40 Days for Life of Wausau et al v. Illick, Ralph et al

Filing 2

Motion for Temporary Restraining Order by Plaintiffs 40 Days for Life of Wausau, Janet Kraimer Nichols, Mary Litschauer, Theresa Whitaker. (Lubinsky, Lori)

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WISCONSIN ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

40 DAYS FOR LIFE OF WAUSAU, an unincorporated association, and THERESA WHITAKER, JANET KRAIMER-NICHOLS, and MARY LITSCHAUER, individuals, Plaintiffs, vs. RALPH ILLICK, MARATHON COUNTY PUBLIC LIBRARY, TIM GIERL, AUDREY ASCHER, GARY BEASTROM, KEN DAY, ALISON MORROW, KATIE ROSENBERG, SCOTT WINCH, MARATHON COUNTY, WISCONSIN, a body politic, and KEITH LANGENHAHN, Defendants.

Case No. 11-cv-231

MOTION FOR TEMPORARY RESTRAINING ORDER AND PRELIMINARY INJUNCTION Plaintiffs, 40 Days for Life of Wausau and Theresa Whitaker, Janet Kraimer-Nichols, and Mary Litschauer, by and through their undersigned counsel, move the Court pursuant to Fed. R. Civ. P. 65(a) for entry of a temporary restraining order, immediately restraining defendants, their officers, agents, servants, agents and/or attorneys from: Barring plaintiffs from using their previously confirmed room reservation, or from carrying out their purported rescission of that reservation, and thereby censoring and suppressing plaintiffs' intended exhibiting and screening of the movie "BloodMoney" at the defendants' library on Sunday, April 3, 2011, from 1 pm to 3 pm. Plaintiffs further move for a preliminary injunction. This motion is supported by the complaint and supporting declaration, and by the memorandum accompanying this motion.

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Plaintiffs are cognizant of the Court's "Procedure To Be Followed on Motions For Injunctive Relief." Respectfully submitted, AXLEY BRYNELSON, LLP Dated: March 30, 2011 By: /s/ Lori M. Lubinsky Lori M. Lubinsky Attorneys for Plaintiffs 2 East Mifflin Street, Suite 200 Madison, Wisconsin 53703 Telephone: [phone] Facsimile: [phone] [e-mail]

Peter Breen Thomas More Society, a public interest law firm 29 S LaSalle, Ste 440 Chicago, IL 60603 [phone] [e-mail] Admission pro hac vice forthcoming Thomas Olp, Esq. 2111 Comprehensive Drive Aurora, IL 60505 630-851-4722 x4202 Fax. [phone] Email: [e-mail] Admission pro hac vice forthcoming David L. Heaton, Esq. 8007 East Jefferson Street Wausau, WI 54403 (admitted in Illinois) Admission pro hac vice forthcoming

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