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Plaintiffs, Rocky Mountain Gun Owners and Colorado Citizens for Life, move
pursuant to Fed. R. Civ. P. 65 for a Temporary Restraining Order to stay an
administrative hearing scheduled for December 17, 2014, at which Defendants will seek
to tax and otherwise burden Plaintiffs for exercising their First Amendment rights near
the date of an election. In support of this Motion, Plaintiffs rely on the arguments set
forth in their Memorandum in Support of their Motion for a Temporary Restraining Order
filed simultaneously herewith.
Pursuant to D.C.COLO.LCivR 7.1(a), Plaintiffs conferred with opposing counsel
regarding the relief requested in this Motion. Defendants will oppose this Motion.
Pursuant to D.C.COLO.LCivR 65.1, undersigned counsel hereby certifies that
this motion was filed on December 8, 2014, at 11:50 a.m (EST). Copies of all pleadings
and documents filed as part of this motion were provided to opposing counsel for all
parties to this action.
Dated: December 8, 2014
Respectfully submitted,
/s/ David A. Warrington
David A. Warrington
Laurin H. Mills
Andrew J. Narod
Paris R. Sorrell
LeClairRyan, A Professional Corporation
2318 Mill Road, Suite 1100
Alexandria, Virginia 22314
Telephone: (703) 684-8007
Facsimile: (703) 647-5999
david.warrington@leclairryan.com
laurin.mills@leclairryan.com
andrew.narod@leclairryan.com
paris.sorrell@leclairryan.com
James O. Bardwell
Rocky Mountain Gun Owners
501 Main Street, Suite 200
Windsor, CO 80550
Telephone: (877) 405-4570
Facsimile: (202) 351-0528
jb@nagrhq.org
Counsel for Plaintiffs Rocky Mountain Gun
Owners and Colorado Campaign for Life
CERTIFICATE OF SERVICE
I hereby certify that on December 8, 2014, I electronically filed the foregoing
document with the Clerk of Court using the CM/ECF system, which will send notice of
such filing to counsel of record who are registered with CM/ECF.