“Pursuant to FED. R. CIV. P. 65, Donald J. Trump for President, Inc. (“Plaintiff”) respectfully moves this Court to enter an administrative stay and temporary restraining order (“TRO”) to enjoin the State of New Mexico, the Electors and the Secretary of State (collectively, the “Defendants”) and all of their agents, officers, presidential electors, and others acting in concert from taking action to have such electors take any official action – including without limitation participating in the disposition of certificates of votes for President and Vice President that would ordinarily be performed in accordance with 3 U.S.C. 11, that are made and signed, or will be made and signed, in accordance with 3 U.S.C. 9. until further order of this Court and then issue a preliminary injunction or stay against their doing so – until further order of this Court, and to preliminarily enjoin and to stay such actions pending the final resolution of this action on the merit.”
“Alternatively, the Court should reach the merits, vacate the Defendant Electors’ certifications from the unconstitutional 2020 election results, and remand to the state of New Mexico legislature pursuant to 3 U.S.C. § 2 to appoint electors” is seriously the text of a complaint filed by the Trump campaign Monday in a federal court against the state of New Mexico.