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UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

_________________________________________

)

LEIGH BROWN ) Civil Case No.

4711 Myers Lane )

Harrisburg, NC 28075, )

)

LEIGH BROWN FOR CONGRESS )

4711 Myers Lane )

Harrisburg, NC 28075, )

)

LEIGH BROWN & ASSOCIATES )

24 Cabarrus Avenue East )

Concord, NC, ) PLAINTIFFS’ MOTION FOR 

) TEMPORARY RESTRAINING 

Plaintiff, ) ORDER

)

v. )

)

FEDERAL ELECTION COMMISSION )

1050 First Street, NE )

Washington, DC 20463, )

Defendant. )

_________________________________________ )

Leigh Brown, Leigh Brown for Congress, and Leigh Brown & Associates (collectively 

“Plaintiffs”) move for a Temporary Restraining Order against Defendants to enjoin them from 

enforcing 52 U.S.C. § 30104(f), 11 C.F.R. § 100.29 (“electioneering communications”), 11 C.F.R. 

§§ 104.5(j), 114.10(b)(2),110.11(a)(4) and 11 C.F.R. § 104.20 (electioneering communications 

disclaimer and reporting requirements) as applied to Plaintiff Leigh Brown & Associates current 

radio advertisements until such time as this Court can hear a preliminary injunction request based 

on the forthcoming motion. The electioneering communications window for the upcoming 

primary for North Carolina’s Ninth Congressional District begins this Sunday – April 14, 2019 –

and it is this date that necessitates this request for a temporary restraining order.

Case 1:19-cv-01021-TJK Document 2 Filed 04/11/19 Page 1 of 3
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This motion is made on the grounds specified in this motion, Plaintiffs’ brief in support 

thereof, the Verified Complaint, the Exhibits attached to the Verified Complaint, and such other 

and further evidence as may be presented to the Court at the time of the hearing.

Plaintiff respectfully requests oral argument either in person or telephonic at the hearing 

because of the complexities and the important constitutional rights involved in this case.

Pursuant to Local Rule 7(m), Plaintiffs have conferred with Counsel for the Federal 

Election Commission who state that they oppose this motion.

Dated: April 11, 2019

Respectfully submitted,

/s/_Jason Torchinsky______

Jason Torchinsky (D.C. Bar No. 976033)

jtorchinsky@hvjlaw.com

J. Michael Bayes (D.C. Bar No. 501845)

jmbayes@hvjlaw.com

HOLTZMAN VOGEL JOSEFIAK TORCHINSKY 

PLLC

45 North Hill Drive, Suite 100

Warrenton, VA 20186

Tel: (540) 341-8808

Fax: (540) 341-8809

Counsel for Plaintiffs

Case 1:19-cv-01021-TJK Document 2 Filed 04/11/19 Page 2 of 3
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CERTIFICATE OF SERVICE

I do hereby certify that, on this 11th day of April 2019, the foregoing Motion for Temporary 

Restraining Order was filed electronically with the Clerk of Court using the CM/ECF system. The 

following parties were served either electronically on April 11th or by USPS First Class Mail on 

April 12, 2019.

/s/Jason Torchinsky

Jason Torchinsky (D.C. Bar No. 976033)

Federal Election Commission

1050 First Street, NE

Washington, DC 20463

Attorney General William Barr

c/o Assistant U.S. Attorney of Administration

Justice Managment Division

950 Pennsylvania Ave. NW

Room 1111

Washington, D.C. 20530

Jessie K. Liu

United States Attorney for the District of Columbia

Civil Process Clerk

555 4th St. N.W. 

Washington, D.C. 20530

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