IN THE CIRCUIT COURT FOR THE COUNTY OF ST. LOUIS, MISSOURI
CAMPAIGN FOR ACCOUNTABILITY,
660 Pennsylvania Ave., SE, Ste. 303,
Washington, DC 20003,
Relator,
V.
CIRCUIT COURT CLERK JOAN M. GILMER,
TWENTY-FIRST CIRCUIT FOR THE
COUNTY OF ST. LOUIS,
Respondent.
REAL PARTIES AT INTEREST:
ANDREW F. PUZDER,
C/O Jerome F. Raskas, Attorney,
7701 Clayton Road,
St. Louis, MO 63117
and
LISA PUZDER HENNING,
C/O Alisse Cheryl Camazine, Attorney,
165 N. Meramec Ave., Ste. 110,
St. Louis, MO 63105
Interested Parties.

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Case No. ________________
Division

PETITION FOR WRIT OF PROHIBITION
COMES NOW Relator, by and through counsel, and for its Petition for Writ of
Prohibition states and alleges as follows:
1. That this is a civil action seeking an order of the Court pursuant to Section
452.4301, as further set out below, and pursuant to Supreme Court Rule 972.

1

All references to statutes herein are to the Revised Statues of Missouri (2016).

2

Mo. Sup. Ct. R. 97.

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17SL-CC00433

3. That Relator Campaign for Accountability is a not-for-profit corporation in good
standing in the District of Columbia and has applied for recognition as a 501(c)(3) with the
Internal Revenue Service, with its principal offices in Washington, D.C.
4. That the identified parties of interest named in this petition formerly were plaintiff
and defendant in certain matters which were before the Circuit Court of the State of
Missouri, 21st Circuit for the County of St. Louis, specifically in Case Numbers 21482862,
21577367, 21546046, 21546046-01 and 21546046-02, during the period between 1982 to
1997, and which are identified by their names in court docket records for those cases in the
21st Circuit for the County of St. Louis, all of which are attached as Exhibit A to this Petition.
5. That Section 452.430 states "All pleadings and filings in a dissolution of marriage
... or modification ... filed prior to August 28, 2009, ... shall be subject to inspection only by
the parties, an attorney of record, ... or upon order of the court for good cause shown."
6. That Relator has attempted to access the cases cited above, as set out in the
attached affidavit marked as Exhibit B, but has been unable to gain access to those court
records in that Relator is not a party to the cases, and is not within the class of all the parties
who are identified in Section 452.430 as having access to the pleadings in these cases
identified above without order of this Court.
7. That a party at interest, Andrew F. Puzder, has been named by United States
President Donald Trump as his designated nominee for Secretary of Labor and his
confirmation is pending before the United States Senate at this time.
8. That pursuant to the United States Constitution, Art. II, Sec. 2, the United States
Senate has the authority to provide "Advice and Consent" in regard to the United States
President's nominations for cabinet officials, including the Secretary of Labor. Therefore,

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2. That the Court has jurisdiction over this action pursuant to Section 452.430.

information regarding his prior marriage and his divorce proceeding, which was heard in the
21st Circuit Court, State of Missouri - are of high interest and concern to the members of the
Senate Health, Education, Labor and Pensions Committee, who will conduct the hearing on
Mr. Puzder's nomination, as well as the public at large.
9. That further, given that he has accepted the nomination and agreed to provide the
U.S. Senate with considerable information that otherwise would remain private, Andrew
Pudzer has acknowledged the position he seeks makes him a public figure. As a result, any
right to privacy that he might claim to documents in the case files that might be considered
closed pursuant to Section 452.430 should be overriden by this Court.
10. That attached to this petition is Relator's Suggestions in Support, which are
incorporated herein.
WHEREFORE, Relator requests that a preliminary order in Prohibition be issued by
this Court commanding Respondent to file an answer directed to this petition.
Respectfully submitted,
/s/ Jean Maneke
Jean Maneke, Mo. Bar 28946
THE MANEKE LAW GROUP, L.C.
420 Nichols Road, Ste. 200
Kansas City, MO 64112
(816) 753-9000
Facsimile: (816) 753-9009
jmaneke@manekelaw.com
ATTORNEYS FOR RELATOR

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information regarding the background and prior acts of Andrew Puzder - including