APPLICATION FOR TEMPORARY RESTRAINING ORDER

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.: _____________

APPLICATION FOR TEMPORARY RESTRAINING ORDER (Without Notice)

 

 

 

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. The IRS has liens out for Plaintiffs’ bank accounts and vehicles. Plaintiffs need their vehicles for business and personal use.
  2. As a result of the liens on Plaintiffs’ vehicles, Plaintiffs have to rent vehicles to make sure they do not get sold at auction at half the price they are worth.
  3. The IRS is charging Plaintiffs too much for the car rentals.
  4. The IRS is causing an undue burden on Plaintiffs. Plaintiffs were told by one of the AZ DOR agents that they were removing the hold on the vehicles. However, that has not happened. Plaintiffs expect that the IRS will not remove the liens unless this Court issues an Order to that effect.

In addition, Plaintiffs state as follows:

  1. Plaintiffs have filed in this action a lawsuit seeking inter alia, an injunction, restitution order, and order for compensation.
  2. The IRS does not intend to remove the liens from Plaintiffs’ vehicles before the trial of this action or a hearing on Plaintiffs’ Application for Temporary Restraining Order.
  3. Unless the IRS is enjoined and restrained by this Court, Plaintiffs will suffer immediate injury, loss and damage before the hearing and disposition of the Application for Preliminary Injunction, and before Defendant’s and Defendant’s attorney can be heard in opposition to this Application.
  4. As it is detailed in the accompanying Affidavit of Plaintiff Dale Ground, every reasonable effort has been made to notify Defendant or Defendant’s attorney of this Motion, including attempts to notify Defendant by telephone.

This Application for Temporary Restraining Order is supported by the documents listed below, which are incorporated herein by reference:

  1. First Amended Complaint
  2. Affidavit of Plaintiff Dale Ground.

 

Respectfully submitted this [DATE],

 

 

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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