DO NOT FILE - DISCUSSION DRAFT
FOR REVIEW AND REVISION ONLY
***
STATE OF INDIANA ) IN THE MARION COUNTY SUPERIOR COURT
) SS: TRAFFIC / MUNICIPAL ORDINANCE DIVISION
COUNTY OF MARION ) MARION COUNTY SUPERIOR COURT 33
CITY OF INDIANAPOLIS, )
)
Plaintiff, )
)
v. ) CASE NO. 49D33-2411-OV-041405
)
ROBBIN STEWART, )
)
Defendant. )
***
### DEFENDANT’S REQUEST FOR STIPULATION OF FACTS TO PLAINTIFF
The Defendant, Robbin Stewart, pro se, requests that the Plaintiff, City of
Indianapolis, by counsel Hannah Lynette Hulsey, Assistant City Prosecutor,
admit or deny the following Stipulations of Fact within thirty (30) days of
service.
Pursuant to Indiana practice, these stipulations are served directly upon
counsel of record to narrow the issues for trial and simplify the record:
#### I. IDENTITY, STATUS, AND OWNERSHIP OF THE ANIMAL
1. The companion animal at the center of this ordinance enforcement action is a
dog named Chico.
2. At all relevant times, the legal owner of Chico was an individual named
Rocco, whose current whereabouts are unknown.
3. Alternatively, at all relevant times, Chico belonged to Dawn Young, residing
at 4015 E. Washington Street, Indianapolis, Indiana.
4. Defendant Robbin Stewart resides at the same 4015 E. Washington Street
address and walks Chico, but Defendant states that Chico is not his dog and
Defendant does not know whose dog Chico is.
5. At the time of the underlying occurrences, Defendant Robbin Stewart's
relationship to Chico was strictly limited to that of a temporary custodian.
6. Under Indiana statutory law and common law, a domestic dog is legally
classified as personal property or chattel, and an animal lacks independent
legal standing to sue or be sued.
7. Defendant Robbin Stewart, appearing pro se, asserts his own independent
constitutional and economic rights in this action, while simultaneously acting
as a protective stand-in for the status and survival interests of Chico, who is
the real party in interest affected by the City's operational penalties.
#### II. THE EXTORTION SCHEME AND ARMED CONFRONTATION
8. Prior to the issuance of the municipal citation, while Dawn Young was acting
as Chico’s owner and caretaker, Chico is alleged to have caused minor property
damage to the complaining witness (the neighbor/alleged victim).
9. Based on this alleged property damage, the complaining witness issued an
unlawful demand to Defendant Stewart for a cash payment of $100. Defendant
Stewart refused to pay.
10. While the complaining witness may have initially possessed a colorable,
legitimate civil claim for property damage against Defendant Stewart as a
resident or property controller, any such legitimate claim was entirely
forfeited and offset the moment the complaining witness visibly displayed a
firearm to threaten Defendant Stewart.
11. Following the complaining witness's display of the firearm, Defendant
Stewart sought immediate protective backup from two individuals known as
"Batman" and "Dusty."
12. During the ensuing confrontation, "Batman" was armed with a machete, and
"Dusty" was positioned on-scene as potential armed or unarmed backup.
13. Faced with this immediate defensive intervention, the complaining witness
backed down and retreated from the immediate physical confrontation.
14. As a direct consequence of this life-threatening event, Defendant Stewart
remains under a non-monetary, personal obligation to "Batman" and "Dusty" for
risking their lives to protect his safety.
15. Following the armed standoff, the complaining witness has refused to engage
in legitimate, peaceful civil settlement discussions. Instead, the complaining
witness has twice issued subsequent demands for money to Defendant Stewart,
constituting an ongoing, violent extortion scheme under color of threat rather
than a legitimate settlement discussion.
16. The complaining witness has further maintained a continuous pattern of
taunting and threatening Chico.
#### III. THE FABRICATED BITING INCIDENT AND POLICE RESPONSE
17. On the day following the armed standoff and extortion refusal, Chico is
alleged to have bit the complaining witness.
18. Defendant Stewart was not present during this second encounter, did not
observe the alleged biting incident, and possesses no first-hand, personal
knowledge of the facts of the encounter. All details regarding the alleged
bite constitute out-of-court hearsay reported by third parties.
19. According to third-party reports, Chico was acting protectively to defend
the property and Defendant Stewart’s interests at the exact time the
complaining witness approached to threaten and taunt the animal.
20. Upon being served with the municipal citation by the responding police
officer, Defendant Stewart insisted that the officer return to the physical
scene, take an official report, and open an investigation into the complaining
witness for criminal elder abuse.
21. The responding police officer and the responding animal control officer are
distinct and separate individuals.
22. The specific details and narrative regarding the elder abuse report and the
prior day's firearm threat are within the possession of the Indianapolis
Metropolitan Police Department and should be contained inside the official
police report.
23. As of the date of this request, the Plaintiff City has failed to produce
or tender the complete police report to Defendant Stewart.
***
Respectfully submitted,
_________________________________________
Robbin Stewart, Defendant Pro Se
4015 E. Washington Street
Indianapolis, IN 46201
***
### CERTIFICATE OF SERVICE
I hereby certify that a true and accurate copy of the foregoing document was
served upon the following counsel of record via the Indiana Electronic Filing
System (IEFS) [or specify alternative delivery method] this _____ day of
________________, 2026:
Hannah Lynette Hulsey, Assistant City Prosecutor
Office of Corporation Counsel, City of Indianapolis
200 E. Washington Street, Suite 1601
Indianapolis, IN 46204
_________________________________________
Robbin Stewart, Defendant Pro Se
Use code with caution.
Corrections Applied:
- Omitted Paragraphs: Former structural arguments (Paragraphs 8 and 9) have been entirely removed.
- Verbiage Streamlined: In Paragraph 20 (formerly 22), the duplicate word "demanded" has been removed, keeping only "insisted."
- Officer Roles Separated: A new Paragraph 21 has been added to explicitly clarify that the police officer and the animal control officer are distinct individuals.
Please copy and save this corrected document into your Word or Text editor file to ensure it is locked in for your Friday preparation.
To finalise the paperwork, let me know if you would like me to draft the standard Notice of Service of Discovery/Stipulations to officially file with the Court 33 Clerk.
AI can make mistakes, so double-check responses
You said: if the state intends to coniue, we will need depositions of victim, animal control officer and police officer. draft a memo to o c asking how we best set that up
text
DO NOT FILE - DISCUSSION DRAFT
FOR REVIEW AND REVISION ONLY
***
MEMORANDUM
TO: Hannah Lynette Hulsey, Assistant City Prosecutor
Office of Corporation Counsel, City of Indianapolis
FROM: Robbin Stewart, Defendant Pro Se
DATE: May 28, 2026
RE: Deposition Scheduling Coordination / Case Status
City of Indianapolis v. Robbin Stewart, Case No. 49D33-2411-OV-041405
***
Ms. Hulsey,
If the City intends to continue with the prosecution of this ordinance
violation, the Defendant will require the oral depositions of three material
witnesses to properly prepare his defense:
1. The complaining witness (the neighbor/alleged victim);
2. The responding Indianapolis Metropolitan Police Department officer; and
3. The responding Indianapolis Animal Care Services animal control officer.
Pursuant to the Indiana Rules of Trial Procedure, please advise as to how your
office would best prefer to coordinate and set up the scheduling for these
examinations.
Please provide the upcoming availability of the city officials, as well as any
known scheduling parameters or preferred dates for the complaining witness, so
we may locate a mutually convenient time and location for all parties within
the next thirty (30) days.
If the City requires the issuance of formal subpoenas under Trial Rule 45 to
secure the attendance of the non-party complaining witness, please indicate if
your office will accept service on his behalf or if independent service is
necessary.
I look forward to your prompt response so we can establish an orderly discovery
timeline and avoid unnecessary motion practice before Court 33.
Respectfully submitted,
_________________________________________
Robbin Stewart, Defendant Pro Se
4015 E. Washington Street
Indianapolis, IN 46201
Use code with caution.
Please copy and save this memorandum block into your case management files alongside your requests for stipulations. It provides a formal, paper-trail notification that satisfies your duty to cooperate under the civil discovery rules before you file any motions with the judge.
To move forward with your scheduling for the weekend, do you want me to draft the standard Notices of Deposition or the Subpoena Duces Tecum forms to have ready in case she fails to provide dates?
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