City of Jackson Airport Suit

7/25/2019 City of Jackson Airport Suit

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IN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF MISSISSIPPI

NORTHERN DIVISION

JEFFERY A. STALLWORTH P

VS. CASE NO.: 3:16-CV-246

GOVERNOR DEWEY PHILLIP PHIL

BRYANT, STATE OF MISSISSIPPI,MISSISSIPPI LEGISLATURE, EAST METRO

PARKWAY, and MISSISSIPPI

DEPARTMENT OF TRANSPORTATION

TONY T. YARBER, Mayor of the City of

Jackson, Mississippi, on behalf of the

Citizens of the City of Jackson, Mississippi;TONY T. YARBER, individually as a

taxpayer and citizen of the City of Jackson,

Mississippi; MELVIN V. PRIESTER, JR.;

ASHBY FOOTE, KENNETH I. STOKES,

DEKEITHER STAMPS, CHARLES

TILLMAN, TYRONE HENDRIX, MARGARET

BARRETT-SIMON, all in their officialcapacities as elected members of the City

Council of the City of Jackson, Mississippi,

from their respective wards and in their

individual capacities as citizens of the City

of Jackson on behalf of themselves and all

others similarly situated; JACKSON

MUNICIPAL AIRPORT AUTHORITY;

BOARD OF COMMISSIONERS OF THEJACKSON MUNICIPAL AIRPORT

AUTHORITY; EVELYN O. REED, MR.

VERNON W. HARTLEY SR., LAWANDA D.

HARRIS, REV. JAMES L. HENLEY JR., and

DR ROSIE L T PRIDGEN all in their

DEF

APPLICA

INTER

Case 3:16-cv-00246-CWR-FKB Document 9 Filed 06/23/16 Page


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MOTION TO INTERVENE

Applicants Tony T. Yarber, Mayor of the City of Jackson, Mississip

of the Citizens of the City of Jackson, Mississippi and individually as a

taxpayer of the City of Jackson, Mississippi, Melvin I. Priester, Jr., Tyro

Ashby Foote, Kenneth I. Stokes, DeKeither Stamps, Charles H. T

Margaret Barrett Simon, all in their official capacities as elected member

Council of the City of Jackson, Mississippi, from their respective

individually as citizens of the City of Jackson, Mississippi, on behalf of the

all others similarly situated, the Jackson Municipal Airport Authority (J

Board of Commissioners of the JMAA (the JMAA Board), Dr. Rosie L.

Rev. James L. Henley Jr., LaWanda D. Harris, Mr. Vernon W. Hartl

Evelyn O. Reed, each in his or her official capacity as a Commissioner on

Board and individually as citizens of the City of Jackson, Mississippi,

themselves and all others similarly situated, (collectively, Applicant

undersigned counsel, file this Motion to Intervene seeking to intervene as

right in this civil case pursuant to Rule 24(a)(2) of the Federal Ru

Procedure. Applicants seek leave to intervene as Plaintiffs in this case

claims against Defendant Governor Phil Bryant, in his official capacity,

Governor Tate Reeves, in his official capacity, Madison County, Miss



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In support of this Motion and as more fully developed in the ac

Memorandum being filed simultaneously with this Motion:

1. Applicants have interests in the transaction that is the su

suit as specifically and particularly set forth in the attached proposed co

2. Applicants are so situated that disposition of this action w

intervention will, or may as a practical matter, impair or destroy the

protect that interest.

3. Applicants interests cannot be adequately represented

parties.

4. In the alternative, Applicants are entitled to permissive i

under Rule 24(b)(1)(B).

Accordingly, Applicants respectfully request leave to intervene a

themselves as plaintiffs in this civil action.

Dated: June 23, 2016.

Respectfully submitted,

Mayor Tony T. Yarber, Mayor City of Jackson, Mississippi, o

of the Citizens of the City of J

Mississippi; Melvin V. Priester

Ashby Foote, Kenneth I. Stoke

DeKeither Stamps, Charles Ti



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By: s/ Monica D. Joiner

Monica D. Joinder, Bar No

Gail W. Lowery, Bar No. 14Kristen Blanchard, Bar No

Office of the City Attorney

455 East Capitol Street

Post Office Box 2779

Jackson, Mississippi 39205

Telephone: (601) 960-1799

Facsimile: (601) [email protected]

[email protected]

[email protected]

Mayor Tony T. Yarber, individ

taxpayer and citizen of the Cit

Jackson, Mississippi, on behal

himself and all others similarl

By: s/Kimberly Banks

Kimberly Banks, Bar No.

P.O. Box 12303

Jackson, MS 39236-2303

Telephone: (601) 609-6732

Facsimile: (855) [email protected]

Melvin V. Priester, Jr., Ashby

Kenneth I. Stokes, DeKeither

Charles Tillman, Tyrone Hend

Margaret Barrett-Simon, indiv

citizens of the City of Jackson

Mississippi, on behalf of themall others similarly situated

By: s/ Everett Sanders

Everett Sanders, Bar No.

Sanders La Firm PLLC



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Jackson Municipal Airport Au

Board of Commissioners of th

Municipal Airport Authority, DL. T. Pridgen, Rev. James L. H

LaWanda D. Harris, Mr. Verno

Hartley Sr., and Evelyn O. Ree

in his or her official capacity a

Commissioner on the Board o

Commissioners of the Jackson

Municipal Airport Authority

By: s/ Fred Banks, Jr.

Fred Banks, Jr., Bar No. 17

LaToya C. Merritt, Bar No

Nicholas F. Morisani, Bar N

Phelps Dunbar, LLP

4270 I-55 North

Jackson, Mississippi 39211Post Office Box 16114


Telephone: (601) 352-2300

Facsimile: (601) 360-9777

[email protected]

[email protected]

[email protected]

By: s/ John Walker

John Walker, Bar No. 6883

Kevin B. Bass, Bar No. 103

Walker Group, PC

1410 Livingston Lane, Suit

Post Office Box 22849

Jackson, MS 39225-2849Telephone: (601) 948-4589

Facsimile: (601) 354-2507

[email protected]

[email protected]



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By: s/ Tylvester Goss

Tylvester Goss, Bar No. 49Goss & Williams, PLLC

1441 Lakeover Road


Telephone: (601) 981-2800

Facsimile: (601) 981-7979

Email: [email protected]

James L. Henley, Jr., Pro Se,

individually as a citizen of th

Jackson, Mississippi, on beha

himself and all others similar

situated

By: s/ James L. Henley, Jr.James L. Henley, Jr.

4860 North State Street

P. O. Box 31464


Telephone: (601) 519-2393



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CERTIFICATE OF SERVICE

I, Fred Banks, Jr., certify that on June 23, 2016, I electronically fiabove and foregoing Motion to Intervene with the Clerk of the Court usin

CM/ECF system which sent notification of such filing to the following:

I further certify that on June 23, 2016, I forwarded via U.S. Mail a

stamped copy of the foregoing Memorandum in Support of Motion to Inte

the following:

Jeffrey A. Stallworth

6286 Hanging Moss Road


Pro SePlaintiff

Justin L. Matheny, Esq.

MISSISSIPPI ATTORNEY GENERALS OFFICE

P.O. Box 220

550 High Street (39201)

Jackson MS 39205-0220

(601) 359-3825

[email protected]

Andre LaVerne Edney, Esq.

Bradley C. Moody, Esq.

Donald Jeffrey Wagner, Esq.

BAKER DONELSON BEARMAN CALDWELL & BERKOWITZ

One Eastover Center

100 Vision Drive, Suite 400

P.O. Box 14167 (39236-4167)

Jackson MS 39211

(601) 351-2472

[email protected]@bakerdonelson.com

[email protected]

Daniel B. Smith, Esq.

MISSISSIPPI DEPARTMENT OF TRANSPORTATION

mailto:[email protected]:[email protected]:[email protected]


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City of Jackson Airport Suit