Case: 45C11:23-cv-00266-JM Document#:1 Filed: 08/21/2023 Page 1 of 20 IN THE CIRCUIT COURT OF MADISON COUNTY, MISSISSIPPI MAYOR MARY HAWKINS BUTLER, IN HER INDIVIDUAL AND OFFICIAL CAPACITIES, AND THE CITY OF L MADISON, MISSISSIPPI Case No. 13-4 aM Plaintiff, versus MADISON COUNTY SUPERVISOR F Lo deoke D GERALD STEEN; MADISON COUNTY SUPERVISOR KARL M. AUG 21 2023 panes MAD eon COUNT ANITA MPNgY, CIRCUIT CLERK SUPERVISOR PAUL GRIFFIN; AND i ‘THE OHIO CASUALTY INSURANCE 0 DIE COMPANY D/B/A LIBERTY MUTUAL SURETY Defendants. COMPLAINT Plaintiff's Mayor Mary Hawkins Butler, as an individual taxpayer, and the City of Madison, as an interested government entity, bring this action under Miss. Code § 25-1-45 for civil liability for failure to perform duties and Miss. Code § $1-7-57 for unlawful expenditures, against Madison County Supervisors Gerald Steen, Karl Banks, and Paul Griffin, and their surety, the Ohio Casualty Insurance Company (Liberty Mutual’) INTRODUCTION In the mid-2000s, the Minnie J. Bozeman Family Limited Partnership donated approximately 85 acres of land to Madison County. The Partnership attempted to put conditions on its donation, requiring that construction of Reunion Parkway begin fiovsss1062Case: 45CI1:23-cv-00266-JM Document #:1 Filed: 08/21/2023 Page 2 of 20 within two years of its donation. But the Mississippi Department of Transportation required an unrestricted donation, so the Partnership executed an unrestricted deed to Madison County with no reversion. The Partnership also sought to have its adjacent land rezoned, and the County agreed, but the Mississippi Court of Appeals reversed. This case arises out of throc Supervisors’ illegal attempt to make the same deal with the Partnership again, Even though the County owns the 35 acres free and clear, Gorald Steen, Karl Banks, and Paul Griffin authorized County Attorney Mike Espy to negotiate a new deal with the Partnership, under which the Partnership agreed to “donate” the 35 acres (which the County already owns), in exchange for an agreement to rezone the Partnership’s adjacent property and to pay the Partnership $965,000, which the Partnership agreed to return if an interchange with on- and off-ramps is built at Reunion Parkway. Nothing about this deal is legal. The County does not owe the Partnership a guarantee that MDOT will build an interchange; the Supervisors cannot pay public funds to the Partnership for nothing in return; they cannot contract to vote to approve rezoning of the Partnership's adjacent property; and they cannot meet to authorize the County Attorney to negotiate such a deal in private meetings with no minutes. As a taxpayer, Mayor Mary Hawkins objects. And the City of Madison is seeking to annex the Partnership's property, and therefore it has an interest in the transaction. soresstvev2Case: 45C11:23-cv-00266-JM Document #:1 Filed: 08/21/2023 Page 3 of 20 PARTIES 1. Mayor Mary Hawkins Butler is an adult individual resident of Madison County. Mayor Hawkins Butler is a taxpayer of Madison County. She serves as the Mayor of the City of Madison. 2. The City of Madison is a municipal corporation organized and existing under the laws of the State of Mississippi. The City has filed a petition to annex property that is the subject of this Complaint. See The City of Madison, Mississippi v. City of Gluckstadt, Mississippi et al, 45CH1:23-cv-00563. 3. Gerald Steen is an adult individual resident of Madison County. Mr, Steen serves on the Madison County Board of Supervisors as the Supervisor for District Three of Madison County and may be served at his residence located at 312 Bob White Lane, Ridgeland, Mississippi. 4, Karl M, Banks is an adult individual resident of Madison County. Mr. Banks serves on the Madison County Board of Supervisors as the Supervisor for District Four of Madison County. Mr. Banks can be served at his residence located at 104 Southampton Circle, Madison, Mississippi, or at his workplace located at 819 W. North Street, Canton, Mississippi. 5. Paul Griffin is an adult individual resident of Madison County, Mr Griffin serves on the Madison County Board of Supervisors as the Supervisor for District Five of Madison County and ean be served at his residence located at 1010 Sulphur Springs Road, Camden, Mississippi. ova93i062Case: 45C11:23-cv-00266-JM Document#:1 Filed: 08/21/2023 Page 4 of 20 6. The Ohio Casualty Insurance Company, doing business as Liberty Mutual Surety (‘Liberty Mutual’), is the surety that issued the official bonds for Gerald Steen, Karl Banks, and Paul Griffin pursuant to Miss. Code § 19-3-5. The Ohio Casualty Insurance Company is a corporation formed under the laws of the State of New Hampshire with its principal mailing address at 100 Liberty Way, Dover, New Hampshire, 08820. Liberty Mutual may be served by service of process upon its registered agent, the United States Corporation Company, at 109 Executive Dr., Ste 8, Madison, Mississippi 39110. VENUE AND JURISDICTION 7. ‘The amount in controversy exceeds two hundred dollars, and jurisdiction is proper in the Circuit Court of Madison County under Miss. Code § 9-7- 81. 8. Venue is proper in Madison County under Miss. Code § 11-11-3(@). FACTUAL ALLEGATIONS 9. On dune 18, 2007, the Madison County Board of Supervisors (the “Board”) voted to adopt and approve a Memorandum of Understanding between Madison County, Mississippi and the Minnie J, Bozeman Family Limited Partnership. See Exhibit “A,” June 18, 2007 Board Minutes. The Memorandum of Understanding is attached as Exhibit “L” to the Minutes. Under the Memorandum of Understanding, the Minnie J. Bozeman Family Limited Partnorship agreed to donate cleven acres of real property to Madison County, subject to the condition that the County must reach a “timely” agreement with the Mississippi Department of 0149510602Case! 45CI1:23-ev-00266-JM Document #:1 Filed: 08/21/2023 Page 5 of 20 ‘Transportation and the Federal Highway Administration for construction of Reunion Parkway and the construction of an interchange. 10. On June 25, 2007, the Board voted to adopt and approve an amended Memorandum of Understanding with the Minnie J. Bozeman Family Limited Partnership, See Exhibit “B," June 25, 2007 Board Minutes. 11, The Memorandum of Understanding with the Minnie J. Bozeman Family Limited Partnership is recorded at Book 2244, Page 0070 of the records of the Chancery Clerk of Madison County, Mississippi. See Exhibit “O,” Recorded Memorandum of Understanding. 12, On February 10, 2009, the Minnie J. Bozeman Family Limited Partnership conveyed by Special Warranty Deed the property described in the Memorandum of Understanding. The Special Warranty deed contains an automatic reversion if construction of the proposed interchange has not commenced by the second anniversary of the deed. The Special Warranty Deed is recorded at Book 2402, Page 0578 of the records of the Chancery Clerk of Madison County, Mississippi. See Exhibit “D,” Special Warranty Deed. The land conveyed is 35.0748 acres in the North ¥ of Section 81, T8N-R2E, and the NW % of Section 32, TSN-R2E, of Madison County. 13. On August 24, 2009, the Board voted to approve an addendum to the Memorandum of Understanding with the Minnie J, Bozeman Family Limited Partnership. The Minutes reflect that the addendum was necessary due to “the requirements of the MDOT which preclude reversionary interests in deeds and right of way instruments.” See Exhibit “E,” August 24, 2009 Board Minutes, rovasst04v2Case: 45CI1:23-cv-00266-JM Document#:1 Filed: 08/21/2023 Page 6 of 20 14, On Soptember 8, 2009, the Board voted to approve an addendum to the Memorandum of Understanding with the Minnie J. Bozeman Family Limited Partnership, to correct the warranty deed recorded in Book 2042 at Page 578. See Exhibit “F,” September 8, 2009 Board Minutes. Supervisors Banks and Griffin were on the Board of Supervisors at this time, 15, On September 15, 2009, the Minnie J. Bozeman Family Limited Partnership executed an Amended and Restated Special Warranty Deed, found at Deed Book 2469, Page 0890. The Amended Deed removes the reversion. The land conveyed is 35.0748 acres in the North % of Section 81, T8N-R2E, and the NW % of Section 32, T8N-R2E, of Madison County. See Exhibit “G,” Amended and Restated Special Warranty Deed. 16, As of September 15, 2009, Madison County was the owner in fee simple of the 35.0743 acres in the North % of Section 31, TSN-R2E, and the NW ¥ of Section 82, TSN-R2E, of Madison County, conveyed in the Amended and Restated Special Warranty Deed. The Minnie J. Bozeman Family Limited Partnership no longer owned any interest in the subject property. 17. On dune 4, 2010, Madison County sued the Mississippi Department of ‘Transportation for failing to fund the Reunion Parkway Phase III project. See Case No, 25CI1-10-cv-432WAG (Hinds Cty. Cir. Ct.). The parties entered into a settlement agreement, which provides that the Mississippi Transportation Commission will assume responsibility for constructing an interchange to connect Reunion Parkway East to the West Side of the Interstate when either the Gluckstadt Road interchange movsgsi042Case: 45CI1:23-ev-00266-JM Document #:1 — Filed: 08/21/2023 Page 7 of 20 or the Highway 463 interchange reach a service level “F.” See Exhibit “H,” Settlement Agreement. 18. On June 7, 2010, the Board voted to approve the Minnie J. Bozeman Family Limited Partnership's petition for rezoning 17 acres on the corner of Gluckstadt Road and Bozeman Road from Special Use to C-1, The Mississippi Court of Appeals reversed. See Speyerer v. Bd, of Supervisors, 139 So. 3771 (Miss. Ct. App. 2014), 19. On March 17, 2014, Supervisors Steen, Banks, and Griffin voted to authorize the Tax Assessor to place the 85 acres donated to the County back to the grantor, Minnie J, Bozeman Family Limited Partnership, back on the land roll. See Exhibit “I,” March 17, 2014 Board Minutes, The County executed no deed returning the property to the Minnie J. Bozeman Family Limited Partnership. Nor could the Partnership re-acquire title through adverse possession. Smith v. Sims, 281 So. 3d 1069, 1075-76 (Miss. Ct. App. 2019). 20. On November 15, 2021, the Board voted to authorize payment to the Minnie J, Bozeman Family Limited Partnership in the amount of $1,030,700.00 for acquisition of right of way related to the Reunion Parkway Phase II Project. Attached to the Agenda as Item 28 is the Closing Statement for Parcels 001-00-00-W / 001-00- 00-T-001, 002, 008, 004, 005 & 006 / 001-00-00-E-001 and executed deeds, filed on November 11, 2021, conveying the property. The area of acquisition is 36.0743 acres. See Exhibit “J,” November 15, 2021 Board Minutes, This is the same property described in the September 15, 2009 Special Warranty Deed. sroveg3i04e2Case: 45CI1:23-ev-00266-JM Document #:1 Filed: 08/21/2023 Page 8 of 20 21. In other words, the Board voted to authorize payment to the Minnie J. Bozeman Family Limited Partnership for property that Madison County already owned. 22. The payment was based upon an Appraisal conducted by BBG, Ine., at the request of Mr. Karl Banks. See Exhibit “K,” Appraisal. The Appraisal noted that the property is primarily zoned SU-1 (Special Use District) and R-1 (Residential Estate District), Nonetheless, the Appraisal valued the property based on Commercial Development Use 23. On danuary 18, 2022, the Board voted to approve a Memorandum of Understanding related to the purchase of land related to the Reunion Parkway Phase 2 Project. The MOU is not attached to the January 18, 2022 minutes. See Exhibit “L,” January 18, 2022 Board Minutes. 24, The Minnie J. Bozeman Family Partnership recorded the Memorandum of Understanding in the land records of Madison County as a “Special Warranty Deed” at Book 4168, Page 554 to the records of the Chancery Clerk of Madison County. Paul Griffin signed the Memorandum of Understanding, See Exhibit “M,” Recorded 2022 Memorandum of Understanding, 25. On February 4, 2022, the Board issued a check to the Minnie J. Bozeman Family Limited Partnership in the amount of $965,000 from Trustmark Account No. GED. Whe Board also issued a $1,000 check from the same account to Integrated Right of Way, LLC. The $1,000 check shows on the February 3, 2022 106931062Case: 45CI1:23-cv-00266-JM Document #:1 Filed: 08/21/2023 Page 9 of 20 claims docket as from Account No. 324-300-955. The $965,000 check does not appear on the claims docket, See Exhibit “N,” February 2022 Claims Docket, 26. On February 22, 2022, the Board voted unanimously to approve an administrative adjustment in a sum certain regarding Reunion Parkway Phase 2 Project. Nothing is attached to the minutes reflecting this sum certain. See Exhibit “0,” February 22, 2022 Board Minutes. 27, On April 18, 2022, the Board approved as a consent item, Item 24, the Reunion Phase II Quarterly Report to DPA ($8m SB 2002). This Quarterly Report contains an unsigned MOU with the Minnie J, Bozeman Family Limited Partnership See Exhibit “P,” April 18, 2022 Board Minutes, 28. Under the 2022 Memorandum of Understanding, the parties agreed that ‘any deeds currently on file with the Madison County Chancery Clerk will be revoked.” See Exhibit “M,” {| 10. The Board, therefore, agreed to revoke its interest in the subject property in exchange for no compensation under the guise of accepting a donation of property the County already owns, 29. The Board agreed to “cooperate” with the Minnie J. Bozeman Family Limited Partnership “to provide all documentation necessary to achieve federal and state charitable credits...” See Exhibit “M,” {9 30. The Board agreed to pay the Minnie J. Bozeman Family Limited Partnership $965,000, and the Partnership agreed to return the payment if an interchange is constructed that connects Interstate-55 with Reunion Parkway via on- off ramps, See Exhibit “M.” morasst042Case: 45CI1:23-cv-00266-JM Document #:1 Filed: 08/21/2023 Page 10 of 20 31. ‘The 2022 Memorandum of Understanding contains no time limitation on the construction of the interchange, See Exhibit "M.” 32, While the Reunion Parkway extension has been funded and approved, the construction of an interchange with on-off ramps has not. 33. In sum, the Board agreed for the Minnie J. Bozeman Family Limited Partnership to “donate” land that the Partnership did not own (and therefore to receive tax credits for the donation), and to allow the Partnership to hold public funds as a guarantee that MDOT will construct an interchange with on- and off-ramps. 34, In addition to the conditions stated in the 2022 Memorandum of Understanding, the Minnie J. Bozeman Limited Family Partnership obtained an additional condition of the County's assistance in the re-zoning of the Minnie J. Bozeman Limited Family Partnership's property. 35. On February 16, 2023, County Attorney Mike Espy presented the application for rezoning for the Minnie J. Bozeman Family Limited Partnership property, The Planning and Zoning Commission minutes state that “Mr. Espy advised that Richard Skinner and the Minnie J. Bozeman Limited Family Partnership had graciously worked with Madison County on an agreement for the donation of right-of-way property to Madison County in order that Madison County could have clear title to that property to advance the project with MDOT. Mr. Espy confirmed that Madison County had agreed to assist in the re-zoning of the subject property in order for the Applicant to make commercial use of his property, and had provided Applicant with information on the planned 10 sroissgi0w2Case: 45CI1:23-cv-00266-JM Document #:1 Filed: 08/21/2023 Page 11 of 20 roadway and ramps that would traverse his property.” See Exhibit “Q,” Feb. 16, 2028 Planning and Zoning Commission Minutes. 36. Mr. Espy told the Planning and Zoning Commission: Now, in order to make this area viable, there's got to be a ramp, a ramp ingress egress off of 1-55, and that's what this concerns. So this particular partition concerns Mr. Skinner and the Bozeman Family Partnership, who owns land on the west side of 1-55, and I've been personally involved in this for a couple of years, We had to get right of way because MDOT said there couldn't be any cloud on the title concerning the right of ways ifwe want to build a ramp...so I personally met with Mr, Skinner a couple of times and we worked out a deal where he was extraordinarily generous, frankly, where he donated--he donated-it was sort of a negotiation. He didn’t want to donate all of it, because he's been fooled in the past by the County, where he donated land that was never any ramps, never any bridge, so the county gave the land back to him that he had donated. So I told him in my office, I said the only way this bridge won't happen is if Vladmir Putin bombs this county, Madison County, I don't think it’s going to happen, because it's got 100% support of the Board of Supervisors. So what we decided to do was to appraise the acreage that we needed him to donate. And he-we filed a deed where all of it was donated to the Madison County Board of Supervisors, 80 we have no cloud of title on the land, the deed has been filed, MDOT understands and everything is cool, but in order that we would have a partnership with him, he actually donated half of the land to Madison County. ‘And s0 in good faith, Madison County wrote him a check for the remaining 50% value of the land, that lets him know we're not shucking and jiving this time, we're going to join you in partnership to build these ramps and to build this bridge, and then the day that the cars are licensed...the day we cut the ribbon the ramps for the cars.,.he is going to write us a check back that we gave him for 50%, So that'll make it a complete value of a 100% donation. So that’s generous. ql fro1493106v2Case: 45C11:23-cv-00266-JM Document #:1 Filed: 08/21/2023 Page 12 of 20, So we're moving in accord with him, We believe that a bridge there is going to be very helpful to reduce traffic congestion, particular between City of Madison and Gluckstadt, There's going to be a bridge there with ramps on and off, it's been dosigned, it's been planned, we know what it costs, and we've gotten half the money in our treasury, enough that we're confident that it’s going to happen. We also know that Mr. Skinner can’t wait for two years for something to be built, for the bridge and ramp to be built. He has commercial interests in this land that's zoned agricultural. And I told him personally, and the Board confirmed, I don’t say anything without authorization of my Board, that we would do our best, to rezone this land, so that he could begin planning for commercial projects, shopping center, office building, whatever. ‘And also in order to help him do that, we told him, and my Board understands, that we made available to his engineer, the contours, you know where the road is going to be built, the elevations, the turns, so he can plan his curb cutouts, so that if it’s going to be a shopping center, already knows where the curb cutouts going to he, ‘cause he’s able to choose them, and the Board acquiesced, the Board did that for him in cooperation for what we're trying to do today. So I believe what you're going to hear today is their effort to come before to ask for this to be rezoned to commercial from agriculture, there's going to be a bridge, it’s going to happen...” 37. The Planning and Zoning Commission voted to approve the application for rezoning. The City timely appealed the decision. 38. On April 17, 2023, the Board voted to continue consideration of the rezoning application. 39. At the same meeting, John Rounsaville of Waggoner Engineering presented to the Board, Mr. Rounsaville stated, “We meet monthly already with your existing team, several of you board members, Mr. Espy, Arnie Hederman, and 12 soasi04r2Case: 45C11:23-cv-00266-JM Document#:1 Filed: 08/21/2023 Page 13 of 20, Michael Goud, and Tommie Cardin at Butler Snow, we meet monthly to discuss your ongoing strategic funding initiatives associated with your ongoing projects, and that has delivered results...” 40, On May 15, 2023, the Board held a public hearing on the City’s appeal of the Planning and Zoning Commission decision. The Board voted to continue the hearing. 41. On June 5, 2023, the Board held a public hearing on the City’s appeal of the Planning and Zoning Commission decision. Madison County Supervisor Trey Baxter noted that the City had raised the issue of contract zoning, and he noted that the County's minutes did not authorize contract zoning. 42. County Supervisors Steen, Banks, and Griffin voted to approve the Minnie J, Bozeman Limited Family Partnership's Application for Rezoning. See Exhibit “R,” June 5, 2023 Board Minutes, GOUNT1 43. The City incorporates by reference all preceding paragraphs of this Complaint. 44, County Attorney Espy stated to the Planning and Zoning commission that the Board authorized his statements and actions. 45, County Attorney Espy represented that the Board authorized him to tell the Minnie J, Bozeman Family Limited Partnership that the Board would rezone the Partnership's property as part of Espy's negotiations with the Partnership regarding the “donation” of property to the County. 13 novassi082Case: 45C11:23-cv-00266-JM Document#:1 Filed: 08/21/2023 Page 14 of 20, 46, No minutes of the County reflect authorization to Espy to offer to rezone the Partnership's property in exchange for the Partnership's “donation” of property to the County. 47. On information and belicf, County Supervisors Steen, Banks, and Griffin met with County Attorney Espy in a private meeting or meetings, at Butler Snow or elsewhere, in violation of the Open Meetings Act, and provided Espy with the authority to offer rezoning in exchange for structuring the transaction as a “donation,” which allowed the Partnership to wrongfully take valuable tax credits, to profit from the interest earned on the funds paid to the Partnership, and to have a financial guarantee that the County would build (or have built) the on- and off-ramp interchange, regardless of public need or the County's settlement agreement with MDOT. 48. Miss. Code Amn. § $1-7-57 allows any taxpayer to sue any elected public officer who appropriates or authorizes the expenditure of any money to an object not authorized by law. See Canton Farm Equip., Inc. v. Richardson, 601 So. 24 1098 (Miss. 1987). 49. Under Mississippi law, a governing body may not bargain away its zoning power by committing to make a developer's preferred zoning changes before engaging in the public process xequired by its own ordinances and state laws. See Old Canton Hills Homeowners Ass'n v. Mayor & City Council of City of Jackson, 749 So. 2d 54, 57-59 (Miss. 1999); 1 Am. Law, Zoning § 9:21 (5th ed.). 14 syoveasio42Case: 45C11:23-cv-00266-JM Document #:1 Filed: 08/21/2023 Page 15 of 20, 50. Under Miss, Code § 25-1-43, a public officer shall not enter into any contract on behalf of the state, or of any county, city, town, or village thereof, without being specially authorized thereto by law or by an order of the board of supervisors or municipal authorities. 51. Under Miss. Code § 19-3-40(8) and Section 66, Article 4 of the Miss. Const. (1890), no board of supervisors of any county is authorized to grant any donation without legislative authorization, No statute authorizes the Madison County Board of Supervisors to donate the real property at issue, nor the $965,000 gratuitously given to the Minnie J. Bozeman Family Limited Partnership. 52. County Supervisors Steen, Banks, and Griffin’s authorization to County Attorney Espy to offer to pay the Partnership and to rezone the Partnership's property, in exchange for a “donation” of land that the County already owned, is an object not authorized by law 53. Miss, Code § 25-1-45 allows “any perzon interested” to file suit on the bond of a county officer for damages caused by the officer's knowing and willful failure, neglect, or refusal to perform any duty required by law, or for violation of official obligations in any respect. 54. Miss. Code § 19-3-5 allows any taxpayer of the county to sue on such bond. 55. County Supervisors Steen, Banks, and Griffin's authorization of the contract zoning is a knowing and willful refusal to perform their mandatory duty to engage in a fair public process of considering the application for rezoning. 16 Ho19s1062Case: 45CI1:23-cv-00266-JM Document #:1 Filed: 08/21/2023 Page 16 of 20 56. County Supervisors Steen, Banks, and Griffin's authorization of County Attorney Espy’s nogotiation of the Memorandum of Understanding, which was not attached to the minutes of the meeting in which the Memorandum of Understanding was approved, is a knowing and willful violation of their official duties, in thet they approved (1) the donation of public property with no compensation; (2) the payment of money to a private citizen for an object not authorized by law; and (3) the oral contracting for rezoning. 57. Liberty Mutual is liable as the surety on County Supervisors Steen, Banks, and Griffin’s official bonds, See Exhibit “S,” Official Bonds. PRAYER FOR RELIEF WHEREFORE, Plaintiffs respectfully request: (a) Judgment ordering County Supervisors Steen, Banks, and Griffin, jointly and severally, to repay the unlawful expenditure of $965,000 to Madison County; (o) Judgment holding Liberty Mutual liable on the bonds of Steen, Banks, and Griffin up to the amount of bonds ($300,000), to he paid to the County; (© Any further relief the Court may deem appropriate Respectfully submitted, MAYOR MARY HAWKINS BUTLER and _ THE CITY OF MADISON By Their Attorneys, JONES WALKER, LLP By: I. [jh KAY M. PICK] 16 movaost082Case: 45CI1:23-cv-00266-JM Document #:1 Filed: 08/21/2023 Page 17 of 20 Kaytie M. Pickett (MSB No. 103202) Adam Stone (MSB No. 10412) JONES WALKER LLP 190 East Capitol Street, Suite 800 Jackson, Mississippi 39201 ‘Tel.: (601) 949-4900; Fax: (601) 949-4804 kpickett@joneswalker.com astone@joneswalker.com 17 movassi06aCase: 45CI1:23-cv-00266-JM Document #:1 Filed: 08/21/2023 | Page 18 of 20 ‘JONES oc Ton sae WALKER Foctetfprmnior com August 21, 2023, Han Anita Wray Circuit Clerk Madison County Circuit Court 128 W North Street Canton, MS 39046 Re: Mayor Mary Havikins Butler, In Her Individual and Official Capacities, and the City of Madison, Mississippi vs Madison County Supervisor Gerald Steen, et af, Madison County Court Dear Ms. Wray: Enclosed please find the original and five (5) copies of a Complaint with exhibits for filing together with a civil cover sheet and our firm's check in the amount of $151.00. Please file the original, stamp the copies “filed” and retum to us with our ctfice messenger. Also enclosed please find three originals of the following Summonses to be issued ~ a. Madison County Supervisor Gerarld Steen; b, Madison County Supervisor Kar! M, Banks; ©. Madison County Supervisor Paul Griffin; and d. The Ohio Casualty Insurance Company dibya Liberty Mutual Surety. Piease file one of each of the summonses and return two issued originals of each with our office messenger. ‘Also enclosed is the original and one (1) copy of the Notice of Service for the following Plaintiffs’ First interrogatories to Madison County Supervisor Gerald Steen; Plaintiffs’ First Requests for Production of Documents to Madison County Supervisor Gerald Steen; Plaintiffs’ First interrogatories to Madison County Supervisor Kari M. Banks, Plaintiffs’ First Requests for Production of Documents to Madison County Supervisor Karl M, Banks; * Plaintiffs’ First Interrogatories to Madison County Supervisor Paul Griffin; and + Plaintiffs’ First Requests for Production of Documents to Madison County Supervisor Paul Griffin. ‘TOO EEE Capita SISSI-SUHE' BOO) SERSAN’ MS 3O2OT™ "POT BOR AZT" VRKEOT MS 38205-0827 7 601.649.4900 | F: 601.949.4804 joneswalker.com o1sosisveCase! 45CI1:23-cv-00266-JM Document #:1 Filed: 08/21/2023 Page 19 of 20 Please file the original Notice and return a stamped filed copy to us, ‘Thank you for your assistance in this matter. If you should you have any questions, please feel free to contact me. Kats Labo Kaytie if. Pickett Enclosures August 21, 2023 Page 2 Hoisonne9v