& IN THE SUPREME COURT OF OHIO Athens, OH 45701, Relator Supreme Court No. 2012-1920 COMPLAINT IN MANDAMUS vs. Ohio Attorney General 30 East Broad Street, 16th Floor Respondent MOTION FOR LEAVE TO FILE 2NDAMENDED COMPLAINT FOR A WRIT OF MANDAMUS Now comes Relator, and move for leave to file the 2"d Amended Complaint for a Writ of Mandamus, a copy of which is hereto attached. HLEUD,wm d;8 L9013 i ri,.tnk 01- g_;ou^^ ^^PRBM-L Wu^^ ^^ OHiO Respectfully Submitted, Cinser ohnson Athens, Oh 45701 2
IN THE SUPREME COURT OF OHIO Athens, OH 45701, Relator Supreme Court No. 2012-1920 COMPLAINT IN IMANDAMUS vs. Ohio Attorney General 30 East Broad Street, 16 th Floor Respondent 2nd AMENDED COMPLAINT FOR A WRIT OF MANDAMUS Athens, OH 45701 Pro Se Relator Assistant Attorney General Constitutional Office Section 30 E Broad Street, 16th Floor Cpunsel For Respondent 1
s 2ND AMENDED COMPLAINT FOR A WRIT OF MANDAMUS Relator, asks this Court to issue a writ of mandamus, which prohibits Respondent, by and through Assistant Attorney General, Brian Mooney, from issuing verbal or written threats directed to Relator, and prevents Respondent from engaging in behaviors that are intended to intimidate Relator. In support of this request, Relator states as follows: 1) Relator is a resident of Cuyahoga County, Ohio. 2) Respondent is the Ohio Attorney General, whose principal office is located in Franklin County, Ohio. 3) On or about September 11, 2012, Respondent, by and through Assistant Attorney General, Brian Mooney, warned Relator, through a voice mail message, not to act on behalf of the Chagrin Falls Park Community Center Corporation of Chagrin Falls Park, Ohio. 4) In a letter dated October 9, 2012, Respondent warned Relator, " You are hereby put on notice that if you continue to file any document relating to Chagrin Falls Park Community Center Corporation with the Ohio Secretary of States Office that the Attorney Generals Office will take appropriate legal actions, including but not limited to filing a lawsuit against you to enjoin you from furthering your criminal activity, " Respondent further said Relator was attempting to "steal funds from a legitimate charitable entity. These actions must stop." 5) Relator advises the herein Court, that she has never met Respondent, and has never spoken to Respondent concerning The Chagrin Falls Park Community Center Corporation or any other topic. Respondent then, is in no position to brand Relator a 'criminal' or otherwise bar Relator from acting in her official capacity. 6) Relator advises the Court that there is one, active Ohio corporation known as The Chagrin Falls Park Community Center Corporation, and Relator, as Principal, may act on its behalf. If any other entity or person is acting on behalf of The Chagrin Falls Park Community Center Corporation, it is that entity or person that is committing fraud, and or criminal acts, not Relator. Further, Respondent lacks authority to tell Relator what she can or can not do on behalf of a private corporation. 7) Because Respondent threatened, libeled and attempted to intimidate Relator through written and voice mail communications, by and through Brian Mooney, Assistant Attorney General for Ohio, Relator asks this Court to issue a writ of mandamus preventing Respondent from engaging in behaviors which are unauthorized by law. 2
WHEREFORE Relator prays for a writ of mandamus compelling Respondent to discontinue verbal and written threats to Relator. In the alternative, Relator prays for an order directing Respondent to show cause why it should be permitted to act outside the scope of the law and its official duty. Respectfully Submitted, 0- Cinseree hnson Athens, Oh 45701 CERTIFICATE OF SERVICE I certify that a copy of the foregoing was served this 19" day of January, 2013, by regular US mail, upon the fnilrneiina rniincal nf rarnrrl ^rrc rv^v...-.b...,...^..-.....,...,.. 30 E Broad Street, 16`h Floor 30 E Broad Street Columbus, OH 43215 e^i Cins ee Johnson 3
IN THE SUPREME COURT OF OHIO Athens, Ohio 45701 Relator Supreme Court Case No 2012-1920 AFFIDAVIT IN SUPPORT OF SECOND AMENDED COMPLAINT FOR MANDAMUS vs Ohio Attorney General 30 E Broad Street Respondent AFFIDAVIT IN SUPPORT OF SECOND AMENDED COMPLAINT FOR MANDAMUS AIIIeTIs, 0(Ilo 457V1 Relator Pro Se Assistant Attorney General 7n r Q..-,.d c+.-.,._,+ 1 Gth [Il^^.r av ^ urvau alrccl,..cv IrrovI Counselfro Respondents
, AFFIDAVIT IN SUPPORT OF SECOND AMENDED COMPLAINT FOR MANDAMUS The undersigned Relator, after being duly sworn and cautioned states as follows: 1) I,, am the Relator in this matter. I am a resident of Cuyahoga county, Ohio. 2) Respondent is the Ohio Attorney General, whose principal office is located in franklin County, Ohio. 3) Respondent has issued verbal and written threats in its official capacity, by and through Assistant Attorney General Brian Mooney. 4) Respondents actions constitute an abuse of process, and violate Relators due process right to form, and, act on behalf of an Ohio corporation. 5) Relator seeks a Writ of Mandamus because there is no other remedy in law. FURTHER AFFIANT SAYETH NAUIGHT: A Cinseree J,^,hnson 61/ Sworn to and subscribed in my presence this r^ day of January, 2013 Notary Public, State of Ohio CIAVibIA DER Notary Pub4ic, S$gte of Ohio, Cuy. Cty. My oommissic n expsteu June 14, 2014 My commission expires on
N CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing was served by regular US mail on this 19th day of January 2013, upon the following counsel of record: Assistant Attorney General 30 E Broad Street, 16tf Floor ^ Cinseree J Pson