1 Menes Ankh El

Cap Stone Law Firm

2 Telephone: (317)590-7563
E-mail: CapStoneLawFirm@gmail.com
3 P.O. Box 88045
Indianapolis, Indiana 46208
4

6 IN THE UNITED STATES DISTRICT COURT

7 FOR THE SOUTHERN DISTRICT OF INDIANA

8 INDIANAPOLIS DIVISION

10 Menes Ankh El,

11 Plaintiff CASE #:______________________________

v.
12
STATE OF INDIANA, Plaintiff’s Verified Motion for Emergency
13 COUNTY OF MARION, Restraining Order and Preliminary Injunction.

CITY OF INDIANAPOLIS, Request For Expedited Hearing

14
Defendant. Request For Oral Argument
15

16

17

18 MOTION
19 I, Menes Ankh El, have filed this motion with the accompanying complaint,
20 seeking emergency restraining order and preliminary injunction enjoining
21 Defendants and their agents from enforcing Defendants’ Administrative codes on or
22 against Me through physical violence or the initiation of commercial and civil
23 actions, which involve the enforcement of Defendants’ administrative codes and
24 ordinances.

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25 I seek provisional relief in light of the imminent physical danger that the I
26 face from Defendants through a commercial action in which the Defendants intend
27 to again imprison Me through commercial fraud. The records of the actions at issue
28 show that the Defendants have already demonstrated a willingness and ability to
29 defraud Me of My life vi et armis and through commercial actions.

30 INTRODUCTION
31 The Defendants are for-profit municipal corporations. Their codes are
32 statutory in nature and only apply to officers of the Defendants or corporations
33 created under the Defendants’ administrative codes. All of their actions as they
34 pertain to the attached suit are commercial in nature.
35 In 2012, Defendants initiated several fraudulent civil actions against Me.
36 The Defendants’ actions resulted in Plaintiff being enslaved for 9 years under
37 fraudulent pretenses. In 2020, the Defendants released Me from the fraudulent
38 imprisonment. All of the Defendants’ fraudulent actions at issue were initiated
39 under 27 CFR 72.11, making them commercial actions. The fraud is evinced in the
40 Defendants’ several refusals to prove that the Defendants’ administrative code
41 applies to Me.
42 Today, the Defendants are still trying to enforce their administrative statutes
43 through force and fraud without ever proving that they even apply to Me. Their
44 court has issued an administrative warrant for My arrest again while still
45 fraudulently refusing to prove that the court has the proper jurisdiction.
46 LEGAL STANDARD
47 Preliminary injunctive relief is appropriate where the plaintiff establishes
48 that “[1] is likely to succeed on the merits. [2] that he is likely to suffer irreparable
49 harm in the absence of preliminary relief, [3] that the balance of equities tips in his
50 favor, and [4] that an injunction is in the public interest.” Winter v. Nat, Res,
51 Def, Council, Inc., 555 U.S. 7, 20 (2008).
52
53

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54 ARGUMENT
55 I satisfy each of the four elements for immediate injunctive relief. First, I am
56 likely to succeed on the merits of My claim because My claim is directly supported
57 by the Defendants’ own Administrative Code, as well as the most recent acts of
58 agents of the Defendants, and the official record of all of the court proceedings at
59 issue, which show that it is the Defendants’ custom to commit commercial fraud in
60 violation of their own codes as well as the Constitution.
61 Second, the Plaintiff has already suffered 9 years of irreparable harm from
62 the Defendants’ commercial fraud. There is also great deal of evidence in the
63 official records of the proceedings for all of the actions at issue which demonstrate
64 the Defendants’ continued willingness to commit fraud. The some of the most
65 recent fraudulent actions, being under 49D22-2204-IF-011989 and 49H01-2111-IF-
66 003988, in which the courts filed default judgments against Me after I challenged
67 the subject-matter jurisdiction of the courts. The default judgments were made
68 without request from the prosecutors whom had not even appeared in the case.
69 Under 49D23-2211-CM-030700, the Defendants have openly falsified the record and
70 issued an administrative warrant for My arrest while also refusing to answer My
71 jurisdictional challenges.
72 Third, both equity and public interest, as well as My physical safety and
73 wellbeing, favor an emergency restraining order, and injunction where the
74 Defendants have willfully and consistently committed commercial fraud in their
75 courts. The consistency of their actions, as public officials, should be viewed as a
76 definite point of deep concern by this Court. The Defendants’ actions go to the core
77 of the integrity of all of the courts of the states and UNITED STATES. The record
78 of the proceedings in the most recent action complained of demonstrates the
79 dedication of the Defendants to committing commercial fraud.
80 I. Plaintiff Is Likely To Succeed On The Merits
81 According to the Defendants’ definition, their statutes only apply to the
82 “bodies politic”. I am not a body politic or part of any bodies politic which are
83 commercially liable to the Defendants. Due to their administrative nature, those

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 84 statutes which are directed at actual human beings can only be applied to those
85 human beings who work within the corporate structure that is the Defendants (i.e.
86 public servants) or those who contract with the Defendants.
87 Additionally, pursuant to Rule 2 of Defendants’ own Rules of Trial Procedure,
88 there is none but “civil action”. By federal definition, specifically 27 CFR 72.11, all
89 of the Defendants’ actions at issue are commercial in nature.
90 When the Defendants initiated several actions resulting in My imprisonment,
91 I challenged the subject-matter jurisdiction of the courts. The judges refused to
92 make the prosecutors prove that the subject-matter jurisdiction of the court is
93 proper, resulting in Plaintiff being enslaved for 9 years.
94 Plaintiff is likely to succeed on the merits due to the fact that the Defendants’
95 own codes and statutes, in addition to the records of the court proceedings at issue,
96 prove the Plaintiff’s case with little or no argument.
97 The Defendants’ actions are in direct contravention of the United States
98 Constitution and the Laws of UNITED STATES. Commercially, the Defendants
99 have committed various types of fraud and breached their fiduciary obligations to
100 the Plaintiff through the misapplication of their administrative codes, as well as
101 violated their own codes and statutes, while ignoring stare decisis and res judicata
102 from their own supreme court.
103 II. Plaintiff Will Be Irreparably Harmed Absent Injunctive Relief
104 Plaintiff has already spent 9 years in slavery for his Lawful commercial acts,
105 including the initiation commercial processes against the Defendants, for which the
106 Defendants sent Plaintiff into 5 of those 9 years of slavery. Over that time, Plaintiff
107 lost several of his elder family members to death, and a sibling to sickness. Plaintiff
108 has missed several once in a lifetime events such as the graduation of his children
109 from high school, the wedding of his oldest child and the birth of his grandchildren.
110 Irreparable harm has already been done. Another result of the Defendants’
111 interferences is that Plaintiff, lost hundreds of thousands of dollars in real property
112 and tens of thousands of dollars in personal property.

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113 Although, by their own definition, Defendants’ codes and statutes do not
114 apply to Plaintiff, Defendants enforce their Administrative codes by force. It is easy
115 for the courts to say that the people may disregard an unconstitutional law.
116 However, the fact and the reality of the situation is that most of the police officers
117 are admittedly ignorant of the statutes that they enforce.
118 The Defendants, through their agents, have placed Plaintiff in the current
119 unlawful situation in which Plaintiff cannot survive unless he violates the
120 Defendants’ Administrative statutes.
121  Defendants will not allow Plaintiff a “driver’s license”, even though Plaintiff
122 has a valid receipt showing that Plaintiff paid the fines required for
123 Defendants to grant a “license”.
124  Defendants will not allow Plaintiff to “register” his automobile because he
125 does not have the insurance that he cannot get without a “driver’s license”.
126 This is regardless of the fact that, pursuant to the U.S. Supreme court, the
127 requirement of insurance is unconstitutional as it pertains to the private
128 vehicle.
129  Because of the risk of incarceration and the loss of his private automobile,
130 Plaintiff cannot use his private automobile pursue adequate work in different
131 locations to even pay the fraudulent fines that Defendants demand that the
132 Plaintiff pay. In this era of Covid-19, public transportation is dangerous.
133  Defendants have placed Plaintiff in a situation which, prevents Plaintiff from
134 supporting himself and his family or even visiting his family due to the risk
135 being re-enslaved for traveling to work or to handle private business without
136 a “driver’s license” in his “unregistered” private automobile.
137  The fraudulent felony labels that the Defendants have placed on the Plaintiff,
138 a college educated, Desert Storm veteran and ex-teacher, have made it
139 virtually impossible for the Plaintiff to find suitable housing or work in the
140 fields of commerce that Plaintiff has worked and trained in for half of his life.
141 The Defendants’ blatant disregard and disrespect for Law and Equity have
142 already taken 9 years of Plaintiff’s life on a whim, leaving Plaintiff jobless and

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143 virtually homeless with no way to properly support himself or his family. Absent
144 immediate injunctive relief, Plaintiff will suffer further irreparable damage from
145 the Defendants, as they have placed Plaintiff in a position in which Plaintiff must
146 violate Defendants’ Administrative codes in order to survive.
147 Additionally, as stated earlier, there is great deal of evidence in the official
148 records of the proceedings for all of the actions at issue which demonstrate the
149 Defendants’ continued willingness to disregard the Law of the Land, and to
150 retaliate for commercial litigation, the most recent violation being under 49H01-
151 2111-IF-003988.
152 A threat of irreparable harm is “sufficiently immediate to warrant
153 preliminary injunctive relief if the plaintiff is likely to suffer irreparable harm
154 before a decision on the merits can be rendered”. Boardman v. Pac. Seafood Grp.,
155 822 F.3d 1011 (9th Cir. 2016).

156 III. The Equities And Public Interest Favor Immediate Relief
157 Based on the facts of the situation, equitable principles and factors such as
158 the fact that the Defendants’ statutes, by their own definitions, descriptions and the
159 nature of the statutes, do not, cannot, and should not be applied against Plaintiff.
160 Also, the records of the court proceedings at issue prove that the Defendants
161 unlawfully enslaved Plaintiff under color of law, through a usurpation of
162 jurisdiction.
163 Additionally, the public interest favors immediate relief due to the fact that
164 the accompanying complaint and issues raised therein, such as the usurpation of
165 jurisdiction, go to the core principles and integrity of the judicial system created by
166 the Constitution of the united States of America, which agents of the Defendants
167 were supposed to be sworn to uphold.
168 “In weighing equities, a court must balance the competing claims of injury
169 and must consider the effect on each party of the granting or withholding of the
170 requested relief.” Doe, 418 F.Supp. 3d at 599. And when “the government is the
171 defendant, generally the balancing of the equities and the public interests factors

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172 merge.” Id. “When the alleged action by the government violates federal law, the
173 public interest factor generally weighs in favor of the plaintiff.” Id.
174 Finally, denying an injunction would not be in the public interest, signaling
175 that there is no more accountability for the public servants who have sworn to
176 uphold the U.S. Constitution and Laws of United States. Denying an injunction
177 would also be contrary to equitable principles, signaling that there is no equity.
178 CONCLUSION
179 For the foregoing reasons, Plaintiff respectfully requests that the Court grant
180 his Motion for Emergency Permanent Restraining Order and Permanent Injunction,
181 enjoining Defendants from enforcing STATE’s Administrative Codes on or against
182 Plaintiff.
183 AFFIRMATION
184 I affirm that the foregoing is true, exact, correct and not misleading, to the
185 best of my knowledge and informed belief.

186 Dated: June 22, 2023

187 /s/ Menes Ankh El

188 Menes Ankh El,
189 All Rights Reserved
190
191
192 CERTIFICATE OF SERVICE
193 Hereby certify that this VERIFIED MOTION FOR EMERGENCY
194 RESTRAINING ORDER AND PRELIMINARY INJUNCTION and accompanying
195 VERIFIED CLAIM AND COMPLAINT have been filed electronically filed with the
196 Court. U.S. Marshall’s service on the Defendants has been requested at the
197 following addresses:
198  Indiana state and STATE OF INDIANA – 201 W. Washington Street, Ste.
199 201, Indianapolis, Indiana 46204
200  CITY OF INDIANAPOLIS – 200 E. Washington Street, Ste. 1260,
201 Indianapolis, Indiana 46204

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202  COUNTY OF MARION – 200 E. Washington Street, Ste. 801, Indianapolis,
203 Indiana 46204

204 /s/ Menes Ankh El

205 Menes Ankh El

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