Huron Answer
Huron Answer
Huron Answer
2019 CV 0275
Stacy Chubak Hinners, el al.,
Tygh M Tone
Plaintiffs, CASE NO. 2019 CV 0275
Defendants.
DEFENDANTS' ANSWER
Now corne Defendants City of Huron, Mayor Brad Hartung, Vice Mayor Richard "Trey"
Hardy, Council Member Sam Artino, Counsel Member Joe Dike, Council Member Glen Ginesi,
Council Member Rick Schaffter, and Council Member Christine Crawford, by and through
counsel, and for their Answer to Plaintilrs Complaint herein state as follows:
FIRST DEFENSE:
.>. The allegations contained in paragraph 3 of Plaintiffs' Complaint state legal conclusions
the allegations contained in paragraph 2 of Plaintiffs' Complaint, but do not contest the
want of knowledge.
want of knowledge.
only that the City of Huron is a Municipal Corporation with a seven-member City
Council, and that City Council is currently comprised of Mayor Brad Hartung, Vice
Mayor Trey Hardy, Council Member Sam Artino, Council Member Joe Dike, Council
Member Glen Ginesi, Council Member Rick Schaffter, and Council Member Christine
10. For the allegations contained in paragraph 10 of Plaintiffs' Complaint, Defendants aver
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II. For the allegations contained in paragraph II of Plaintiffs' Complaint, Defendants aver
12. For the allegations contained in paragraph 12 of Plaintiffs' Complaint, Defendants aver
18. For the allegations contained in paragraph 18 of Plaintiffs Complaint, Defendants aver
that Exhibit 3 speaks for itself. Further answering, Defendants deny the allegations
19. For the allegations contained in paragraph 19 of Plaintiffs' Complaint, Defendants aver
that Exhibit 4 to Plaintiffs' Complaint speaks for itself. Further answering, Defendants
20. For the allegations contained in paragraph 20 of Plaintiffs' Complaint, Defendants aver
that Exhibit 5 to Plaintiffs' Complaint speaks for itself. Further answering, Defendants
22. For the allegations contained in paragraph 22 of Plaintiffs' Complaint, Defendants aver
26. For the allegations contained in paragraph 26 of Plaintiffs' Complaint, Defendants aver
that Exhibit 7 to Plaintiffs' Complaint speaks for itself. Further answering, Defendants
27. For the allegations contained in paragraph 27 of Plaintiffs' Complaint, Defendants aver
that Exhibit 7 to Plaintiffs' Complaint speaks for itself. Further answering, Defendants
29. For the allegations contained in paragraph 29 of Plaintiffs' Complaint, Defendants aver
that Exhibit 4 to Plaintiffs' Complaint speaks for itself. Further answering, Defendants
30. For the allegations contained in paragraph 30 of Plaintiffs' Complaint, Defendants aver
that Exhibit 8 to Plaintiffs' Complaint speaks for itself. Further answering, Defendants
33. For the allegations contained in paragraph 33 of Plaintiffs' Complaint, Defendants aver
that Exhibit 9 speaks for itself and therefore no response is required. Defendants deny
34. For the allegations contained in paragraph 34 of Plaintiffs' Complaint, Defendants aver
that Exhibit 10 speaks for itself. Further answering, Defendants deny the allegations
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35. The allegations contained in paragraph 35 of Plaintiffs' Complaint contain legal
39. Defendants expressly deny each and every allegation not expressly admitted herein as
true.
SECOND DEFENSE
40. Plaintiffs' Complaint fails to state a claim upon which relief can be granted.
THIRD DEFENSE
FOURTH DEFENSE
42. Plaintiffs are barred from relief because Defendants acted lawfully at all times.
FIFTH DEFENSE
SIXTH DEFENSE
SEVENTH DEFENSE
45. The City of Huron is not sui juris and therefore is not subject to suit.
EIGHTH DEFENSE
46. Plaintiffs are proceeding pro se and are therefore not entitled to attorney's fees.
NINTH DEFENSE
47. Plaintiffs are not entitled to attorney fees pursuant to R.C. 121.22(1)(2).
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TENTH DEFENSE
48. Plaintiffs claims are barred because any Open Meeting Act violations, which are
ELEVENTH DEFENSE
49. Plaintiffs lack standing to pursue some of their claims or claimed relief.
TWELFTH DEFENSE
50. Defendants reserve the right to assert any other defenses that become known or available
Wherefore, having Answered and denied Plaintiffs' claims, Defendants hereby respectfully
request that this case be dismissed and that they recover their costs and attorney fees for defending
Respectfully submitted,
Email: ~:~~~~~~:~:~
Counsel for Defendants
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CERTIFICATE OF SERVICE
The undersigned hereby certifies that a copy of the foregoing Answer was tiled
electronically on June 17,2019. Notice of this tiling will be sent by electronic mail and USPS
Jason Hinners
1130 Mudbrook Road
Huron, OH 44839
Jhinners [email protected]
Q:\1wdataiPERSOiPERSO Lifigation'Hinners v. City ofHuron (OMAj'Pleadings (fVord)\20J9.06.17- Defs. Answer to Pi. Campi..doer