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SUPREME COURT OF THE STATE OF NEW YORKAPPELLATE DIVISION SECOND DEPARTMENT
DEAN G. SKELOS and PEDRO ESPADA, JR., as duly elected
members of the New York State Senate,
Plaintiffs-Respondents,DAVID A. PATERSON, as Governor of the State of New York,
RICHARD RAVITCH, as Lieutenant Governor of the State ofNew York, and LORRAINE CORTES-VAZQUEZ, as Secretary ofState of the State of New York,
Defendants-Appellants.
Nassau Co. Sup. Ct.
Index No.: 13426-2009Hon. William R. Lamarca
DEFENDANTS-APPELLANTS' MEMORANDUM OF LAWIN SUPPORT OF MOTION FOR INTERIM STAY ANDEXPEDITED APPEAL
QUINN, EMANUEL, URQUHART, OLIVER& HEDGES, LLP
KATHLEEN M. SULLIVAN
FAITH E. GAY
ROBERT JUMAN
51 Madison Avenue
22d Floor
New York, NY 10022
(212) 849-7000
Counsel for Defendant-Appellants
Date: July
22,
2009
 
PRELIMINARY STATEMENT
Late yesterday, the trial court granted Respondents a preliminary injunction which statedthat Lieutenant Governor Ravitch "is preliminarily enjoined from exercising any of the powers of
the office of Lieutenant-Governor of the State of New York." (Order at 18.). CPLR 6311 states
that a "preliminary injunction to restrain a public officer. . . of the state from performing astatutory duty may be granted only by the supreme court at a term in the department in which theofficer . . . is located or in which the duty is required to be performed." By this order to showcause, appellants seek an emergency stay of the above referenced preliminary injunction, whichwas granted without authority contrary to the plain text of CPLR 6311, and will cause irreparableharm to the Governor and the State of New York.
STATEMENT OF FACTS
Appellants respectfully refer the Court to the facts set forth
in
the Affirmation of Faith E.Gay dated July 22, 2009 (Gay Affirmation), including their memoranda of law in support of their
moving papers in opposition to the motion for preliminary injunction and in support of theirmotion to dismiss Respondents' complaint, which are attached as Exhibits D and E to the Gay
Affirmation.
ARGUMENT
I.
HIS COURT SHOULD STAY THE PRELIMINARY INJUNCTION ORDERED
BY THE TRIAL COURT
The court below granted an injunction that CPLR 6311 expressly forbids. The injunctionrestrains the second highest officer in the state from performing his statutory duties. UnderCPLR 5518, the Appellate Division has the power to grant, modify, limit, and vacate either apreliminary injunction or a temporary restraining order while the ease is on appeal (i.e., after anotice of appeal has been filed•and served). In effect, it
g
ives the appellate division during the
 
appeal stage the same powers that the supreme court has during the action's pretrial and trial
stage.
See, e.g., Humane Soc. of U.S.
v.
County of Monroe,
192 A.D.2d 1139 (4th Dep't 1993)
(vacating preliminary injunction pursuant to CPLR 5518 because plaintiff failed to showlikelihood of success on the merits);
Broadvvall America, Inc.
v.
Bram Will-El LLC,
821
N.Y.S.2d 190, 191 (1st Dep't 2006) (interim relief granted under CPLR 5518 pending applicationfor stay pending appeal). Moreover, under CPLR 5519(a)(1), a stay of all proceedings to enforcea judgment is automatic when the appellant is an officer of the state, and under CPLR 5519(c),the court to which an appeal is taken may stay all proceedings to enforce the order appealed
from.
An application to the Appellate Division for relief pending resolution of an appeal under
CPLR 5518 will be reviewed
de novo,
using the same standards as applied by the Supreme Court
in respect of the original order.
See Romano v. Sullivan County Harness Racing Assn, Inc.,
106
A.D.2d 819 (3d Dep't 1984);
see also Humane Soc. of US. v. County of Monroe,
192 A.D.2d
1139 (4th Dep't 1993) (vacating preliminary injunction pursuant to CPLR 5518 because plaintifffailed to show likelihood of success on the merits). On an application for an order pendingappeal in respect of a preliminary injunction, this Court asks whether there is a reasonableprobability of success on appeal and whether plaintiff has demonstrated irreparable injury.
Romano,
106 A.D.2d at 820.
Courts will order a stay of a trial court's order under 5519(c) pending resolution of an
appeal to preserve the status quo or where to do so would be in the public interest".
Town of
Orangetow
n
 
v. Magee,
218 A.D.2d 733 (2d Dep't 1995) (ordering a stay of enforcement of trialcourt and appellate court orders pursuant to CPLR 5519(c) pending determination of the appeal
to the COurt of Appeals);
Russell v. New
York
City Housing
Authority,
608 N.Y.S2d 592 (N.Y.
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