Tab 1
SUPERIOR COURT OF THE STATE OF RIDGEWAY
FOR THE COUNTY OF RIDGEWAY
------------------------------------------------------------------------X
ALEXBLUBEAR,
Plaintiff, INDEX No.
v.
RIDGEWAY DEPARTMENT OF STATE et. al.,
Defendant.
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PLAINTIFF'S APPLICATION FOR TEMPORARY RESTRAINING ORDER WITH
EQUITABLE RELIEF AND ORDER TO SHOW CAUSE WHY A PRELIMINARY
INJUNCTION SHOULD NOT ISSUE
Pursuant to Rule 45(a) of the Ridgeway Rules of Civil Procedure, the Plaintiff
Alexblubear, hereby applies to this Court for a temporary restraining order ("TRO") with other
equitable relief. In support of the motion, Plaintiff states as follows:
1. Plaintiff brings this action to halt the defendant’s continued violations of statutory and
constitutional laws of the State of Ridgway. As part of their operations, the State
Department and the Secretary of State Ab_bae has blocked all public communications
within the State Department Discord server which is a direct violation of the right to free
speech as afforded by the Ridgeway Constitution. The defendants' conduct strips the
residents of Ridgeway of their right to free speech and other constitutional protections.
2. As a result of the foregoing, Defendants are engaged in ongoing violations of 1 R. Stat. §
3115 deprivation of rights under the color of the law, which prohibits conduct by any
state actors that willfully and/or knowingly violate the rights of any person(s) in their
contact.
3. Plaintiff therefore seeks a TRO:
a. Temporarily restraining and enjoining the Defendants from violating 1 R. Stat. §
3115 by blocking all public communications within the State Department Discord
server;
b. Temporarily restraining and enjoining the Defendants from infringing on the right
to free speech as afforded by the Constitution of the State of Ridgeway;
c. Requiring Defendants and any authorized person(s) to reinstate the public
communications channel within the State Department Discord;
d. Requiring Defendants and any authorized person(s) to notify the public of the
reinstatement of the public communications channel;
e. Restraining and enjoining Defendants and certain third parties from destroying or
concealing documents;
4. A memorandum of support of TRO and proposed TRO are filed concurrently.
WHEREFORE, Plaintiff respectfully requests that this Court grant this motion by entering the
proposed TRO.
DATE:
July 29, 2025
Respectfully Submitted
/s/ Alexblubear
Alexblubear
Represented Pro Se
SUPERIOR COURT OF THE STATE OF RIDGEWAY
FOR THE COUNTY OF RIDGEWAY
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ALEXBLUBEAR,
Plaintiff, INDEX No.
UDNER SEAL
v.
RIDGEWAY DEPARTMENT OF STATE et. al.,
Defendant.
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MEMORANDUM IN SUPPORT OF PLAINTIFF'S APPLICATION FOR TEMPORARY
RESTRAINING ORDER WITH EQUITABLE RELIEF AND ORDER TO SHOW
CAUSE WHY A PRELIMINARY INJUNCTION SHOULD NOT ISSUE
TABLE OF CONTENTS
I. INTRODUCTION
II. FACTS
A. Defendants
B. Defendants Continued Violations of Applicable Law
III. A TEMPORARY RESTRAINING ORDER SHOULD ISSUE AGAINST DEFENDANTS
A. This Court has Authority to Grant Relief
B. Plaintiff Suffices the Requirements Needed for a TRO and Preliminary Injunction
C. Plaintiff is Likely to Succeed on the Merits of its Claim that Defendants Have Engaged in
Unfair Acts or Practice
1. The likelihood of irreparable harm to the plaintiff if the injunction is denied,
2. The likelihood of harm to the defendant if the request for relief is granted
3. The likelihood of harm that the plaintiff will succeed on the merits
4. Public interest
D. The Equities Weigh In Favor Of Granting Injunctive Relief
IV. THE SCOPE OF THE PROPOSED TRO IS NECESSARY AND APPROPRIATE IN
LIGHT OF DEFENDANTS' UNLAWFUL CONDUCT
A. Conduct Relief
B. Reinstatement of Public Communication Server
C. Notification to Residents
D. Preservation of Records
V. Conclusion
TABLES OF AUTHORITIES
Cases
ACLU v. Reno I, 1996 WL 65464
CFTC v. Hunt, 591 F.2d 1211, 1220 (7th Cir.)
Connection Distrib. Co. v. Reno, 154 F.3d 281, 288 (6th Cir. 1998)
Elrod v. Burns, 427 U.S. 347, 373 (1976)
Five-Star Auto Club, 97 F. Supp. 2d 502, 536 (S.D.N.Y. 2000)
FTC v. Amy Travel Serv. Inc., 875 F.2d 564, 571–72 (7th Cir. 1989)
FTC v. Gem Merch. Corp., 87 F.3d 466, 468 (11th Cir. 1996)
FTC v. R.N. Singer, Inc., 668 F.2d 1107, 1111 (9th Cir. 1982)
FTC v. U.S. Oil & Gas Corp., 748 F.2d 1431 (11th Cir. 1984) (per curiam)
FTC v. Warner Commc'ns, Inc., 742 F.2d 1156, 1165 (9th Cir. 1984)
FTC v. World Wide Factors, Ltd., 882 F.2d at 347
G & V Lounge, Inc. v. Michigan Liquor Control Comm’n, 23 F.3d 1071, 1079 (6th Cir. 1994)
Nightclubs, Inc. v. City of Paducah, 202 F.3d 884, 887 (6th Cir. 2000)
SEC v. R.J. Allen & Assoc., Inc., 386 F. Supp. 866, 877 (S.D. Fla. 1974)
World Travel Vacation Brokers, 861 F.2d at 1030
Statutes
1 R. Stat. § 3115
Rules
Rule 45(a) Ridgeway Rules of Civil Procedure
I. INTRODUCTION
Alexblubear, the Plaintiff, brings this action to halt the Defendants’ reckless, outrageous,
and unfair operational practice by continued violations of Ridgeway Statutory Laws and
Constitutional Rights afforded to those who are residents and or visiting the State of Ridgeway.
Defendants’ acts and omissions constitute an ongoing violation of Ridgeway State Law
and Constitutional protections. In addition to placing irreparable harm to the Plaintiff and others
similarly situated, Defendants have knowingly and willfully continued to violate the laws of
Ridgeway for personal gain and benefit.
Defendants unwitting victims cannot reasonably avoid injury because they are unable to
redress these violations of law with the Defendants as they fail to properly uphold statutory law.
A temporary restraining order ("TRO") is necessary to immediately halt Defendants'
illegal practices and protect the rights of the plaintiff and others similarly situated. The proposed
TRO filed herewith would enjoin Defendants' illegal conduct, require the immediate
reinstatement of the public communications server, and provide for notifying the victims of the
deprivation of rights, This relief is critical to prevent further harm to the injured plaintiff and
preserve the Court's ability to provide effective final relief.
II. FACTS
A. Defendants
Defendants, The Ridgeway State Department and their Secretary, are government actors
whose responsibilities include (1) Defending all laws of the State of Ridgeway; (2) Defending
the constitution of the State of Ridgeway; (3) Protecting the rights and interest of the public; and
(4) Providing a safe environment free of criminal behavior. The actions in which the defendants
have taken are in direct contradiction of that oath in which they vowed to defend.
The Department of State is an executive agency under the Executive Authority within the
Governor’s Cabinet that is responsible for safeguarding the States’ records, among other
responsibilities that are required under the Ridgeway Statutes. The location of the principal
operation is within the State of Ridgeway.
Ab_bae is the Secretary of State for the Department of State for the State of Ridgeway.
The Secretary of State is the principal officer that leads and manages the Department of State and
ensures that all statutory requirements and mandates are filled and supported. The Secretary
principal governmental operations are within the County of Ridgeway and the State of
Ridgeway.
B. Defendants’ Continued Violations of Applicable Law
Defendants have violated several statutory laws under the color of the law, which
includes 1 R. Stat. § 3115, more specifically violating Article I Section 9 of the Ridgeway
constitution that provides that “That the people have a right to freedom of speech, and of writing
and publishing their sentiments, concerning the transactions of government, and therefore the
freedom of the press ought not to be restrained.”
Since at least July 27. 2025 Defendants’ actions have led to a deprivation of rights,
including free speech, due to the removal of the public communications server within the
Official, government sanctioned, State Department Discord server.
State Law and the Ridgeway Constitution provides that no governmental actor can limit
and restrict free speech of person(s) under its authority, perceived or actual, under the color of
the law.
III. A TEMPORARY RESTRAINING ORDER SHOULD ISSUE AGAINST
DEFENDANTS
To immediately halt Defendants' illegal practices and prevent continued harm, the Court
should issue a TRO enjoining Defendants' unfair and illegal conduct, requiring the immediate
reinstatement of the public communications server, providing for other ancillary relief, and
ordering Defendants to show cause why a preliminary injunction should not issue.
A. This Court Has the Authority to Grant the Requested Relief
Under Rule 45(a) of the Ridgeway Rules of Civil Procedure this court has the right to
grant injunctive relief by authorizing a temporary restraining order against the Defendants for
their continued violations of law.
The Superior Court for the State of Ridgeway has continually exercised their authority to
grant TROs with ancillary equitable relief in civil administrative cases. The Superior Court has
the power to issue a permanent injunction to enjoin acts and practices that violate the law, it also
has authority to grant whatever preliminary injunctions are justified by the usual equitable
standards." FTC v. R.N. Singer, Inc., 668 F.2d 1107, 1111 (9th Cir. 1982) This "unqualified grant
of statutory authority .. . carries with it the full range of equitable remedies . . . . " FTC v. Gem
Merch. Corp., 87 F.3d 466, 468 (11th Cir. 1996) Accord FTC v. U.S. Oil & Gas Corp., 748 F.2d
1431 (II th Cir. 1984) (per curiam); FTC v. Amy Travel Serv .. Inc., 875 F.2d 564, 571-72 (7th
Cir. 1989).
This Court also has personal jurisdiction over the Defendants, and venue is proper as the
acts or omissions by the defendants took place substantially or in part within the County of
Ridgeway and the State of Ridgeway respectfully.
B. Plaintiff Suffices the Requirements Needed for a TRO and Preliminary Injunction
Plaintiff suffices the requirements needed for a TRO and a preliminary injunction under
the 4 part test needed for a private litigant. These include: (1) the likelihood of irreparable harm
to the plaintiff if the injunction is denied, (2) the likelihood of harm to the defendant if the
request for relief is granted, (3) the likelihood of harm that the plaintiff will succeed on the
merits, and (4) public interest. Nightclubs, INC. V. City of Paducah, 202 F.3d 884, 887 (6th Cir.
200). However, it is well established that in cases of alleged constitutional violation(s) the
four-part test normally applied to preliminary injunctions logically reduces itself to one factor,
and the likelihood of success on the merits factor is determinative. Connection Distrib. Co. V.
Reno, 154 F.3d 281, 288 (6th Cir. 1998) (citing Golden V. Kelsey-Hayes Co., 73d 648, 653) cert,
denied, 519 U.S. 807 (1996)); Elrod V. Burns, 427 U.S. 347, 373 (1976) (even temporary loss of
constitutional rights establishes irreparable injury); G & V lounge, INC. V. Michigan Liquor
Control Comm’n 23 F.3d. 1071, 1079 (6th Cir. 1994) (public interest always lies with the
protection(s) of the party’s constitutional rights.) Accordingly, the crucial inquiry for the Court is
whether the statute in question is likely to be found unconstitutional. Thus, the plaintiff turns to
the likelihood of success on the merits. Plaintiffs need not prove their whole case to show a
likelihood of success on the merits. If the balance of hardships tips in favor of the plaintiff, then
the plaintiff must only raise “questions going to the merits so serious, substantial, difficult and
doubtful, as to make them fair ground for litigation and thus more deliberative investigation”
“ACLU v. Reno I, 1996 WL 65464 *2 (E.D. Pa.) (quoting Hamilton Watch Co. v. Benrus Watch
Co., 206 F.2d 738, 740 (2d Cir. 1953)).
1. The likelihood of irreparable harm to the plaintiff if the injunction is denied
The Plaintiff maintains that the actions and omissions of the Defendants cause irreparable
harm because even if the right of free speech is temporarily lost it is still a substantial harm faced
by the Plaintiff. The Supreme Court ruled in G & V lounge, INC. V. Michigan Liquor Control
Comm’n 23 F.3d. 1071, 1079 (6th Cir. 1994) that the court must maintain the public's interest in
parties constitutional rights. The Court further maintained in Elrod V. Burns, 427 U.S. 347, 373
(1976) that a temporary loss of rights is still an irreparable harm.
Defendants will continue to violate the Rights aforementioned if a TRO is not issued
enjoining the defendants from continuing their actions.
2. The likelihood of harm to the defendant if the request relief is granted
If a public communication channel is required as part of the plaintiffs request, the
Defendant will not go through any substantial harm or burdens as placed.
The Defendants, as a governmental agency and actors, are required to maintain the laws
of the State of Ridgeway and the TRO is only meant to enjoin the defendants from doing the
opposite, there is no monetary or demonstrative request that will in turn place a burden or
significant risk to the defendant.
On the contrary, if a TRO is not issued against the Defendants, hundreds of similarly
situated individuals within the State Department have and will continue to have a deprivation of
a core fundamental right that is afforded to us by our governing document.
3. The likelihood of harm that the plaintiff will succeed on the merits
The Plaintiff is likely to succeed on the merits in this matter due to continued violations
of the law. As held in Lindke v. Freed, 601 U.S. 187 (2024), the United States Supreme Court
said that no governmental actors can prohibit the right of free speech, in accordance with their
official duties.
The Defendants violated 1 R. Stat. § 3115 by prohibiting the free speech of Residents and
others within the Department of State Discord Server, by allowing this action to continue you are
depriving hundreds of people of their constitutional and statutory rights.
As set forth in the complaint, the Department of State continued these actions, even after
being informed of the violations by the Plaintiff and given ample time to rectify their actions.
4. Public Interest
The court maintains that public interest is for the greater good and welfare of the
residents and any person subjected to the jurisdiction of the State of Ridgeway.
Several residents of the State of Ridgeway have stated their interest in the case because
they are realizing their rights are being violated as well and are considering filing suit. This court
has the power to enjoin the defendant's behavior from continuing and must enjoin them from
continuing to do so.
As aforementioned, the Supreme Court in G & V lounge, INC. V. Michigan Liquor
Control Comm’n 23 F.3d. 1071, 1079 (6th Cir. 1994) held that all person(s) subjected to the
authority of the government must side with the parties constitutional rights because that will
always be in the direct interest of the public.
C. The Equities Weigh In Favor Of Granting Injunctive Relief
Once the Plaintiff establishes the likelihood of its ultimate success on the merits,
preliminary injunctive relief is warranted if the Court, weighing the equities, finds that relief is in
the public interest. The public interest in halting Defendants' reckless and unfair practices far
outweighs any interest Defendants may have in continuing to limit communications in the State
Department server.
In balancing the equities between the parties, the public equities receive far greater
weight. FTC v. Warner Commc 'ns, Inc., 742 F.2d 1156, 11 65 (9th Cir. 1984); FTCv. World
Wide Factors, Ltd.. 882 F.2d at 347; World Travel Vacation Brokers, 861 F.2d at 1030. The
public interest is especially strong in the context of the enforcement of… laws. Mallett, 818 F.
Supp. 2d at 149
In contrast, the private equities in this case are not compelling. Compliance with the law
is hardly an unreasonable burden. See World Wide Factors, 882 F.2d at 347 (stating "there is no
oppressive hardship to Defendants in requiring them to comply with the FTC Act, refrain from
fraudulent representation or preserve their assets from dissipation or concealment''). This is
particularly true here, where Defendants' conduct indicates that, in the absence of the requested
relief: Defendants are likely to continue engaging in illegal conduct, causing foreseeable,
ongoing injury to the residents of Ridgeway. See Five-Star Auto Club. 97 F. Supp. 2d 502, 536
(S.D.N.Y. 2000) " [P]ast illegal conduct is highly suggestive of the likelihood of future
violations."); SEC v. R.J Allen & Assoc., Inc. , 386 F. Supp. 866, 877 (S.D. Fla. 1974) (past
misconduct suggests likelihood of future violations); CFTC v. Hunt, 591 F.2d 1211, 1220 (7th
Cir.), cert. denied, 442 U.S. 921 ( 1979). The proposed injunction would preclude only harmful,
illegal behavior, the public equities supporting the injunctive relief outweigh any burden such
relief could possibly impose on Defendants. See, e.g., Nar 'I Soc y of Pro.f Eng 'rs. v. United
States, 435 U .S. 679, 697 (1978).
V. THE SCORE OF THE PROPOSED TRO IS NECESSARY AND
APPROPRIATE IN LIGHT OF THE DEFENDANTS’ UNLAWFUL CONDUCT
As the memorandum of law has forcefully shown, the plaintiff is likely to succeed in
proving that the Defendants’ unfair and illegal practices violate State Law and deprive the
residents of Ridgeway of their constitutional rights, and that the balance of equities strongly
favors the public. Preliminary injunctive relief is thus justified. To ensure effective final relief,
including for residents harmed by Defendants' unlawful practices, the Plaintiff requests that the
Court issue an order prohibiting Defendants from engaging in the unlawful conduct, requiring
the immediate instatement of a public communication channel.
A. Conduct Relief
To prevent new injury and limit future additional harm to persons already injured, the
proposed TRO would prohibit Defendants from: (1) Infringing the constitutional right to free
speech; (2) Violating the Statutory Rights afforded by the Ridgeway State Statutes; (3) Continue
any criminal or civilly illegal behavior.
B. Reinstatement of the Public Communications Server
The proposed TRO also would require Defendants and any third parties authorized to
reinstate the public communications channel located in the State Department Discord Server.
This action will in turn solidify the right to speech as afforded by the State Constitution.
Failing to properly protect the rights afforded is a clear violation of the laws of the State
of Ridgeway and provides basis for judicial redress.
C. Notification of Restoration to Residents
The proposed TRO would furthermore require the Defendants and any third parties
authorized to notify the residents and any person(s) under the jurisdiction of the State of
Ridgeway that the public communications is reinstated due to a lawsuit that was filed to inform
the public that they too can seek redress for the deprivation of the right of free speech.
The public has the right to know in a formal setting that the Department of State is
complying with all judicial orders and rulings.
D. Preservation of Records
The proposed TRO contains a provision directing Defendants to preserve records.
including electronic records, and evidence. It is appropriate to enjoin Defendants from destroying
evidence and doing so would place no significant burden on them. See SEC v. Unifund SAL, 910
F .2d 1028, 1 040 n.11 (2d Cir. 1990) (characterizing such orders as "innocuous").
V. CONCLUSION
Defendants have caused and likely will continue to cause substantial public injury by
violating the laws of the State of Ridgeway. Thus, for the above reasons, the FTC respectfully
requests that this Court issue the attached proposed TRO to protect the public and the Plaintiff
from further injury and help ensure effective relief for those harmed.
Dated: July 29, 2025
Respectfully Submitted
/s/ Alexblubear
Alexblubear
Represented Pro Se
