STATE OF MICHIGAN {IN THEE CIRCUTT COURT FOR THE COUNTY OF WAYNE, CIVIL DIVISION CGERALDINE TRAGER, at, ete Soars : WA roster env orsouracart, Shp een, Det TAWFIRM OF BILE COLOVOS BILL COLOVOS (P3844) ‘Auomey for Pant 12142 Bi Toledo Road Southgate, Michigan $8195, (734) 2422000 ‘OPEN MEETINGS ACT AND INJUNCTIVE RELIEF “PURSUANT TO MCI.15261, ETAL. NOW COMES your Plinif, GERALDINE TRAGER, by her atoms, BILL COLOVOS, and for ber sompsia! aguinst Defendant, Cly of Southene, represents the following: : JURISDICTIONAL ALLEGATIONS 1. Plain, GERALDINE TRAGER, i siden! of he City of Soutgte, County of Wayns, Sut of Michignn 2 Defendant, City of Southgate, is a Municipal Corporation and a "Public body”subject tthe provisions ofthe "Open Mein Act MCL 15.261, tl. 3, The wong sto complsined of by Plt were commited by Defendants overnng by ake County of Wayne, Sit of Micon. 4. The swongfil ations of Defendant were commit atx Southgate City Count Meting on October 6,200 5. This Court hs jrsticion review Defendant's ation hat vioited the Open Meetings Act. YACIUALBACKGROUND 6 The City of Souga, 2h Disvet Cout, and Judge James Kanes sued in Federal Cour by Loi Shek, the fomer Cou Administrator, end Mary Jb, 8 omer Coust employee, Each alleged certain inpopeeies tht Judge Kandrevas commited 7. White the Iwsut was pending, the parton are ofa the mater with etd Jag Richard Kautnan. 8. tthe conelsion ofthe finn the pts reached a eet, 9. The stement incade cxnuin amount of mons tobe pido each of he aries, Upon payment ofthe monies, each Plaintiff would damiss ter respective Innit gin the iy of Southgate, 28h Dist Cour and ade James Kaneva 10, The svongfi acon tha Plant complains of tok place atte Octber 6, 2010, City of Southgate Coun! Meeting 1. At sid City Come Mesing, he Coun vik the Open Mosings Act by iacesing tnd setting te above referenced vl Inwuits without giving te publi proper starry nti, ‘VIOLATIONS OF THE OPEN MEETINGS ACT 12, Phin hereby incorpo cach nd ever legion setae paragraphs 1asf ily ef bein 13, The Defendant, City of Southgnte, volt the Open Mectngs Act in the {oloing paral: ‘led to prpety pos the specie sbjet mater onthe agenda garding ‘roped clued meeting (See Exhibit °A") Failed to tke & 23 rl all vote of come! members call the closed session. MCL 1827 Failed to state the specie purpose or purposes ofthe closed session MCL 15257 Fail to eat into he minutes ofthe meeting at which the woe is taken the rola vote and he purpose fo calling the cloned Sesion, ICL 1527 Faldo site in the open meeting the reson why los meeting Was ‘ecesryand Bled to te wy an open meting woud ave ‘lien financial eet om the lieing or stement potion of the public dy. MCL 18.268, Filed w pope a separate set of minutes during the closed meeting MCL18267 Filed to have a sepa st of mints othe closed meting approved by the council MCL 15.267 Fale to properly nd to the agenda ofthe open meeting the subject ‘mater f the png gation against te Cir of Southgate, 24 Dist (Cou sa Jue James Kandrevss. (Se Exhibit") Pale to set forth the specific ems of the setement, incon the fous! of monies blag pid fo cach of the individuals sing the City of ‘Southgate (See Exit 5") aie opropesyanthorize an individual on behalf ofthe City of ‘Souths wo ign any setemeatdociments based on monis being pid ‘by oren bal ofthe Cyto entioe the companing individuals wo diss ‘lr rexpetve wou. (See Exhibit "B") 4. As ares ofthe above wrongfil actions ofthe Defendant, the City of Southante lata the Open Mostings Ac 15. In ilating the Open Mecings Act, the City of Soutngte Governing Body filed to maintain an open and transparent Goverment.16, Plaintiff brings this cause of action to invalidate the actions of the Defendant in attempting to hold an illegal closed meeting and then attempt to setle civil lawsuits against the City of Southgate, all in violation of the Open Meetings Act. 17, Plaintiff further requests that this Court compel the City of Southgate to act in compliance with the Open Meetings Act and enjoin any further noncompliance. MCL 15.271 WHEREFORE, Plaintiff GERALDING TRAGER, respectfully requests that this Court center Judgment against Defendant, City of Southgate and find the Defendant violated the Open Meetings Act, MCL 15.261, et.al, and grant relief as requested within Plaintiff's Complaint Respectfully Submitted, LAW FIRM OF BILL COLOVOS fa-/7- 20/0 B Dated BILL COLOVOS P38434 Attomey for Paint 12142 Dix-Toledo Road Southgate, Michigan 48195 (734) 282-2900