) 558-4000
Fax: (212) 558-3588
Email: [email protected]
Attorney for Plaintiff
