Upsolve, Inc. et al v. James

Filing 5

MOTION for Preliminary Injunction . Document filed by Rev. John Udo-Okon, Upsolve, Inc...(Silbert, Gregory)

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UPSOLVE, INC. and REV. JOHN UDOOKON,
Plaintiffs,
-v-

Case No. ____________

LETITIA JAMES,LQKHURIILFLDOFDSDFLW\DV
$WWRUQH\*HQHUDORIWKH6WDWHRI1HZ<RUN,
Defendant.

NOTICE OF PLAINTIFFS' MOTION FOR PRELIMINARY INJUNCTION
PLEASE TAKE NOTICE that upon the accompanying memorandum of law and
declarations, exhibits in support, and complaint in this action, dated January 25, 2022, Plaintiffs
Upsolve Inc., and Rev. John Udo-Okon (“Plaintiffs”), by and through their undersigned counsel,
will move this Court, on such date as the Court may set, for an Order pursuant to Rule 65(a) of
the Federal Rules of Civil Procedure enjoining Defendant and other state agencies—as well as
their agents, offices, and employees—from applying New York’s unauthorized practice of law
rules and taking any action that would interfere with Plaintiffs’ intended exercise of their
constitutional rights to provide free, reliable, narrowly-circumscribed legal advice to low-income
individuals facing debt collection lawsuits.

Dated: New York, New York
January 25, 2022

Respectfully submitted,
/s/ Gregory Silbert
Gregory Silbert
Robert B. Niles-Weed
Elena De Santis
WEIL, GOTSHAL & MANGES LLP
767 Fifth Avenue
New York, New York 10153
[phone]
Zachary D. Tripp*
WEIL, GOTSHAL & MANGES LLP
2001 M Street, NW
Washington, DC 20036
[phone]
*Pro hac vice motion forthcoming
Counsel for Plaintiffs

2