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Page 1 FILED
03-28-2025
CIRCUIT COURT
DANE COUNTY, WI
STATE OF WISCONSIN
CIRCUIT COURT
DANE COUNTY
JOSH KAUL, in his official capacity as
Wisconsin Attorney General
17 West Main Street
Madison, WI 53703,
2025CV001087
Honorable Susan M.
Crawford
Branch 1
Plaintiff,
v.
ELON MUSK
2110 Ranch Road 620 S. #341886
Austin, TX 78734, and
AMERICA PAC
P.O. Box 341027
Austin, TX 78734,
Defendants.
SUMMONS
THE STATE OF WISCONSIN
To each entity and individual named above as a defendant:
You are hereby notified that the plaintiff named above has filed a lawsuit or
other legal action against you. The complaint, which is attached, states the nature
and basis of the legal action.
Within twenty (20) days of receiving this summons, you must respond with a
written answer, as that term is used in Wis. Stat. ch. 802, to the complaint. The court
IF YOU REQUIRE THE ASSISTANCE OF AUXILIARY AIDS OR SERVICES BECAUSE OF A DISABILITY, CALL (608) 266-4678
AND ASK FOR THE DANE COUNTY CIRCUIT COURT ADA COORDINATOR.Page 2 may reject or disregard an answer that does not follow the requirements of the
statutes. The answer must be sent or delivered to the court, whose address is
215 South Hamilton Street, Suite 1000, Madison, Wisconsin 53703, and to Karla Z.
Keckhaver and Lewis W. Beilin, Assistant Attorneys General, plaintiff’s attorneys,
whose address is Wisconsin Department of Justice, Post Office Box 7857, Madison,
Wisconsin 53707-7857. You may have an attorney help or represent you.
If you do not provide a proper answer within twenty (20) days, the court may
grant judgment against you for the award of money or other legal action requested in
the complaint, and you may lose your right to object to anything that is or may be
incorrect in the complaint. A judgment may be enforced as provided by law. A
judgment awarding money may become a lien against any real estate you own now
or in the future and may also be enforced by garnishment or seizure of property.
Dated this 28th day of March 2025.
Respectfully submitted,
JOSHUA L. KAUL
Attorney General of Wisconsin
Electronically signed by:
s/Karla Z. Keckhaver
KARLA Z. KECKHAVER
Assistant Attorney General
State Bar #1028242
LEWIS W. BEILIN
Assistant Attorney General
State Bar #1038835
KEVIN L. GRZEBIELSKI
Assistant Attorney General
State Bar #1098414
2Page 3 Attorneys for Attorney General
Joshua L. Kaul
Wisconsin Department of Justice
Post Office Box 7857
Madison, Wisconsin 53707-7857
(608) 266-1221
(608) 294-2907 (Fax)
keckhaverkz@doj.state.wi.us
beilinlw@doj.state.wi.us
grzebielskikl@doj.state.wi.us
3Page 4 FILED
03-28-2025
CIRCUIT COURT
DANE COUNTY, WI
STATE OF WISCONSIN
CIRCUIT COURT
ATTORNEY GENERAL JOSH KAUL,
DANE COUNTY
2025CV001087
Honorable Susan M.
Crawford
Branch 1
Plaintiff,
v.
ELON MUSK and
AMERICA PAC,
Defendant.
COMPLAINT
INTRODUCTION
On March 27, 2025, Elon Musk posted this statement to his X.com account:
1Page 5 Wisconsin law forbids anyone from offering or promising to give anything of
value to an elector in order to induce the elector to go to the polls, vote or refrain from
voting, or vote for a particular person. Wis. Stat. § 12.11(1m). Musk’s announcement
of his intention to pay $1 million to two Wisconsin electors who attend his event on
Sunday night, specifically conditioned on their having voted in the upcoming April 3,
2025, Wisconsin Supreme Court election, is a blatant attempt to violate Wis. Stat.
§ 12.11. This must not happen.
The Attorney General brings this action pursuant to Wis. Stat. § 5.07 seeking
immediate, temporary and permanent injunctive relief to prevent Musk and America
PAC’s egregious attempt to buy votes in a Wisconsin election.
PARTIES
1.
Plaintiff is Joshua L. Kaul, Attorney General of Wisonsin, who is
authorized to bring this action by Wis. Stat. § 5.07. The Attorney General is head of
the Wisconsin Department of Justice, whose address is Risser Justice Center, 17 West
Main Street, Madison, WI 53703.
2.
Defendant Elon Musk is the founder of America PAC. He is also the
owner of X.com, formerly Twitter. His address is 2110 Ranch Road 620 S. #341886
Austin, TX 78734.
3.
Defendant America PAC is a federal political action committee. Its
address is P.O. Box 341027, Austin, TX 78734. Defendant Musk was the founder and
remains principal funder of America PAC. The Treasurer of America PAC is Chris
Young.
2Page 6 JURISDICTION AND VENUE
1.
The Court has jurisdiction pursuant to Wis. Stat. § 5.07, which
authorizes the Attorney General to “sue for injunctive relief, a writ of mandamus or
prohibition, or other such legal or equitable relief as may be appropriate to compel
compliance with” the laws regulation the conduct of elections or election campaigns,
whenever a violation of such laws “occurs or is proposed to occur.” Wis. Stat. § 5.07.
2.
Venue is appropriate in Dane County pursuant to Wis. Stat. § 5.07 and
801.50. Defendants have publicized two $1 million payments throughout the state,
indeed throughout the nation and world, via online platforms. Voters in all Wisconsin
counties are being solicitated to participate in the Defendants’ scheme, including
voters in Dane County.
RELEVANT LAW
3. Wisconsin Stat. § 5.07 provides:
Whenever a violation of the laws regulating the conduct of elections or
election campaigns, other than a violation of the laws regulating
campaign financing, occurs or is proposed to occur, the attorney general
or the district attorney of the county where the violation occurs or is
proposed to occur may sue for injunctive relief, a writ of mandamus or
prohibition, or other such legal or equitable relief as may be appropriate
to compel compliance with the law. No bond is required in such actions.
4.
Wisconsin Stat. § 12.11(1m) provides that “[a]ny person who does any of
the following violates this chapter:
(a) Offers, gives, lends or promises to give or lend, or endeavors to
procure, anything of value, or any office or employment or any privilege
or immunity to, or for, any elector, or to or for any other person, in order
to induce any elector to:
1. Go to or refrain from going to the polls.
3Page 7 2. Vote or refrain from voting.
3. Vote or refrain from voting for or against a particular person.
4. Vote or refrain from voting for or against a particular
referendum; or on account of any elector having done any of
the above.
(b) Receives, agrees or contracts to receive or accept any money, gift,
loan, valuable consideration, office or employment personally or for any
other person, in consideration that the person or any elector will, so act
or has so acted.
(c) Advances, pays or causes to be paid any money to or for the use of
any person with the intent that such money or any part thereof will be
used to bribe electors at any election.
FACTS
5.
On March 27, 2025, Elon Musk posted to his X.com account the following
statement:
6.
As of 11:57 pm on March 27, 2025, there were already 19.5 million
views of Musk’s X.com post.
7.
The post was also widely reported by the news media. See, e.g., Scott
Bauer, Wisconsin Supreme Court Race; Musk to hold rally, deliver $2M to voters,
4Page 8 FOX6 News (Mar. 28, 2025), https://www.fox6now.com/news/wisconsin-supremecourt-race-musk-hold-rally-deliver-2m-voters; Alison Dirr, et al., Elon Must says he
will be in Wisconsin Sunday, hand out $2M ahead of Supreme Court election,
Milwaukee
Journal
Sentinel
(Mar.
28,
2025),
https://www.jsonline.com/story/news/politics/2025/03/28/musk-coming-to-wisconsinahead-of-tuesday-state-supreme-court-ele
8.
Musk is the founder and largest funder of America PAC. America PAC,
https://theamericapac.org/ (last visited Mar. 28, 2025); see also America PAC,
Fed. Election Comm’n, https://www.fec.gov/data/committee/C00879510/?cycle=2024
(last visited Mar. 28, 2025).
9.
Musk is also the owner of X.com, formerly Twitter.
10.
Defendants’ announcement of two $1 million payments to Wisonsin
electors to vote in the Wisconsin Supreme Court election is a further step in their
ongoing involvement in the April 3, 2025, Wisconsin election.
11.
Defendant America PAC has also offered a $100 payment to any
Wisconsin registered voter who signs an online “Petition” that expresses the signer’s
agreement with certain statements regarding judges.
12.
The Petition was publicized via an America PAC post on X.com on March
20, 2025. @america, X.com, https://x.com/america/status/1902888358432370773
(Mar. 20, 2025, 8:01 p.m.) and was reported widely in the media. See, e.g., Scott
Bauer, Musk group offers $100 to Wisconsin voters ahead of pivotal state Supreme
Court
election,
AP
News.com
(March
5
21,
2025
1:57
PM
CDT),Page 9 https://apnews.com/article/wisconsin-supreme-court-musk-trumpb9be6119d500bdacc9c6341be013cd62.
13.
The Petition also offered $100 for each additional registered voter who
signs the Petition and identifies the referring voters by name and email address.
14.
Although the initial Petition announcement only offered $100 payments,
America PAC announced on March 27, 2025, that it had given $1 million to a
Wisconsin registered voter who had signed the Petition. Mariana La Roche, Musk
PAC gives Wisconsin voter $1 million after petition campaign, WISN 12 (Mar. 27,
2025, 10:59 PM CDT), https://www.wisn.com/article/musk-pac-gives-wisconsin-voter1-million-after-petition-campaign/64310654.
15.
As of 12:20 pm on March 28, 2025, Musk’s March 27, 2025, post on X.com
shown in paragraph 1 appears to have been taken down. Jessica Piper & Andrew
Howard, Musk butts up against state law with (now deleted) $1 million check
giveaway,
Politico.com
(March
28,
2025
updated
1:49
PM
EDT),
https://www.politico.com/news/2025/03/28/elon-musk-wisconsin-supreme-courtgiveaway-00257082.
6Page 10 16.
As of 12:28 pm on March 28, 2025, Musk posted on X.com the following:
17.
As of the time of this filing, neither Musk nor America PAC have
announced that their plan to pay $1 million to two Wisconsin electors on Sunday
March 30, 2025, has been cancelled.
LEGAL CLAIM
INJUNCTION: Wis. Stat. §§ 5.07, 813.02
18.
Plaintiff re-alleges all preceding paragraphs and incorporates them
herein by reference.
7Page 11 Defendant Musk’s public statement on March 27, 2025, demonstrates
an intention to violate Wis. Stat. § 12.11. Although the post appears to have been
taken down from the X.com site as of this filing, the offer has not been withdrawn.
20.
Upon information and belief, despite taking down the X.com post,
neither Musk nor America PAC have announced that the plan to make two $1 million
payments to Wisconsin electors who have voted in the Wisconsin Supreme Court
election has been cancelled.
21.
Wisconsin Stat. § 5.07 authorizes this Court to grant injunctive relief to
prevent violations of Wis. Stat. § 12.11 from occurring and to issue any legal or other
equitable relief necessary to compel compliance with Wis. Stat. § 12.11.
22.
Defendants’ actions demonstrate the appropriateness of immediate
injunctive relief pursuant to Wis. Stat. § 813.02.
PRAYER FOR RELIEF
On the basis of the foregoing and all papers submitted to the Court
herewith and in further support of this Complaint, Attorney General Kaul
respectfully requests that the Court grant the following:
1.
A temporary restraining order prohibiting Defendants from any further
promotion of the million-dollar gifts to attendees of the planned Sunday March 30,
2025.
2.
A temporary restraining order prohibiting Defendants from making any
payments to Wisconsin electors to vote.
8Page 12 Temporary and permanent injunctive relief on appropriate terms to
restrain and prohibit all actions by Defendants taken in furtherance of a planned
violation of Wis. Stat. § 12.11.
4.
Other such legal or equitable relief as may be appropriate to compel
compliance with the law.
Dated this 28th day of March 2025.
Respectfully submitted,
JOSHUA L. KAUL
Attorney General of Wisconsin
Electronically signed by:
s/Karla Z. Keckhaver
KARLA Z. KECKHAVER
Assistant Attorney General
State Bar #1028242
LEWIS W. BEILIN
Assistant Attorney General
State Bar #1038835
KEVIN L. GRZEBIEKSKI
Assistant Attorney General
State Bar #1098414
Attorneys for Attorney General
Joshua L. Kaul
Wisconsin Department of Justice
Post Office Box 7857
Madison, Wisconsin 53707-7857
(608) 266-1221
(608) 294-2907 (Fax)
keckhaverkz@doj.state.wi.us
beilinlw@doj.state.wi.us
grzebielskikl@doj.state.wi.us
9
PDF Page 1
PlainSite Cover Page
PDF Page 2
Case 2025CV001087
Document 3
Filed 03-28-2025
Page 1 of 12
FILED
03-28-2025
CIRCUIT COURT
DANE COUNTY, WI
STATE OF WISCONSIN
CIRCUIT COURT
DANE COUNTY
JOSH KAUL, in his official capacity as
Wisconsin Attorney General
17 West Main Street
Madison, WI 53703,
2025CV001087
Honorable Susan M.
Crawford
Branch 1
Plaintiff,
v.
ELON MUSK
2110 Ranch Road 620 S. #341886
Austin, TX 78734, and
AMERICA PAC
P.O. Box 341027
Austin, TX 78734,
Defendants.
SUMMONS
THE STATE OF WISCONSIN
To each entity and individual named above as a defendant:
You are hereby notified that the plaintiff named above has filed a lawsuit or
other legal action against you. The complaint, which is attached, states the nature
and basis of the legal action.
Within twenty (20) days of receiving this summons, you must respond with a
written answer, as that term is used in Wis. Stat. ch. 802, to the complaint. The court
IF YOU REQUIRE THE ASSISTANCE OF AUXILIARY AIDS OR SERVICES BECAUSE OF A DISABILITY, CALL (608) 266-4678
AND ASK FOR THE DANE COUNTY CIRCUIT COURT ADA COORDINATOR.
PDF Page 3
Case 2025CV001087
Document 3
Filed 03-28-2025
Page 2 of 12
may reject or disregard an answer that does not follow the requirements of the
statutes. The answer must be sent or delivered to the court, whose address is
215 South Hamilton Street, Suite 1000, Madison, Wisconsin 53703, and to Karla Z.
Keckhaver and Lewis W. Beilin, Assistant Attorneys General, plaintiff’s attorneys,
whose address is Wisconsin Department of Justice, Post Office Box 7857, Madison,
Wisconsin 53707-7857. You may have an attorney help or represent you.
If you do not provide a proper answer within twenty (20) days, the court may
grant judgment against you for the award of money or other legal action requested in
the complaint, and you may lose your right to object to anything that is or may be
incorrect in the complaint. A judgment may be enforced as provided by law. A
judgment awarding money may become a lien against any real estate you own now
or in the future and may also be enforced by garnishment or seizure of property.
Dated this 28th day of March 2025.
Respectfully submitted,
JOSHUA L. KAUL
Attorney General of Wisconsin
Electronically signed by:
s/Karla Z. Keckhaver
KARLA Z. KECKHAVER
Assistant Attorney General
State Bar #1028242
LEWIS W. BEILIN
Assistant Attorney General
State Bar #1038835
KEVIN L. GRZEBIELSKI
Assistant Attorney General
State Bar #1098414
2
PDF Page 4
Case 2025CV001087
Document 3
Filed 03-28-2025
Page 3 of 12
Attorneys for Attorney General
Joshua L. Kaul
Wisconsin Department of Justice
Post Office Box 7857
Madison, Wisconsin 53707-7857
(608) 266-1221
(608) 294-2907 (Fax)
keckhaverkz@doj.state.wi.us
beilinlw@doj.state.wi.us
grzebielskikl@doj.state.wi.us
3
PDF Page 5
Case 2025CV001087
Document 3
Filed 03-28-2025
Page 4 of 12
FILED
03-28-2025
CIRCUIT COURT
DANE COUNTY, WI
STATE OF WISCONSIN
CIRCUIT COURT
ATTORNEY GENERAL JOSH KAUL,
DANE COUNTY
2025CV001087
Honorable Susan M.
Crawford
Branch 1
Plaintiff,
v.
ELON MUSK and
AMERICA PAC,
Defendant.
COMPLAINT
INTRODUCTION
On March 27, 2025, Elon Musk posted this statement to his X.com account:
1
PDF Page 6
Case 2025CV001087
Document 3
Filed 03-28-2025
Page 5 of 12
Wisconsin law forbids anyone from offering or promising to give anything of
value to an elector in order to induce the elector to go to the polls, vote or refrain from
voting, or vote for a particular person. Wis. Stat. § 12.11(1m). Musk’s announcement
of his intention to pay $1 million to two Wisconsin electors who attend his event on
Sunday night, specifically conditioned on their having voted in the upcoming April 3,
2025, Wisconsin Supreme Court election, is a blatant attempt to violate Wis. Stat.
§ 12.11. This must not happen.
The Attorney General brings this action pursuant to Wis. Stat. § 5.07 seeking
immediate, temporary and permanent injunctive relief to prevent Musk and America
PAC’s egregious attempt to buy votes in a Wisconsin election.
PARTIES
1.
Plaintiff is Joshua L. Kaul, Attorney General of Wisonsin, who is
authorized to bring this action by Wis. Stat. § 5.07. The Attorney General is head of
the Wisconsin Department of Justice, whose address is Risser Justice Center, 17 West
Main Street, Madison, WI 53703.
2.
Defendant Elon Musk is the founder of America PAC. He is also the
owner of X.com, formerly Twitter. His address is 2110 Ranch Road 620 S. #341886
Austin, TX 78734.
3.
Defendant America PAC is a federal political action committee. Its
address is P.O. Box 341027, Austin, TX 78734. Defendant Musk was the founder and
remains principal funder of America PAC. The Treasurer of America PAC is Chris
Young.
2
PDF Page 7
Case 2025CV001087
Document 3
Filed 03-28-2025
Page 6 of 12
JURISDICTION AND VENUE
1.
The Court has jurisdiction pursuant to Wis. Stat. § 5.07, which
authorizes the Attorney General to “sue for injunctive relief, a writ of mandamus or
prohibition, or other such legal or equitable relief as may be appropriate to compel
compliance with” the laws regulation the conduct of elections or election campaigns,
whenever a violation of such laws “occurs or is proposed to occur.” Wis. Stat. § 5.07.
2.
Venue is appropriate in Dane County pursuant to Wis. Stat. § 5.07 and
801.50. Defendants have publicized two $1 million payments throughout the state,
indeed throughout the nation and world, via online platforms. Voters in all Wisconsin
counties are being solicitated to participate in the Defendants’ scheme, including
voters in Dane County.
RELEVANT LAW
3. Wisconsin Stat. § 5.07 provides:
Whenever a violation of the laws regulating the conduct of elections or
election campaigns, other than a violation of the laws regulating
campaign financing, occurs or is proposed to occur, the attorney general
or the district attorney of the county where the violation occurs or is
proposed to occur may sue for injunctive relief, a writ of mandamus or
prohibition, or other such legal or equitable relief as may be appropriate
to compel compliance with the law. No bond is required in such actions.
4.
Wisconsin Stat. § 12.11(1m) provides that “[a]ny person who does any of
the following violates this chapter:
(a) Offers, gives, lends or promises to give or lend, or endeavors to
procure, anything of value, or any office or employment or any privilege
or immunity to, or for, any elector, or to or for any other person, in order
to induce any elector to:
1. Go to or refrain from going to the polls.
3
PDF Page 8
Case 2025CV001087
Document 3
Filed 03-28-2025
Page 7 of 12
2. Vote or refrain from voting.
3. Vote or refrain from voting for or against a particular person.
4. Vote or refrain from voting for or against a particular
referendum; or on account of any elector having done any of
the above.
(b) Receives, agrees or contracts to receive or accept any money, gift,
loan, valuable consideration, office or employment personally or for any
other person, in consideration that the person or any elector will, so act
or has so acted.
(c) Advances, pays or causes to be paid any money to or for the use of
any person with the intent that such money or any part thereof will be
used to bribe electors at any election.
FACTS
5.
On March 27, 2025, Elon Musk posted to his X.com account the following
statement:
6.
As of 11:57 pm on March 27, 2025, there were already 19.5 million
views of Musk’s X.com post.
7.
The post was also widely reported by the news media. See, e.g., Scott
Bauer, Wisconsin Supreme Court Race; Musk to hold rally, deliver $2M to voters,
4
PDF Page 9
Case 2025CV001087
Document 3
Filed 03-28-2025
Page 8 of 12
FOX6 News (Mar. 28, 2025), https://www.fox6now.com/news/wisconsin-supremecourt-race-musk-hold-rally-deliver-2m-voters; Alison Dirr, et al., Elon Must says he
will be in Wisconsin Sunday, hand out $2M ahead of Supreme Court election,
Milwaukee
Journal
Sentinel
(Mar.
28,
2025),
https://www.jsonline.com/story/news/politics/2025/03/28/musk-coming-to-wisconsinahead-of-tuesday-state-supreme-court-election/82702597007/.
8.
Musk is the founder and largest funder of America PAC. America PAC,
https://theamericapac.org/ (last visited Mar. 28, 2025); see also America PAC,
Fed. Election Comm’n, https://www.fec.gov/data/committee/C00879510/?cycle=2024
(last visited Mar. 28, 2025).
9.
Musk is also the owner of X.com, formerly Twitter.
10.
Defendants’ announcement of two $1 million payments to Wisonsin
electors to vote in the Wisconsin Supreme Court election is a further step in their
ongoing involvement in the April 3, 2025, Wisconsin election.
11.
Defendant America PAC has also offered a $100 payment to any
Wisconsin registered voter who signs an online “Petition” that expresses the signer’s
agreement with certain statements regarding judges.
12.
The Petition was publicized via an America PAC post on X.com on March
20, 2025. @america, X.com, https://x.com/america/status/1902888358432370773
(Mar. 20, 2025, 8:01 p.m.) and was reported widely in the media. See, e.g., Scott
Bauer, Musk group offers $100 to Wisconsin voters ahead of pivotal state Supreme
Court
election,
AP
News.com
(March
5
21,
2025
1:57
PM
CDT),
PDF Page 10
Case 2025CV001087
Document 3
Filed 03-28-2025
Page 9 of 12
https://apnews.com/article/wisconsin-supreme-court-musk-trumpb9be6119d500bdacc9c6341be013cd62.
13.
The Petition also offered $100 for each additional registered voter who
signs the Petition and identifies the referring voters by name and email address.
14.
Although the initial Petition announcement only offered $100 payments,
America PAC announced on March 27, 2025, that it had given $1 million to a
Wisconsin registered voter who had signed the Petition. Mariana La Roche, Musk
PAC gives Wisconsin voter $1 million after petition campaign, WISN 12 (Mar. 27,
2025, 10:59 PM CDT), https://www.wisn.com/article/musk-pac-gives-wisconsin-voter1-million-after-petition-campaign/64310654.
15.
As of 12:20 pm on March 28, 2025, Musk’s March 27, 2025, post on X.com
shown in paragraph 1 appears to have been taken down. Jessica Piper & Andrew
Howard, Musk butts up against state law with (now deleted) $1 million check
giveaway,
Politico.com
(March
28,
2025
updated
1:49
PM
EDT),
https://www.politico.com/news/2025/03/28/elon-musk-wisconsin-supreme-courtgiveaway-00257082.
6
PDF Page 11
Case 2025CV001087
Document 3
Filed 03-28-2025
Page 10 of 12
16.
As of 12:28 pm on March 28, 2025, Musk posted on X.com the following:
17.
As of the time of this filing, neither Musk nor America PAC have
announced that their plan to pay $1 million to two Wisconsin electors on Sunday
March 30, 2025, has been cancelled.
LEGAL CLAIM
INJUNCTION: Wis. Stat. §§ 5.07, 813.02
18.
Plaintiff re-alleges all preceding paragraphs and incorporates them
herein by reference.
7
PDF Page 12
Case 2025CV001087
19.
Document 3
Filed 03-28-2025
Page 11 of 12
Defendant Musk’s public statement on March 27, 2025, demonstrates
an intention to violate Wis. Stat. § 12.11. Although the post appears to have been
taken down from the X.com site as of this filing, the offer has not been withdrawn.
20.
Upon information and belief, despite taking down the X.com post,
neither Musk nor America PAC have announced that the plan to make two $1 million
payments to Wisconsin electors who have voted in the Wisconsin Supreme Court
election has been cancelled.
21.
Wisconsin Stat. § 5.07 authorizes this Court to grant injunctive relief to
prevent violations of Wis. Stat. § 12.11 from occurring and to issue any legal or other
equitable relief necessary to compel compliance with Wis. Stat. § 12.11.
22.
Defendants’ actions demonstrate the appropriateness of immediate
injunctive relief pursuant to Wis. Stat. § 813.02.
PRAYER FOR RELIEF
On the basis of the foregoing and all papers submitted to the Court
herewith and in further support of this Complaint, Attorney General Kaul
respectfully requests that the Court grant the following:
1.
A temporary restraining order prohibiting Defendants from any further
promotion of the million-dollar gifts to attendees of the planned Sunday March 30,
2025.
2.
A temporary restraining order prohibiting Defendants from making any
payments to Wisconsin electors to vote.
8
PDF Page 13
Case 2025CV001087
3.
Document 3
Filed 03-28-2025
Page 12 of 12
Temporary and permanent injunctive relief on appropriate terms to
restrain and prohibit all actions by Defendants taken in furtherance of a planned
violation of Wis. Stat. § 12.11.
4.
Other such legal or equitable relief as may be appropriate to compel
compliance with the law.
Dated this 28th day of March 2025.
Respectfully submitted,
JOSHUA L. KAUL
Attorney General of Wisconsin
Electronically signed by:
s/Karla Z. Keckhaver
KARLA Z. KECKHAVER
Assistant Attorney General
State Bar #1028242
LEWIS W. BEILIN
Assistant Attorney General
State Bar #1038835
KEVIN L. GRZEBIEKSKI
Assistant Attorney General
State Bar #1098414
Attorneys for Attorney General
Joshua L. Kaul
Wisconsin Department of Justice
Post Office Box 7857
Madison, Wisconsin 53707-7857
(608) 266-1221
(608) 294-2907 (Fax)
keckhaverkz@doj.state.wi.us
beilinlw@doj.state.wi.us
grzebielskikl@doj.state.wi.us
9
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