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A lawsuit was filed May 8, 2019 in Hamilton County Common Pleas Court against Colerain Township officials regarding legal services
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ORIGINAL
HAMILTON COUNTY
COURT OF COMMON PLEAS
STATE OF OHIO, ex rel,
KATHY MOHR : CASENO. A1g0z246
c/o Matt Miller-Novak a
Godbey Law, LLC :
708 Walnut St., Ste. 600 : JUDGE:
Cincinnati, OH 45239
STATE OF OHIO, ex rel,
STEPANIE WRIGHT
c/o Matt Miller-Novak
Godbey Law, LLC
708 Walnut St., Ste. 600
Cincinnati, OH 45239
Relators, : COMPLAINT FOR
as : INJUNCTIVE RELIEF
COLERAIN TOWNSHIP
4200 Springdale Rd.
Cincinnati, OH 45251
and,
RAJ RAJAGOPAL
In his official capacity
4200 Springdale Rd.
Cincinnati, OH 45251
and,
©
>
DAN UNGER
In his official capacity
4200 Springdale Rd.
Cincinnati, OH 45251
and,
GREG INSCO : a
Inhis official capacity : i \
4200 Springdale Rd. : |
Cincinnati, OH 45251 : HH
Respondents. : 125369602 INI !
y Relators Kathy Mohr and Stephanie Wright state the following for their Complaint
against Respondents Colerain Township, Raj Rajagopal, Dan Unger, and Greg Insco:
PARTIES
1. Relator Kathy Mohr (“Mohr”) is a resident of Colerain, Ohio, and she is bringing
this Action as a relator for the State of Ohio.
2. Relator Stephanie Wright (“Wright”) is a resident of Colerain, Ohio, and she is
bringing this Action as a relator for the State of Ohio. (the Complaint with refer to
both Mohr and Wright collectively as “Relators”)
3. Respondent Colerain Township is a public body located in Hamilton County, OH,
and it is subject to Ohio's Open Meetings Act under R.C. § 121.22.
4. Respondents Raj Rajagopal, Dan Unger, and Greg Insco are Trustees of Colerain
‘Township and are being sued in their official capacities. (the Complaint will refer
to all Respondents collectively as “Respondents”).
JURISDICTION AND VENUE
5. This Court has jurisdiction to hear this case under R.C.'§ 121.22, and this is the
proper venue because the transactions and occurrences asserted in this Complaint
happened in Hamilton County, Ohio.
BACKGROUND
6. In late 2018, Respondents were engaged in the process of deciding which law firm
to contract with to provide legal services to Colerain Township because its existing-
contract with Schroeder, Maundrell, Barbiere, & Powers (“SMBP”) was set to
expire at the end of 2018. 7. Respondents issued a “Request for Proposals for Legal Services,” which it posted
‘on its website, posted in the Cincinnati Enquirer, and the Court Index with the
proposals due on October 26, 2018 at 1pm. (Exhibit 1).
8. Colerain received four proposals for legal services from four different law firms:
Calfee, Frost, Dinsmore, and SMBP. (Id.)
9. Respondents met with and “interviewed” representatives from the four different
law firms on November 27, 2018 in an executive session, so the public was not
able to observe Respondents’ deliberations. (Id.)
10.On November 27, 2018, the Respondents motioned to enter executive session
claiming they were going to discuss “employment and compensation of public
employees” under R.C, § 121(g)(1). (Exhibit 2).
11, Then, on December 4%, 2018, the Respondents again cited R.C. § 121.22(G)(1) to
allegedly discuss the “employment and compensation of public employees.”
(Exhibit 3).
12. However, according to their own written records, Respondents were instead
discussing the “future of legal services for the Township.” (Exhibit 1).
13. Respondents then chose SMBP over the other three law firms in private, and
Respondents then took official action in private to direct the Township
Administrator to bring forward a contract with SMBP in private without the public
present. (Id.)
14. Thus, the Respondents met privately without public notice to deliberate on and to
privately take an official action to hire one law firm over the other three
competitors.
15. According to Respondents, this is a common practice in Colerait
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