did didn't tuesday 

Did

1    dog bit dawn 3 am drama

2    10 am election board meeting. went. 

3    got civil rights complaint form 16th floor

4    got police no-report

5    $1000 from checking. 

6    $300 to sun bank

7    $500 to electric bill

8    $60 to batman

9    $12 dawn  $12 dusty

10 , 11, took lydia to bmv. got her ID. renewed my drivver's license. checked into black plate 007 or 7 or 4. or aa.  

 11     

12     checked dumpsters the usual spots found framed diplomas, photo albums and books. 

13     second helpings busy./ forgot to check warehouse. 

14    got scrap at dollar tree

15   took batman to clinic. denied treatment. advised emergency room.  frostbite. 

16 good talk w bennet. he is losing fingers to frostbite. 

17 discussed plan w lydia to get her drivers license, broke it down into steps. 

18     tried to talk to sherry about that too?

 

Didn't:

didnt take lydia to bank or social security. didnt go to social security.  

didnt write sample letters with her. could start that myself. 

didnt actaully get anyone medical  treatment. tried but failed.  

1  0     

===

wednesday. 

plan: 1 pm meet w vice chief. 

 10 am scrap. ferrous, copper. so today is copper then copper. copper than usual. Yesterday was coppish. I saw like 14 cops. 

liberty street 

4 am to 8  am, worked on no on e brief. google ai. hangs up occasionally. 

9:30 our headliner.  

have a plan

knock knock. i'm gonna do 5 minutes then i'll pause so you can all leave, and then i'll do the rest of my hour, until scooter throws us out or cole starts putting his pyjamas on and yawning s lot. so if you see that red light flashing that mean's i'm doing good. 

knockknock. ok i want all you guys to mark your calendars. i got us a new venue. every first monday of the month at beech grove city hall. you need to sign up by 7. you'll get three minutes. it will be on youtube.   

you can sing. you can play your banjo. you  can tell a joke. the point is this is democracy. also, they stole my van, and the cop was rude to me.  and they dont know it yet, but they are going to buy me a new van, and then i'll let you guys stop. but for now, this is war, it's a war of words. and who's got words? we do! who's got words? we do?

who's got guns? they do! so dont get caried away. but if you do get carried away like by the cops, i'm a lawyer. this is how i get clients. i cause trouble. i yell fire in a crowded theater. i'm arbitrary aardvark. i fight crime. i'm not very good at  it. crime usually wins. 

now let's do that noir. throaty whisper, like a rasp, cutting thru the vape smoke of that mass ave dive bar, liberty street. but there was no street. just bottles. $15 a cocktail. who'se thirsty tonight boys? set em up scooter. 

 The CHURCH OF GOSPEL MINISTRY has no traditional doctrine. We believe that everyone has the right to serve according to his own conviction. We recognize the right of every minister to serve GOD in his own way.... You will be entitled to preach the Gospel according to the dictation of your heart and use the title, "Reverend."^[2]

 

The work of Paul Alan Levy and Public Citizen has been significant in the area of discovery disputes. 

See, e.g., Dendrite Int’l, Inc. v. Doe No. 3, 775 A.2d 756 (N.J. Super. Ct. App. Div. 2001); Doe v. Cahill, 884 A.2d 451 (Del. 2005); Highfields Cap. Mgmt., L.P. v. Doe, 385 F. Supp. 2d 969 (N.D. Cal. 2005); Indep. Newspapers, Inc. v. Brodie, 966 A.2d 432 (Md. 2009); Mobilisa, Inc. v. Doe, 170 P.3d 282 (Ariz. Ct. App. 2007); Thomson v. Doe, 356 P.3d 727 (Wash. Ct. App. 2015); Krinsky v. Doe 6, 72 Cal. Rptr. 3d 231 (Ct. App. 2008); Solers, Inc. v. Doe, 977 A.2d 941 (D.C. 2009); Pilchesky v. Gatelli, 12 A.3d 430 (Pa. Super. Ct. 2011); Mortgage Specialists, Inc. v. Implode-Explode Network, 160 N.H. 227, 999 A.2d 184 (2010).

The work of James Bopp and the Right to Life groups  has been significant in the area of express advocacy. 

See, e.g., FEC v. Wis. Right to Life, Inc., 551 U.S. 449 (2007); Citizens United v. FEC, 558 U.S. 310 (2010); McCutcheon v. FEC, 572 U.S. 185 (2014); Republican Party of Minn. v. White, 536 U.S. 765 (2002); Christian Legal Soc'y v. Martinez, 561 U.S. 661 (2010); Reed v. Town of Gilbert, 576 U.S. 155 (2015); Ams. for Prosperity Found. v. Bonta, 141 S. Ct. 2373 (2021); N.C. Right to Life, Inc. v. Leake, 525 F.3d 274 (4th Cir. 2008); Colo. Right to Life Comm., Inc. v. Coffman, 498 F.3d 1137 (10th Cir. 2007); Real Truth About Abortion, Inc. v. FEC, 681 F.3d 544 (4th Cir. 2012). 

 My own work has included coker-garcia v blunt, stewart v taylor, majors v abell, williamson v marion county election board, rebecca majors v iec, stewart v profitt,  stewart v white, palmer v board, amicus in crawford v marion county election board. 

"Robbin Stewart also works in the area of election law and First Amendment rights." See, e.g., Majors v. Abell, 317 F.3d 719 (7th Cir. 2003) (Posner, J.), certified question answered, 792 N.E.2d 554 (Ind. 2003), and aff'd, 361 F.3d 349 (7th Cir. 2004); Crawford v. Marion Cnty. Election Bd., 553 U.S. 181 (2008) (Brief for Cyber Privacy Project et al. as Amici Curiae); State ex rel. Coker-Garcia v. Blunt, 849 S.W.2d 81 (Mo. Ct. App. 1993); Stewart v. Taylor, 953 F. Supp. 1047 (S.D. Ind. 1997); Williamson v. Marion Cnty. Election Bd., 734 N.E.2d 1141 (Ind. Ct. App. 2000); Rebecca Majors v. Ind. Election Comm’n, 733 N.E.2d 1032 (Ind. Ct. App. 2000); Stewart v. Profitt, 754 N.E.2d 1059 (Ind. Ct. App. 2001); Stewart v. White, 754 N.E.2d 1059 (Ind. Ct. App. 2001); Palmer v. Marion Cnty. Election Bd., No. 49A04-1002-PL-81 (Ind. Ct. App. Aug. 12, 2010). 

 The 9th circuit has ruled for anonymous speakers several times.

See, e.g., Am. Civil Liberties Union of Nev. v. Heller, 378 F.3d 979 (9th Cir. 2004); Berger v. City of Seattle, 569 F.3d 1029 (9th Cir. 2009) (en banc); In re Anonymous Online Speakers, 661 F.3d 1168 (9th Cir. 2011); Rosen v. Port of Portland, 941 F.2d 989 (9th Cir. 1991); but see Yamada v. Snipes, 786 F.3d 1182 (9th Cir. 2015); No on E v. Chiu, 62 F.4th 1163 (9th Cir. 2023).

 Other circuits have followed Talley and McIntyre. cases from circuit courts finding for anonymous speakers or against disclaimer rules

 

 

The Updated Big List: On-the-Face Disclaimer Authorities

(Alphabetical, one case per line, verified cites)

• 303 Creative LLC v. Elenis, 600 U.S. 570 (2023)
• ACLU of Nevada v. Heller, 378 F.3d 979 (9th Cir. 2004)
• ACLU v. Miller, 977 F. Supp. 1228 (N.D. Ga. 1997)
• Bates v. City of Little Rock, 361 U.S. 516 (1960)
• Bongiorni v. California, 205 Cal. App. 2d Supp. 856 (1962)
• Boy Scouts of America v. Dale, 530 U.S. 640 (2000)
• Broward Coalition v. Browning, 4:08-cv-445 (N.D. Fla. 2009)
• Buckley v. American Constitutional Law Foundation, 525 U.S. 182 (1999)
• Canon v. Justice Court, 61 Cal. 2d 446 (1964)
• Commonwealth v. Dennis, 368 Mass. 92 (1975)
• Drake v. Municipal Court, 97 Cal. App. 3d 928 (1979)
• Evergreen Ass'n, Inc. v. City of New York, 740 F.3d 233 (2d Cir. 2014)
• Ghafari v. Municipal Court, 87 Cal. App. 3d 255 (1978)
• Griset v. Fair Political Practices Commission, 25 Cal. 4th 688 (2001)
• Hurley v. Irish-American GLB Group of Boston, 515 U.S. 557 (1995)
• Janus v. AFSCME, 585 U.S. 878 (2018)
• Kentucky Right to Life, Inc. v. Terry, 108 F.3d 637 (6th Cir. 1997)
• Lovell v. City of Griffin, 303 U.S. 444 (1938)
• Majors v. Abell, 361 F.3d 349 (7th Cir. 2004)
• McIntyre v. Ohio Elections Commission, 514 U.S. 334 (1995)
• Meyer v. Grant, 486 U.S. 414 (1988)
• Miami Herald Publishing Co. v. Tornillo, 418 U.S. 241 (1974)
• NAACP v. Alabama, 357 U.S. 449 (1958)
• National Institute of Family and Life Advocates v. Becerra, 585 U.S. 755 (2018)
• Pacific Gas & Electric Co. v. Public Utilities Commission, 475 U.S. 1 (1986)
• People v. Duryea, 76 Misc. 2d 948, 351 N.Y.S.2d 978 (Sup. Ct. 1974)
• People v. White, 116 Ill. 2d 171 (1987)
• Price v. State, 622 N.E.2d 954 (Ind. 1993)
• Riley v. National Federation of the Blind, 487 U.S. 781 (1988)
• Sampson v. Buescher, 625 F.3d 1247 (10th Cir. 2010)
• Schuster v. Municipal Court, 109 Cal. App. 3d 887 (1980)
• State v. Acey, 633 S.W.2d 306 (Tenn. 1982)
• State v. Barney, 92 Idaho 581 (1968)
• State v. Fulton, 337 So. 2d 1066 (La. 1976)
• State v. Moses, 390 So. 2d 1314 (La. 1980)
• State v. North Dakota Education Association, 262 N.W.2d 731 (N.D. 1978)
• Talley v. California, 362 U.S. 60 (1960)
• Tattered Cover, Inc. v. City of Thornton, 44 P.3d 1044 (Colo. 2002)
• Watchtower Bible & Tract Society v. Village of Stratton, 536 U.S. 150 (2002)
• West Virginians for Life, Inc. v. Smith, 919 F. Supp. 954 (S.D. W. Va. 1996)
• Wilson v. Stocker, 819 F.2d 943 (10th Cir. 1987)
• Wooley v. Maynard, 430 U.S. 705 (1977)

Target: "Refusal" Cases for Overturning

To force compliance, we need to strike down the lower court rulings that incorrectly treat disclaimers as "minimal burdens" or apply a lower standard than McIntyre:

1. Seymour v. Village of Shorewood Hills, 755 F. Supp. 2d 1057 (2010) (Refused to apply McIntyre to signs).
2. Morefield v. Moore, 540 S.W.2d 866 (Ky. 1976) (Refused to follow Talley for political ads).

 

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF INDIANA
SOUTH BEND DIVISION

ROBBIN STEWART

,
Plaintiff,

v.

STARKE COUNTY ELECTION BOARD,
[NAME OF BOARD MEMBER 1], in individual capacity,
[NAME OF BOARD MEMBER 2], in individual capacity,
[NAME OF BOARD MEMBER 3], in individual capacity,

THERESE PUGH

,

DAVID SINN

,

JUSTIN RISNER

,

MARGARET BARLOG

, and

MARK BARLOG

,
Defendants.

Case No.: ___________

---

COMPLAINT FOR VIOLATION OF CIVIL RIGHTS (42 U.S.C. § 1983)

Plaintiff,

Robbin Stewart

, by counsel, alleges as follows:

I. INTRODUCTION

1. This is a civil rights action for nominal and actual damages arising from a coordinated conspiracy between a government body and five private citizens to enforce a void statute, silence dissent, and harass a senior citizen under color of law.
2. Defendants utilized Ind. Code § 3-9-3-2.5—a statute already declared constitutionally suspect in Stewart v. Taylor—to conduct a quasi-judicial "Star Chamber" where Plaintiff’s counsel was gagged to prevent notice of the law's invalidity.

II. JURISDICTION AND VENUE

3. This action arises under 42 U.S.C. § 1983 and the First and Fourteenth Amendments. Jurisdiction is proper under 28 U.S.C. § 1331.
4. Venue is proper in the Northern District of Indiana as the events occurred in Starke County.

III. PARTIES

5. Plaintiff
   Robbin Stewart
   is a citizen and a Republican candidate for Clerk in Marion County, appearing in Starke County as a proposed expert witness on election law.
6. Defendant Starke County Election Board is a government entity. The individual Board members are sued in their individual capacities.
7. Defendants
   Pugh
   ,
   Sinn
   ,
   Risner
   , and the Barlogs ("The Five Complainants") are private citizens who acted as State Actors by jointly conspiring with the Board.

IV. FACTUAL ALLEGATIONS

8. On or about February 2026, the Board held a quasi-judicial hearing regarding disclaimer violations against a "nice old lady" (Respondent).
9. The Board afforded the Five Complainants a platform to openly threaten the Respondent with jail and fines under IC § 3-9-3-2.5.
10. Plaintiff’s counsel was present to offer Plaintiff as an expert witness to provide Notice of Invalidity, specifically citing the anonymity protections in Stewart v. Taylor.
11. The Board and the Five Complainants reached a "meeting of the minds" to prevent this notice. The Board ordered Plaintiff’s counsel to be silent, effectively "gagging" the only person capable of making a constitutional record.
12. Because IC § 3-9-3-2.5 is void ab initio, the Board acted ultra vires and without subject matter jurisdiction.

V. CLAIMS FOR RELIEF

COUNT I: Conspiracy to Deprive Constitutional Rights (42 U.S.C. § 1983)
13. The Defendants engaged in joint activity to suppress protected speech and deny Due Process.
14. The "Asymmetric Gag" (hearing the conspirators while silencing the expert's counsel) constitutes Viewpoint Discrimination.

COUNT II: First Amendment Retaliation & Chilling Effect
15. The harassment of the Respondent and the silencing of the Plaintiff's counsel created an objective chilling effect on Plaintiff’s own political speech and candidacy.

VI. PRAYER FOR RELIEF

Plaintiff requests:

• ✅ Nominal Damages of $1.00 to vindicate the constitutional right.
• ✅ Actual Damages for emotional distress, reputational harm, and chilled speech.
• ✅ Punitive Damages against the individuals for willful blindness and malice.
• ✅ Declaratory Judgment that IC § 3-9-3-2.5 is void.

---

Do you have the specific names of the Board members and the "nice old lady" to finalize the party descriptions?

 

May 2024 involved four private citizens (

Therese Pugh

,

David Sinn

,

Justin Risner

, and

Margaret/Mark Barlog

) who filed complaints against candidate

Debbie Wappel

for missing campaign disclaimers.

If your client intends to sue private citizens for "conspiring to chill speech," you must navigate several significant legal hurdles.

1. The Challenge of Suing Private Complainants

Suing private citizens for filing government complaints is difficult due to several protections:

• The Noerr-Pennington Doctrine: This legal principle generally protects private parties from liability for exercising their First Amendment right to petition the government for a redress of grievances, even if their motive is to "chill" a competitor's speech.
• Anti-SLAPP Laws: Indiana’s Anti-SLAPP (Strategic Lawsuit Against Public Participation) statute (IC 34-7-7) protects individuals who speak out on matters of public interest. If a court finds your lawsuit is aimed at punishing them for their protected petitioning, the case can be dismissed quickly, and your client may be ordered to pay their attorney fees.

 (citing Whittington v. State, 669 N.E.2d 1363, 1370 (Ind. 1996); Price v. State, 622
N.E.2d 954, 960 (Ind. 1993)).
16. Id. at 493 n.3 (citing statutes from Massachusetts, Arkansas, Maine, and California
creating rights to actions for damages for state constitutional violations).
17. Id. at 493 (citing IND. CODE §§ 33-23-12-1 to -3 (2004)).

STATE OF INDIANA
IN THE [INSERT COUNTY] [CIRCUIT/SUPERIOR] COURT

[YOUR NAME], Defendant,
v. CASE NO. [INSERT CASE NUMBER]
[PLAINTIFF AGENCY], Plaintiff.

DEFENDANT’S VERIFIED MOTION TO VACATE VOID JUDGMENT AND EMERGENCY REQUEST FOR STAY OF ENFORCEMENT

The Defendant, [Your Name], appearing pro se, respectfully moves this Court pursuant to Indiana Trial Rule 60(B)(6) and (B)(8) to vacate the Abatement Order issued on [Date]. This Motion is based on jurisdictional defects, constitutional infirmity, and extraordinary circumstances that have rendered the continued enforcement of this Order a threat to public safety and human life.

---

I. STATEMENT OF THE CASE

This matter involves a "quasi-criminal" enforcement action regarding the Defendant’s property, a historic parsonage built circa 1917 for Tuxedo Baptist Church. Despite the Defendant’s status as an ordained minister and his documented efforts to restore the property to its original charitable use, the Plaintiff Agency obtained an order for physical invasion via "bulldozers and guns." The execution of this order has resulted in a catastrophic breakdown of the Due Course of Law and the creation of a lethal environment for the residents.

---

II. THE ORDER IS VOID FOR CONSTITUTIONAL INFIRMITY

1. Standard of Proof: Following the framework of Price v. State (1993), the State may not "materially burden" a core constitutional value—such as political speech or the "free interchange of thought"—without proving a particularized harm. Here, the Court applied a "preponderance of the evidence" standard to authorize a high-intrusion armed invasion. Because the proceeding has "harsh and far-reaching effects," Article I, Section 12 and the Fourteenth Amendment require Clear and Convincing Evidence. An order issued on a deficient standard is void ab initio.
2. Unconstitutional Taking: The execution of the Order resulted in the seizure of approximately $111,000 in personal property without compensation being "first assessed and tendered" as required by Article I, Section 21.

---

III. LACK OF SUBJECT MATTER JURISDICTION

The Plaintiff failed to exhaust mandatory administrative remedies under the Administrative Orders and Procedures Act (AOPA).

1. Written Non-Waiver: Defendant previously filed a written Non-Waiver of Administrative Rights, demanding a formal hearing for all proposed actions.
2. Failure to Exhaust: By bypassing the requested hearing and moving directly to judicial enforcement, the Plaintiff deprived this Court of Subject Matter Jurisdiction. A judgment entered without jurisdiction is void under Rule 60(B)(6).

---

IV. FRAUD ON THE COURT AND UNCLEAN HANDS

The Plaintiff’s agents have engaged in a pattern of misconduct that taints the equity of this proceeding:

• Perjury: Witness [Inspector 2] provided demonstrably false testimony regarding the property's utilities (electricity) to secure the order.
• Criminal Misconduct: The initial investigation involved mailbox tampering by [Inspector 1] and an unauthorized ex parte trespass by Agent Chip Jefferson to coerce an "informal resolution" outside the presence of Defendant's counsel.

---

V. EXTRAORDINARY CIRCUMSTANCES AND THE PUBLIC INTEREST

Under Rule 60(B)(8), relief is justified by the "body count" and destabilization resulting from this Order:

1. Loss of Life: Since the invasion, three individuals—Vegas, Gary, and Honesty Rady—have died. A fourth, TJ, was reportedly murdered during the ongoing destabilization.
2. Physical Injury: Occupant Michelle was hospitalized with a broken spleen, and Dawn was recently mauled in the chaotic environment created by the State's presence.
3. Vulnerable Occupants: The Order ignores the presence of Kenny (70), who is bedridden, and others who have been displaced into homelessness.
4. Predatory Intent: Evidence suggests the complaints were manufactured by a neighboring LLC in an extortionate scheme to force the Defendant to sell his "castle" for private commercial development.

---

VI. EMERGENCY MEDICAL NECESSITY

The destruction of the Defendant’s farm—an essential, life-sustaining mental health practice for his diagnosed Major Depressive Disorder—has placed the Defendant in a state of acute nervous prostration. This "State-Created Danger" has rendered the Defendant bedridden and unable to work. To continue enforcement is to place the Defendant’s life in immediate, irreparable jeopardy.

---

RELIEF SOUGHT

Defendant respectfully requests that the Court:

1. Vacate the Order as void under Rule 60(B)(6);
2. Issue an Immediate Stay of Enforcement to prevent further loss of life or property;
3. Schedule an Evidentiary Hearing to address the Plaintiff’s misconduct and the jurisdictional failures.

I affirm, under the penalties for perjury, that the foregoing representations are true.

Respectfully submitted,

[Your Signature]
[Your Address]

---

Would you like me to prepare the "Proposed Order" for the Judge to sign, which officially stops the bulldozers pending the hearing?