Here is my reply to Gabe Whitley's protective order and his reply to my reply. This would be fun if it weren't so annoying.

1. STATE OF INDIANA ) IN THE MARION COUNTY
) SUPERIOR COURT
)
COUNTY OF MARION ) SS.
)
GABRIEL WHITLEY ) CAUSE NO. 49D22-2402-006950
Petitioner )
)
Vs. )
)
ABDUL-HAKIM SHABAZZ )
Respondent )
RESPONDENT'S REPLY TO THE PETITIONER’S REQUEST FOR AN ORDER OF
PROTECTION AND REQUEST TO SANCTION PETITIONER
Comes now Respondent, Abdul-Hakim Shabazz, pursuant to Indiana Trial Rule 12 (b)(6) and
files this answer to Petitioner’s request for an order of protection.
This Court should deny the Petitioner’s petition for a protective order for the following reasons.
1. Petitioner is a candidate for Congress, and Respondent is a political writer, reporter and
commentator, and a protective order would violate the federal and state Constitutions.
2. The Petitioner has not met the standard for the issuance of a protective order.
3. A close inspection of Petitioner’s public record would show on numerous occasions,
Petitioner attacked the Respondent.
4. Petitioner knowingly and intentionally made material false statements that go to the heart
of his complaint and, therefore, should have been found to committed perjury.
In support of this motion, the Respondent submits his contemporaneously filed brief in support
of his Motion and further requests all other just and appropriate relief.
Respectfully submitted,
Abdul-Hakim Shabazz
By /s/Abdul-Hakim Shabazz
Attorney for the Plaintiff
Attorney #34964-49
Abdul-Hakim Shabazz

2. Attorney at Law 4418 Braemar Dr., Suite B
Indianapolis, IN 46254
(317)727-1250
E-mail attyabdul@gmail.com

3. CERTIFICATE OF SERVICE
CERTIFICATE OF SERVICE I certify that on the 6th day of March 2024, I electronically filed the
foregoing document using the Indiana E-Filing System (IEFS).
I also certify that on the 7th day of March 2024, service of a true and complete copy of the
above and foregoing pleadings or papers were made upon each party or attorney of record
herein using the Indiana E-Filing System (IEFS).
BY: /s/ Abdul-Hakim Shabazz

4. STATE OF INDIANA ) IN THE MARION COUNTY
) SUPERIOR COURT
)
COUNTY OF MARION ) SS.
)
GABRIEL WHITLEY ) CAUSE NO. 49D22-2402-006950
Petitioner )
)
Vs. )
)
ABDUL-HAKIM SHABAZZ )
Respondent )
MEMORANDUM IN SUPPORT OF RESPONDENT’S MOTION TO DENY
PETITIONER’S PETITION FOR A PROTECTIVE ORDER AND
FOR THIS COURT TO SANCTION PETITIONER
Comers now Respondent Abdul-Hakim Shabazz and files this memorandum in support of his
motion to deny the petitioner’s petition for a protective order and for this court to sanction the
Petitioner for committing perjury.
ARGUMENT
1. The Petitioner is a candidate for Congress, and the Defendant is a political
writer/reporter/commentator, and a protective order would violate the 1st
Amendment as constitutionally protected activities cannot be deemed to be
stalking or harassment.
Stalking and harassment do not include statutorily or constitutionally protected activity.
Ind. Code § 35-45-10-2. To grant Petioner’s protective order would run afoul of both the U.S
Constition’s First Amendment and freedom of the press
Congress shall make no law respecting an establishment of religion, or prohibiting the
free exercise thereof; or abridging the freedom of speech, or of the press; or the right of
the people peaceably to assemble, and to petition the Government for a redress of
grievances. (U.S. Constitution, Article 1, Section 9)
Section 9 of the Indiana Constitution

5. Section 9. No law shall be passed, restraining the free interchange of thought
and opinion, or restricting the right to speak, write, or print, freely, on any subject
whatever; but for the abuse of that right, every person shall be responsible.
(Indiana State Constitution,
Petitioner is a candidate for Congress, running as the self-proclaimed front-runner as a
Republican in the Seventh Congressional District. (Honest-Gabe.Org) Respondent is the editor
and Publisher of Indy Politics, a political news website that has been covering Indiana politics
since 2011. (IndyPoitics.Org) To grant Petioner’s protective order would run afoul of both the
U.S. and State Constitutions as covering candidates for public office, particularly during an
election year, is statutorily protected activity as such coverage is in the regular activities of a
political reporter.
2. Petitioner has not met the standard for the issuance of a protective order.
Protective orders are similar to injunctions, and therefore in granting such an order the
trial court must sua sponte make special findings of fact and conclusions thereon. Hanauer v.
Hanauer, 981 N.E.2d 147, 148 (Ind. Ct. App. 2013) (citing Ind. Trial Rule 52(A)(1)). The courts
apply a two-tiered standard of review: they first determine whether the evidence supports the
findings, and then determine whether the findings support the order. Id. at 149.
A.A. v. K.A., 2022 Ind. App. Unpub. LEXIS 404, *3-4, 187 N.E.3d 917, 2022 WL 1132765 (Ind.
Ct. App. April 18, 2022)
The Indiana Civil Protection Order Act was enacted to promote the "protection and
safety of all victims of domestic or family violence in a fair, prompt, and effective manner" and to
prevent "future domestic violence, family violence, and harassment." Ind. Code § 34-26-5-1.
Domestic violence includes stalking, which is defined as: "a knowing or an intentional course of
conduct involving repeated or continuing harassment of another person that would cause a
reasonable person to feel terrorized, frightened, intimidated, or threatened and that actually
causes the victim to feel terrorized, frightened, intimidated, or threatened." Ind. Code §
35-45-10-1. However, stalking "does not include statutorily or constitutionally protected activity."
Id.
Harassment is defined as: "conduct directed toward a victim that includes but is not
limited to repeated or continuing impermissible contact that would cause a reasonable person to
suffer emotional distress and that actually causes the victim to suffer emotional distress." Ind.
Code § 35-45-10-2. Impermissible contact includes "[f]ollowing or pursuing the victim" or
"[c]ommunicating with the victim[.]" Ind. Code § 35-45-10-3. And, as with stalking, "[h]arassment
does not include statutorily or constitutionally protected activity[.]" Ind. Code § 35-45-10-2.
A person who has been a victim of stalking may file a petition for a protective order. Ind.
Code § 34-26-5-2(a).
A finding that domestic or family violence or harassment has occurred sufficient to justify
the issuance of an order . . . means that a respondent represents a credible threat to the safety

6. of a petitioner or a member of a petitioner's household. Upon a showing of domestic or family
violence or harassment by a preponderance of the evidence, the court shall grant relief
necessary to bring about a cessation of the violence or the threat of violence.
Ind. Code § 34-26-5-9(g). We have also noted the "significant ramifications of an improperly
granted protective order[,]" which can pose "a considerable threat to the respondent's liberty."
Barger v. Barger, 887 N.E.2d 990, 993-94 (Ind. Ct. App. 2008). "For example, at the state level,
violation of the trial court's protective order is 'punishable by confinement in jail, prison, and/or a
fine.'" Id. at 993 (quoting Ind. Code § 34-26-5-3).
Petitioner has provided no evidence to show that Respondent has engaged in stalking or
harassment. Respondent has not attempted to cause Petioner in fear of physical harm.
Respondent has never threatened Petitioner’s life on social media.
The reason Petitioner has failed to show evidence is because none exists.
3. A close inspection of Plaintiff’s public record would show on numerous
occasions, Petitioner attacked and harassed Respondent.
On numerous occasions, Petitioner has attacked Defendant on the Internet and social
media. Petitioner filed a complaint with the Indiana Disciplinary Commission (11/2/23), accusing
the Respondent of using his law license to bully and threaten him into a settlement. (Exhibit A)
The matter was reviewed by the Disciplinary Commission and denied.
Petitioner filed a complaint with the Marion County Election Commission in February
accusing the Respondent of using campaign funds from his 2023 race for mayor to pay off his
car and buy a washer and dryer. (Exhibit B). Although the matter is under review by the
Commission, Petitioner has provided no evidence to support his claims.
Petitioner has written several “news articles” attacking Respondent, including accusing
the Respondent of rape (See Exhibit C) and committing perjury in a previous deposition (Exhibit
D), none of which are true and are subject to a defamation suit.
4. Petitioner knowingly and intentionally made material false statements that go to
the heart of his complaint and, therefore, should have been found to committed perjury.
Petitioner affirmed that under the penalties for perjury, the allegations that he made in his
petition for a protective order were true on the basis of his personal knowledge and that he
believed the facts stated were true.
Petitioner has provided this Court with no evidence to substantiate his claim.
Petitioner has provided no evidence of threats, stalking or harassment.
Petitioner has provided no evidence of Respondent sending a threatening letter.
Petitioner has provided no evidence of Respondent threatening his life on social media.
The reason Petitioner has provided this Court with no evidence is because that evidence does
not exist.

7. Petitioner knew that when he filed his request for a protective order, he knew there was
no evidence to back up his claim. Petitioner has committed perjury by knowingly, willingly and
intentionally making false statements that are at the heart of his petition and should be
sanctioned by the court.
Petitioner has a history of making false, misleading and fraudulent statements in the public
square.
● Petitioner is under investigation by the Indiana Election Division for reporting false and
fraudulent campaign finance reports.
● Petitioner filed a fraudulent complaint against incumbent President Joe Biden’s
campaign with the Indiana Election Division, arguing that the President did not meet the
requirement for signatures to be placed on the ballot. That was not true, and Petitioner
failed to show up at the hearing.
● Petitioner has been the subject of numerous lawsuits and default judgments for failure to
pay his bills: 49D13-2311-CC-042630, 49D11-2310-CC-041554,
82C01-2309-CC-004517, 82D07-2212-SC-007240.
WHEREFORE, Plaintiff respectfully requests that this Court deny Petitioner’s request for
a summary judgment, sanction him for perjury and award Respondent all attorneys fees and
other reasonable costs.
Respectfully submitted,
Abdul-Hakim Shabazz
By /s/Abdul-Hakim Shabazz
Attorney for the Plaintiff
Attorney #34964-49
Abdul-Hakim Shabazz
Attorney at Law 4418 Braemar Dr., Suite B
Indianapolis, IN 46254
(317)727-1250
E-mail attyabdul@gmail.com

8. CERTIFICATE OF SERVICE
CERTIFICATE OF SERVICE I certify that on the 6th day of March 2024, I electronically filed the
foregoing document using the Indiana E-Filing System (IEFS).
I also certify that on the 7th day of March 2024, service of a true and complete copy of the
above and foregoing pleadings or papers were made upon each party or attorney of record
herein using the Indiana E-Filing System (IEFS).
BY: /s/ Abdul-Hakim Shabazz