Robert Joseph McGraw Properties, LLC

 HEALTH AND HOSPITAL CORPORATION ) OF MARION COUNTY, ) ) Plaintiff / ) Counter-Defendant, ) ) v. ) ) ROBBIN STEWART, ) ) Defendant / Counter- ) Plaintiff / Third-Party ) Plaintiff, ) DEFENDANT’S SUPPLEMENTAL REQUEST FOR PRODUCTION OF SYSTEMIC OPERATIONAL DATA Comes now the Defendant, Robbin Stewart, pro se, and pursuant to Rules 26 and 34 of the Indiana Rules of Trial Procedure, requests that the Plaintiff, Health and Hospital Corporation of Marion County, produce the following operational data and administrative records within thirty (30) days of service of this request: 1. Any and all annual, quarterly, or monthly data logs kept by the Plaintiff from January 1, 2021, to the present detailing the total number of civil petitions filed seeking the judicial destruction, euthanasia, or permanent removal of domestic canines or puppies under Marion County Code Chapter 799. 2. Copies of all finalized chronological case summaries (CCS) or final judicial orders in Marion County where the designated counsel representing the Plaintiff successfully obtained a signed order for the euthanasia or destruction of an animal. 3. Systemic data sheets showing the percentage of animal enforcement actions initiated by the Plaintiff that were prosecuted under a preponderance of the evidence standard rather than a clear and convincing evidence standard. 4. Any formal written guidelines, internal memos, or office policy documents governing the criteria Plaintiff's legal counsel must evaluate before submitting a formal recommendation to a court seeking an animal destruction order. Dated: June 10, 2026 Respectfully submitted, ____________________________________ Robbin Stewart, Defendant Pro Se [Your Address] [Your Phone] [Your Email] CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing Discovery Request has been served upon the Plaintiff, Health and Hospital Corporation of Marion County, via the Indiana E-Filing System (IEFS) or by leaving a copy in t

STATE OF INDIANA  )                  IN THE MARION SUPERIOR COURT
                  ) SS:              CIVIL DIVISION 20
COUNTY OF MARION  )                  CASE NO. 49D20-2311-OV-045330

HEALTH AND HOSPITAL CORPORATION   )
OF MARION COUNTY,                 )
                                  )
      Plaintiff /                 )
      Counter-Defendant,          )
                                  )
v.                                )
                                  )
ROBBIN STEWART,                   )
                                  )
      Defendant / Counter-        )
      Plaintiff / Third-Party     )
      Plaintiff,                  )
                                  )
v.                                )
                                  )
JOHN DOE 1 (Primary Complainant), )
BILL DOE (Of 4007 E. Wash.),       )
JOHN DOE 3 (Caretaker), and       )
JOHN DOE 4 (Caretaker's Employer),)
                                  )
      Cross-Defendants /          )
      Third-Party Defendants.     )

   DEFENDANT’S COUNTERCLAIM, THIRD-PARTY COMPLAINT, AND CROSS-CLAIMS

Comes now the Defendant, Counter-Plaintiff, and Third-Party Plaintiff, Robbin 
Stewart, pro se, and pursuant to Indiana Rules of Trial Procedure 13, 14, and 
19, files this Counterclaim against Counter-Defendant Health and Hospital 
Corporation of Marion County, Cross-Claims against Cross-Defendant John Doe 1, 
and Third-Party Complaints against Third-Party Defendants Bill Doe, John Doe 
3, and John Doe 4, seeking joint and several damages in the amount of $165,000, 
and in support thereof, states as follows:

                               PARTIES
1. Defendant, Counter-Plaintiff, and Third-Party Plaintiff Robbin Stewart is a 
   resident of Marion County, Indiana.
2. Plaintiff and Counter-Defendant Health and Hospital Corporation of Marion 
   County (HHC) is an independent municipal corporation operating within Marion 
   County, Indiana.
3. Cross-Defendant John Doe 1 is the primary complainant in the underlying 
   ordinance enforcement action and a resident of Marion County.
4. Third-Party Defendant Bill Doe is a resident of Marion County residing at 
   4007 E. Washington Street, who houses, harbors, and actively facilitates 
   the actions of Cross-Defendant John Doe 1.
5. Third-Party Defendant John Doe 3 is an individual operating as a caretaker 
   within Marion County, Indiana.
6. Third-Party Defendant John Doe 4 is a business entity or employer doing 
   business in Marion County, Indiana, operating under the principle of 
   respondeat superior relative to the actions of John Doe 3.

                                FACTS
7. On or about [Day One Date], Cross-Defendant John Doe 1, an active user 
   of illicit controlled substances, specifically heroin, approached Third-Party 
   Plaintiff Robbin Stewart and issued an unlawful extortion demand for $100.
8. Upon refusal of the extortion demand, Cross-Defendant John Doe 1 retreated 
   into his residence, retrieved a firearm, and unlawfully displayed said 
   firearm in a threatening and intimidating manner toward Third-Party Plaintiff.
9. Third-Party Defendant Bill Doe maintained full knowledge of John Doe 1's 
   criminal conduct, actively housed him at 4007 E. Washington Street, and 
   engaged in concerted activity to facilitate an ongoing campaign of 
   harassment and extortion against Stewart.
10. Separately, Third-Party Defendant John Doe 3 placed Third-Party Plaintiff 
    in immediate apprehension of offensive, harmful physical contact by issuing 
    verbal threats to execute physical violence utilizing a firearm.
11. At all times relevant to the verbal firearm threats, John Doe 3 was 
    acting within the scope of his employment, under the direction, control, 
    and benefit of Third-Party Defendant John Doe 4.
12. On Day Two, a full twenty-four hours after the armed extortion attempt, 
    Cross-Defendant John Doe 1 entered into immediate, uninvited proximity to 
    the property and person of Third-Party Plaintiff to intentionally provoke 
    an animal interaction and manufacture a fraudulent civil liability claim, 
    in direct continuation of the prior day's extortion scheme.
13. Approximately one month prior to the alleged incident, John Doe 1 
    launched a distinct physical attack against the subject animal, causing 
    the animal to retain a defensive memory of this physical trauma.
14. Counter-Defendant HHC, through its agents, personnel, or assistant 
    prosecutors, maintained actual or constructive knowledge of the extortionate 
    scheme, the armed intimidation, and the lack of individual probable cause, 
    yet intentionally chose to process, adopt, and prosecute the manufactured 
    complaint.
15. Counter-Defendant HHC acted in concert and entered into a tacit or explicit 
    combination with John Doe 1 to validate, weaponize, and enforce the 
    fraudulent ordinance citation, thereby directly aiding, abetting, and 
    conspiring in the ongoing extortion and abuse of process against Stewart.
16. Five (5) independent eyewitnesses observed and will corroborate this 
    systemic pattern of armed intimidation, uninvited proximity, prior animal 
    abuse, governmental complicity, and manufactured fraud.

               COUNT I: CIVIL CONSPIRACY TO COMMIT EXTORTION 
            (Against HHC, John Doe 1, and Bill Doe, Jointly)
17. Counter-Plaintiff incorporates paragraphs 1 through 16 as if fully 
    set forth herein.
18. Counter-Defendant HHC, Cross-Defendant John Doe 1, and Third-Party 
    Defendant Bill Doe entered into a concerted agreement, combination, 
    and common design to accomplish an unlawful purpose, specifically: the 
    criminal extortion, intimidation, and fraudulent manufacture of civil 
    ordinance liability against Stewart.
19. Counter-Defendant HHC advanced this conspiracy by utilizing its statutory 
    enforcement authority to validate an ungrounded ticket, despite being put 
    on notice of the underlying threats, armed intimidation, and provocation.
20. As a direct and proximate result of this conspiracy, Stewart suffered 
    severe administrative, professional, financial, and personal damages.

                    COUNT II: CIVIL ASSAULT / INTIMIDATION
                     (Against John Doe 1 and John Doe 3)
21. Third-Party Plaintiff incorporates paragraphs 1 through 20 as if fully 
    set forth herein.
22. On Day One, John Doe 1 intentionally placed Third-Party Plaintiff in 
    imminent apprehension of harmful or offensive contact by displaying a 
    firearm to back up a criminal cash demand.
23. Separately, John Doe 3 intentionally placed Third-Party Plaintiff in 
    imminent apprehension of harmful or offensive contact by issuing verbal 
    threats of armed violence.
24. These actions constitute civil assault under Indiana common law, causing 
    direct emotional trauma and security costs to Third-Party Plaintiff.

             COUNT III: RESPONDEAT SUPERIOR / VICARIOUS LIABILITY
                          (Against John Doe 4)
25. Third-Party Plaintiff incorporates paragraphs 1 through 24 as if fully 
    set forth herein.
26. At all times relevant, Third-Party Defendant John Doe 3 was an employee, 
    agent, or servant acting within the clear scope of his employment with 
    Third-Party Defendant John Doe 4.
27. Under the Indiana common-law doctrine of respondeat superior, an employer 
    is liable for the tortious acts of its employees committed within the scope 
    of employment.
28. Third-Party Defendant John Doe 4 is vicariously liable for the torts and 
    armed threats committed by its employee against Third-Party Plaintiff.

                          PRAYER FOR RELIEF
WHEREFORE, Defendant, Counter-Plaintiff, and Third-Party Plaintiff Robbin 
Stewart respectfully requests that this Court enter judgment in his favor and 
against Counter-Defendant HHC, Cross-Defendants, and Third-Party Defendants, 
jointly and severally, for compensatory damages, consequential damages, and 
punitive damages in the total amount of ONE HUNDRED SIXTY-FIVE THOUSAND DOLLARS 
($165,000.00), alongside the costs of this action, and all other just and 
proper relief.

Dated: June 10, 2026

                                    Respectfully submitted,

 STATE OF INDIANA ) IN THE MARION SUPERIOR COURT ) SS: CIVIL DIVISION 20 COUNTY OF MARION ) CASE NO. 49D20-2311-OV-045330 HEALTH AND HOSPITAL CORPORATION ) OF MARION COUNTY, ) ) Plaintiff, ) ) v. ) ) ROBBIN STEWART, ) ) Defendant. ) ORDER The Court, having reviewed Defendant’s Motion for Continuance, now finds that said Motion should be GRANTED. IT IS THEREFORE ORDERED that the hearing currently scheduled for June 15, 2026, is hereby VACATED. This matter is rescheduled for a hearing on the _____ day of ________________, 2026, at ________ ___.m., which date shall be not less than thirty (30) days from the date of this Order. SO ORDERED this _____ day of ________________, 2026. ____________________________________ Judge, Marion Superior Court

 COUNTY OF MARION ) CASE NO. 49D20-2311-OV-045330

HEALTH AND HOSPITAL CORPORATION   )
OF MARION COUNTY,                 )
                                  )
      Plaintiff,                  )
                                  )
v.                                )
                                  )
ROBBIN STEWART,                   )
                                  )
      Defendant.                  )

                               ORDER

The Court, having reviewed Defendant’s Motion for Jury Trial, and being duly 
advised in the premises, now finds that said Motion should be GRANTED.

IT IS THEREFORE ORDERED that this matter shall be set for a trial by jury. The 
Court Clerk is directed to calendar this cause accordingly and issue notice to 
the parties.

SO ORDERED this _____ day of ________________, 2026.

                                    ____________________________________
                                    Judge, Marion Superior Court

Use code with caution.

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 STATE OF INDIANA ) IN THE MARION SUPERIOR COURT

                  ) SS:              CIVIL DIVISION 20
COUNTY OF MARION  )                  CASE NO. 49D20-2311-OV-045330

HEALTH AND HOSPITAL CORPORATION   )
OF MARION COUNTY,                 )
                                  )
      Plaintiff,                  )
                                  )
v.                                )
                                  )
ROBBIN STEWART,                   )
                                  )
      Defendant.                  )

                         MOTION FOR JURY TRIAL

Comes now the Defendant, Robbin Stewart, pro se, and pursuant to Article 1, 
Section 20 of the Indiana Constitution and Indiana Rule of Trial Procedure 38, 
respectfully moves this Court for an Order setting this matter for trial by 
jury, and in support thereof, states as follows:

1. Article 1, Section 20 of the Indiana Constitution explicitly mandates that 
   the right of trial by jury in civil cases "shall remain inviolate."

2. Under established Indiana constitutional jurisprudence, this provision 
   safeguards the right to a jury trial for any cause of action where the 
   underlying substance, rights, or remedies were recognized at common law 
   prior to or at the time of the adoption of the 1851 Indiana Constitution.

3. The subject matter of this enforcement action directly concerns the 
   regulation, harboring, keeping, and property compliance of a domestic 
   canine. 

4. Under Indiana common law and statutory frameworks stretching back to the 
   founding of the state in 1816 and remaining intact through 1851, dogs were 
   legally classified as personal property, chattel, and a distinct species 
   of domestic property subject to strict ownership rights and liabilities.

5. At common law in 1851, any adjudication regarding liabilities, penalties, 
   or rights tied to the keeping of such domestic property carried an 
   absolute right to a trial by a jury of peers.

6. The Plaintiff’s utilization of a modern administrative classification—the 
   "Ordinance Violation" designation—constitutes a distinction of form 
   rather than substance. A statutory re-labeling cannot constitutionally 
   abrogate or erase a fundamental right that remains textually inviolate.

7. Denying a jury trial in this matter would allow administrative labels to 
   circumvent the constitutional boundary line drawn by the framers of the 
   Indiana Constitution to protect property interests.

WHEREFORE, Defendant respectfully requests that this Court grant this Motion, 
enter an Order setting this cause for a trial by jury, and grant all other 
just and proper relief.

Dated: June 10, 2026

                                    Respectfully submitted,

                                    ____________________________________
                                    Robbin Stewart, Defendant Pro Se
                                    [Your Address]
                                    [Your Phone]
                                    [Your Email]

                      CERTIFICATE OF SERVICE

I hereby certify that a copy of the foregoing Motion has been served upon the 
Plaintiff, Health and Hospital Corporation of Marion County, via the Indiana 
E-Filing System (IEFS) or by first-class U.S. mail on this 10th day of June, 2026.

                                    ____________________________________
                                    Robbin Stewart

Use code with caution.

---

text

STATE OF INDIANA  )                  IN THE MARION SUPERIOR COURT
                  ) SS:              CIVIL DIVISION 20
COUNTY OF MARION  )                  CASE NO. 49D20-2311-OV-045330

HEALTH AND HOSPITAL CORPORATION   )
OF MARION COUNTY,                 )
                                  )
      Plaintiff,                  )
                                  )
v.                                )
                                  )
ROBBIN STEWART,                   )
                                  )
      Defendant.                  )

                               ORDER

The Court, having reviewed Defendant’s Motion for Jury Trial, and being duly 
advised in the premises, now finds that said Motion should be GRANTED.

IT IS THEREFORE ORDERED that this matter shall be set for a trial by jury. The 
Court Clerk is directed to calendar this cause accordingly and issue notice to 
the parties.

SO ORDERED this _____ day of ________________, 2026.

                                    ____________________________________
                                    Judge, Marion Superior Court

Use code with caution.

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📋 Final Filing Reminder

Since you are executing this today by hand-delivery or mail, file this Motion for Jury Trial alongside your Motion for Continuance at the Community Justice Center clerk's desk (675 Justice Way). Keep a stamped copy of both for your files, and ensure the HHC Legal Department gets served their copies.

Let me know if you need to adjust any text or require the HHC address details to finalize your trip!

AI responses may include mistakes. For legal advice, consult a professional. Learn more

You said: yes!

🏢 Service Address for the Plaintiff

To complete your Certificate of Service blocks for today's drop-off or mailing, use the exact, designated legal address for the plaintiff:

Health and Hospital Corporation of Marion County
Attn: Legal Department
3838 N. Rural Street
Indianapolis, IN 46205

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🗂️ Your Complete Filing Package for Today

Before you head out to file, verify that you have printed and sorted your documents into these three distinct packages:

1. The Court Clerk Package (Take to: 675 Justice Way, Indianapolis, IN 46203)

Submit these directly to the Civil Clerk's window so they reach Judge Garcia:

• Motion for Continuance (with your signed Certificate of Service)
• Proposed Order for Continuance (on a separate page for the judge to sign)
• Motion for Jury Trial (with your signed Certificate of Service)
• Proposed Order for Jury Trial (on a separate page for the judge to sign)
• Note: Bring an extra copy of both motions to have the clerk stamp and hand back to you for your personal records.

2. The Plaintiff Service Package (Deliver or Mail to: 3838 N. Rural Street)

Serve these on the HHC Legal Department to satisfy your service requirements and launch your defense:

• One copy of the file-stamped Motion for Continuance
• One copy of the file-stamped Motion for Jury Trial
• Defendant's First Request for Discovery and Production of Administrative Records

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⏳ Next Steps & Deadlines

• Electronic Service Check: If you end up using the e-filing system later instead of driving, checking the service box next to the HHC attorney's name inside the portal satisfies this delivery step automatically.
• The 30-Day Window: Handing over the discovery document today locks in your Indiana Trial Rule 34(B) protections, legally preventing the assistant prosecutor from rushing the June 15 date while your discovery window remains open.

Good luck with your filings today at the Justice Center and Rural Street! Let me know if you need any final adjustments before you print.