On March 16, 2023 a
Hearing
was filed
involving a dispute between
Jefferson, Jrmar J,
and
City Of Dallas,
Johnson, Bilierae,
for OTHER (CIVIL)
in the District Court of Dallas County.
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CAUSE NO. DC-23-03562
JRMAR “JJ” JEFFERSON § IN THE DISTRICT COURT
§
Plaintiffs, §
§
§
§
§
V § 14TH JUDICIAL DISTRICT
§
BILIERAE JOHNSON, in her official §
capacity as City Secretary for the City §
of Dallas. §
§
Defendant. § DALLAS COUNTY, TEXAS
TEMPORARY RESTRAINING ORDER
Came on for consideration, Plaintiff’s application for temporary restraining
order. After reviewing Plaintiff s petition, application, the evidence, and considering
the arguments of counsel, the Court finds that Jefferson will suffer imminent and
irreparable harm in being stripped of his ability to campaign for mayor of Dallas if
the Court does not issue this temporary restraining order (“TRO”) and that there is
no adequate remedy at law to compensate Jefferson for such deprivation of his civil
rights. The evidence in the record shows a likelihood that Jefferson will prevail on
the merits of his ultra Vires claim Whereas he appears to have complied with
applicable law in submitting his application to be placed on the ballot for mayor and
Defendant Bilierae Johnson (the “Secretary”) refused to certify his name to the ballot
which she was required to do under TeX. Elec. Code § 141.037.
Therefore, the Court hereby ORDERS the Secretary to immediately certify
Jrmar Jefferson’s name to be placed on the ballot for mayor of the City of Dallas
pursuant to Tex. Elec. Code § 141.047.
This Order will remain in place until the hearing on Jefferson’s application for
temporary injunction is held. This hearing is set for at
in the 14th Judicial District Court, 600 Commerce St., 5th Floor,
Dallas, Texas 7 5202.
The Court ORDERS that the parties shall each be entitled to following
expedited discovery in advance of the temporary injunction hearing:
o 10 requests for production
o 10 requests for admission
o 5 interrogatories
o 2 depositions, not to exceed 3 hours each.
Responses to written discovery must be served Within 5 days of service of the
discovery requests. Deposition notices must be served three days in advance of the
deposition.
Plaintiff is ORDERED to post bond in the amount of $ for this
temporary restraining order to issue.
Date:
PRESIDING JUDGE
Form of Order respectfully submitted by:
ls/ Paul M. Davis
Paul M. Davis
Texas Bar No. 24078401
Paul M. Davis & Associates, P.C.
9355 John W. Elliott Dr.
Suite 25454
Frisco, TX 75033
945-348-7884
paul@fireduptxlawver.com
ATTORNEY FOR PLAINTIFF
J RMAR JEFFERSON
CERTIFICATE OF SERVICE
I hereby certify that I served the foregoing document on all counsel of record
in this case Via EFile Texas on this 315‘: day of March 2023.
ls/ Paul M Davis
Paul M. Davis
CERTIFICATE OF CONFERENCE
I hereby certify that I conferenced with counsel for Defendants by email on
March 30, 2023 regarding the foregoing Temporary Restraining Order, and
Defendants are opposed.
Paul M. Davis
/s/
Paul M. Davis
Automated Certificate of eService
This automated certificate of service was created by the efiling system.
The filer served this document via email generated by the efiling system
on the date and to the persons listed below. The rules governing
certificates of service have not changed. Filers must still provide a
certificate of service that complies with all applicable rules.
Paul Davis on behalf of Paul Davis
Bar No. 24078401
pauldavis@utexas.edu
Envelope ID: 74213617
Filing Code Description: Non-Signed Proposed Order/Judgment
Filing Description: PROPOSED TEMPORARY RESTRAINING ORDER
Status as of 3/31/2023 12:25 PM CST
Associated Case Party: JRMARJJEFFERSON
Name BarNumber Email TimestampSubmitted Status
Paul Davis paul@fireduptxlawyer.com 3/31/2023 11:36:37 AM SENT
Associated Case Party: BILIERAE JOHNSON
Name BarNumber Email TimestampSubmitted Status
Andrew Spaniol andrew.spaniol@dallas.gov 3/31/2023 11:36:37 AM SENT
Kathleen Fones kathleen.fones@dallas.gov 3/31/2023 11:36:37 AM SENT
Associated Case Party: CITY OF DALLAS
Name BarNumber Email TimestampSubmitted Status
Stacy Rodriguez stacy.rodriguez@dallas.gov 3/31/2023 11:36:37 AM SENT
Document Filed Date
April 03, 2023
Case Filing Date
March 16, 2023
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CAUSE NO. DC-23-03562 JRMAR “JJ” JEFFERSON § IN THE DISTRICT COURT § Plaintiffs, § § § § § V § 14TH JUDICIAL DISTRICT § BILIERAE JOHNSON, in her official § capacity as City Secretary for the City § of Dallas. § § Defendant. § DALLAS COUNTY, TEXAS TEMPORARY RESTRAINING ORDER Came on for consideration, Plaintiff’s application for temporary restraining order. After reviewing Plaintiff s petition, application, the evidence, and considering the arguments of counsel, the Court finds that Jefferson will suffer imminent and irreparable harm in being stripped of his ability to campaign for mayor of Dallas if the Court does not issue this temporary restraining order (“TRO”) and that there is no adequate remedy at law to compensate Jefferson for such deprivation of his civil rights. The evidence in the record shows a likelihood that Jefferson will prevail on the merits of his ultra Vires claim Whereas he appears to have complied with applicable law in submitting his application to be placed on the ballot for mayor and Defendant Bilierae Johnson (the “Secretary”) refused to certify his name to the ballot which she was required to do under TeX. Elec. Code § 141.037. Therefore, the Court hereby ORDERS the Secretary to immediately certify Jrmar Jefferson’s name to be placed on the ballot for mayor of the City of Dallas pursuant to Tex. Elec. Code § 141.047. This Order will remain in place until the hearing on Jefferson’s application for temporary injunction is held. This hearing is set for at in the 14th Judicial District Court, 600 Commerce St., 5th Floor, Dallas, Texas 7 5202. The Court ORDERS that the parties shall each be entitled to following expedited discovery in advance of the temporary injunction hearing: o 10 requests for production o 10 requests for admission o 5 interrogatories o 2 depositions, not to exceed 3 hours each. Responses to written discovery must be served Within 5 days of service of the discovery requests. Deposition notices must be served three days in advance of the deposition. Plaintiff is ORDERED to post bond in the amount of $ for this temporary restraining order to issue. Date: PRESIDING JUDGE Form of Order respectfully submitted by: ls/ Paul M. Davis Paul M. Davis Texas Bar No. 24078401 Paul M. Davis & Associates, P.C. 9355 John W. Elliott Dr. Suite 25454 Frisco, TX 75033 945-348-7884 paul@fireduptxlawver.com ATTORNEY FOR PLAINTIFF J RMAR JEFFERSON CERTIFICATE OF SERVICE I hereby certify that I served the foregoing document on all counsel of record in this case Via EFile Texas on this 315‘: day of March 2023. ls/ Paul M Davis Paul M. Davis CERTIFICATE OF CONFERENCE I hereby certify that I conferenced with counsel for Defendants by email on March 30, 2023 regarding the foregoing Temporary Restraining Order, and Defendants are opposed. Paul M. Davis /s/ Paul M. Davis Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules. Paul Davis on behalf of Paul Davis Bar No. 24078401 pauldavis@utexas.edu Envelope ID: 74213617 Filing Code Description: Non-Signed Proposed Order/Judgment Filing Description: PROPOSED TEMPORARY RESTRAINING ORDER Status as of 3/31/2023 12:25 PM CST Associated Case Party: JRMARJJEFFERSON Name BarNumber Email TimestampSubmitted Status Paul Davis paul@fireduptxlawyer.com 3/31/2023 11:36:37 AM SENT Associated Case Party: BILIERAE JOHNSON Name BarNumber Email TimestampSubmitted Status Andrew Spaniol andrew.spaniol@dallas.gov 3/31/2023 11:36:37 AM SENT Kathleen Fones kathleen.fones@dallas.gov 3/31/2023 11:36:37 AM SENT Associated Case Party: CITY OF DALLAS Name BarNumber Email TimestampSubmitted Status Stacy Rodriguez stacy.rodriguez@dallas.gov 3/31/2023 11:36:37 AM SENT