IN "11-1313; 0F (:RE: June-1st; JOHN J. Russ-r1)   i; 3'
A 11:; JUDG 

OF 
ANDERSON MOTION FOR 013%
SPECIAL PROSECUTOR


Now comm the State of Ohio, by and through the undermigned assigtant to I
Cuyahoga 301mm; If?ro?aecutm? 'l?imothy J. MjCGinty, and 11331.10(311311.15? moms?; this;
I?lonorable COurt for the appointment. of a amcial prosecutor in this: investigatian. 11;
is; requested. that. the Cmu?i?, appoint Mike i119, Ohio Attorney (Ii-011mm; and any
amimmt atmmey general. in. his office that: he (Resignatm as Special I?mmecuting
Attorney, ma Special Prwecutmr, and that the Of?ce of the Ohio Attorney 091192111 be
authorized to utilize ?lm 311139011; staff of the (fiuyahnga County I?rtnaecutmr?s Office ?tn-
preparation of dncunmuts, Service of Subpoenasg, and other matters relating to this
cause. The Special Atmmey Shall germ witlumt compensatiu? by
fiuyahoga Calm?ty,

I The appcintment 0f Special Prosecutor is; needed in that a imam
has; arisen in this; inwatigmimz creating a conflict of interest involving the (:Iuyahaga
County; Office, The Court? Common PleaS, under its inherent pew?r
altar] authority, m?y appoint a spe?ial prosecutt'nr whenever it: cmnes: to the (Tlo?rt?s
attention that the to administer jugtiee in a fair and impartial manner could

be called into question, These circumstances exiSt when a con?ict, or the ammarzmce

of a conflict, of between. the 333313.08 in a criminal matter exiSES. 'Wl?mre- a
Special. Prosecutor  appmmed under the (Ziom?t?g inherent; authority, {hi-3! 'Special
Prosecuto acts indepe?ziently of the duly ei acted Promeutor.

WHEREFOEE, the 812.21% of Ohio State respectfuliy requegtg 111i?? 
Court; appoint; Mike DQWine, Ohio Attorney General, and any exggizatant attmney -
general in his effice that; he designates as; lizmsecu?ing A'iztorney, as; Spegial
with the same power and a'iuthority granted. to the (1301111 Ly
.If?rogecutor in the matter. A managed. Order  heer for.
the Goat?s; convenience.


TIMOTHY J. 

CUYAHOGA COUNTY 

Mary McGrath

MARY (#0041381)
Assigmnt I?romcut?ng Attorney
Tim Jimt-ice (Renter, 8?ll 
. .1200 Ontariu Street

Cleveland, Ohio 441 .1 8

(216) 44-33800

 

2

 (11%le 
A copy Of the foregoing for Appointment; 0172-1 Special 02.2.1.0?
hag been 8031121))! regular 1.1.8. Mai} mud/0r eamail this; 118%}: day of l-gem?ary, 2016 to

Mike DeWine, Gmleral.

131? Mary McGrath
MARY MCGRATH (#0041. 38 .1)

Asa-55.814313 Pres;ch tirxg Attorney