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. ) CAUSE No. 2:14-cv-325-JVB-PRC
)
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. )


STIPULATION

The parties, by their respective counsel, hereby stipulate as follows:
1. That the Court enter the attached Order on Request for Preliminary
Injunction.
2. That all further proceedings in this case, including the necessity of
filing an answer or other response to the complaint, be stayed pending a decision in
the case now filed in the Supreme Court of the United States under cause number
14-277, Penny Bogan, in her Official Capacity as Boone County Clerk, et al., v.
Marilyn Rae Baskin, et al. All defenses to the merits are preserved to the
defendants; no defense to the merits is waived.
3. That no bond be required of the plaintiffs.
case 2:14-cv-00325-JVB-PRC document 12 filed 09/10/14 page 1 of 3
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WHEREFORE, the parties urge the court to enter the attached Order, stay
all proceedings until further order of the court and grant them all other just and
proper relief.
Respectfully Submitted,

s/J. Michael Hearon (with permission)
J. Michael Hearon, #31597-49
QUARLES & BRADY LLP
135 North Pennsylvania Street
Indianapolis, Indiana 46204
Telephone: (317) 957-5000
Facsimile: (317) 957-5017
michael.hearon@quarles.com

Counsel for Plaintiffs
Respectfully Submitted,

GREGORY F. ZOELLER
Indiana Attorney General
Atty. # 1958-98

By: s/Melinda J. Schwer
Melinda J. Schwer, #19351-53
Deputy Attorney General

By: s/David A. Arthur
David A. Arthur, #2461-48
Deputy Attorney General
Indiana Govt. Center South, 5th Floor
302 W. Washington Street
Indianapolis, IN 46204-2770
Telephone: (317_ 234-4665 (Schwer)
Telephone: (317) 232-6286 (Arthur)
Facsimile: (317) 232-7979
Melinda.Schwer@atg.in.gov
David.Arthur@atg.in.gov

Counsel for VanNess and Zoeller
s/Nancy Moore Tiller (with permission)
Nancy Moore Tiller, #1652045
NANCY MOORE TILLER & ASSOC.
11035 Broadway, Suite A
Merrillville, Indiana 46307
Telephone: (219) 662-2300
Facsimile: ((219) 662-8739
NMT@tillerlaw.com

Counsel for Brown

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CERTIFICATE OF SERVICE

I hereby certify that on September 10, 2014, I electronically filed the
foregoing stipulation and the attachment to it with the Clerk of the Court using the
CM/ECF system which sent notification of such filing to the following:
Lucy R. Dollens
J. Michael Hearon
QUARLES & BRADY LLP
Lucy.Dollens@quarles.com
Michael.Hearon@quarles.com

Nancy Moore Tiller
NANCY MOORE TILLER & ASSOC.
NMT@tillerlaw.com


s/David A. Arthur
David A. Arthur
Deputy Attorney General


case 2:14-cv-00325-JVB-PRC document 12 filed 09/10/14 page 3 of 3
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. ) CAUSE No. 2:14-cv-325-JVB-PRC
)
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. )


ORDER ON REQUEST FOR PRELIMINARY INJUNCTION

The parties, by their respective counsel, having filed their Stipulation, the
court now ORDERS as follows:
1. Defendants Michael A. Brown, in his Official Capacity as Lake County
Clerk, William C. VanNess II, M.D., in his Official Capacity as Commissioner, State
Department of Health, and Greg Zoeller, in his Official Capacity as Indiana
Attorney General, and all those acting in concert with them are ENJOINED from
enforcing Indiana statute 31-11-1-1(b) against recognition of Plaintiffs, Veronica
Romeros and Mayra Yvette Riveras, valid out-of-state marriage; the State of
Indiana must recognize their marriage. In addition, should either Plaintiff pass
away in Indiana, the court orders William C. VanNess II, M.D., in his official
case 2:14-cv-00325-JVB-PRC document 12-1 filed 09/10/14 page 1 of 3
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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 lists the other Plaintiff as the surviving spouse. This order shall
require that Defendant VanNess issue directives to local health departments,
funeral homes, physicians, coroners, medical examiners, and others who may assist
with the completion of said death certificate explaining their duties under the order
of this court. This preliminary injunction will remain in force until the court renders
judgment on the merits of the Plaintiffs claims.
2. All further proceedings in this case, including the necessity of filing an
answer or other response to the complaint, are hereby STAYED pending a decision
in the case now filed in the Supreme Court of the United States under cause
number 14-277, Penny Bogan, in her Official Capacity as Boone County Clerk, et al.,
v. Marilyn Rae Baskin, et al. All defenses to the merits are preserved to the
defendants.
3. The above ORDER is issued without bond.
All of which is ORDERED this ____ day of September, 2014.

__________________________________________
JOSEPH VAN BOKKELEN
United States District Judge



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Copies to:

J. Michael Hearon
QUARLES & BRADY LLP
michael.hearon@quarles.com

Lucy R. Dollens
QUARLES & BRADY LLP
lucy.dollens@quarles.com

Melinda J. Schwer
Deputy Attorney General
Melinda.Schwer@atg.in.gov

David A. Arthur
Deputy Attorney General
David.Arthur@atg.in.gov

Nancy Moore Tiller
NANCY MOORE TILLER & ASSOC.
NMT@tillerlaw.com

case 2:14-cv-00325-JVB-PRC document 12-1 filed 09/10/14 page 3 of 3