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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF INDIANA
HAMMOND DIVISION
VERONICA ROMERO, individually and as
parent and next friend of B.Y.R. and I.R.,
and MAYRA YVETTE RIVERA
Plaintiffs,
v.
MICHAEL A. BROWN, in his official
capacity as LAKE COUNTY CLERK;
WILLIAM C. VANNESS II, M.D., in his
official capacity as the COMMISSIONER,
INDIANA STATE DEPARTMENT OF
HEALTH; and GREG ZOELLER, in his
official capacity as INDIANA ATTORNEY
GENERAL,
Defendants.
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Civil Action No. 2:14-cv-0325
PLAINTIFFS VERONICA ROMERO, MAYRA YVETTE RIVERA, B.Y.R., AND I.R.S
MOTION FOR TEMPORARY RESTRAINING ORDER
Pursuant to Rule 65 of the Federal Rules of Civil Procedure, Plaintiffs Veronica Romero,
Mayra Yvette Rivera, B.Y.R., and I.R. respectfully move the Court for a temporary restraining
order that immediately: (1) enjoins Defendants and all those acting in concert from enforcing the
Indiana laws against recognition of Plaintiffs Veronica Romero and Mayra Yvette Riveras legal
out-of-state marriage as applied to them; and (2) should Plaintiff Mayra Yvette Rivera pass away
in Indiana, orders William C. VanNess II, M.D., in his official capacity as the Commissioner of
the Indiana State Department Of Health, and all those acting in concert, to issue a death
certificate that records her marital status as married and that lists Plaintiff Veronica Romero as
the surviving spouse; said order shall require that Defendant VanNess issue directives to local
health departments, funeral homes, physicians, coroners, medical examiners, and others who
case 2:14-cv-00325-JVB-PRC document 2 filed 09/08/14 page 1 of 3
may assist with the completion of said death certificate explaining their duties under the order of
this Court. A Memorandum of Law in Support of Plaintiffs Motion is filed herewith for the
Courts consideration. To verify the facts therein, Plaintiffs have attached Exhibit A to the
Supporting Memorandum. A proposed order is attached
Notice will be provided to the Defendants, but due to the extraordinary nature of Plaintiff
Mayra Yvette Riveras rapidly deteriorating health condition, Plaintiffs request an immediate
ruling on the merits and entry of a temporary restraining order. Plaintiffs further request that
they be exempted from the Federal Rule of Civil Procedure 65(c) bond requirement.
* * *
case 2:14-cv-00325-JVB-PRC document 2 filed 09/08/14 page 2 of 3
Dated: September 8, 2014 Respectfully submitted,
/s/ J. Michael Hearon
Lucy R. Dollens, #23547-49
J. Michael Hearon, #31597-49
QUARLES & BRADY LLP
135 North Pennsylvania Street
Indianapolis, Indiana 46204
(317) 957-5000
lucy.dollens@quarles.com
michael.hearon@quarles.com
Steven V. Hunter (pro hac vice)
QUARLES & BRADY LLP
300 North LaSalle Street, Suite 4000
Chicago, Illinois 60654
(312) 715-5000
steven.hunter@quarles.com
Camilla B. Taylor (pro hac vice)
LAMBDA LEGAL DEFENSE &
EDUCATION FUND, INC.
105 West Adams, Suite 2600
Chicago, Illinois 60603
(312) 663 4413
ctaylor@lambdalegal.org
Counsel for Plaintiffs
case 2:14-cv-00325-JVB-PRC document 2 filed 09/08/14 page 3 of 3