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Manookian Chancery Suit Against Office of Legislative Administration
Manookian Chancery Suit Against Office of Legislative Administration
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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petitions this Court for access to certain public records, and to obtain judicial
I. INTRODUCTION
This is a public records case requesting that this Court order the Office
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records under their control to Brian Manookian. Mr. Manookian is a citizen
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
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
resident of Davidson County. OLA and Director Ridley denied his access to
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-
injunctive relief under Tenn. Code Ann.§ 10-7-505(d), 29-1-101 et seq., 29-
IV. FACTS
7. The Tennessee Public Records Act, Tenn. Code Ann. § 10-7- 503,
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8. On April 20, 2023, NewsChannel5 Investigative Reporter Phil
Campbell had been found to have repeatedly sexually harassed one or more
legislative interns. Rep. Campbell resigned from his position roughly six
reporting that:
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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.”
Public Records Act. The OLA transacts official business via email and is
required under the Act to accept public records requests from citizens of
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11. Troubled at the news that Tennessee taxpayers were funding the
was refusing to release the details of the payments, including the process by
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
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
2022, or 2023.
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d. Any and all records reflecting or related to any state funds
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2021, 2022, or 2023.
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g. Any and all records reflecting any funds spent by the state,
intern.
13. Neither the OLA nor Connie Ridley ever responded to Mr.
treated as a denial.
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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
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any of its employees, agents, or others acting on its behalf,
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from 2020 to the present.
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c. Any and all records (including emails, text messages, and
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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
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
Respondents.
18. The Tennessee Public Records Act, Tenn. Code Ann. § 10-7-503
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Tennessee, promoting government accountability and proper public
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
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
Respondents.
responsive documents.
public is entitled access and which are not confidential records under Tenn.
requests.
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inspect the relevant records.
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29. As a result of their willful refusals, Mr. Manookian has incurred
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
31. That the Court grant this Petition and order Respondent to
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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