1:14-cv-00405 #38

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF INDIANA

INDIANAPOLIS DIVISION

MICHELLE BOWLING, et al.,

Plaintiffs,

v.

MICHAEL PENCE, in his official capacity
as Governor of the State of Indiana, et al.,

Defendants.
)
)
)
)
)
)
)
)
)
)

Case No. 1:14-cv-405-RLY-TAB

REPLY MEMORANDUM IN SUPPORT OF
DEFENDANTS MOTION FOR SUMMARY JUDGMENT

GREGORY F. ZOELLER
Attorney General of Indiana

THOMAS M. FISHER
Solicitor General

Office of the Attorney General
IGC South, Fifth Floor
302 W. Washington Street
Indianapolis, IN 46204
Tel: (317) 232-6255
Fax: (317) 232-7979
Tom.Fisher@atg.in.gov

Counsel for Defendants

Case 1:14-cv-00405-RLY-TAB Document 38 Filed 07/24/14 Page 1 of 17 PageID #: 470

i
TABLE OF CONTENTS

TABLE OF AUTHORITIES .......................................................................................................... ii
REPLY MEMORANDUM IN SUPPORT OF DEFENDANTS MOTION FOR
SUMMARY J UDGMENT .............................................................................................................1
ARGUMENT ...................................................................................................................................1
I. Although the Court Has Already Disposed of Plaintiffs Equal Protection and Due
Process Claims in Related Litigation, Other Claims Remain for Adjudication ..................1
II. Defendants Cross-Motion for Summary J udgment Was Timely Filed and the Court
Should Deny Plaintiffs Motion to Strike ............................................................................2
III. The Governor and the Attorney General Are Not Proper Defendants .................................3
IV. The Tax Injunction Act Bars Plaintiffs Claims Against the Commissioner .......................7
V. Indianas Traditional Marriage Definition Does Not Violate Plaintiffs Right of
Access to Courts ..................................................................................................................8
CONCLUSION ..............................................................................................................................12
CERTIFICATE OF SERVICE ......................................................................................................13


ii

TABLE OF AUTHORITIES
CASES
Ankenbrandt v. Richards,
504 U.S. 689 (1992) ...................................................................................................................9
Boddie v. Connecticut,
401 U.S. 371 (1971) ...........................................................................................................10, 11
Christopher v. Harbury,
536 U.S. 403 (2002) ...................................................................................................................9
Johnson v. Orr,
551 F.3d 564 (7th Cir. 2008) .....................................................................................................7
Lewis v. Casey,
518 U.S. 343 (1996) ...................................................................................................................9
Morrison v. Sadler,
821 N.E.2d 15 (Ind. Ct. App. 2005)...........................................................................................7
Okpalobi v. Foster,
244 F.3d 405 (5th Cir. 2001) .....................................................................................................5
Southern Pacific Transportation Company v. Brown,
651 F.2d 613 (9th Cir. 1980) .....................................................................................................5
Walker v. Gilligan,
487 F.2d 508 (6th Cir. 1973) .....................................................................................................8
STATUTES
Ind. Code 31-11-1 et seq. ..............................................................................................................6
Ind. Code 31-11-1-1 ............................................................................................................ passim
Ind. Code 31-11-11-1 ....................................................................................................................6
Ind. Code 31-11-11-3 ....................................................................................................................6
Ind. Code 31-11-11-7 ....................................................................................................................6

iii

RULES
Fed. Rule Civ. P. 8(a)(2) ..................................................................................................................8
CONSTITUTIONAL PROVISIONS
Ind. Const. Article 5, 16 ................................................................................................................4
OTHER AUTHORITIES
Office of the Governor, Statement on Federal Court Ruling on Indianas Marriage
Statute, available at http://www.in.gov/activecalendar/EventList.aspx?view=
EventDetails&eventidn=176231&information_id=202906&type=&syndicate=
syndicate (J une 25, 2014) ..........................................................................................................4
Tim Evans, Indiana Couple Files Federal Lawsuit to Recognize Same-Sex Marriage,
Indianapolis Star, Mar. 7. 2014 ..................................................................................................6


1

REPLY MEMORANDUM IN SUPPORT OF
DEFENDANTS MOTION FOR SUMMARY JUDGMENT

Defendants Michael Pence, Gregory Zoeller, Michael Alley, and Anita Samuel
respectfully submit this reply memorandum in support of their Motion for Summary J udgment.
ARGUMENT
I. Although the Court Has Already Disposed of Plaintiffs Equal Protection and Due
Process Claims in Related Litigation, Other Claims Remain for Adjudication

Plaintiffs claim that Indianas traditional marriage definition, Indiana Code Section 31-
11-1-1, violates the Equal Protection and Due Process Clauses of the Fourteenth Amendment is
functionally identical to the claims made by the plaintiffs in the related cases Baskin v. Bogan,
No. 1:14-cv-355-RLY-TAB, Fujii v. Commissioner, No. 1:14-cv-404-RLY-TAB, and Lee v.
Abbott, No. 1:14-cv-406-RLY-MJ D. Contrast Bowling Doc. No. 1 at 18-20 with Baskin Doc.
No. 30 at 26-32, Fujii Doc. No. 22 at 20-23, and Lee Doc. No. 52 at 7-15.
1
Because the Court
ruled in those cases that Section 31-11-1-1 violates both the Equal Protection and Due Process
Clauses, there is little point in Defendants providing additional argument on these claims.
Defendants do, however, reserve all rights and preserve all defenses relating to their Equal
Protection and Due Process arguments. See Doc. No. 26 at 12-42. Defendants have, of course,
appealed the judgments in Baskin, Fujii, and Lee, and will do so here as well.
While summary judgment in the Plaintiffs favor may be a foregone conclusion with
respect to their Equal Protection and Due Process claims, several other issues remain to be
adjudicated in this case. Plaintiffs have asserted that Section 31-11-1-1 violates the Full Faith
and Credit Clause, the Establishment Clause, the right of access to courts, and the right to travel.
See Doc. No. 20 at 19-23, 30-35. Of these claims, Plaintiffs summary judgment response
memorandum addresses only their access-to-courts claim. Doc. No. 30 at 40-43. Thus, with

1
Hereafter, all citations to the record reference the Bowling docket unless otherwise noted.

2

respect to the Full Faith and Credit, Establishment Clause, and right to travel claims, Defendants
stand on the arguments made in their opening summary judgment memorandum. See Doc. No.
26 at 8-12, 49-52.
II. Defendants Cross-Motion for Summary Judgment Was Timely Filed and the Court
Should Deny Plaintiffs Motion to Strike

Plaintiffs ask this Court to strike the Defendants Cross-Motion for Summary J udgment
because [t]he parties agreed that all dispositive motions were to be filed no later than April 21,
2014 . . . [and] Defendants Motion for Summary J udgment was not filed until May 29, 2014[.]
Doc. No. 30 at 1. The Court must decline this request as Plaintiffs have plainly misconstrued the
April 21 dispositive-motion deadline and, regardless, suffer no prejudice from Defendants
Cross-Motion for Summary J udgment.
The Court established the April 21 deadline during a status conference with counsel from
all five same-sex marriage cases. See Doc. No. 17; Baskin Doc. No. 40; Fujii Doc. No. 28; Lee
Doc. No. 17; Love Doc. No. 20. During that status conference, various plaintiffs counsel had
informed the Court that they planned to file dispositive motions on their clients behalf.
Accordingly, the Court established that any such motions would be due by April 21. Id. Neither
counsel for Defendants nor, apparently, any of the other plaintiffs counsel, understood this
deadline to apply to any cross-motions for summary judgment Defendants might file in response
to the plaintiffs motions. Indeed, Defendants filed their cross-motions for summary judgment in
Baskin, Fujii, and Lee after April 21 with no objection from the plaintiffs in those cases. See
Baskin Doc. No. 55 (cross-motion filed April 22); Fujii Doc. No. 44 (cross-motion filed May 7);
Lee Doc. No. 41 (cross-motion filed May 15). The Court ruled on the parties cross-motions for
summary judgment in Baskin, Fujii, and Lee in a consolidated order issued on J une 25, 2014.
Baskin Doc. No. 89. That ruling included summary judgment for Defendants as to some parties,

3

id. at 31-32, and in no way indicated that the Court considered Defendants cross-motions to be
untimely.
What is more, allowing Defendants to file responsive cross-motions for summary
judgmentas opposed to simultaneous cross-motionspromotes greater efficiency and judicial
economy. When parties file simultaneous cross-motions, they essentially argue across one
another and must file a total of six briefs (three from each side) in order to make and respond to
all the relevant arguments. When the non-moving party is permitted to file a responsive cross-
motion, on the other hand, only four briefs are necessary. Greater efficiency across fewer briefs
is especially critical where, as here, there are a number of related cases pending before the same
court on the same issue.
Finally, Plaintiffs have not explained how they have been injured by Defendants cross-
motion or how this case should be resolved if the Court strikes Defendants cross-motion for
summary judgment. If the Court wishes to rule in Defendants favor on any of the remaining
claims, there is no mechanism to do so in the absence of a cross-motion for summary judgment.
Instead, presumably, those claims would proceed to trial. As Plaintiffs have expressed a strong
desire to move this case forward (see Doc. No. 33 at 3), and there is no dispute of material fact
(see Doc. No. 30 at 1-3), it is difficult to imagine that Plaintiffs want a trial. As a practical
matter, therefore, Defendants cross-motion for summary judgment is necessary to propel this
case toward resolution. Accordingly, the Court should adhere to the model it followed in Baskin,
Fujii, and Lee and refuse to strike the Defendants cross-motion for summary judgment.
III. The Governor and the Attorney General Are Not Proper Defendants
1. In Love, Fujii, and Lee, this Court explicitly held that the Governor is not a
proper party because the Plaintiffs injuries are not fairly traceable to him and cannot be

4

redressed by him. Baskin Doc. No. 89 at 10; Love Doc. No. 32 at 7. The Bowling Plaintiffs
claims with respect to the Governor are indistinguishable from the claims made by the Love,
Fujii, and Lee Plaintiffs. In all four cases, Plaintiffs argued that the Governor is a proper
defendant due to his general duty to take care that the laws are faithfully executed. Ind. Const.
art. 5, 16; see also Doc. No. 30 at 7; Love Doc. No. 26 at 2; Fujii Doc. No. 46 at 14; Lee Doc.
No. 46 at 29-30. The Court has explicitly rejected this rationale, holding in Love that Plaintiffs
have failed to establish that the Governor has the authority to enforce, or plays any other role
respecting, Indianas Defense of Marriage Act. Love Doc. No. 32 at 5-7; see also Baskin Doc.
No. 89 at 10 (reaffirming Loves holding).
Notwithstanding the Courts clear and firm ruling on this matter, Plaintiffs contend that a
press release issued by the Governors office after the Courts J une 25 ruling acknowledg[es]
his authority to enforce the statute[.] Doc. No. 30 at 10. In fact, the press release contains
nothing more than a blanket statement expressing support for the Attorney Generals appeal of
the J une 25 ruling and affirming that the State of Indiana will comply with the federal courts
order as this case moves through the appeals process. Office of the Governor, Statement on
Federal Court Ruling on Indianas Marriage Statute, available at http://www.in.gov/
activecalendar/EventList.aspx?view=EventDetails&eventidn=176231&information_id=202906
&type=&syndicate=syndicate (J une 25, 2014). The press release does not direct any state officer
or agency to do anything in relation to enforcing the statute.
Furthermore, no matter the degree of gubernatorial control over agency action, the
Governors general supervisory authority is not enough to justify suit against him. As the Court
explained in its order dismissing the Love lawsuit, [e]ven if the Governor did exercise some
measure of managerial authority over [those] . . . who may administer some aspect of marriage

5

law, that authority would be insufficient to justify a suit against the Governor . . . . Love Doc.
No. 32 at 5. This is so because (1) Plaintiffs complained-of injury is not fairly traceable to the
Governor because he lacks the authority to enforce the challenged statute against them, and (2)
because the Governor cannot enforce the challenged statute, he cannot redress Plaintiffs
injury. Id. Guidance from a governor to subordinate agencies does not constitute enforcement
of statutes that the agencies themselves are charged with enforcing. See Southern Pacific
Transportation Company v. Brown, 651 F.2d 613, 614 (9th Cir. 1980) (finding that an officials
duty to advise and direct those responsible for enforcement of a statute is insufficient to make
him a proper defendant); see also Okpalobi v. Foster, 244 F.3d 405, 427, 428 (5th Cir. 2001) (en
banc) (finding governor to be an improper defendant because the governor cannot be enjoined
to act in any way that is beyond his authority to act in the first place. . . . This is not to say that
the administrators of [the statute] themselves could not be enjoined to do a particular act that was
within their authoritybut these plaintiffs must sue those individuals authorized to exercise the
orders of the injunction.).
Finally, there is no merit to Plaintiffs suggestion that Governor Pences public
statements on traditional marriage make him a proper defendant to this action. No doctrine
exists under which an official can be sued on the basis of his public statements rather than his
official acts. Indeed, Plaintiffs cite no authority in support of their rather astonishing position.
Indianas traditional marriage definition is the result of a policy choice made by the legislature.
The Governors public statements in support of that choice in no way expose him to suit
regarding the laws constitutionality.
2. In Baskin, the Court held that the Attorney General is a proper defendant owing to
his broad authority to assist in the prosecution of any offense, particularly the criminal

6

provisions in place to prevent individuals from marrying in violation of [Section 31-11-1-1].
Baskin Doc. No. 89 at 9 (citing Ind. Code 31-11-11-7; 31-11-11-1; 31-11-11-3). The Bowling
Plaintiffs contend that the same rationale applies to their claims against the Attorney General.
Doc. No. 30 at 12. The statutes cited by the Court in Baskin, however, are criminal provisions
relating to licensure and solemnization of marriages, not recognition of marriages. See Ind.
Code 31-11-11-7 (A person who knowingly solemnizes a marriage . . . prohibited . . . by IC
31-11-1 commits a Class B misdemeanor.); Ind. Code 31-11-11-1 (criminalizing the provision
of false information to the clerk of the court when applying for a marriage license); Ind. Code
31-11-11-3 (same). As the Bowling Plaintiffs seek recognition of their existing marriagesnot
the licensure or solemnization of new marriagesthe Attorney General is not capable of
enforcing any of these statutes against them. In short, the Attorney General does not have a
sufficient connection and role in enforcing such statutes for purposes of Ex Parte Young.
Baskin Doc. No. 89 at 9-10.
Plaintiffs claim that the Attorney General has made public statements that he intends to
enforce Indianas Anti-Recognition statute, Doc. No. 30 at 12, but the statements to which
Plaintiffs refer have only to do with the Attorney Generals handling of this and the other related
constitutional challenges to Indianas traditional marriage definition. Specifically, the Attorney
General has stated that he will represent the state and defend [Section 31-11-1-1] now and on
any appeal and that [a]s state governments lawyer, he must defend the states authority to
define marriage at the state level within Indianas borders. Id. (citing Tim Evans, Indiana
Couple Files Federal Lawsuit to Recognize Same-Sex Marriage, Indianapolis Star, Mar. 7.
2014). In other words, the Attorney General has said that he will defend a state statute against a
constitutional challengeas is his duty under the lawnot that he will assist in the prosecution

7

of any criminal charges against these Plaintiffs. The analysis does not change when the Attorney
General intervenes in a case to defend the constitutionality of an Indiana law (see Doc. No. 30 at
12-13 (citing Morrison v. Sadler, 821 N.E.2d 15 (Ind. Ct. App. 2005)) or when he files an
amicus brief in a case that has some relation to or bearing on Indiana law (see id. at 13 (citing
Brief for the State of Indiana, et al. as Amici Curiae in Support of Reversal, Kitchen v. Herbert,
No. 13-4178 (10th Cir. Feb. 10. 2014)). Simply put, defending the constitutionality of a
statutewhether as a defendant, intervenor, or amicusis not the same as enforcing a statute.
Likewise, the Attorney Generals issuance of official opinions advising public officials
that Section 31-11-1-1 prohibits the recognition of same-sex marriages, Doc. No. 30 at 12, has
nothing to do with his broad authority to assist in the prosecution of marriage-related offenses.
Baskin Doc. No. 89 at 9. Again, the Plaintiffs point to no provisions of the Indiana Code
criminalizing the recognition of same-sex marriages. Thus, the Attorney Generals advice to
public officials regarding various forms of recognition of same-sex marriage is unrelated to any
enforcement powers he may have that would give plaintiffs standing to sue him where licensure
is concerned.
IV. The Tax Injunction Act Bars Plaintiffs Claims Against the Commissioner
Plaintiffs argue that the Tax Injunction Act does not bar their claims against the
Commissioner of the Indiana Department of Revenue because Plaintiffs are not challenging the
collection of State taxes or seeking a federal court order to avoid paying state taxes but, rather,
are challenging the DORs tax filing guidance which prevents them from filing joint tax
returns. Doc. No. 30 at 14. Allowing them to file jointly, they claim, would not impede the
collection of taxes or reduce the flow of tax revenue because Indiana has a flat 3.4% tax rate for
individual income. Id. at 15 (quoting Johnson v. Orr, 551 F.3d 564, 571 (7th Cir. 2008)).

8

What Plaintiffs appear to be saying is that they suffer no specific tax harm as a result of
their inability to file joint tax returns. If this is true, then they have stated a claim for which there
is no relief. They counter, however, that [a]s a result of DORs policy, [they] were required to
spend additional time and preparation fees to prepare and file two separate Indiana tax returns
with a filing status of single and to prepare three federal income tax returns. Doc. No. 30 at
14. This relatively minor burden is hardly a concrete harm sufficient to confer Article III
standing.
In all events, federal courts lack jurisdiction over plaintiffs tax claims where, as here, an
adequate state remedy exists. See Walker v. Gilligan, 487 F.2d 508, 510 (6th Cir. 1973) (per
curiam) ([F]ederal courts have repeatedly expressed the judicial policy that anticipatory federal
adjudication of state tax laws must be avoided where adequate state remedies exist.). Indeed,
federal courts have held that the Tax Injunction Act removes jurisdiction even where plaintiffs
claims do not directly challenge the amount of tax collected. See, e.g., id. (holding that the Act
barred plaintiffs claims challenging the constitutionality of an Ohio law requiring married
couples filing joint federal income tax returns also to file joint state income tax returns).
Accordingly, the Court has no jurisdiction to adjudicate Plaintiffs claims against the
Commissioner.
V. Indianas Traditional Marriage Definition Does Not Violate Plaintiffs Right of
Access to Courts

1. Plaintiff Linda Bruner acknowledges that she did not separately plead her right-
of-access-to-courts claim and now attempts to shoehorn it into her broader Due Process claim.
See Doc. No. 30 at 41. She contends that her passing reference to the denial of access to courts
in the context of her Due Process argument is sufficient to comply with Rule 8s requirement of
a short and plain statement of the claim showing that the pleader is entitled to relief. Id. (citing

9

Fed. Rule Civ. P. 8(a)(2)). Such a statement can hardly be characterized as plain, however,
when it is buried within other claims. As Defendants explained in their opening summary
judgment brief, Bruner neither alleges a violation of right of access to courts as a separate count
nor includes a specific demand for declaratory or injunctive relief that would address such a
claim; thus, the Court should treat this claim as waived. See Doc. No. 26 at 43.
2. Bruner argues that the domestic relations exception does not bar her claim
because she is not asking this Court to issue a decree of dissolution, but rather, she is requesting
this Court to find Indianas Anti-Recognition statute unconstitutional . . . . Doc. No. 30 at 42.
This statement oversimplifies the matter. Regardless of the specific relief Bruner is requesting
here, the result, should she succeed, will be to obtain a divorce decree in state court by way of a
federal court proceeding. This falls squarely within the domestic relations exception, which
encompasses [] cases involving the issuance of a divorce, alimony, or child custody decree.
Ankenbrandt v. Richards, 504 U.S. 689, 704 (1992).
3. Even if the Court finds there are no jurisdictional barriers to Bruners access-to-
courts claim, it must nevertheless fail on the merits. The right of access to courts is violated
when systemic official action frustrates a plaintiff . . . in preparing and filing suits at the present
time. Christopher v. Harbury, 536 U.S. 403, 413 (2002). The right requires the government to
provide only a reasonably adequate opportunity to present claimed violations of fundamental
constitutional rights to the courts. Lewis v. Casey, 518 U.S. 343, 351 (1996) (internal
quotations omitted) (emphasis added).
Under this standard, Bruner has suffered no violation of her right of access to the courts.
She filed a petition for dissolution in state court and alleges no systemic official action that
frustrate[d] her ability to do so. Instead, she contends that her right of access has been violated

10

because the Marion Superior Court dismissed her dissolution action in reliance upon Indianas
traditional marriage definition. Doc. No. 30 at 42.
As courts have repeatedly held, however, a state courts lack of subject-matter
jurisdiction over a claim, as opposed to a courts refusal even to accept and docket a pleading
initiating a claim, does not constitute an unconstitutional denial of access to courts. See Doc. No.
26 at 46-47 (collecting cases). Bruner makes no attempt to argue otherwise. Instead, she
continues to rely on Boddie v. Connecticut, 401 U.S. 371 (1971), for the broad proposition that
[a]ccess to the Courts is a fundamental right that is rooted in the Due Process Clause of the
Fourteenth Amendment. Doc. No. 30 at 41. As Defendants explained in their opening brief,
however, this reliance is misplaced. See Doc. No. 26 at 46. In Boddie, indigent married parties
were prevented from having their divorce action heard in court because they could not pay a
filing fee. Boddie, 401 U.S. at 376, 379. The Court held that the filing fee was a violation of the
plaintiffs right of access to courts because the fee was a bar to the filing of their lawsuit. Id. at
380. Again, Bruner was able to file her dissolution action and have her claims heard by the
Marion Superior Court.
Although the trial court ultimately dismissed her dissolution action, Bruners access
does not end there, of course. Bruner notes that she plans to timely file her Notice of Appeal
with the Indiana Court of Appeals. Doc. No. 30 at 41. Thus, she can hardly claim she has been
denied access to courts when her claim has been heard by a state trial court and is ripe for appeal.
Nor has Bruner explained why a separate federal court lawsuit is the proper vehicle for
adjudication of her constitutional challenge to Section 31-11-1-1. Presumably, Bruner plans to
appeal the trial courts dismissal of her dissolution action on the grounds that Section 31-11-1-
1the basis for the trial courts dismissalis unconstitutional. If the Indiana Court of Appeals

11

and/or Indiana Supreme Court agree with her in this regard and issue a decision holding Section
31-11-1-1 unconstitutional, then the state trial courts will follow suit and begin adjudicating on
the merits dissolution petitions filed by same-sex couples married in other States. Thus, there is
no need for parallel federal litigation to adjudicate the same constitutional claims Bruner will be
pursuing in state court.
4. In their previous brief, Defendants explained that while a same-sex couple
married in another State may not be able to obtain a division of property by way of a formal
divorce decree, Indiana courts may nonetheless equitably divide their property upon the couples
request. See Doc. No. 26 at 48-49. Bruner contends, however, that an equitable division of
property that has been acquired during the relationship is not the equivalent to a dissolution of
marriage because, in a dissolution, the court divides all property, not just the property that was
acquired during the marriage. Doc. No. 30 at 43.
Even if true, this is not a violation of Bruners right of access to courts. The right
mandated by Boddie and its brethren is the ability to file a petition for dissolution, not the
guarantee of a specific remedy. See Boddie, 401 U.S. at 383 (directing the State only to provide
access to the means [for divorce]). The relevant point is that same-sex couples married in
other States can file an action in state court requesting an equitable division of their property.
That such property may be divided differently than the property of an opposite-sex married
couple does not diminish the fact that same-sex couples have access to the courts and the ability,
generally, to obtain some relief. If anything, Bruners objection in this regard generally (though
not meritoriously) sounds in Equal Protection, not in the Due Process right of access to courts.
In all events, however, it must fail.

12

CONCLUSION
The Court should deny Plaintiffs Motion for Summary J udgment and grant Defendants
Motion for Summary J udgment.
Respectfully submitted,

GREGORY F. ZOELLER
Attorney General of Indiana

s/ Thomas M. Fisher
Thomas M. Fisher
Solicitor General

IGC South, Fifth Floor
302 W. Washington Street
Indianapolis, IN 46204
Tel: (317) 232-6255
Fax: (317) 232-7979
Tom.Fisher@atg.in.gov

Counsel for Defendants


13

CERTIFICATE OF SERVICE

I hereby certify that on J uly 24, 2014, I electronically filed the foregoing with the Clerk
of the Court using the CM/ECF system, which sent notification of such filing to the following:
Richard A. Mann
Lisa M. J oachim
J ennifer A. Mann
Todd D. Small
Megan L. Clearwaters
RICHARD A. MANN, P.C.
RMann@RichardMann-LawOffice.com
LJ oachim@RichardMann-LawOffice.com
J Mann@MannLaw.us
TSmall@RichardMann-LawOffice.com
MClearwaters@MannLaw.us

s/ Thomas M. Fisher
Thomas M. Fisher
Solicitor General

Indiana Government Center South 5th Floor
302 W. Washington St.
Indianapolis, IN 46204-2770
Phone: (317) 232-6255
Fax: (317) 232-7979
Email: Tom.Fisher@atg.in.gov


1:14-cv-00405 #38

Uploaded by

Document Information

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

1:14-cv-00405 #38

Uploaded by

Copyright:

Available Formats

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF INDIANA

You might also like