Vandergriff et al v. Clermont County Public Library Board of Trustees

Filing 2

Vandergriff et al v. Clermont County Public Library Board of Trustees

Doc. 2

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO WESTERN DIVISION GEORGE AND CATHY VANDERGRIFF and : INSTITUTE FOR PRINCIPLED POLICY, : : Plaintiffs, : : vs. : : CLERMONT COUNTY PUBLIC LIBRARY : BOARD OF TRUSTEES, : : Defendant. :

Case No.: 1:08-cv-381 ORAL ARGUMENT REQUESTED

PLAINTIFFS' MOTION FOR PRELIMINARY INJUNCTION

Plaintiffs, by and through counsel and pursuant to Fed. R. Civ. P. 65(a), move this Court for a preliminary injunction enjoining Defendant from enforcing its discriminatory meeting room policy to prohibit Plaintiffs from conducting a religiously-based financial planning workshop, in violation of Plaintiffs' rights guaranteed by the First and Fourteenth Amendments to the United States Constitution and Article I, Section 7 of the Ohio Constitution. Unless Defendant's unconstitutional conduct is immediately enjoined, Plaintiff will continue to suffer irreparable harm for which there is no adequate remedy at law. The grounds for this Motion are set forth in a Memorandum separately filed herewith. Plaintiffs request that the requirement for bond be waived.

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Respectfully submitted,

Benjamin W. Bull+ AZ Bar No. 009940 Attorney for Plaintiff Timothy D. Chandler* CA Bar No. 234325 Attorney for Plaintiff ALLIANCE DEFENSE FUND 101 Parkshore Drive, Suite 100 Folsom, California 95630 Telephone: [phone] Email: [e-mail]

/s/ David R. Langdon David R. Langdon OH Bar No. 0067046 Lead Attorney for Plaintiff LANGDON LAW LLC 11175 Reading Road, Ste. 104 Cincinnati, Ohio 45241 Telephone: [phone] Email: [e-mail]

+Of Counsel *Pending admission pro hac vice

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CERTIFICATE OF SERVICE I hereby certify that on June 4, 2008, I electronically filed the foregoing document with the Clerk of Court using the CM/ECF system. In addition, I hereby certify that the foregoing document will be served upon the named defendant with the complaint. /s/ David R. Langdon David R. Langdon OH Bar No. 0067046 Attorney for Plaintiff Langdon & Hartman LLC 11175 Reading Road, Ste. 104 Cincinnati, Ohio 45241 Telephone: [phone] Email: [e-mail]

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