Case 3:16-cv-01296-JM-BLM Document 3 Filed 05/31/16 Page 1 of 2

1 David Loy (229235)

ACLU FOUNDATION OF SAN DIEGO &
2 IMPERIAL COUNTIES
P.O. Box 87131
3 San Diego, CA 92138-7131
Telephone: (619) 232-2121
4 Facsimile: (619) 232-0036
davidloy@aclusandiego.org
5
Ryan T. Darby, Esq. (SBN 264357)
6 THE LAW OFFICE OF RYAN T. DARBY
525 B Street, Suite 1500
7 San Diego, CA 92101
Telephone: (619) 858-4766
8 Facsimile: (619) 243-7226
darby@darby.law
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Attorneys for Plaintiff THE KOALA
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11 UNITED STATES DISTRICT COURT
12 SOUTHERN DISTRICT OF CALIFORNIA
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14 THE KOALA, an unincorporated Case No.: '16CV1296 JM BLM
student association,
15 PLAINTIFF’S MOTION FOR
Plaintiff, PRELIMINARY
16 INJUNCTION
v.
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PRADEEP KHOSLA, et al.,
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Defendants.
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TO ALL PARTIES AND THEIR COUNSEL OF RECORD
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PLEASE TAKE NOTICE that as soon as the matter may be heard before the
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judge assigned to this case, at a date and time to be designated by the assigned
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judge, of which Plaintiff will serve notice, Plaintiff will and hereby does move this
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Court for an order granting a preliminary injunction prohibiting Defendants and
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their officers, agents, servants, employees, and attorneys, and any person in active
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concert or participation with any of the foregoing persons, from:
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 Case 3:16-cv-01296-JM-BLM Document 3 Filed 05/31/16 Page 2 of 2

1 1. Enforcing any motion, resolution, or other official action that

2 disqualifies registered student organizations at the University of California, San
3 Diego (“UCSD”) from eligibility to receive funds derived from campus activity
4 fees to publish student newspapers or other periodicals;
5 2. Categorically refusing to disburse funds derived from campus activity
6 fees to Plaintiff for purposes of publishing a student newspaper or other periodical
7 on the ground that Plaintiff would use such funds to publish a student newspaper or
8 other periodical; and
9 3. Taking any action that discriminates or retaliates against Plaintiff
10 because of the viewpoint expressed by Plaintiff in Plaintiff’s publications or
11 otherwise.
12 Plaintiff’s Motion is based on this Notice of Motion and Motion; the
13 concurrently-filed supporting Memorandum of Points and Authorities, and
14 declarations attached thereto; on all papers, pleadings, records and files in this case;
15 on all matters of which judicial notice may be taken; and on such other argument
16 and/or evidence as may be presented to this Court at a hearing on this motion.
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Dated: May 31, 2016 Respectfully submitted,
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By: s/David Loy
19 David Loy
20 davidloy@aclusandiego.org
21 Ryan T. Darby
22 Attorneys for Plaintiff
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