AFFIDAVIT IN SUPPORT OF APPLICATION FOR TEMPORARY RESTRAINING ORDER

February 12, 2024

Dale & Svitlana Ground

7830 E. Redfield Road #5

Scottsdale, AZ 85260

Plaintiffs, pro se

 

 

IN THE SUPERIOR COURT OF THE STATE OF ARIZONA

IN AND FOR THE COUNTY OF MARICOPA

 

DALE & SVITLANA GROUND,

Plaintiffs,

vs.

 

INTERNAL REVENUE SERVICE

Defendant

 

Case No.: _____________

AFFIDAVIT IN SUPPORT OF APPLICATION FOR TEMPORARY RESTRAINING ORDER (Without Notice)

 

 

 

I, DALE GROUND, being duly sworn, hereby states as follows:

Pursuant to Ariz. R. Civ. P. 65(b), Plaintiffs Dale Ground and Svitlana Ground herein, pro se, respectfully request this Court issue forthwith a temporary restraining order, without notice, restraining and enjoining the Defendant. Defendant’s officers, agents, servants, employees, and any and all other persons in active concert or participation with them, from placing Plaintiffs’ cars under the levy. Plaintiffs make this application based on the following reasons:

  1. I am an adult of sound mind, hence competent to swear this affidavit.
  2. I am one of the Plaintiffs in this action.
  3. I make this affidavit in Support of my Application for Temporary Restraining Order.
  4. The IRS has liens out for our bank accounts and vehicles.
  5. My wife and I need the vehicles for business and personal use.
  6. As a result of the liens on our vehicles, we have to rent vehicles to make sure they do not get sold at auction at half the price they are worth.
  7. The IRS is charging us too much for the car rentals.
  8. The IRS is causing an undue burden on us.
  9. We were told by one of the AZ DOR agents that they were removing the hold on the vehicles. However, that has not happened.
  10. I expect that the IRS will not remove the liens unless this Court issues an Order to that effect.
  11. Unless the IRS is enjoined and restrained by this Court, we will suffer immediate injury, loss and damage before the hearing and disposition of the Application for Preliminary Injunction.
  12. We have made every reasonable effort to notify Defendant or Defendant’s attorney of this Motion, including attempts to notify Defendant by telephone.

 

I, DALE GROUND affirm under penalties of perjury that the foregoing representations are true.

_________________________________

DALE GROUND

 

Subscribed and sworn to before me this ____ day of April, 2023.

 

____________________________________

______________, Notary Public

 

CERTIFICATE OF SERVICE

Original e-filed with the Clerk of Court on this date [ENTER DATE]. A copy has been or will be sent to the Defendant via ______________ on [ENTER DATE] to:

 

Felissa Bermudez

Kristin K. Mayes

Attorney General

(Firm Bar No. 14000)

Kimberly Cygan (013977)

Lisa Neuville (012285)

Shyla Freestone (026244)

Assistant Attorney General

2005 North Central Avenue

Phoenix, AZ 85004-1592

Telephone:     (602) 542-8385

(602) 542-8444

(602) 542-8371

DATED:

___________________

Dale Ground

 

__________________

Svitlana Ground

 

 

 

 

 

 

 

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