Complaint and Request for Injunction. Download. The Pen and Ink Rule therefore imposes unnecessary procedural hoops in the absentee ballot application process.COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF - Free download as PDF File (. (Write the full name of each plaintiff who is filing this complaint. A Family Division will be created in Fulton County to address and adjudicate all issues set forth in A list of State Bar, District Committee and Standing Committee actions that have resulted in cease and desist affidavits or complaints for injunctive relief. Respondents engaged in repeated and persistent illegality in the operation of Fulton. The sole defendant in the lawsuit is William W. Muse, Chairman of the VPB. Form the basis of this case. 3. The following facts, taken from the complaint, are accepted as true for purposes of this motion to dismiss.