IN THE COURT OF COMMON PLEAS FRANKLIN COUNTY, OHIO State ex rel. ProgressOhio.org : 172 E. State St., Ste. 203 : 1 1CVHOS -10647 Columbus, OH 43215, : CASENO. and : James W. Spillman : JUDGE 646 Lexington Ave. : Marion, Ohio 43302, : and 2 Ivan Stithem + Case Designation “H” 303 Executive Drive, Apt. O : Marion, Ohio 43302, and Bobbie L. Peters + Complaint With Constitutional Issues 14999 Wheeler Road + For Declaratory Judgment And Lagrange, Ohio 44050, : Injunctive and Mandamus Relief and : Michelle L. Ward Mowery 4623 Tacoma Ave. Lorain, Ohio 44055, and Hubert Morgan 5500 Ingleside Ave. Vermillion, Ohio 44089, and Tina K. Gift 131 South Wild Cherry Lane Congress, Ohio 44287, and Amic A. Puster 1040 Sunshine Court Grafton, Ohio 44044, Plaintiffs-Relators,State of Ohio clo Mike DeWine Ohio Attorney General 30 East Broad St. 14" Floor Columbus, Ohio 43215, and John R. Kasich in his Official Capacity ‘As Governor, State of Ohio 77 South High Street Columbus, Ohio 43215, and Mike DeWine in his Official Capacity As Ohio Attomey General 30 East Broad St. 14" Floor Columbus, Ohio 43215, and Ohio Department of Rehabilitation and Correction c/o its Director Gary C. Mohr 770 West Broad St. Columbus, OH 43222, and Gary C. Mohr, Director Ohio Department of Rehabilitation and Correction 770 West Broad St. Columbus, OH 43222, and Ohio Department of Admin. Services clo its Director Robert Blair 30 East Broad St., Ste 4040 Columbus, OH 43215, and Robert Blair, Director Ohio Department of Admin. Services 30 East Broad St., Ste 4040 ‘Columbus, OH 43215, Defendants-Respondents.Nature of the Action 1. This action is brought by Plaintifis-Relators seeking Declaratory Judgment, Injunctive Relief and a Writ of Mandamus because Am. Sub. H.B. No. 153 of the 129" General Assembly purports to authorize the sale of state-owned prisons to private contractors and the separate authorizations in Am. Sub. H.B. No. 153 are unconstitutional and Am, Sub. H. B. No. 153 is itself unconstitutional, 2. Plaintiffs seek: a declaration of the rights of all parties under R.C. 9.06 and R.C. 753.10 as enacted in Am, Sub, H.B. No. 153 of the 129 General Assembly and under R.C. 4117.01(C) including a declaration that all employees hired by, or who work for, a contractor or grantee pursuant {0 a contract or deed authorized by those sections are, or remain, public employees after execution of the contract or sale and conveyance of the prisons (herein “facilities”), Plaintiffs also seek a declaration that various sections of R.C. 9.06, R.C. 753.10 enacted or amended in ‘Am, Sub. H.B. No. 153 of the 129" General Assembly (the Appropriations Bill) be found and declared unconstitutional on its face and as applied and unenforceable pursuant to: the “One Subject Rule” of Section 15 (D), Article IL, of the Ohio Constitution, the “Prohibition Against Joining Property Rights” in Section 4, Article VIII of the Ohio Constitution and Article II, Sections ! and le of the Ohio Constitution (which allows for a referendum on certain laws). 3. Plaintiffs seek an injunction restraining and enjoining the state of Ohio and all Defendants from implementing, administering, enforcing or spending any sums pursuant to the provisions in Am, Sub. H. B. No. 153 as enacted by the 129" General Assembly; and an injunction restraining and enjoining R.C. 9.06 and R.C.