Here's the brief laying out the Attorney General's arguments and the motion for temporary relief pending a final decision, asking the court to "temporarily and preliminarily enjoin[ Mr. Blagojevich] from acting as Governor." Note that Abner Mikva — a former Congressman, D.C. Circuit Judge, and Clinton White House Counsel, as well as an advisor of President-Elect Obama's — is on the brief.

Mikva was also a monitor in the 2004 Ukrainian elections, which reminds me of a joke I had heard in the 1990s.

Thanks to Keith Blackwell for the pointer.

UPDATE: Here's the heart of the AG's argument about why Gov. Blagojevich should be removed for "disability" (the legal test) (PDF p. 15):

The pervasive nature, volume, and severity of the illegal acts charged in the complaint indicate that Mr. Blagojevich is unable to distinguish between his financial interests and his official duties and between illegal acts and legal conduct, rendering him incapable of legitimately exercising his authority as Governor. The nature and volume of those acts clearly evidence a disability that has rendered Mr. Blagojevich unable to serve. As a result of the federal complaint relating to his official acts, Mr. Blagojevich's future official acts -- many of which are the subject of the federal complaint -- will be subject to challenge as illegal or improperly motivated. Because the integrity of Mr. Blagojevich's future official acts will be in question, his ability to provide effective leadership has been eliminated and the state government is paralyzed.

Given the serious criminal charges that he faces, it is also very likely that Mr. Blagojevich's future official actions will not be calculated to advance the best interests of the People, but rather will necessarily be designed to improve his public standing and position with regard to the pending criminal charges. Furthermore, Mr. Blagojevich clearly will not be able to devote his attention to his official duties because of the pending charges and likely criminal trial.

Further, Mr. Blagojevich's ability to borrow money in his official capacity is compromised. The State has postponed a $1.4 billion short-term debt offering because of the uncertainty over whether the State can provide the necessary accompanying certification that no threatened or pending controversy or litigation challenge Mr. Blagojevich's title to office. The State is also at risk of having its bond rating lowered due to concerns over the pending criminal charges.

Here's more on the bond rating item.