IN THE CHANCERY COURT OF

DAVIDSON COUNTY, TENNESSEE

TWENTIETH JUDICIAL DISTRICT AT NASHVILLE

BRIAN MANOOKIAN,

Petitioner,

v.
Case No.___________
OFFICE OF LEGISLATIVE
ADMINISTRATION and CONNIE
RIDLEY, in her official capacity,

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Respondents.
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PETITION FOR ACCESS TO PUBLIC RECORDS AND TO
OBTAIN JUDICIAL REVIEW OF DENIAL
___________________________________________________

Pursuant to the Tennessee Public Records Act, Tenn. Code Ann.§§ 10-
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7-501, et seq. to 10-7-505 (the "Act"), petitioner Brian Manookian hereby

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petitions this Court for access to certain public records, and to obtain judicial

review of the actions of respondents, the Office of Legislative Administration

and Connie Ridley, in denying the Petitioner access to those records.

I. INTRODUCTION

This is a public records case requesting that this Court order the Office

of Legislative Administration and its Director, Connie Ridley, to disclose

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records under their control to Brian Manookian. Mr. Manookian is a citizen

of the State of Tennessee residing in Davidson County.

After local media reported that the Office of Legislative Administration

had secretly funneled taxpayer money in order to advance a cover-up of

sexual harassment of a Legislative Intern by a member of Tennessee’s

General Assembly, Mr. Manookian sought certain documents directly from

the Office of Legislative Administration (“OLA”) and its director, Connie

Ridley. After the OLA variously ignored or rejected his request, Mr.

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Manookian brought his petition under the Tennessee Public Records Act.
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II. THE PARTIES

1. The Office of Legislative Administration is a statutorily created

governmental entity. It is created by Tenn. Code Ann. § 3-13-101(a). It

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functions are enumerated by statute. Among other things, the OLA is

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statutorily directed to “[m]ake disbursements of funds for all other lawful

expenses of the general assembly” as well as perform various and significant

budgeting, personnel, record-keeping, recruiting, hiring, and training

functions. Id. at (a)(1)-(12).

2. Connie Ridley is the Director of the Office of Legislative

Administration and its public records request coordinator and records

custodian within the meaning of those terms under the Tennessee Public
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Records Act. She is sued solely in her official capacity in order to require her

to make available the public records requested by Mr. Manookian.

3. Brian Manookian is a citizen of the State of Tennessee, and

resident of Davidson County. OLA and Director Ridley denied his access to

records under their custody after Mr. Manookian lodged a request.

III. JURISDICTION AND VENUE

4. This Court has subject matter jurisdiction over this petition

under Tenn. Code Ann.§§ 10-7-505(b), 16-11-101 et seq., 29-14-102 and 29-

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14-103.
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5. As the county where TSBA is headquartered and stores its

records, venue is proper in Davidson County under Tenn. Code Ann. §§ 10-

7-505(b) and 20-4-l0l(a).

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6. This Court has authority to enter a declaratory judgment and

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injunctive relief under Tenn. Code Ann.§ 10-7-505(d), 29-1-101 et seq., 29-

14-102, 29-14-103, and Tenn. R. Civ. P. 65 et seq.

IV. FACTS

7. The Tennessee Public Records Act, Tenn. Code Ann. § 10-7- 503,

applies to records “made or received” in connection with the transaction of

official business by any “government agency.”

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 8. On April 20, 2023, NewsChannel5 Investigative Reporter Phil

Williams reported that Republican Tennessee State Representative Scotty

Campbell had been found to have repeatedly sexually harassed one or more

legislative interns. Rep. Campbell resigned from his position roughly six

hours after Mr. Williams broke the story.

9. Within Mr. Williams’ investigation was additional information

reporting that:

“Republicans did not remove the 39-year-old East Tennessee

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lawmaker from his leadership position nor from his committee
assignments. But taxpayers are paying for his actions.
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NewsChannel 5 has learned that potentially thousands of dollars
have been spent to protect one victim, relocating her from the
downtown apartment building where she and Campbell both had
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apartments, shipping her furniture back home in another part of
the state and placing her in a downtown hotel for the remainder
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of her internship.”

10. The OLA is a governmental entity covered by the Tennessee

Public Records Act. The OLA transacts official business via email and is

required under the Act to accept public records requests from citizens of

Tennessee via email.

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 11. Troubled at the news that Tennessee taxpayers were funding the

cover-up of sexual harassment by a powerful lawmaker, and that the OLA

was refusing to release the details of the payments, including the process by

which those payments were approved, Mr. Manookian requested certain

documents from the OLA through Director Ridley and her staff of attorneys

in three separate written requests made on April 21, 2023 and April 22, 2023

(“The April Public Records Requests”).

12. The April Public Records Requests are attached in their entirety

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as Exhibits 1-3 and include specific access to:
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a. Any and all records reflecting or relating to hotel or moving

expenses paid by the legislature in relation to a legislative

intern in 2021, 2022, or 2023.

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b. Any and all records reflecting or relating to hotel or moving

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expenses paid by the legislative budget office in relation to

a legislative intern in 2021, 2022, or 2023.

c. Any and all records reflecting or relating to hotel or moving

expenses in relation to a legislative intern received by the

legislature, your office, any legislative committee or

subcommittee, or the legislative budget office in 2021,

2022, or 2023.
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 d. Any and all records reflecting or related to any state funds

spent to relocate a legislative intern to a hotel in Nashville

in 2021, 2022, or 2023.

e. Any and all records reflecting or related to any state funds

spent for a legislative intern to reside in a hotel in Nashville

in 2021, 2022, or 2023.

f. Any and all records reflecting or related to any state funds

spent to move any furnishings for a legislative intern in

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2021, 2022, or 2023.
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g. Any and all records reflecting any funds spent by the state,

legislature, legislative budget office, any internship

program, or any agency of the State of Tennessee as a result

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of conduct by Rep. Scotty Campbell toward a legislative

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intern.

13. Neither the OLA nor Connie Ridley ever responded to Mr.

Manookian April Public Records Requests. Pursuant to the Act,

Respondents’ decision to ignore Mr. Manookian properly made requests is

treated as a denial.

14. On May 9, 2023, veteran legislative reporter Sam Stockard with

the Tennessee Lookout published an article entitled “House speaker

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indicates staff, subcommittee spent money in harassment case.” The article

reported that the OLA was, in fact, in possession of records directly

responsive to Mr. Manookian’s prior requests, statin, in part:

House Speaker Cameron Sexton is pointing at the Office of

Legislative Administration and a House ethics subcommittee in
the expense of nearly $9,000 in the case of a 19-year-old intern
harassed by former Rep. Scotty Campbell…

Asked Monday who authorized the expenditures to relocate an

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intern to a new apartment complex in the final days of the
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Legislature’s session, Sexton’s spokesman Doug Kufner said
state law, TCA 3-13-101 (a)10, enables the Office of Legislative
Administration director to “make disbursements of funds for all
other lawful expenses of the General Assembly.”
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15. The same morning, May 9, 2023, Mr. Manookian made a fourth
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records request under the Act directed to the OLA and Connie Ridley seeking

records related to taxpayer funds spent to cover-up Rep. Campbell’s sexual

harassment. Specifically, Mr. Manookian requested:

a. Any and all records (including emails, text messages, and

other communications) of expenses paid by, reviewed by,

or approved by the Office of Legislative Administration or

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 any of its employees, agents, or others acting on its behalf,

reflecting any sum of money paid to TownPlace Suites from

2020 to the present.

b. Any and all records (including emails, text messages, and

other communications) of expenses paid by, reviewed by,

or approved by the Office of Legislative Administration or

any of its employees, agents, or others acting on its behalf,

reflecting any sum of money paid to Two Men and a Truck

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from 2020 to the present.
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c. Any and all records (including emails, text messages, and

other communications) of expenses paid by, reviewed by,

or approved by the Office of Legislative Administration or

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any of its employees, agents, or others acting on its behalf,

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reflecting $935 in cash paid to any legislative intern from

2020 to the present.

d. Any and all records (including emails, text messages, and

other communications) of expenses paid by, reviewed by,

or approved by the Office of Legislative Administration or

any of its employees, agents, or others acting on its behalf,

reflecting any sum of money used to compensate a

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 legislative intern for moving out of the Capitol Towers from

2020 to the present.

e. Any and all records (including emails, text messages, and

other communications) reflecting any of the expenses

referenced in the attached NewsChannel5 Article by Phil

Williams (attached as Exhibit 4) which were approved,

reviewed, paid for, or communicated about by the Office of

Legislative Administration or any of its employees, agents,

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or other individuals acting on its behalf.
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16. As of the date of the filing of this Petition, the Respondents have

ignored, declined, or otherwise refused and denied Mr. Manookian’s

requests for access to records.

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V. CLAIM
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17. Pursuant to the Tennessee Public Records Act, Tenn. Code Ann.

§ 10-7-101, et seq.; and Tenn. Code Ann. § 29-25-101, Petitioner brings this

action seeking access to certain public records, created and maintained by

Respondents.

18. The Tennessee Public Records Act, Tenn. Code Ann. § 10-7-503

et seq., governs the right of access to the records of government agencies in

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Tennessee, promoting government accountability and proper public

oversight of government activities.

19. Tenn. Code Ann. § 10-7-503 et seq. provides in pertinent part

that “[a]ll municipal records ... shall at all times, during business hours, be

open for personal inspection by any citizen of Tennessee ...” to the extent that

those records were “made or received pursuant to law or ordinance or in

connection with the transaction of official business by any governmental

agency.”

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20. Brian Manookian is a citizen of the State of Tennessee.
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21. On April 21, April 22, and May 9, 2023, Brian Manookian

submitted requests to Respondents for public records under Tenn. Code

Ann.§ 10-7-503. See Ex. 3.

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22. Respondents have denied Mr. Manookian’s request either

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through express denial or refusal to respond.

23. To the best of Mr. Manookian’s knowledge, information and

belief, the requested records are in the possession, custody, or control of

Respondents.

24. To the best of Mr. Manookian’s knowledge, information and

belief, Respondents house and maintain those records in Davidson County

where the OLA is headquartered.

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 25. To date, Respondents have not denied that they controls

responsive documents.

26. The aforementioned records are public records to which the

public is entitled access and which are not confidential records under Tenn.

Code Ann. § 10-7-504 or any other state or federal law.

27. Respondents wrongly and willfully denied Mr. Manookian’s

requests.

28. Respondents have no authority to refuse Petitioner's request to

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inspect the relevant records.
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29. As a result of their willful refusals, Mr. Manookian has incurred

costs and expenses.

VI. PRAYER FOR RELIEF

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WHEREFORE, Petitioner prays:

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30. That the Court issue an Order to Show Cause requiring

Respondents to appear before this Court and to show cause, if any such cause

can be shown, why this Petition should not be granted with respect to each

record withheld as provided by Tenn. Code Ann.§ 10-7-505(b).

31. That the Court grant this Petition and order Respondent to

provide, and otherwise permit Petitioner to receive, the aforementioned

documents, as set forth above in the request. See Exs. 1-4.

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 32. That the Court issue a declaration that the records Petitioner

requested are public records under Tennessee law.

33. That Petitioner recover judgment against Respondents for costs

incurred in obtaining the records sought as provided by § 10-7- 505(g).

34. That the Court order Respondents to show cause as to why

Petitioner should not recover attorney's fees as provided by§ 10-7-505(g).

35. That the Court grant Petitioner any and all other relief to which

it appears he is entitled.

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Dated: May __, 2023

Respectfully submitted,
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___________________
BRIAN MANOOKIAN
1906 Glen Echo Road, 150229
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Nashville, TN 37215
615-257-5660
[email protected]

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