and award the Contract. The awarding of the Contract on or about August 9,2013, was unlawful in that it violated Alabam
bid law, including but not limitedto Ala. Code, 1975, §§ 41-16-27 and 41-16-30, by rejecting the bid of DTA, which was the
“lowest responsible bidder” under the specifications of th
e RFP, and awarding the Contract to acompany in which Mike Hubbard has a direct or indirect financial or personally beneficialinterest.2.
DTA’s bid complied with every specification of the RFP
, including thespecification for compensation. DSI, who was awarded the Contract, submitted a bid that did notconform to the compensation specification, and, as a result, DSI underbid DTA. Twin CitySecurity, LLC, was the only other company to submit a bid, and its bid, likewise, did notconform to the compensation specifications in the RFP.3.
DTA seeks to temporarily, preliminarily, and permanently enjoin the AlabamaLegislature, DSI, and Derrick Hamilton from taking any further action with respect to theawarding, signing, and performance of the Contract. DTA has filed contemporaneously herewitha Motion for Temporary Restraining Order to preserve the status quo (i.e., prevent any further action with respect to the awarding, signing, and performance of the Contract) and to protect theinterest of the State of Alabama and its citizens until such time as an evidentiary hearing can be
held on DTA’s request for preliminary injunctive relief.
JURISDICTION AND VENUE
This is an action for injunctive relief, declaratory judgment, and damages inexcess of minimum jurisdictional limits of this Court. This Court has jurisdiction of this actionunder Ala. Code, 1975, § 41-16-21,
(Competitive Bid Law). Venue is proper inMontgomery County, Alabama, because the Alabama Legislature is a branch of government of