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Motion
IN THE DISTRICT COURT OF THE COMMONWEALTH OF REDMONT
MOTION FOR EMERGENCY INJUNCTION
Evidence and proof of representation shall be attached onto this post for the honorable Judge to review, and will also be presented with the complaint when it is filed.
Your Honor,
1. The Plaintiff Holds a Pre-Existing Contractual Right to the Subject Properties.
On 2/26/2026, the Plaintiff .Suixgen entered into a valid and fully executed Contract of Sale with 12700k for properties C163 and C166 in Reveille at a purchase price of $100,000. The Sale Contract was signed by all parties — the Opposing Party at 4:39 PM EST, the Plaintiff's agent at 4:39 PM EST, and Two Guys Realty's agent at 4:34 PM EST. The Plaintiff was ready, willing, and able to tender full payment at Closing. The Opposing Party's subsequent deportation from the Commonwealth rendered it unable to perform its obligation to transfer the properties, constituting a material breach of the Sale Contract pursuant to the Contracts Act § 7. The Plaintiff's contractual right to these specific properties is therefore vested and enforceable.
2. The Properties Face Imminent and Irreparable Harm by Government Action.
Pursuant to the Economic Standards Act § 5(2)(a), the Department of Construction and Transportation holds the authority to evict, vault, and auction properties belonging to deported players. As 12700k has been deported, properties C163 and C166 are presently subject to that authority and face imminent disposition. The DCT maintains a well-established practice of moving swiftly to vault and auction deported players' properties. Once C163 and C166 are transferred to a third-party buyer at public auction, the Plaintiff's remedy of specific performance is permanently and irreversibly extinguished — no court order can compel the transfer of property already conveyed to an innocent purchaser for value. Monetary damages are an inadequate substitute for the loss of unique, specific real property to which the Plaintiff holds a vested contractual right. This harm is both imminent and irreparable. This Court granted identical injunctive relief on identical grounds in Plura72 v. Department of Construction and Transportation [2025] DCR 80.
3. The Plaintiff Is Likely to Succeed on the Merits.
The underlying claim is straightforward. A valid Sale Contract was executed, all formalities were observed, and the Plaintiff performed or stood ready to perform all of its obligations. The Opposing Party failed entirely to transfer the properties at Closing. The Opposing Party's deportation does not constitute a force majeure event, as the Contracts Act § 13(4) expressly excludes events arising from a party's own negligence, mismanagement, or acceptance of unnecessary risk. The merits of this claim are strong, and this Court's threshold for likelihood of success is readily satisfied.
4. The Balance of Hardships Overwhelmingly Favors the Plaintiff.
A temporary freeze imposes no meaningful burden on the Commonwealth or the DCT. The properties will remain held by the government regardless of whether they are vaulted pending auction or vaulted pending this Court's resolution of the matter — the DCT's administrative burden is identical in either case. By contrast, denying this injunction permanently and irrevocably destroys the Plaintiff's contractual rights with no possibility of restoration. There is no competing hardship that can be weighed against the permanent extinguishment of a vested property right.
5. Relief Requested.
The Plaintiff respectfully requests that this Court:
(a) Immediately enjoin the Department of Construction and Transportation from auctioning, vaulting, pruning, transferring, or otherwise disposing of properties C163 and C166 for the duration of this litigation; and
(b) Should any such disposition occur after the filing of this motion, order it fully rescinded and the properties placed in escrow pending final resolution of the complaint.