STATE OF RIDGEWAY
COUNTY OF RIDGEWAY
IN THE SUPERIOR COURT OF
THE STATE OF RIDGEWAY
TROOPER_NOVICH,
Plaintiff(s),
v.
RIDGEWAY COUNTY SHERIFF’S
OFFICE, a Ridgeway Government
Agency;
DANIELRAEGAN, in his capacity as
Ridgeway County Sheriff,
Defendant(s).
Case Number: RSC-CV-3101
Presiding: Hon. bommes
MOTION TO DISMISS
EMERGENCY MOTION FOR TEMPORARY RESTRAINING ORDER
PLAINTIFF, Trooper_Novich, by and through the undersigned counsel, submits this motion in
the above-entitled matter, pursuant to Rid. R. Civ. P. 47(a), and moves the court to issue a
temporary restraining order enjoining the enforcement of Plaintiff’s suspension. Attached hereto
and herewith is a memorandum of law in support of the motion to dismiss.
June 27, 2024 Respectfully submitted,
MatthewSandringham
Counsel of Record
Clarke, Feelings & Associates, LLP.
Managing Partner
R. Bar. No. 16103
Attorney for Plaintiff
LAW OFFICES OF CLARKE, FEELINGS & ASSOCIATES, LLP.
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STATE OF RIDGEWAY
COUNTY OF RIDGEWAY
IN THE SUPERIOR COURT OF
THE STATE OF RIDGEWAY
TROOPER_NOVICH,
Plaintiff(s),
v.
RIDGEWAY COUNTY SHERIFF’S
OFFICE, a Ridgeway Government
Agency;
DANIELRAEGAN, in his capacity as
Ridgeway County Sheriff,
Defendant(s).
Case Number: RSC-CV-3101
Presiding: Hon. bommes
MEMORANDUM OF LAW
MEMORANDUM OF LAW
PLAINTIFF, Trooper_Novich, by and through the undersigned counsel, by and through the
undersigned counsel, submits this memorandum of points and authorities in support of the
motion for TRO.
INTRODUCTION
Plaintiff, Trooper_Novich, submits this emergency motion for temporary restraining
order to enjoin the Ridgeway County Sheriff’s Office enforcement of a suspension issued on the
22nd of June 2024.
ARGUMENTS
I. APPLICANT WILL SUFFER AN IMMEDIATE AND IRREPARABLE INJURY
Plaintiff was suspended on the 22nd of June 2024, through a Disciplinary Action Notice
issued by the RCSO Internal Affairs Unit. This suspension was temporarily suspended by the
Internal Affairs Unit Chief Investigator pending an enquiry. However, today was reinstated.
Plaintiff intends on filing an administrative complaint due to a blatant violation of
Statutory law that the Defendant has ignored - even when brought up by Plaintiff’s counsel.
Plaintiff is likely to succeed in his appeal on the basis of that statutory violation, and thus,
would have their disciplinary action overturned and become unenforceable. On this basis, if the
suspension was allowed to continue by this court, Plaintiff would suffer an irreparable injury,
including the loss of earnings, and career reputational damage.
Temporary Restraining Order is correct in this matter, as there is not enough time for a
hearing to take place to resolve this dispute for a preliminary injunction to be issued against the
department.
CONCLUSION
For the foregoing reasons, we ask that the court issues an emergency Temporary
Restraining Order which enjoins the County Sheriff’s Office from enforcing the suspension of
Plaintiff.
LAW OFFICES OF CLARKE, FEELINGS & ASSOCIATES, LLP.
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June 27, 2024 Respectfully submitted,
MatthewSandringham
Counsel of Record
Clarke, Feelings & Associates, LLP.
Associate Attorney
R. Bar. No. 16103
Attorney for Plaintiff
LAW OFFICES OF CLARKE, FEELINGS & ASSOCIATES, LLP.
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