Case: 25CI1:22-cv-00714-AHW Document #: 19 Filed: 07/19/2023 Page 1 of 2

IN THE CIRCUIT COURT OF HINDS COUNTY, MISSISSIPPI

JAKE SLINKARD PLAINTIFF

vs. Civil Action Number: 22-714

THE GREATER JACKSON ARTS

COUNCIL DEFENDANT

TRUSTMARK BANK GARNISHEE - DEFENDANT

MOTION FOR DISBURSEMENT OF FUNDS SUBJECT TO GARNISHMENT

COMES NOW, the Plaintiff, by and through counsel and respectfully request this

Honorable Court to Order Garnishee, Trustmark Bank, to pay the amount Garnishee is indebted to

Defendant to the client trust account of Plaintiff’s counsel, Langston & Lott, PLLC. In support

thereof, Plaintiff would show:

1. On April 24, 2023, Plaintiff, Jake Slinkard, recovered a judgment in the Circuit

Court of Hinds County against The Greater Jackson Arts Council for the sum of $57,600.00.

2. After enrolling the judgment, Plaintiff served a Writ of Garnishment on Trustmark

Bank on June 2, 2023.

3. On July 12, 2023, Trustmark Bank filed its Answer to Garnishment whereby it

stated it is indebted to the Defendant, The Greater Jackson Arts Council, in the sum of $23,588.27.

4. Trustmark Bank further requested that this Court instruct Trustmark Bank as to the

amount indebted - $23,588.27.

5. Plaintiff, Jake Slinkard, requests that this Court instruct Trustmark Bank to remit

the amount, $23,588.27, to Plaintiff’s counsel’s client trust account.

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Case: 25CI1:22-cv-00714-AHW Document #: 19 Filed: 07/19/2023 Page 2 of 2

WHEREFORE, PRESMISES CONSIDERED, Plaintiff respectfully requests this

Honorable Court to instruct Garnishee, Trustmark Bank, to pay the sum of $23,588.27 to Plaintiff’s

counsel’s client trust account.

Respectfully Submitted,

JAKE SLINKARD

By: /s/ William “Jack” Simpson _____

WILLIAM “JACK” SIMPSON, MBN 106524
Attorney for the Plaintiff

LANGSTON & LOTT, PLLC

100 South Main Street
Post Office Box 382
Booneville, MS 38829
Telephone: (662) 728-9733
Facsimile: (662) 728-1992
Email: jsimpson@langstonlott.com

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 Case: 25CI1:22-cv-00714-AHW Document #: 2 Filed: 11/15/2022 Page 1 of 5

IN THE CIRCUIT COURT OF HINDS COUNTY, MISSISSIPPI

JAKE SLINKARD PLAINTIFF

v. CIVILACTIONNO. ~-7/Cj
THE GREATER JACKSON ARTS
COUNCIL DEFENDNANTS

COMPLAINT

COMES NOW, the Plaintiff, Jake Slinkard, by and through his attorney, and brings this

Complaint against Defendant The Greater Jackson Arts Council. In support thereof, Plaintiff

would show:

PARTIES
1. Plaintiff, Jake Slinkard, is an adult resident of Madison County, Mississippi.

2. Defendant, The Greater Jackson Arts Council ("GJAC"), is a Mississippi

Corporation with its principal place of business at 201 East Pascagoula, Suite 103 Jackson, MS

39201. GJAC can be served with process through its regist~red agent, William Painter, at 100

Vision Drive Suite 400 Jackson, MS 39211.

JURISDICTION AND VENUE

3. This court has subject matter jurisdiction by virtue of a contractual agreement

entered into by and between the parties in Hinds County, Mississippi, which was to be executed

in whole or part in Hinds County, Mississippi. The Plaintiffs herein are seeking compensatory and

other damages in an amount in excess of Two Hundred Dollars ($200.00). Therefore, pursuant to

Section 9-7-81 of the Mississippi Code of 1972, as amended, original jurisdiction of this matter is

in the Circuit Court of Hinds County, Mississippi.

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4. Venue is proper pursuant to Mississippi Code Annotated Section 11-11-3 because

a substantial alleged act or omission and a substantial event that caused the injury occurred in

Hinds County, Mississippi.

5. The Circuit Court of Hinds County, Mississippi has subject matter jurisdiction of

this civil action and venue is proper in this Court. Further, this Court may exercise in personam

jurisdiction over the Defendants, because the Defendants reside in and conduct business within the

State of Mississippi.

6. The Plaintiffs herein demand a jury trial of this civil action pursuant to Rule 38 of

the Mississippi Rules of Civil Procedure as is their right pursuant to Article III, Section 31 of the

Mississippi Constitution of 1890.

FACTUAL BACKGROUND
7. On April 19, 2022, Jake Slinkard and GJAC ("the Parties") entered into a

contractual agreement for Mr. Slinkard to provide media production services.

8. The contract specified that it was to commence on May 1, 2022, and end on April

30, 2023.

9. Mr. Slinkard agreed to provided GJAC with access to six (6) half days of

production, at a reduced rate of $400 per half day, in exchange for $2,400 per month.

10. The contract further specified that Mr. Slinkard was to be paid within fifteen (15)

days of invoicing GJAC for the monthly $2,400 payment.

11. From May through October of 2022, Mr. Slinkard provided vanous media

production services for GJAC.

12. From May through July of2022, GJAC remitted the payment owed to Mr. Slinkard

under the contract.

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13. Upon information and belief, sometime in August of 2022, Jon Salem, Mr.

Slinkard's primary contact with GJAC, was terminated.

14. After Mr. Salem was terminated, GJAC stopped making timely payments to Mr.

Slinkard under the contract.

15. Sometime in mid-August, Mr. Slinkard reached out to Silbrina Wright, Executive

Director of GJAC, about the late/non-payment.

16. Ms. Wright assured Mr. Slinkard that his payment for August was being process

and would be made soon.

17. After numerous attempts, Ms. Wright and GJAC finally paid Mr. Slinkard on

September 3, 2022- but for September's invoice.

18. Mr. Slinkard has not been paid for August, October, or November.

19. On many occasions, Mr. Slinkard reached out to Ms. Wright and GJAC about the

nonpayment.

20. GJAC and Ms. Wright responded to Mr. Slinkard's inquiries by blocking not one

but two different phone lines that Mr. Slinkard used to communicate GJAC.

21. Despite GJAC's failure to pay and unwillingness to respond to Mr. Slinkard, he has

continuously made himself available to GJAC for media production services.

22. GJAC has never made known to Mr. Slinkard that the services he provided were

less than satisfactory in any way.

23. Mr. Slinkard has suffered emotional distress and mental anguish as a result of

GJAC's actions.

COUNT I- BREACH OF EXPRESS WARRANTY

24. Plaintiff, by this reference, adopts and re-asserts all allegations, averments, and

statements of fact contained in the preceding paragraphs of this Complaint.

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25. Pursuant to the contract, GJAC agreed to make monthly payments of$2,400 to Mr.

Slinkard in exchange for access to six (6) half days of production.

26. GJAC breached this express warranty by failing to pay Mr. Slinkard for the months

of August, October, and November of2022.

27. This breach proximately caused the damages for which recovery is sought.

COUNT II- BREACH OF THE COVENANT OF GOOD FAITH AND FAIR DEALING
28. Plaintiff, by this reference, adopts and re-asserts all allegations, averments, and

statements of fact contained in the preceding paragraphs of this Complaint.

29. In Mississippi, all contracts contain an implied covenant of good faith and fair

dealing.

30. GJAC breached the covenant of good faith and fair dealing by intentionally

withholding payment under the contract, refusing to communicate with Mr. Slinkard, and blocking

all communication channels Mr. Slinkard used to correspond with GJAC.

31. Such actions by GJAC amount to conscious wrongdoing an evince a dishonest

purpose.

32. This breach proximately caused the damages for which recovery is sought.

DAMAGES
33. Plaintiff, by this reference, adopts and re-asserts all allegations, averments, and

statements of fact contained in the preceding paragraphs of this Complaint.

34. As a direct and proximate result of the acts and omission of Defendant as set forth

herein above, Plaintiff has suffered substantial actual and compensatory damages, including but

not limited to the monthly payments lost under the contract, costs associated with searching for

replacement work, emotional distress and mental anguish, and attorneys' fees.

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35. The actions and/or inactions of Defendants were grossly negligent, entitling

Plaintiff to punitive damages under Mississippi Code Section 11-1-65 (1972, as amended) and/or

under the common law, in an amount sufficient to punish Defendants and to deter similar future

conduct.

WHEREFORE, PREMISES CONSIDERED, Plaintiffs demand judgment against

Defendant for actual, compensatory and punitive damages in an amount to be determined by this

Honorable Court or by jury, in addition to attorneys' fees and any and all additional relief the Court

may deem appropriate.

Respectfully Submitted,
JAKE SLINKARD

By:
W LIAM "JACK" SIMPSON, MBN 106524
Attorney for the Plaintiffs

LANGSTON & LOTT, PLLC

100 South Main Street
Post Office Box 382
Booneville, MS 38829-0382
Telephone: (662) 728-9733
Facsimile: (662) 728-1992
Email: jsimpson@langstonlott.com