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UNITED STATES DISTRICT COURTSOUTHERN DISTRICT OF OHIOWESTERN DIVISIONTHOMAS E. BRINKMAN, JR.,andCOALITION OPPOSED TOADDITIONAL SPENDING & TAXES(a/k/a COAST),andMARK W. MILLER,Plaintiffs,v.ARMOND D. BUDISH, Speaker of theOhio House of Representatives andChairman of the Joint Legislative EthicsCommittee of the Ohio GeneralAssembly,andBILL HARRIS, President of the OhioState Senate and Vice-Chairman of theJoint Legislative Ethics Committee of the Ohio General Assembly,andWILLIAM BATCHELDER, Member of the Joint Legislative Ethics Committeeof the Ohio General Assembly,andCAPRI CAFARO, Member of the JointLegislative Ethics Committee of the OhioGeneral Assembly,:::::::::::::::::::::::::::::::::::::::::Case No. 1:09-CV-00326Judge _______________________Magistrate Judge ______________VERIFIED COMPLAINT FORTEMPORARY RESTRAINING ORDER,PRELIMINARY AND PERMANENTINJUNCTIONS ANDDECLARATORY JUDGMENT
Case 1:09-cv-00326-SJD Document 1 Filed 05/11/2009 Page 1 of 23
 
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andLOUIS BLESSING, Member of theJoint Legislative Ethics Committee of the Ohio General Assembly,andJOHN CAREY, Member of the JointLegislative Ethics Committee of the OhioGeneral Assembly,andJENNIFER GARRISON, Member of theJoint Legislative Ethics Committee of the Ohio General Assembly,andMATT HUFFMAN, Member of theJoint Legislative Ethics Committee of the Ohio General Assembly,andDALE MILLER, Member of the JointLegislative Ethics Committee of the OhioGeneral Assembly,andSUE MORANO, Member of the JointLegislative Ethics Committee of the OhioGeneral Assembly,andTOM NIEHAUS, Member of the JointLegislative Ethics Committee of the OhioGeneral Assembly,and::::::::::::::::::::::::::::::::::::::::::::::
Case 1:09-cv-00326-SJD Document 1 Filed 05/11/2009 Page 2 of 23
 
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MATTHEW SZOLLOSI, Member of the Joint Legislative Ethics Committeeof the Ohio General Assembly,andTONY W. BLEDSOE, ExecutiveDirector and Legislative InspectorGeneral of the Joint Legislative EthicsCommittee of the Ohio GeneralAssembly,andJOINT LEGISLATIVE ETHICSCOMMITTEE OF THE OHIOGENERAL ASSEMBLY,andJOSEPH T. DETERS,Hamilton County Prosecuting Attorney,andRON O’BRIEN,Franklin County Prosecuting Attorney,Defendants.::::::::::::::::::::::::::::
Now come Plaintiffs, THOMAS E. BRINKMAN, JR., COALITION OPPOSED TOADDITIONAL SPENDING & TAXES (“COAST”), and MARK W. MILLER and for theirComplaint, allege as follows:
NATURE OF ACTION
1.
 
This is an action to vindicate core First Amendment rights of free speech, freedomof association and the petitioning of government for redress of grievances, all of which are beinginfringed by overly broad and burdensome provisions of the Ohio Ethics Law, Chapter 102 of 
Case 1:09-cv-00326-SJD Document 1 Filed 05/11/2009 Page 3 of 23
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