D.O.G.E -> MOTION FOR INJUNCTION AGAINST KENTUCKY DEPARTMENT OF MOTOR VEHICLES

[CIABrad.eth]

IN THE [Eastern District Of Alexandria] OF [Central Intelligence Agency Jurisdiction]
[121-po-588]

[Bradley Tyler Burns / Chief Prosecutor CIA],
Plaintiff,

v.

KENTUCKY DEPARTMENT OF MOTOR VEHICLES,
Defendant.

REQUEST FOR INJUNCTION

TO THE HONORABLE JUDGE OF SAID COURT:

COMES NOW the Plaintiff, [Bradley Tyler Burns / Gary Smith Representing Central Intelligence Agency], and respectfully represents unto the Court as follows:

1. PARTIES AND JURISDICTION
a. Plaintiff, [Bradley Tyler Burns / Gary Smith Representing Central Intelligence Agency], is a resident of [Lexington, Fayette, Kentucky & Las Vegas, Nevada].
b. Defendant, Kentucky Department of Motor Vehicles ("KDMT"), is an agency of the Commonwealth of Kentucky responsible for vehicle registration and regulation.

2. FACTUAL BACKGROUND
a. Plaintiff is an owner/operator of a vehicle registered with KDMT,DOT, with over 30 registered work vehicles in the county of question.
b. It has come to the attention of the Plaintiff that the KDMT has failed to report or accurately account for over 500,000+ miles associated with the operational use of vehicles within its jurisdiction.
c. As a result of these unreported miles, there is a substantial discrepancy in the assessment and collection of gas taxes owed to the Commonwealth of Kentucky, which has caused economic harm to the Plaintiff and other registered vehicle owners.

3. GROUNDS FOR INJUNCTION
a. Plaintiff asserts that this failure to report has resulted in a direct economic impact on registered vehicle owners, leading to financial losses and potential penalties.
b. The actions of the Defendant are arbitrary, capricious, and contrary to the statutory obligations of KDMT under Kentucky law.
c. Injury to the Plaintiff is imminent, and without intervention from the Court, Plaintiff and other affected parties will continue to face financial detriment.

4. REQUEST FOR INJUNCTIVE RELIEF
WHEREFORE, Plaintiff respectfully requests that this Honorable Court issue a temporary and permanent injunction against the Kentucky Department of Motor Vehicles, ordering the following:
a. Immediate cessation of all operations related to vehicle mile reporting until a satisfactory resolution is reached.
b. A thorough review and accurate reporting of all miles associated with registered vehicles in Kentucky.
c. A comprehensive audit of gas tax collections and assessments related to the unreported miles.
d. Any other relief the Court deems just and proper.

DATED this [09] day of [03], [2025].

[Bradley Tyler Burns]
[401 Courthouse Square]
[Alexandria, Virginia, USA]
[702.773.4529]
[ciabradleyburns@gmail.com]

Attorney for Plaintiff (if applicable):
[Gary Smith III]
[Smith Solutions LLC]
[gary@smithsolutions.us]

CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing was served upon the Defendant by [method of service] on this [Date] day of [Month], [Year].

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[Bradley Tyler Burns]

[Chief Prosecutor CIA]