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Case 5:12-cv-00019-DCB-MTP Document 68-8 Filed 02/07/13 Page 1 of 32

IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF MISSISSIPPI WESTERN DIVISION KENYA BURKS VS. CITY OF VICKSBURG, MISSISSIPPI AND PAUL WINFIELD, INDIVIDUALLY AND IN HIS OFFICIAL CAPACITY PLAINTIFF CIVIL ACTION NO. 5:12-cv-00019-DCB-JMR

DEFENDANTS

PLAINTIFF’S RESPONSES TO DEFENDANT, PAUL WINFIELD’S, FIRST SET OF INTERROGATORIES

INTERROGATORY NO. 1.:

State your full name, any other name (including

any nicknames) that you have used or been known by during your lifetime, address, telephone number, cell phone number, personal electronic mail address, work electronic mail address, Social Security number, drivers’ license number, and date of birth. State any other addresses, telephone numbers, cell phone numbers, personal electronic mail addresses, and work electronic mail addresses that you have had in the past five years. RESPONSE: Name: Kenya Burks Kenya Burks –Shorter Address: P.O. Box 82 Lake Providence, LA SS# xxx-xxDL# MS DL LA DL (I think) MS DL XXXXX (My first MS DL number was my social until they changed that numbering method to a more secure numbering system). TX DL – I don’t remember the DL number I had in TX

EXHIBIT “H”

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DOB# Telephone numbers: Previous Cell # Cell # Current cell # Email Address: Work Email Address: 5 Years Work Address: I don’t remember my exact work email addresses, but they would be some variation of my name:

INTERROGATORY NO. 2.:

Identify the user name and email address for

any Facebook account maintained by you from July 2009 through the present. RESPONSE: Plaintiff objects to this interrogatory as seeks information that

is irrelevant, overly broad, unduly burdensome, and would likely lead a violation of the Computer Fraud and Abuse Act, 18 U.S.C. § 1030; the Store Communications Act, 18 U.S.C. §§ 2701-2712; and the Wiretap Act, as amended by the Electronic Privacy Communications Act ("EPCA"), 18 U.S.C. §§ 2510-2522. Notwithstanding, my Facebook account is INTERROGATORY NO. 3.: Provide the name, address and telephone

number of each and every person who has knowledge or information of any relevant facts concerning any matter raised by any pleading in this action and describe in detail the substance of that person’s knowledge. RESPONSE: Plaintiff objects to this interrogatory as it is overly broad and

vague. Anderson v. UPS, Inc., 2010 U.S. Dist. LEXIS 123878 *6 (D. Kan. Nov. 22, 2010); Aikens v. Deluxe Fin. Servs., Inc., 217 F.R.D. 533, 538 (D. Kan. 2003); Hilt v. SFC Inc., 170 F.R.D. 182, 186-7 (D. Kan. 1997); Stephens v. City of Chi, 203 F.R.D. 2

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353, 361-2 (N.D. Ill. 2008). disclosures.

Notwithstanding, please see Plaintiff’s Pre-discovery

INTERROGATORY NO. 4.:

Identify each person you expect to call as an

expert witness at trial and, with respect to each person, provide the following information: (a) (b) (c) (d) (e) The subject matter on which he or she is expected to testify; The facts and opinions to which he or she is expected to testify; The grounds for each opinion to which he or she is expected to testify; His or her occupation and profession; His or her job title or position and the name, address and telephone

number of his or her employer; (f) His or her educational background, including the names of all institutions

attended, the dates of attendance and the degrees received. RESPONSE: Plaintiff has not designated an expert at this time but will

supplement this response if she does. INTERROGATORY NO. 5.: Identify each supervisor, co-worker, agent and

other person associated with the City of Vicksburg who you believe has sexually harassed you or treated you unlawfully or improperly, and, for each individual identified, state the basis of your contention that he or she sexually harassed you or otherwise treated you unlawfully or improperly, describing without limitation (1) all allegedly improper or unlawful acts of each individual identified; (2) the date, time and location of each alleged act; (3) all persons who witnessed each alleged act or have knowledge

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that the alleged act was committed; and (4) the actions you took to notify the City of Vicksburg, Mayor Winfield or anyone else that the alleged act occurred. RESPONSE: Only Mayor Paul Winfield has overtly sexually harassed me.

However, since I have been gone from the City, I have learned that this seems to be the culture of the current Administration. I have since found that this type of harassment is not unique to me. It is something that has been occurring and I was the one that openly brought it to the public’s attention. a. Mr. Mayfield has said many sexually explicit inappropriate things in my

presence. He has done crazy little things as I walked away that citizens witnessed and he has said things about his admiration for my physical makeup, but he said them to other men who told me. Once when Mr. Mayfield made an inappropriate remark

directly to me, I advised him that I have always had a healthy relationship with my father and I wasn’t looking for a father figure. After that, he calmed down. Marie Thompson

complained and literally cried to Lee Davis Thames and Mayor Winfield once about Mr. Mayfield asking her about licking food off her chest at 2 Sisters Restaurant in Jackson after the Mayor received a proclamation from the State Legislators. After this happened to Marie Thompson, Lee Thames worked with Walterine Langford to put together a memo to circulate to all department heads and the Board regarding making sexual comments to employees and warning of the implications associated with those remarks. b. Chief Walter Armstrong acted unlawfully by not arresting the Mayor when

he witnessed him physically attack me. Prior to the Chief witnessing Paul attack me, I had a detailed discussion with the Chief about what Kenny Daniels, EMS Chief, had warned me that Paul was planning to do to me because I would not continue to have

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relations with him. I advised the Chief that Kenny Daniels stated that Paul’s brother, Michael Winfield, had advised Paul not to do that to me because I did a great job as the Chief of Staff and because it was unlawful for him to alter my job due to my lack of sexual interaction with him. After discussing this with Chief Armstrong, he made an attempt to discuss this with the Mayor. The Mayor in turn came into the office and threatened me. .Alderman Mayfield acted unethically by allowing his cousin, Paul Winfield, to persuade him into ridding me of my position because the affair between me and him (Paul Winfield) ended. Alderman Mayfield mentioned to several people over the course of two years that he knew of our affair. I had a detailed discussion with Mr. Mayfield about the affair and the alleged criminal activity that was being rumored about the Mayor’s business dealings. I also brought this concern to Alderman Beauman after he advised me that if I knew anything about the Mayor’s wrong-doings “to Bring It”. Alderman Beauman sympathized with my situation and mildly scolded me in a “fatherlike” manner, stating he was sorry for what happened to me and that I was too smart to have had relations with a person like Paul. INTERROGATORY NO. 6.: Please state the month, day and year that you

contend the alleged consensual extramarital affair between you and Mayor Winfield began and the month, day and year the alleged consensual extramarital affair ended. RESPONSE: The affair began August 2009 in Tunica, MS. The affair

began to end in August of 2010 and became really bad around December of 2010. The Mayor spent 2-4 nights a week at my residence at various different times beginning August of 2009. We also spent time at various different hotels in and out of town. I have collected some of the receipts from these stays. (New Orleans, LA, Oxford,

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MS(Ole Miss), Madison, MS, Canton, MS, Clinton, MS, Ridgeland, MS, etc) The affair completely ended on Wednesday, April 8, 2011 with a physical fight in the front yard of his home on Main Street with Chief of Police Walter Armstrong present. Although Chief Armstrong stopped Paul from hitting me and picked me up from the concrete, he did not arrest Paul for attacking me. INTERROGATORY NO. 7.: Describe all statements and audio and video

recordings that relate to the circumstances alleged in your Complaint, including: (1) the date those statements or recordings were made; (2) the person making the statement or recording; and (3) the person taking the statement or recording. RESPONSE: and overly broad. Plaintiff objects to this interrogatory as it unduly burdensome Whitlow v. Martin, 259 F.R.D. 349, 354-5 (C.D. Ill. 2009).

Notwithstanding, please see Plaintiff’s response to No. 3 and all telephone and video recordings previously submitted INTERROGATORY NO. 8.: Please state, in detail and not with mere

general statements, the basis for the allegations in paragraph 8 of your First Amended Complaint that toward the end of your employment, Mayor Winfield became physically abusive. Include in your response the dates the alleged abuse(s) occurred, the nature of the alleged abuse(s), and witnesses to the alleged abuse(s). RESPONSE: Plaintiff objects to this interrogatory as it is overly broad and vague.

Anderson v. UPS, Inc., 2010 U.S. Dist. LEXIS 123878 *6 (D. Kan. Nov. 22, 2010); Aikens v. Deluxe Fin. Servs., Inc., 217 F.R.D. 533, 538 (D. Kan. 2003); Hilt v. SFC Inc., 170 F.R.D. 182, 186-7 (D. Kan. 1997); Stephens v. City of Chi, 203 F.R.D. 353, 361-2

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(N.D. Ill. 2008). Notwithstanding, there were several episodes of physical abuse. The abuse progressively got worse with each occurrence: a. The first one occurred the day before the Downtown Partners Meeting.

The mayor was contemplating buying or had just recently bought the home on Mulville Hill Drive in Vicksburg. He had taken me to this home several times during his

purchasing process and on this particular time, I told him that I was not interested in going back to that home. He said that the rumors around town were that he was

buying the home for me and him and that he was divorcing his wife. I told him that he needed to stop lying and what he was saying to me was not impressive at all. I further told him that I would appreciate it if he didn’t keep taking me to that house, because I lived in an apartment. He told me that he would buy me a house too. I told him, until that happens, I don’t want to hear about his second house. He said “That’s the problem with y’all, you always want more.” I stated, I don’t want to hear about you buying a

second house and I don’t want to go back into that house ever again. He was really enraged and said “I pay you $70K”. I said, I work for my $70K, and in all actuality; I also do your job while you are running back and forth to Port Gibson and everywhere else trying to buy two houses. He then took out his wallet, took the money out of it and threw it in my face with the wallet. At that point, I got really mad and told him to take me home. I unstrapped my seat belt and started picking up my bags from the floorboard of his truck. I also started putting back on my heels, which I had taken off in the truck. When we got around the corner from my house near his Barber’s Shop (across from the city garage), he slammed on brakes really hard and my chest hit the dashboard and my head hit the windshield area. Then he started fighting me and I started screaming “Stop

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Hitting Me.” He kept hitting me and was saying shut up and I screamed louder, hoping someone would hear me. I tried to open the door so I could jump out of the truck and he grabbed me and pulled me back in the truck. At that point, I hit him in the eye (which leads to the black eye comment that he mentioned in the text msgs). I was wearing a very large ring (which I still have). After I hit him, I tried to get out the door again. At that point he went ballistic and started beating me in my back. I placed my head between my legs and covered it with my hands. He kept screaming “Look what you did to my eye. How am I going to go home with a black eye? Look at it. Look at it.” I rose up to look at it, jumped out the truck, and ran home without any shoes on and I left

my bags in the car. He called later that night and stated that he needed help with getting the bruising out of his eye because we had the Downtown Partners meeting the following day. b. Another fight occurred at Daiquiri World in Delta, Louisiana. On this

particular day, we were out to dinner and I didn’t want to be there. Paul stated that my attitude was bad and that the owners of the restaurant could tell that I was upset. He said that I shouldn’t be showing everyone that I didn’t want to be there with him. I told him that if he felt that way, then maybe we should leave because I didn’t want to be there with him. He kept trying to talk to me and I wouldn’t talk back (I was totally silent). He became progressively angrier because he said that I had a knack for saying what I wanted to say and then I would give him the silent treatment. He said that he wasn’t going to let me get away with this anymore. So, I left out the restaurant and headed to the car. By the time I got out, he came behind me and hit me. I jumped in the car and he took my keys out of my hand as I was putting them in the ignition. At this point I

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started crying, but I still wouldn’t say anything. He got even angrier and said that I had embarrassed him in front of all those people in the restaurant and he threw my keys at me. They hit me on the shin of my leg and the unlock button on the key fob broke. He

bruised my leg really badly. Then he grabbed my arms and started shaking me back and forth from the driver’s side of the door to the console saying, “You’re going to talk to me.” After I put the keys in the ignition and starting driving back across the bridge, he kept fussing, but he stopped hitting me. He kept trying to get me to talk, but I wouldn’t, so, he decided to jump out of the car at the exit where you leave Delta going back to Vicksburg. He said, he would just walk back home. When he jumped out, I locked the door and drove off. c. On another time, during the Yazoo City/Eagle Lake tornado, Paul came

by and picked me up to ride up to Eagle Lake to assess the damages from the storm (as I was the also the Public Information Officer for the City). We dropped his little boy (Paul Evans) off at his Mom’s house and we proceeded to ride up to Eagle Lake. While there we saw many city and county officials (Mr. Banks, Mr. Mayfield, Deputy Chief Dolan or Barnett (I don’t remember which one), Sammy Rainey, Fire Personnel, Connie from Internal Affairs, etc). I also sent the photos from the storm via the Vicksburg City email address to Anna Booth, the Emergency Management Director, whom I was communicating with on the status of the damage. After we left Eagle Lake, Paul picked up his son from his mom’s and decided to bring me back to his house. He tried to have sex with me in a bedroom adjacent to his son’s bedroom (Jack and Jill style bedroom). The bedroom had antique furniture in it and a beautiful white down comforter on the bed. I told him that he was wrong for that and to take me back home. He stated that

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his wife, Malissa, had called and stated that due to the weather conditions, her flight was cancelled and she was stranded in Memphis. He said that she asked him to come and pick her up. He said he told her that she could wait until the next day to fly out and that he wasn’t coming to Memphis to pick her up. He then said, so you can stay the

night here. I said, no, Paul, it is wrong to stay here in your house and it is definitely wrong to stay here with your son here. His son was asleep downstairs in the master bedroom. I said, no Paul. He said, well, the alarm is set now. You can’t leave. If you set off the alarm the police will show up. As I normally do when I become angry, I shut down and would not talk. He got angry and asked why I was not talking to him. I told him, I just want to go home. I told him I needed a shower and to change clothes and I will come back. He said no, went into his master bedroom closet, pulled out some night clothes for me and said I could take a shower there. I went into their master bathroom and took a shower.(the shower was a really nice shower with about 4 or 5 different shower heads coming from various angles). He came into the shower with me and tried to have sex with me. I eventually maneuvered my way out of the shower, but I fell on the floor because my feet were wet. He picked me up and started pressing against me and I started crying. Then he tried to make me lie in the bed with him and his son. I lay there (he had a red comforter on the bed). I slept on the edge of the bed for a while. Then I tried to go into the den, but I woke him up and he asked me where I was going. I then lay back down. The next morning he woke up and cooked me breakfast. Really strange I know, but he cooked turkey bacon, eggs, and cinnamon toast. He also

dropped a bottle of orange juice and broke it. After I ate the breakfast, he woke his son up and took me back home.

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d.

We had a fight in his office about 2 months prior to my dismissal. It was

on the same day that the Mayor had to speak at the Black History Program at Vicksburg High School. On this particular day, we also met with Tanya Scott and Benjamin

Minnifield regarding the Robert Johnson Foundation. This fight occurred as a result of me coming out of my office to speak with Linda Fondren, who is currently a COV mayoral candidate, who was sitting in Marie Thompson’s office. I had been at work for about a half hour prior to the Mayor and had already spoken with Linda once, but Paul was unaware of this. So, when I walked through my office into Marie’s office to answer a question that Linda had asked earlier, Paul lashed out at me. I really didn’t

understand why he did this, but I found out later. After he did this, I went into his office to take him his daily calendar and he asked me where had I been the night before. I

told him that was none of his business. He told me that he had tried calling me the night before. I told him I go where I want to go at night. He then shook me and pushed me. I then got up, picked up the name plate off his desk and threw it at his head. I missed his head and hit the wall with it and ran out of the office. At the point that I was running out of the office, the Chief of Police walked in the door. He could tell that I was rattled and asked what the matter was. I asked him if he planned on going to the VHS for the Black History program. He said yes. I asked him if I could ride with him. He said yes. About 10 minutes later, Tanya Scott and Benjamin Minnifield arrived for their meeting. I had to compose myself and act as if nothing were wrong and continue with that meeting. During this meeting, the Chief came back to give me a ride to the program. I left out of the meeting early to ride with the Chief. Later Tanya Scott and Ben Minniefield arrived at the school with Paul (in separate vehicles). After the program, Paul asked that I ride

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back with him so we could talk. I believe he talked with the Chief about what happened because the Chief left the school without me. e. Paul and I had a fight at my apartment because he told me that his wife,

Malissa’s, cancer had come back. He told me that his aunt told him that Malissa was sick with breast cancer again and had begun treatment. My response was “Paul, you must be a really bad husband if your wife failed to tell you she is that sick, but she told your aunt.” He said, “No, Malissa is just stupid like that.” I told him that he should probably try to spend more time at home since she is sick. I told him that he should leave now and go home to talk with her about her issue. Instead of him leaving, he decided to bad mouth her and he said that Malissa is used to him being gone and that he doesn’t show her affection because she doesn’t show him any affection. He said that her mother even told her that she was not affectionate enough to have a kid. He

said that Malissa was used to having really bad men in her life and he was the best thing that happened to her. He said Malissa’s 1st husband was an ex-football player

that abused her and sat around the house playing video games all the time. He went on to say that her dad was a provost at Texas Southern University and he had been in trouble with the University and her mom for having relations with the young female students. He said the Malissa and her sisters witnessed all of this and they all had issues because of this. He said her oldest sister was a controlling bitch. And her

younger sister named Neicey was a whore. He said and he took Neicey for a ride on the back of his motorcycle and Neicey started rubbing on his back as if she wanted him to have sex with him. He even went on to say the Grandma, which he called Big Mama or Sugar Mama or some variation thereof, had walked in on him in a room with only his

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underwear on and acting as if she wanted to sleep with him also. He said Neicey was going through her 2nd divorce in Alabama in less than a year and she would probably move in with Malissa and help take care of her so it was no need for him to go home. He then said that Malissa knows what to expect because she had another sister that died of cancer in northern Mississippi a few years earlier. At the end of this

conversation, I concluded that Paul was as close to being the devil as any human being could be and that he was capable of doing anything. I asked him to please leave my house. He got mad and said all us women are crazy and asked why was I taking up for Malissa. I told him to just leave. He had a bottle of water in his hand and he decided to dash the water on me as he left out the door. f. The final physical altercation occurred on Wednesday April 8, 2011,

approximately 1-½ weeks prior to the Mayor terminating my position. This fight began in LD’s Kitchen and ended at his home on Main Street. On this particular day, I left work and headed to Jackson. The Mayor had asked me what I was doing that evening, and I told him I was going to Jackson. After leaving Burlington Coat Factory in Jackson, I returned to Vicksburg and went to LD’s to get something to eat. As I walked in the door, I saw Paul walking towards the men’s restroom. We were both startled. He asked me, “What are you doing here? I thought you were in Jackson.” I told him I was back from Jackson and I was getting something to eat. I proceeded to the counter to order my food and I saw the Chief of Police ordering an alcoholic beverage. He asked me if I wanted anything to drink and I told him no. Then I saw the Mayor’s cousin, Seychan Lewis, sitting at a table with Talisha Garrett (daughter of Socrates Garrett) and another young lady named Talisha (I don’t remember the second Talisha’s last name).

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Seychan was clearly intoxicated as normal, as he kept screaming for me to come and sit with them. I told him I was just getting something to eat and that I was leaving shortly. They proceeded to talk about the meeting they had just had with Chris from Siemens at the World across the Bridge. Talisha Garrett criticized Paul for taking her to a place with a gravel parking lot and talked about how country he and Seychan were. At that point I sniggled because it was obvious that she was talking down to Paul while Paul was trying so hard to impress them. (* Note: This ties to a Criminal Investigation that involves Siemens, Paul, and the Garretts). He then said, “Why are you laughing, you are from Louisiana.” And I said, “Yes, I am.” Then Talisha Garrett proceeded to say, “Oh, you are not from Mississippi?” I said “No, I am from Louisiana.” By that time, my food was ready and I started heading out the door. Paul followed me out the door and started telling me that I needed to go straight home. I told him that he didn’t have any say-so over where I went and to go back in the building and entertain the Talisha’s. He shook me and I told him, “This is the last time that you will put your hands on me.” I told him I had talked to everyone at the City in positions of authority about him physically abusing me and that I was going to tell his wife next. I left and headed to his house. When I got there, I was walking up the driveway to talk with his wife and tell her to please ask her husband to leave me alone. At that time, the Chief drove up in his personal truck and Paul jumped out. He ran up to me and attacked me. We fought for a minute or two in the driveway and he eventually pushed me down. I rolled down the driveway some and the Chief jumped between Paul and me to calm the situation down. The chief picked me up, picked up my shoes and evidently picked up my cell phones that were knocked out of my hand when I fell. As I got into my car and prepared to

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leave, I started looking for my phones and couldn’t find them. I stepped back out of my car and looked for them on the ground. At this time John Barnes drove up. Evidently, Paul called John Barnes out. The Chief kept telling me that I didn’t have any phones and told him that I always have my work and personal phones on me. I asked him to call one of my phones. He did, but we didn’t hear it ring. I asked him to call the other one and his pockets started vibrating and lighting up. I told him to give me my phones. I don’t know if the Chief deliberately tried to take my phones or if he got confused because of everything that happened and forgot that he had placed both of my phones in his pocket. He gave me my phones and John Barnes tried to talk to me. I did not talk to John Barnes. He kept asking me what was wrong. I remained silent, while crying and drove home. It was during this fight that I suffered the shoulder injury. I showed

Chief the bruises on my shoulder and on the back of my head. The Chief looked through my hair to make sure my head was not bleeding. The next day Alderman Mayfield made jokes about the fight in the presence of John Barnes. As I was leaving out of the building to go to lunch, John Barnes was bringing Paul some lunch to the building and Mr. Mayfield said to Paul, “I guess you are hungry after fighting all night.” He then turned to me and said, “Who won the fight?” He had this really ugly smirk on his face. I didn’t say anything. Instead, I walked out the door and proceeded to walk home for lunch INTERROGATORY NO. 9: Please state, in detail and not with mere

general statements, the basis for the allegations in paragraph 11 of your First Amended Complaint that Mayor Winfield was responsible for elimination of your position. Include the identity on any witness who will support this claim.

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RESPONSE:

Plaintiff objects to this interrogatory as it is overly broad and

vague. Anderson v. UPS, Inc., 2010 U.S. Dist. LEXIS 123878 *6 (D. Kan. Nov. 22, 2010); Aikens v. Deluxe Fin. Servs., Inc., 217 F.R.D. 533, 538 (D. Kan. 2003); Hilt v. SFC Inc., 170 F.R.D. 182, 186-7 (D. Kan. 1997); Stephens v. City of Chi, 203 F.R.D. 353, 361-2 (N.D. Ill. 2008). Notwithstanding, after the relationship went bad and I

refused to bring something he left at work to his house (while his wife was not present), the Mayor told me that he would have me fired. This occurred on the same day that he had me writing all of his information for submittal to Tulane University’s MBA program. I memorialized this in an email that can be retrieved from the City of Vicksburg email site. On this day Mr. Walter Crumb, the City Hall janitor, witnessed the verbal altercation. Paul was mad because I would not leave work to bring him his personal mobile phone charger. He stated that he could not come to City Hall because he had his son with him. I told him that I was sorry, but that is a job for his wife. I advised him that I would bring his personal mobile phone charger downstairs if he drove to City Hall, but I would not bring anything to his house, especially since I had been locked in his house before. I wasn’t going to chance that again. When he came upstairs with his son, he stormed into my office and said since I couldn’t bring him his charger, I needed to go home. I told him that I had a few more emails to answer because I had wasted away my day doing his personal work (helping him apply to Tulane) and I didn’t like leaving unfinished work on my desk. He was trying to get me to leave with him. He said he could drop me off at home. I told him no, thanks, I will leave when Mr. Crumb leaves. He then got angry again and said that he knew I could have brought him his charger and that his son was sick. I told him my daughter is at home and I don’t have any sons. He took

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offense to that and said, “So are you telling me that you don’t care about my son being sick?” I said, “What I am saying to you is my daughter is at home and I don’t have any sons.” He did as he normally does and went into a rant and started saying that he was going to fire me, and that all he had to do was say the word to Mayfield and I would be gone. A few days later, Paul came to me and said Mr. Mayfield wanted to fire me because they owed me overtime and that they would discuss it with me in executive session that morning. They did indeed call me into executive session and state they owed me overtime. I clearly advised that I never asked for any money or overtime and that I found it strange that they would bring this to my attention nearly two years after being employed with the city. I asked them to keep the money and they refused. I asked them if I could take the time off and they refused. This was all a part of Paul’s scheme to pay me off with hush money and to paint a negative picture of me to the public. He and his friend Reginald Taylor bragged throughout the community on their plan. When this didn’t work, Paul went to the Board and asked to replace me with someone else. He had the locks changed on the doors and prepared to hire someone else. I walked in on him interviewing Jay Pearson, who has allegedly given him

kickbacks on the Mississippi School of Protocol and Etiquette funding, after Marie Thompson mistakenly left an email on the printer confirming the appointment. It is my understanding that when he took this proposal to the Board (Beauman, Mayfield, Langford, Thames, etc), they advised Paul that they were not in agreement with firing me because I had not done anything wrong. Paul then moved to have the position eliminated. Beauman and Mayfield reportedly advised that they would be amenable to having the position eliminated but they could not go along with Paul’s shenanigans of

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having me fired.

Paul brought this to the Board and was supposed to have voted on

my dismissal. However, he suckered Mayfield into voting on it, secured the 2 votes, and then decided to not vote in an effort to keep his hands clean. Mr. Mayfield told the newspaper that he did not know why Paul, at the last minute, decided not to vote for this. He stated that it was all his (Mr. Mayfield’s) idea. He also had a discussion with me outside of City Hall and told me that one of Paul’s closest supporters told him that Paul had made a fool of them. He said he told that supporter that he doesn’t know why Paul didn’t vote for it. He said that he didn’t have any problems with me, but if Paul felt he didn’t need me as an employee anymore, he was okay with that. Furthermore,

when Paul hired his first cousin Seychan Lewis to come to our office to work, he never talked to me about it. He had Marie take Seychan around and introduce him and no one ever told me, The Chief of Staff is what Seychan’s role was (this is because Paul knew he was firing me). I memorialized this in an email also. Also, as the Chief of Staff, I was leading the process for hiring a new secretary for the office. I had worked with Human Resources (Carolyn Butler) on crafting the job description, posting the job, screening the applications, developing testing and reviewing those results, and narrowing the list down to a group that was ready to be interviewed. All of a sudden, the Mayor advises us that we are not to work on this anymore and that he will be the sole person responsible for picking the secretary. He eliminated me from that process. I went to LD’s to get lunch and I saw the Mayor and his cousin Seychan Lewis interviewing the current secretary, Mrs. Jackie Walker, which is also a former mistress to Paul. He hired her exactly one week after dismissing me.

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INTERROGATORY NO. 10.:

Please state, in detail and not with mere

general statements, the basis for the allegations in paragraph 15 of your First Amended Complaint that “after Plaintiff filed her charge of discrimination with the EEOC, the Defendants again retaliated against the Plaintiff by threatening her with criminal prosecution for baseless charges.” Include in your response, the identity of the

person(s) who made the threat, the date the threat was made, all persons who witnessed the threat and state specifically what words were said by the person making the threat. RESPONSE: Plaintiff objects to this interrogatory as it is overly broad and

vague. Anderson v. UPS, Inc., 2010 U.S. Dist. LEXIS 123878 *6 (D. Kan. Nov. 22, 2010); Aikens v. Deluxe Fin. Servs., Inc., 217 F.R.D. 533, 538 (D. Kan. 2003); Hilt v. SFC Inc., 170 F.R.D. 182, 186-7 (D. Kan. 1997); Stephens v. City of Chi, 203 F.R.D. 353, 361-2 (N.D. Ill. 2008). Notwithstanding, please see letter from Vance and prediscovery disclosures previously produced. INTERROGATORY NO. 11.: Please state, in detail and not with mere

general statements, the basis for the allegations in paragraph 18 of your First Amended Complaint that Mayor Winfield “created a sexually hostile work environment” for you. Include in your response the period of time you contend the work environment was “sexually hostile” and state in detail each fact which supports this claims. RESPONSE: Please see responses to Interrogatories 5, 6, 8 and 9. Please state, in detail and not with mere

INTERROGATORY NO. 12.:

general statements, the basis for the allegations in paragraph 28 of your First Amended Complaint that you complained about the alleged sexual harassment. Include in your

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response the date of each complaint and the identity of the person to whom the complaint was made. RESPONSE: Plaintiff objects to this interrogatory as it is overly broad and

vague. Anderson v. UPS, Inc., 2010 U.S. Dist. LEXIS 123878 *6 (D. Kan. Nov. 22, 2010); Aikens v. Deluxe Fin. Servs., Inc., 217 F.R.D. 533, 538 (D. Kan. 2003); Hilt v. SFC Inc., 170 F.R.D. 182, 186-7 (D. Kan. 1997); Stephens v. City of Chi, 203 F.R.D. 353, 361-2 (N.D. Ill. 2008). Notwithstanding: Complaints to Upper Management: a. Walterine Langford, HR Director: I complained about this to Walterine

Langford, Acting HR Director, on or about March 23, 2011. This was the same day that Officer Jimmy Brooks of the Madison PD was killed in a motorcycle accident. This stemmed from an email that the Mayor had me to send out regarding the crash that lead to Bill Ford coming to our office angry. Walterine Langford brought this to the attention of the Mayor who later chastised me for telling Walterine that he allowed these employees to speak badly towards me because of our issues. He stated that telling Walterine would not help me at all. Instead, it would only cause more problems. On a separate occasion, I advised Walterine and put her on speaker phone with Mani Vaughn Chiperseth of the Vicksburg Post newspaper complaining that Paul had leaked the overtime information to the Post because of our relationship. On an earlier

occasion, Walterine came to me and asked me whether or not Paul and I were in a relationship. She stated that her husband had told her that we were in a relationship

and that she told her husband that she believed I was too professional, pretty, and smart to be in a relationship with Paul. At that point I didn’t either admit or deny the relationship. I just looked at her.

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b.

Lee Davis Thames, City Attorney: On the Tuesday or Wednesday prior to

Paul eliminating my position, I walked in on a telephone discussion that Lee Davis Thames was having with Paul. Paul was advising Lee that he was going to fire me and Lee was telling Paul that it was not a good idea. He kept telling Paul to just think about it for a while. This was after we had the fight in front of his house. Lee begged and pleaded with Paul to not do it. I eventually knocked on the door to let Lee know that I was outside of his door. When I walked in, Lee asked me how long I had been out there. I told him long enough to hear that conversation. I told him that Kenny Daniels had already informed me of what Paul had planned to do to me and that Kenny had talked to Paul’s Uncle Red and his brother Michael (both of whom told him not to allow his emotions to get in the way of logical decisions). I told him that if Paul fires me because I refuse to sleep with him that I would most definitely sue him. Lee evidently talked to Paul about it because Paul came into the office and threatened me again, saying he was going to fire me and he doesn’t care who I tell about what he had done to me. He is Paul Winfield and his daddy was Lawyer Winfield. I am just a smart ass girl from across the bridge. He further threatened me with the Dixie Mafia. (This I reported to the FBI.) He told me that Pete Buford, John Bell, and the Dixie Mafia would have me killed if I sued him. He said they had a lot of money tied up with him and they would kill me before they allowed me to sue him. At first, I thought he had created a Mafia group, but when I researched it and found that the Dixie Mafia was actually a group in Mississippi at some point, I turned this threat over to the Federal Bureau of Investigation.

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c.

Kenny Daniels, EMS Chief: Kenny Daniels is Paul’s cousin-in-law and he

always joked with me about how much he cared for me and how Paul would do other’s harm if he thought anyone had an interest in me. Please see the text messages in my phone from Kenny Daniels. When Paul became angry at me for breaking up with him

and as he stated “running to Jackson every day to see a man” he told his brother Michael and the EMS Chief, who are very close friends and in-laws that he was going to fire me. Kenny Daniels told me that his brother advised him not to do that but Paul was adamant that he wasn’t going to have me working there if I wasn’t going to be fully accessible to him. I told him that Paul cannot legally affect my job positively or negatively due to whether or not I have sex with him. He said that he knew I had a daughter and he wanted to give me a warning. I told him thanks but I would sue Paul if he did that me. Evidently, Kenny went back and talked to Paul’s Uncle Red because Paul came to work and threatened me again with the Dixie Mafia and asked me why I would tell Kenny. I told him because Kenny told me what you are planning on doing to me. He was mad because his Uncle Red knew how serious this situation was. d. Alderman Michael Mayfield: On the same day that I spoke with Walterine

Langford and with Mani Vaugh Chiperseth on speaker phone, I called Mr. Mayfield. We discussed the affair and Mr. Mayfield stated that he told Paul time and time again that the way he handles his business is wrong. He stated that Paul doesn’t even hide that he is in love with me. He said he knew something had gone wrong with me and Paul

because Paul now had too many women in that same building and he doesn’t try to hide it. He told me that Paul was also having an affair with the Deputy City Clerk, Deborah Blake and that is why she tries to avoid me. I told him that Deborah had called me out

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of the blue and asked to have lunch with me. I told him that I thought it was strange for her to ask to go to lunch with me because I had never really talked much to her. Although the conversation went very well and Mr. Mayfield talked about many different things, I found it odd that he was saying so much about Paul’s affairs especially after Paul had discussed with me the affair that Mr. Mayfield had with his secretary, Tasha Bell, that eventually lead to her termination. Paul told me that Tasha Bell and Mr. Mayfield had a long time relationship and someone had sent a letter to Tasha Bell and her husband, and Alderman Mayfield‘s wife, and Human Resources Generalist Carolyn Butler, and Sewer Department Manager Mr. Willie McCroy’s wife about the love triangle that was occurring between Mr. Mayfield and Tasha, Mr. McCroy and Tasha, and Mr. McCroy and Carolyn Butler. Paul stated that once Mayfield’s wife got the letter, she was extremely upset and set up a meeting with Tasha Bell and her husband to discuss the affair that had been occurring with her husband Alderman Mayfield. Paul stated that Alderman Mayfield’s wife gave him an ultimatum to either fire Tasha or divorce her. He said Mr. Mayfield worked it out with Tasha where she would turn in a letter of resignation and state that she was leaving to take care of her mom. Mr. Mayfield in turn agreed to financially support her until she found employment elsewhere. e. Walter Armstrong, Chief of Police: On the day of the Black History

Program, I called the Chief and asked him if he had time to discuss some things with me. He picked me up and we rode around for a time. He rode through Kings and up and down Highway 61. During this time I gave him details of the relationship I had with Paul and advised that now that I had ended the relationship that Paul was treating me poorly in the office, being disrespectful in front of citizens and I asked that he please talk

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with him. I also advised the Chief that I had spent the night in his apartment with Paul once before. I described his apartment to him, told him about the futon, the deer meat in the refrigerator, the few ragged towels in the bathroom closet and his shower curtain. He was angry that Paul had brought this drama into his apartment. He advised that he would. Evidently he spoke with Paul because again Paul came to me angry because I told the Chief his business. I told him that the affair was no secret to the Chief—the Chief had gone out with me and Paul on several occasions and I was certain that he had already picked up on the affair. I told Paul that he needed to seek professional help because he can’t make me be with him. He said telling the Chief doesn’t do any good because the Chief has enough problems of his own. He said that the Chief had

Community Resource Office, Danita Reed, pregnant and that his wife had caught him with a professor from Alcorn. So, telling the Chief wouldn’t do anything but get me fired quicker. I had to work through all of these threats and turmoil while maintaining some level of professionalism and trying to shelter my feelings of discomfort from the citizens and business community. INTERROGATORY NO. 13.: State whether you contend that this Defendant

has made any admissions or statements against his own interests regarding the matters alleged in the Complaint. For each alleged admission or statement, identify the date and location of the statement, each person to whom the statement was communicated and describe in detail the substance of the statement. RESPONSE: Plaintiff objects to this interrogatory as it is overly broad and

vague. Anderson v. UPS, Inc., 2010 U.S. Dist. LEXIS 123878 *6 (D. Kan. Nov. 22, 2010); Aikens v. Deluxe Fin. Servs., Inc., 217 F.R.D. 533, 538 (D. Kan. 2003); Hilt v.

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SFC Inc., 170 F.R.D. 182, 186-7 (D. Kan. 1997); Stephens v. City of Chi, 203 F.R.D. 353, 361-2 (N.D. Ill. 2008). disclosures. INTERROGATORY NO. 14.: List in chronological order all email addresses, Notwithstanding, please see Plaintiff’s Pre-discovery

email accounts and IP addresses (whether personal or business) used by you or by anyone in your residence from January 2009 through the present. RESPONSE: and overly broad. Notwithstanding, This is my personal email address and my minor daughter’s 2 personal email addresses. I also had one other email address that I used to communicate with the Federal Bureau of Investigation (FBI); I forget that email address, but I am sure the FBI can let opposing council know what it is. I don’t have a static IP address, so I don’t know any IP addresses. IP addresses are randomly assigned by an ISP. I just subscribed to home Internet September of 2012. From 2009 – Sept 2011, I utilized the City of Vicksburg’s free downtown Wi-Fi network. INTERROGATORY NO. 15.: Identify each and every computer you have Plaintiff objects to this interrogatory as it unduly burdensome Whitlow v. Martin, 259 F.R.D. 349, 354-5 (C.D. Ill. 2009).

used from January 2009 to the present, including desktop computers, PDAs, portable, laptop, notebook and tablet computers. For purposes of this Interrogatory, the phrase “identify” means to state: (a) (b) (c) the owner and date of purchase of the computer in question; brand, model and serial number of the computer; all purpose(s) for which you used the computer;

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(d) (e)

where this computer is presently located; and, whether you used the computer in connection with your work at the City of

Vicksburg or in communications with this Defendant. RESPONSE: and overly broad. Plaintiff objects to this interrogatory as it unduly burdensome Whitlow v. Martin, 259 F.R.D. 349, 354-5 (C.D. Ill. 2009).

Notwithstanding, as best I can recall, I used the following computers or handheld devices for internet access: City of Vicksburg computer and IPhone, City of Vicksburg library, unemployment office in Jackson, Federal Bureau of Investigation Computer, EEOC Computer, Senior Center computer, Walterine Langford’s computer, Marriot Inn, Memphis TN, my minor niece’s computer to tutor her on math, Hampton Inn, Olathe, KS, Aloft Hotel, Dallas Texas, Aloft Hotel Irving, TX, JP Morgan Chase work computer at Chase, Century Work computer at work, Fed EX Kinko’s computer, Sarah Nix’s computer-Gulfport MS, my phone which has been entered into evidence Samsung brand, handheld at Best Buy whenever I go into one of their stores, I use various laptops at Wal-Mart, Target, and other electronics stores to check how they work/features and benefits, I used my daughter’s PSP, IPOD and her phone. Since I don’t personally own a computer, I don’t know the serial numbers of the computers or remember the makes or models. When I use random computers, it is for no other reason than to check my personal email account, my bank account, the local news, or my Facebook account. The devices that I remember using in communication with the

defendant are my personal cell phones, my work cell phones and my City of Vicksburg work computers (2).

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INTERROGATORY NO. 16.:

Identify each computer which you have had re-

formatted, had the operating system reinstalled in or which you have had scrubbed, wiped clean or overridden and, for each such computer, state the date on which each drive was wiped, the method or program used (e.g., WipeDisk, WipeFile, BurnIt, Data Eraser, etc.), the identity of the person performing the task and the reason the computer was scrubbed, wiped clean or overridden. RESPONSE: None. State with specificity the amount of damage

INTERROGATORY NO. 17.:

you are claiming in this lawsuit, itemize each element of damages and provide a detailed explanation of your basis for arriving at each amount. RESPONSE: DAMAGES BACK WAGES FRONT PAY FOR 5 YEARS COMPENSATORY DAMAGES AMOUNT $156,000 $360,000 $1,000,000

TOTAL* $1,516,000 * Attorney fees and punitive damages to be determined by jury or judge at trial. Back wages are based on Plaintiff’s rate of pay at termination plus one year to trial. Front pay is based on what Plaintiff would have made had she stayed in her position with the City of Vicksburg for five more years. Plaintiff contends that one million dollars in compensatory damages is a fair and equitable amount to which she is entitled because of the pain and suffering she had to endure which was caused by Defendants. INTERROGATORY NO. 18.: For each health care provider from whom you

received any consultation or examination of treatment for any physical or mental injury

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you attribute to the sexual harassment, retaliation or any other cause of action you have alleged in this case, please state the provider’s name, address, the type of consultation, examination or treatment provided and the dates you received consultation, examination or treatment. RESPONSE: Dr. David Barnes, Barnes Family Medical Clinic, Monroe,

LA. He treated me for pain caused by irregularities that occurred as a result of me having many menstrual cycles triggered by stress from this whole ordeal. Additionally, he treated me for the growth on my shoulder that I believe resulted from one of the fights I had with the mayor. He referred me to another doctor in Monroe, but I did not have the required $250 when I went to see him, so the tumor/growth is still on my shoulder. INTERROGATORY NO. 19.: For each instance in which a healthcare

provider advised that you may require future or additional treatment for any mental or physical injury that you attribute to the alleged sexual harassment, retaliation or other causes of action you alleged in this case, please state the name and address of each healthcare provider and the complaints for which the treatment was advised. RESPONSE: See response to No. 18. For each company or individual for whom you

INTERROGATORY NO. 20.:

have worked since April 18, 2011, provide the name, address and telephone number of each company and/or individual, the date(s) of your employment, the name of your immediate supervisor, your rate of pay and the reason you are no longer employed (if applicable).

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RESPONSE: July 2012 to present. a.

JP Morgan Chase - Oct 2011 to July 2012. CenturyTel/Link -

I needed a job desperately and JP Morgan was the first company to hire

me. Although I had applied and Interviewed with Century, Chase offered me a job first (as a rehire) and I accepted the position there. Once Century moved past their hiring freeze and offered me a (rehire) position, I resigned from Chase and started working at Century. I have worked for both companies before in the past. At Chase, I was a Senior Process Analyst, and at Century, I am a Senior Lead Process Analyst. b. JP Morgan Chase 270 Park Avenue New York, NY 10017 700 Kansas

Lane/702Kansas Lane Monroe, LA 1st FL/2ndFl, Employment Verification - 212-6228650, Superintendent – J. Aswell, Pay $75,000/Year. (I was a rehire, so my initial date of employment will show as 1998), c. CenturyTel/Link, 600 New Century Parkway /100 Century Way, New

Century, KS / Monroe, LA, for employment verification contact: EVP General Counsel, Stacey Goff, Direct Supervisor-Kenny Koptka, Pay $82,000/Year plus annual bonuses at 10%. (I am a rehire, so my initial date of employment will show as 2003.) INTERROGATORY NO. 21.: Describe in detail each job you held before

working for the City of Vicksburg, including (1) the name, address and telephone number of each employer; (2) the jobs that you held; (3) the identity of your direct supervisor; (4) the dates that you were employed in these jobs; and (5) the reason your employment was terminated. RESPONSE: responses. Please see Plaintiff’s resume submitted with these

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INTERROGATORY NO. 22.:

For each lawsuit, administrative charge or

proceeding, and court action, whether civil, criminal, workers’ compensation, divorce or otherwise, in which you are or have been a party or witness, identify (1) the style of the action; (2) the nature of the action; (3) your role in the case; (4) the court or other forum in which the action was filed; (4) the lawyers for each party; and (5) the outcome. RESPONSE: None, other than this lawsuit. Have you ever been convicted of any crimes?

INTERROGATORY NO. 23.:

If so, please describe the offenses, state each city and state where you were convicted and the date of each conviction. RESPONSE: None, other than traffic tickets. State the name, address and contact

INTERROGATORY NO. 24.:

information for each school or other academic or vocational institution you have attended, beginning with high school and the dates you attended each school or other academic or vocational institution. Include a statement of the degrees, if you received, and the date the degrees were received. RESPONSE: a Lake Providence High School – Valedictorian of the Class of 1991 b. Grambling State University - Fall of 1991 4.0 GPA c. Northeast LA University – Spring 1992 – Fall 1996 d. Pearl River Community College- Spring 1997 e. Devry University - 2001- 2003 Bachelor of Science in Network Mgmt. Magna cum Laude Graduate f. Dallas County College – Irving Campus 2002 or 2003- Classes toward Bachelors g. Dallas County College – Mountain View Campus 2002 or 2003 – Classes toward Bachelors 30

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h. Keller Graduate School of Management 2003-2005 Masters of Business Administration, Magna cum Laude Graduate This, the 18th day of October 2012. Respectfully submitted, /s Nick Norris NICK NORRIS, MB #101574 Attorney for Plaintiff OF COUNSEL: LOUIS H. WATSON, JR., P.A. 628 North State Street Jackson, MS 39202 Phone: (601) 968-0000 Facsimile: (601) 968-0010 nick@louiswatson.com

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CERTIFICATE OF SERVICE I, NICK NORRIS, attorney for the Plaintiff, do hereby certify that I have this day served via ECF filing or by United States mail, postage prepaid, a true and correct copy of the above and foregoing document to the following counsel of record: Vikki J. Taylor, MSB# 9540 Robert L. Gibbs, MSB #4816 GIBBSWHITWELL PLLC 1400 Meadowbrook Road, Suite 100 Jackson, Mississippi 39211 Phone: (601)487-2640 Fax: (601)366-4295 Email: vtaylor@gibbswhitwell.com Email: rgibbs@gibbswhitwell.com

Gary Friedman Phelps Dunbar, LLP 4271 I-55 North Jackson, MS 39211 601-352-2300 friedmag@phelps.com This, the 18th day of October 2012.

/s Nick Norris NICK NORRIS

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