IN THE SUPERIOR COURT
OF THE STATE OF RIDGEWAY
NOTSFEELINGS,
Plaintiff,
v.
MATRIX_OC,
Defendant.
Case No. RSC-CV-3569
PETITION FOR PRELIMINARY INJUNCTION
Plaintiff, proceeding pro se, petitions this court for the issuance of a preliminary
injunction pursuant to Rid. R. Civ. P. 47(b) which requires Defendant to take down the posted
material identified in the complaint as a misappropriation of the name or likeness of the plaintiff.
A preliminary injunction is appropriate when (1) the plaintiff is likely to succeed on the merits,
(2) the plaintiff is likely to suffer irreparable harm without the injunction, (3) whether the
balance of equities and hardships is in the plaintiff’s favour, and (4) whether an injunction is in
the public interest. See Winter v. Natural Resources Defense Council, Inc., 555 U.S. 7 (2008).
It is clear that the plaintiff is likely to succeed on the merits here. The facts allege that a
screenshot of the plaintiff was taken, including his name and likeness, and then edited to depict
the plaintiff’s endorsement of the defendant, before being posted again. Defendant, knowing that
the plaintiff is a political opponent, acted with at least reckless disregard for the truth when
posting this image, if not having been part of its creation to begin with. This screenshot places
the plaintiff in the public eye, but in a false light, by representing that an endorsement has been
made when that is not the case. These elements satisfy the required elements of the causes of
action, and thus the plaintiff is likely to succeed on the merits.
Plaintiff is likely to suffer irreparable harm as he is currently running for political office.
The public perception of political candidates is a major aspect of their electability. Depicting a
fraudulent claim of endorsement by the plaintiff directly impacts the plaintiff’s standing in the
public view. The longer this announcement with the image remains up, the more harm is made to
the plaintiff’s public image. This damage is irreparable because of the very public nature of the
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post which was made. Plaintiff does not have a similar level of public platform to which they can
speak out against the falsity of the image. Furthermore, if the image is to impact public opinion,
it impacts the upcoming election, which would cause even further irreparable harm. This also
speaks to the balance of equities and hardships, where significant hardship is experienced by the
plaintiff without this injunction and there is very little hardship experienced by the defendant by
compelling their compliance.
The public interest is served by free and fair elections in the United States. That includes
abiding by the rules of fair play. An injunction in this matter is required to serve the public’s
interest in fair play during elections. The public expects politicians to act in a way which is
honest, truthful, and best represents the reality of what they believe. Pure falsehoods contradict
the public interest, and instead cause harm to the public’s level of information regarding political
matters.
Having satisfied the test set out in Winter, there is strong standing to issue a preliminary
injunction. Plaintiff respectfully requests that the court enter such an order as soon as possible to
prevent further harm to the plaintiff’s image.
Dated: January 22, 2025 Respectfully submitted:
_______________________________
notsfeelings, Esq.
R. Bar No. 21101
D: @wisenheimerr
Plaintiff
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