This motion requests a temporary restraining order against the President of the Indianapolis-Marion County City-County Council. It summarizes that without the assistance of the Clerk and independent counsel, the Council cannot conduct business and perform its functions, which would cause irreparable harm. It also notes that preventing the Clerk from performing legal duties could jeopardize the validity of Council actions. The motion asks the court to restrain the Council President from preventing the Clerk and counsel from accessing their offices and equipment to perform their legal functions until the underlying claims can be resolved.

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STATE OF INDIANA ) IN THE MARION SUPERIOR COURT
) SS:
COUNTY OF MARION ) CAUSE NO.
ZACHARY ADAMSON, JARED EVANS, )
MAGGIE LEWIS, FRANK MASCARI, )
JEFF MILLER, WILLIAM OLIVER, )
VOP OSILI, CHRISTINE SCALES, )
each members of the Indianapolis-Marion County )
City-County Council; and )
NATRINA S. DEBOW, Clerk of the Council, )
)
Plaintiffs )
)
v. )
)
STEPHEN CLAY, President of the )
Indianapolis-Marion County City-County Council, )
)
Defendant. )
MOTION FOR TEMPORARY RESTRAINING ORDER
Come now Plaintiffs, by counsel, and hereby request that a
temporary restraining order with notice be entered. In support of this
motion, Plaintiffs state as follows:
1. Plaintiffs adopt and incorporate the allegations set forth in
their Verified Complaint for Declaratory Judgment, Mandate and
Injunctive Relief filed contemporaneously.
2. The Plaintiffs herein who are members of the Council will be
irreparably harmed in their ability to perform their functions as public
officials if the Court fails to grant emergency injunctive relief. As
Filed: 2/8/2018 9:04 AM
Myla A. Eldridge
Clerk
Marion County, Indiana
49D06-1802-PL-005209
Marion Superior Court, Civil Division 6

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explained in their Verified Complaint (at paragraphs 22-24), without the
assistance of the duly-appointed Clerk and independent general
counsel/parliamentarian, the Council cannot conduct the public’s
business, thus doing irreparable harm to the public interest and
requiring the intervention of this Court to restore the status quo ante
pending a final ruling on the merits of Plaintiffs’ claims.
3. Moreover, by impeding and obstructing the legally-appointed
Clerk’s ability to perform the legal responsibilities set forth by Indiana
Law and the Indianapolis-Marion County Municipal Code (“Code”),
Defendant Clay’s actions are jeopardizing the legal validity of any such
functions were those functions to be conducted by a person other than
Clerk DeBow, if they are performed at all.
4. Notice of the filing of Plaintiffs’ Verified Complaint and
Motion for Temporary Restraining Order was provided to Defendant Clay
on this 8th day of February, 2018, by leaving a copy at the Council’s
office located on the second floor of the City-County Building.
5. Plaintiffs request that no bond be required. However, should
the Court determine that some bond be required, they respectfully
request, given that Defendant Clay will suffer no damages should a

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temporary restraining order be entered, that Plaintiffs be required to post
only a minimum bond of $500.00 or less.1
WHEREFORE, Plaintiffs respectfully request that the Court grant
Plaintiffs’ request for a temporary restraining order, and (1) temporarily
restrain and subsequently preliminarily enjoin Defendant Clay and all
those acting in concert with him from taking any actions to prevent Clerk
DeBow or the Council’s general counsel Fred Biesecker from performing
their legal duties such as by denying each unrestricted access to their
respective offices on the Second Floor of the City-County Building, and to
the computer and other office equipment each needs to perform their
legal functions; and (2) grant Plaintiffs DeBow and Councilors any other
or further relief the Court deems necessary to restore the status quo ante
that existed prior to Defendant Clay’s illegal and ultra vires terminations
of Clerk DeBow and general counsel Biesecker on January 31, 2018.
1
Other than the Council’s general counsel, only the Clerk can sign
contracts for legal representation of the Council. See, I.C. § 36-3-4-8.5.

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Respectfully submitted,
/s/Karen Celestino-Horseman /s/ William R. Groth
Karen Celestino-Horseman William R. Groth
Atty. #15762-49 Atty. #7325-49
Of Counsel, Austin & Jones, P.C. Fillenwarth Dennerline Groth &
22 E. Washington St., Ste. 620 & Towe, LLP
Indianapolis, IN 46204 429 E. Vermont St., Ste. 200
Tel: (317) 632-5633 Indianapolis, IN 46202
Fax: (317) 630-1040 Tel: (317) 353-9363
E-mail: karen@kchorseman.com Fax: (317) 351-7232
E-mail: wgroth@fdgtlaborlaw.com
/s/Octavia Florence Snulligan
Octavia Florence Snulligan
Atty. #23995-29
26 W. Washington St.
Indianapolis, IN 46204
Tel: (317) 210-2950
Fax:
E-mail:octavia@ofslaw.com
Counsel for all Plaintiffs