IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF PENNSYLVANIA

Appellate 17-1042

DARRELL PRINCE,
Plaintiff,
vs.
UNITED STATES GOVERNMENT

MOTION FOR EMERGENCY INJUNCTIVE RELIEF AND ACCOMPANYING

MEMORANDUM OF LAW
COME NOW

Plantiff Darrell Prince, pursuant to Constitutional law here move this Honorable Court
for emergency injunctive relief, and in support would state as follows:

FACTUAL BACKGROUND

1. The federal government of the United States of America, has been aware of a massive
threat to the Republic for nearly 40 years- dating back to the Nixon administration, there
were memos about losing cities. The observations, and theoretical framework have been
built upon since before the Civil War, by scientific founding fathers like Tyndale, Fourier,
and early 20th century Arrhenius(Nobel prize laureate)

2. CO2 levels have increased by 43% over the last 50 years- the US, just from oil, puts 15
billion pounds of CO2 into the atmosphere, every day. Methane has increased by similar
amounts, and is 86 times more powerful a greenhouse gas.

3. Global warming is, the heating of the Earth, because of fossil fuel burning, releasing
heat, and CO2, and methane, which act as insulation for the earth. It is the insulation due
to gases that allows temperatures on the earth to support life on it. Currently and for the
forseeable future because of the sheer scale- global warming is irreversible

4. Global warming is a man-made acknowledged threat, to the stability of life in the

United States, currently, by the US government, the President, EPA, NOAA, NASA,
DOE and DoD, as well as the UN, and every major scientific organization on the planet,
and the subject of remarkable consensus in the field of study of >90%

5. In the Northeastern United States, evidence of a clear and unmistakable shift have
occurred, in the form of two consecutive 60 degree Christmases, in the third consecutive
hottest global year on record.(NOAA)

6. There are several likely feedback loops, from albedo, to permafrost, methane
clathrates, that would make the rate of global warming increase exponentially faster- in
other words, the more it warms, the faster it would warm, because at a certain
temperature- more methane and CO2 than is currently in the atmosphere could be
released.(Clathrate Gun)

7. Nature magazine estimates the potential threat at 60 trillion dollars

8. To date, there have been no scale significant expenditures to deal with this threat-other
than nuclear war, or internal strife, the only credible threat to US sovereignty- for scale
size we would look to the Iraq War and subsequent Occupation- 100+ billion per year.

IMMEDIATE INJUNCTIVE RELIEF IS APPROPRIATE

(1) Plaintiff claims have a substantial likelihood of success on merits because the role of
government in protecting natural resources, and the lives of the people (American
interests) is well established, the threat is nearly universally accepted by appropriate and
near appropriate scientific bodies. Similar to a satellite detection of foriegn troop ships
setting sail for America, the onus should be on Congress, and the President to
demonstrate why with such a dire threat to American prosperity, they would risk inaction.

(2) Plaintiff has no adequate remedy at law because no money damages are involved;
though money for corrective actions are sought if appropriate bodies cannot be compelled
to acknowledge and deal with a threat well established.

(3) Irreparable harm will occur unless immediate injunctive relief is granted; all
emissions at present time must be considered irreversible. We cannot know the tipping
point for runaway change occurs- much like radiation sickness, by the time the symptoms
make you sick, you are likely already dead but still walking. Currently the trend is clear,
that warming is happening is clear.

(4) The relief will serve the public interest; long term societal stability is obviously in the
public interest. In addition- the rapid deployment of energy resources, upgrade and the
necessary retrofits to every single American structure, would act to bring millions of non-
outsourceable jobs to every town, city, state in the United States, and primarily the sorts
of hands on work that is currently the cause of low workforce participation rate.
WHEREFORE, Plaintiff respectfully request this Court to enter a writ of mandamus or
order to show cause for failure to address these issues in a public forum, and failing the
ability of the government to come to a decision/ plan to address this at an appropriate
scale we ask to help develop 250 billion in programs to be directed towards appropriate
actions. The US has been proactive with much less official consensus threats, than 95%
of the appropriate bodies concurring, and directed $100 billion per year, and over a
Trillion to the Iraq War and subsequent Occupation. Were China or Russia to be sending
troop ships towards the United States, and Congress or the President refused to address
them, I would expect there to be a demonstration of the reasons for ignoring the safety of
the public announced.

Contingent upon the Defendants willingness to develop and implement a plan that has a
chance of addressing these pressing issues, we seek 250 billion dollars in budget (5
billion per state, mitigated somewhat by population size) to begin the process of
developing the projects and plans capable of ramping to a level that could address the
threat, and make the US a leader (currently lagging China, Germany, Sweden and France
in renewables development and energy usage.) Plantiff will confer with other appropriate
bodies as to other appropriate items for relief than sought in this and the original petition
(enclosed)

Plantiff also seeks to hold in all current government staff in place to deal with climate
change- as well as any data to be held in perpetuity the incoming administration has
demonstrated hostility to Climate Change science, but not cause or credible disagreement
with such science.

Plantiff also seeks a hold on the incoming cabinent members as ineligible, for domestic
entanglements via emoluments clause

Plaintiff further seeks all such other relief as the Court deems just and appropriate.

Respectfully submitted this 30th day of December 2016 by:

Darrell Prince