HAMILTON COUNTY COURT OF COMMON PLEAS PROBATE DIVISION HAMILTON COUNTY, OHIO IN RE: Case No. REMOVAL OF TAMAYA DENNARD FROM THE PUBLIC OFFICE OF JUDGE RALPH WINKLER MEMBER OF CINCINNATI CITY COUNCIL . VERIFIED COMPLAINT CITY OF CINCINNATI ex rel. PURSUANT TO RC. 733.72 MARK W. MILLER 3630 Zumstein Avenue Cincinnati, Ohio 45208, Relator-Complainant v. TAMAYA DENNARD Respondent. Now comes the Relator?Complainant, MARK W. MILLER, and, pursuant to Ohio Rev. Code 733.72 et seq, alleges as follows: 1. MARK W. MILLER is a resident and elector within the CITY OF CINCINNATI. 2. The CITY OF CINCINNATI is a municipal corporation as that term is used in Ohio Rev. Code 733.75. 3. The legislative authority of the CITY OF CINCINNATI is the Cincinnati City Council, composed of nine voting members. 4. TAMAYA DENNARD is a member of the Cincinnati City Council, having assuming such public of?ce in Janualy 2018 and she continues to hold such public of?ce. 5. Attached hereto as Exhibit 1 is a Criminal Complaint, together with the A?tdavit in Support of a Criminal Complaint, ?led against TAMAYA DENNARD on February 24, 2020, in the United States District Court for the Southern District of. Ohio, in a case styled United States v. Tamaya Dennard and assigned Case No. ?00198. 6. As developed more fully in the A?ia?avit in Support of a Criminal Complaint, the contents of which are incorporated herein by reference, TAMAYA DENNARD has solicited, accepted, and received money from at least one private individual in exchange for taking of?cial action in capacity as a member of the Cincinnati City Council. 7. By engaging in the conduct set forth in the A?idavit in Support of a Criminal Complaint, TAMAYA DENNARD has, as a member of the Cincinnati City Council, received, directly or indirectly, compensation for her services as a member of the Cincinnati City Council, contrary to law. 8. By engaging in the conduct set forth in the A?idavit in Support of a Criminal Complaint, TAMAYA DENNARD has, as a member of the Cincinnati City Council, received, directly or indirectly, compensation for her services as a member of the Cincinnati City Council, contrary to law. 9. By engaging in the conduct set forth in the A?idavit in Support of a Criminal Complaint, TAMAYA DENNARD has, as a member of the Cincinnati City Council, is or has been guilty of misfeasance or malfeasance in of?ce. 10. Pursuant to Ohio Rev. Code 733.76, upon trial and proof of TAMAYA DENNARD, as a member of the Cincinnati City Council, either: having received, directly or indirectly, compensation for her services as a member of the Cincinnati City Council, contrary to law; or (ii) having engaged in misfeasance or malfeasance in of?ce, TAMAYA DENNARD is subject to the immediately removal from the public of?ce of a member of the Cincinnati City Council. WHEREFORE, the Complainant, together with the other electors, hereby pray that: A. The Court proceed forthwith with the process and procedure provided for in Ohio Rev. Code 733.72 et seq, with respect to the allegations set forth above, including, without limitation: 1. the forthwith issuance of citation to TAMAYA DENNARD for her appearance before this Court within 10 days from the ?ling of this Complaint; 2. to provide notice to Raul Boggs Muething, the Cincinnati City Solicitor, of this Complaint and the mandate to TAMAYA DENNARD to appear before this Court within 10 days from the ?ling of this Complaint; 3. to set this action for trial not more than 10 days after the return the foregoing citation to TAMAYA DENNARD at which time Paul Boggs Muething, the Cincinnati City Solicitor, shall proceed, pursuant to Ohio Rev. Code 733.73, to conduct the prosecution of this action against TAMAYA B. upon proof of the guilt of TAMAYA DENNARD to the foregoing charges, to enter an order removing TAMAYA DENNARD from the public of?ce of a member of the Cincinnati City Council. C. To undertake and perform any other actions or remedies required or allowed by law. Respectfully submitted, Curt C. Hartman (0064242) THE LAW FIRM 0F Cunt C. HARTMAN 7394 Ridgepoint Drive, Suite 8 Cincinnati, OH 45230 (513) 379?2923 Attorney for Relar0r~C0mplainant