KEN McFEETERS,
Plaintiff,

v.

TOMMY TUBERVILLE, et al.,
Defendants.

EMERGENCY VERIFIED MOTION FOR TEMPORARY
RESTRAINING ORDER, PRELIMINARY INJUNCTION,
AND IMMEDIATE STAY OF PRIMARY ELECTION PROCESS

Plaintiff Ken McFeeters respectfully moves this Court pursuant to Rule 65 of the Federal Rules of Civil Procedure for emergency injunctive relief temporarily staying and enjoining the Alabama primary election process relating to Defendant Tommy Tuberville until Defendant affirmatively demonstrates constitutional and statutory eligibility to seek and hold the office at issue.

This emergency request is brought to preserve the integrity of the electoral process and prevent irreparable harm to Alabama voters, candidates, and the public trust pending judicial determination of Defendant’s lawful residency, domicile, and constitutional qualifications.

Plaintiff alleges that credible and substantial questions exist regarding whether Defendant Tommy Tuberville presently satisfies all constitutional and legal residency requirements necessary to lawfully appear on the ballot and participate in the Alabama primary election process.

Absent immediate intervention by this Court, ballots may be certified and votes cast in a manner that could irreparably compromise the legality and legitimacy of the election process, thereby injuring Plaintiff and the citizens of Alabama in ways that cannot adequately be remedied after the election has occurred.

WHEREFORE, Plaintiff respectfully requests that this Court:

1. Immediately issue a Temporary Restraining Order staying the relevant Alabama primary election process as it pertains to Defendant Tommy Tuberville;
2. Require Defendant Tommy Tuberville to provide sufficient proof establishing constitutional and statutory eligibility to seek and hold the office at issue;
3. Schedule an expedited evidentiary hearing on Plaintiff’s request for Preliminary Injunction;
4. Enjoin further ballot certification, qualification, or participation pending full adjudication on the merits; and
5. Grant such other and further relief as this Court deems equitable, proper, and just.

Respectfully submitted,

KEN McFEETERS
Plaintiff Pro Se