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JENNIFER BRUNNER, OHIO SECRETARY of STATE, Case No. 2010-0415 Case No. 2010-0421

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JENNIFER BRUNNER, OHIO SECRETARY of STATE, Case No. 2010-0415 Case No. 2010-0421 IN THE SUPREME COURT OF OHIO_ STATE ex rei. LE1'OHIOVOTE.ORG, et al., Relators, vs. Original Action in Prohibition JENNIFER BRUNNER, OHIO SECRETARY OF STATE, Respondent. STATE ex. r•el. NEW MODELS, et al., Relators, Case No. 2010-0415 vs. Original Action in Prohibition JENNIFER BRUNNER, OHIO SECRETARY OF STATE, Respondent. STATE ex. r•el. NORMAN B. CUMMINGS, et al., Case No. 2010-0421 Relator, vs. Original Action in Prohibition JENNIFER BRUNNER, OHIO SECRETARY OF STATE, Respondent. MOTION OF RELATOR NEW MODELS FOR PROTECTIVE ORDER AND FOR SANCTIONS David R. Langdon (0067046) Richard Cordray (0038034) Counsel of Record Ohio Attorney General Thomas W. Kidd, Jr. (0066359) Richard N. Coglianese (0066830) Bradley M. Peppo (0083847) Counsel of Record LANGDON LAW LLC Pearl M. Chin (0078810) 11175 Reading Rd., Ste. 104 Erick D. Gale (0075723) Cincicmati, Ohio 45241 Assistant Attorneys General (513) 577-7380 Constitutional Offices Section (513) 577-7383 fax 30 East Broad Street, 16'h Floor dlangdonna lanadonlaw.com Columbus, Ohio 43215 tkiddLi0angdonl aw.com (614) 466-2872 b e o lanudonlaw.com (614) 728-7592 fax richard.co ul ianeseCa)ohioattorneygeneraL Qov Attorneys for Relators LetOhioVote. org, pearl.chin a ohioattorneygeneral.gov Thomas E. Brinkman, Jr., Gene Pierce, erick gale(I-^)ohioattornevgeneral.gov and Carlo LoParo Attorneys for Respondent Ohio Secretary of State Jennifer Brunner John H. Burtch (0025815) Brian J. Laliberte (0071125) Counsel of Record Counsel of Record Rodger L. Eckelberry (0071207) David F. Axelrod (0024023) Robert J. Tucker (0082205) Axelrod, LLC Baker & Hostetler, LLP 250 Civic Center Drive, Suite 500 65 East State Street, Suite 2100 Columbus, Ohio 43215 Columbus, Ohio 43215 (614) 284-7171 (614) 228-1541 (614) 448-4554 (614) 462-2616 fax brianlaliberte a7me.com j bu rtch^a)hakerlaw. com reekelberry^a bakerraw.coni Atiorneys for Relator Norman B. Cummings rtuckcr(u^bakcrlaw.com Attorneys for Relators New Models and Timotlsy C5•auford Relator New Models ("New Models") respectfully moves the Court for an order under Ohio R. Civ. P. 26(C)(1) preventing Respondent Ohio Secretary of State Jennifer Bruimer ("Secretary Brunner") from obtaining the discoveiy she seeks in the Notice of Deposition Duces Tecum Pursuant to Ohio R. Civ. P. 30(B) sent to New Models. This Court has already granted an alternative writ in this action prohibiting Secretary Biunner from enforcing subpoenas issued to Relators New Models and Timothy Crawford and from taking their depositions in seeking to investigate whether LetOhioVote.org or New Models have violated various provisions of the Ohio campaign finance statutes until it determines whether Secretary Brunner has the authority to issues such subpoenas. The Notice issued by Secretary Brunner is a back door attempt to obtain the same or similar information through Civ.R. 30(B). Moreover, the information sought in the Notice is entirely irrelevant to the purely legal issue before this Court of whether Secretary Brunner lias the authority to issue the subpoenas. Under S.Ct. Prac. R. 14.5, Secretary Brunner's actions in issuing this Notice are frivolous and solely for the purpose of harassment and to further her own political agenda. For these reasons and those more fully discussed in the attached memorandum in support, Relator New Models respectfully requests the Court enter a protective order precluding Secretary Brunner from taking the deposition of New Models on March 25, 2010, or seeking any of the discovery in the Notice including any discovery related to whether LetOhioVote.org or New Models has violated the Ohio campaign Gnance statutes. Moreover, under S.Ct. Prac. R. 14.5, New Models seeks its attorneys' fees and expenses in moving for this Order. -1- Respectfully submitted, H. Burtch (0025815) Counsel of Record Rodger L. Eckelberry (0071207) Robert J. Tucker (0082205) Baker & Hostetler, LLP 65 East State Street, Suite 2100 Columbus, Ohio 43215 (614) 228-1541 (614) 462-2616 fax iburtch bbakerlaw.com reckelberryL bakerlaw.com rtucker@baker]aw.com Attorneys for Relators New Models and Timot7ay Crawford MEMORANDUM IN SUPPORT OF MOTION OF RELATOR NEW MODELS FOR PROTECTIVE ORDER AND FOR SANCTIONS 1. INTRODUCTION Ohio Secretary of State Jennifer Brunner ("Secretary Bntnner") seeks to do indirectly that which she cannot do directly. 'this Court has already granted an alternative writ staying the enforcement of subpoenas isstied by Secretary Brunner to investigate alleged violations of Ohio campaign finance statutes until this Court decides the issue of whether Secretary Brunner has the authority to issue such subpoenas. Despite the existence of the alternative writ, Secretary Brunner has now issued a Notice of Deposition Duces Tecum under Civ.R. 30(B)(5) seeking discovery of the same or similar information as the subpoenas, and again attempting to force New Models to appear for a deposition and produce documents related to alleged violations of Ohio campaign finance statutes. Secretary Brunner's actions in directly violating and utterly disregarding this Court's Order can only be seen as an attempt to harass New Models and further her own political agenda. New Models seeks a protective order preventing Secretary Brunner from taking its deposition and seeking the discovery in the Notice, and further, requests that New Models be awarded its reasonable attorneys' fees and expenses in moving for this Order. H. FACTUAL BACKGROUND On or about February 18, 2010, Secretary Brunner's office served two subpoenas on Relators New Models and Timothy Crawford seeking to require them to appear in Ohio on March 5, 2010 to provide testimony and produce documents. The ptirpose of the subpoenas was to investigate wtiether LetOhioVote.org or New Models have violated any of the provisions of the Ohio campaign finance statutes. (Compl. at ¶ 7). On March 5, 2010, Relators New Models and '1'imothy Crawford filed a Complaint for Writ of Prolzibition, Memorandum in Support, and Motion for Alternative Writ seeking a writ of prohibition from the Ohio Supreme coLttt preventing Secretary Brunner from issuing and seeking enforeement of the subpoenas. The sole basis for the Complaint is that Secretary Bmnner does not have the authority to issues these subpoenas under Ohio law. In their Complaint, Relators New Models and Timothy Crawford sought the following relief, among others,: Issue an Alternative Writ of Prohibition staying enforcement of the invalid subpoenas and staying the depositions and document production scheduled for March 5, 2010 until this Court renders a final decision on Relators' Complaint, and then issue a permanent Writ of Prohibition directing Respondent Secretary of State Jennifer Brunner to cease and desist from attempting to enforce the invalid subpoenas, from threatening criminal prosecution for noncompliance with the subpoenas, or from attempting to compel Relators to appear to testify at a deposition or to produce documents. (emphasis added). (Compl, at Request for Relief § C). This Court granted the altemative writ on March 5, 2010 stating that "the issuance of this altemative writ stays the proceedings that relator seeks to prohibit until there is a final determination by the Court." (3/5/2010 Order, copy attached as Exhibit A). On March 22, 2010, Secretary Brunner, through counsel, served a Notice of Deposition Duces Tecum Pursuant to Ohio R. Civ. P. 30(B) ("Notice") on New Models. A true and accurate copy of the Notice is attached as Exhibit B. The Notice states that Secretary Brunner will take the deposition of New Models on Thursday, March 25, 2010, beginning at 1:00 p.m. at the Office of the Ohio Attorney General. (Id.). It requires New Models to produce for deposition a person who can testify as to "(1) New Models' organization status; and (2) New Models' contributions to LetOhioVote.org, including any understanding or agreement between New Modcls and LetOhioVote.org regarding providing funds to LetOhioVote.org." (Id.). -2- The Notice further requires under Rule 30(B)(4) and Rule 34 that the deponent bring and produee the following: I, Any correspondence or other document rcgarding LetOhioVote.org, including any docunient requesting donations to LetOhioVote.org or LetOhioVote.org's referendum petition efforts; 2. All New Models' organizational documents and any amendments thereto, including but not limited to, articles of incorporation and bylaws; and 3. A copy of each "Return of Organization Exempt from Income Tax" (Form 990) filcd by New Models with the tJnited States Department of the Treasury, Internal Revenue Service. (Id.). On March 24, 2010, counsel for Relators New Models and Timothy Crawford sent a letter to counsel for Secretary Brunner explaining that the alternative writ granted by this Court precludes them from taking New Models' deposition and seeking the information requested in the Notice, and that such information is irrelevant to the sole legal issue in this matter of whether the Secretary had the power to issue the subpoenas at issue, and requesting that the Notice be withdrawn, (3/24/10 Itr from J. Burtch to R. Coglianese, attached as Exhibit C). Counsel for Secretary Brunner responded stating that they "would not agree under any circumstance to withdraw the notice of deposition." (3/24/10 email from R. Coglianese, attached as Exhibit D). III. LAW AND ANALYSIS S.Ct. Prac. R. 10.6 states that "[u]nless the Supreme Court orders otherwise, issuance of an alternative writ in a prohibition case stays proceedings in the action sought to be prohibited until final determination of the Supreme Court." (citing S'tate ex. rel. Hughes v. Brown (1972), 31 Ohio St.2d 41, 43, 285 N.E.2d 376, 377), 'fhis Court has already granted an alternative writ staying Secretary Brunner's enforeement of subpoenas issued to, and depositions of, several entities and individuals, ineluding New Models, to investigate alleged violations of campaign -3- financc laws until this Court decides the issue of whether Secretary Bruimer has the authority to issue the subpoenas.
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