Case 1:22-cv-03282-RDM Document 8 Filed 12/21/22 Page 1 of 3 

UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF COLUMBIA 

) 

READY FOR RON ) Judge Randolph D. Moss 

66 W. Flagler Street ) 

Suite 900, #6781 ) No. 1:22-cv-3282-RDM 

Miami, FL 33130, ) 

) 

Plaintiff, ) 

) 

v. ) 

) 

FEDERAL ELECTION COMMISSION ) 

1050 First Street, NE ) 

Washington, DC 20463, ) 

) 

Defendant. ) 

_______________________________________ ) 

PLAINTIFF READY FOR RON’S MOTION FOR PRELIMINARY INJUNCTION 

Plaintiff READY FOR RON respectfully moves this Court for a Preliminary Injunction 

enjoining Defendant FEDERAL ELECTION COMMISSION from conducting any investigation, 

initiating any administrative or other proceedings, making any criminal referral, imposing any fine 

or other sanction, or otherwise attempting to enforce 52 U.S.C. § 30116, 11 C.F.R. § 100.72, or 11 

C.F.R. § 110.1, against Plaintiff READY FOR RON, or any of its agents, officers, contractors, 

employees, volunteers, members, supporters, or signatories, for: 

● providing a signed political petition including signatories’ names and contact 

information (including but not limited to addresses, phone numbers, and/or e-mail addresses) to 

Florida Governor Ron DeSantis to encourage him to become or remain a candidate for President 

in the 2024 election cycle, regardless of whether Governor DeSantis is “testing the waters” under 

11 C.F.R. § 100.72 or has become a candidate under 52 U.S.C. § 30101(2) and 11 C.F.R. § 100.3; 

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Case 1:22-cv-03282-RDM Document 8 Filed 12/21/22 Page 2 of 3 

● providing to Governor DeSantis any supplements or updates to the petition 

containing additional signatories’ names and contact information (including but not limited to 

addresses, phone numbers, and/or e-mail addresses), regardless of whether Governor DeSantis is 

“testing the waters” under 11 C.F.R. § 100.72 or has become a candidate under 52 U.S.C. 

§ 30101(2) and 11 C.F.R. § 100.3; 

● spending funds from its non-contribution Carey account in connection with the 

petition, including but not limited to expenses relating to advertising, signature gathering, 

robocalls, or hotline maintenance; or 

● accepting unlimited contributions to its non-contribution Carey account pursuant 

to this Court’s ruling in Carey v. FEC, 864 F. Supp. 2d 57 (D.D.C. 2002). 

Plaintiff further moves for a PRELIMINARY INJUNCTION enjoining Defendant 

FEDERAL ELECTION COMMISSION from enforcing 11 C.F.R. § 100.72, or otherwise applying 

or enforcing limitations under 52 U.S.C. § 30116 and 11 C.F.R. § 110.1 with regard to the amount 

or value of any donations, gifts, transfers, or disbursements—regardless of whether they are 

monetary, non-monetary, or “in-kind”—to an individual who is not a candidate for federal office 

under 52 U.S.C. § 30101(2) and 11 C.F.R. § 100.3 on the grounds such individual is, was, may be, 

or may have been “testing the waters” or otherwise considering the possibility of becoming a 

candidate at the time such donations, gifts, transfers, or disbursements are or were made. 

A memorandum of law, supporting declaration with exhibits, and proposed order are 

attached. 

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Case 1:22-cv-03282-RDM Document 8 Filed 12/21/22 Page 3 of 3 

Dated this 21st day of December, 2022. 

Respectfully submitted, 

/s/ Dan Backer 

Dan Backer, Esq. (D.C. Bar No. 996641) 

Chalmers & Adams LLC 

441 N. Lee Street, Suite 300 

Alexandria, VA 22314 

(202) 210-5431 

dbacker@ChalmersAdams.com 

Lilian Rodriguez-Baz, Esq.* 

Chief Legal Counsel, Ready for Ron 

66 W Flagler Street, Suite 900 

Miami, FL 33130 

(561) 291-9897 

Lilian@ReadyForRon.com 

*Motion for pro hac vice admission forthcoming 

Attorneys for Plaintiff 

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