Sample pleading format:



DAVID MARBURGER,                     )

       CASE NO.                                    )

     Plaintiff,                                          )          JUDGE


                  vs.                                      )


CITY OF CLEVELAND,                   )          COMPLAINT


     Defendant.                                      )

1. Plaintiff is a freelance journalist who writes and causes to be published news and information of public interest to the general public of northeast Ohio.

2. Defendant is a municipality of Ohio.

3. On January 3, 2001, plaintiff transmitted a letter to the Director of the Planning Commission of the City of Cleveland, an agent and official of the defendant, asking to inspect certain public records of the City. A copy of that request is attached as Exhibit 1.

4. On January 5, 2001, the Director of the Planning Commission notified plaintiff that the Director would not comply with the request.

5. Pursuant to R.C. 149.43 [Ohio's Public Records Act], plaintiff has a clear legal right to inspect the requested records, and defendant has a clear legal duty to make the requested records available for inspection by plaintiff and any other interested citizen. Defendant's refusal to allow the requested inspection violated plaintiff's clear legal right and defendant's clear legal duty.

6. Defendant has no valid justification or excuse for refusing the requested inspection.

7. Plaintiff is entitled to a writ of mandamus compelling defendant to permit the requested inspection; plaintiff has no adequate alternative remedy in the ordinary course of the law.

                                  Respectfully submitted,

                                  David L. Marburger

                                  1900 E. 9th St.

                                  Cleveland, Ohio 44114

                                  (216) 621-0200