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In the Circuit Court for the First Judicial District of Hinds County, Mississippi
Case: 25CI1:17-cv-00084-WAG Document #: 12 Filed: 03/13/2017 Page 1 of 11 IN THE CIRCUIT COURT FOR THE FIRST JUDICIAL DISTRICT OF HINDS COUNTY, MISSISSIPPI JIM HOOD, ATTORNEY GENERAL OF PLAINTIFF THE STATE OF MISSISSIPPI, ex rel. THE STATE OF MISSISSIPPI v. CIVIL ACTION NO. 17-84 MANAGEMENT & TRAINING DEFENDANTS CORPORATION; CHRISTOPHER B. EPPS; CECIL MCCRORY and DEFENDANTS DOES 1 through 5 ______________________________________________________________________________ MANAGEMENT & TRAINING CORPORATION'S MEMORANDUM IN SUPPORT OF MOTION TO DISMISS ______________________________________________________________________________ Defendant Management & Training Corporation ("MTC") submits this memorandum in support of its Motion to Dismiss. As set forth below, multiple counts against MTC should be dismissed pursuant to Rule 12(b)(6) of the Mississippi Rules of Civil Procedure. I. INTRODUCTION On February 8, 2017, the State of Mississippi initiated the present action against Defendants MTC, Christopher Epps, and Cecil McCrory. In the Complaint, the State makes serious and unfounded allegations against MTC. Specifically, the State alleges that MTC participated in a scheme with Epps and McCrory to defraud the State and obtain contracts to operate correctional facilities in Mississippi through bribery and fraud. MTC adamantly denies the State's allegations and intends to prove through the course of this action that it did not engage in any wrongdoing when entering into contracts with the Mississippi Department of Corrections and local correctional facility authorities. However, for purposes of this Motion to Dismiss, MTC must assume that the allegations against it are true (which they are not), and MTC will Case: 25CI1:17-cv-00084-WAG Document #: 12 Filed: 03/13/2017 Page 2 of 11 establish below that many of the State's claims are subject to dismissal pursuant to Rule 12(b)(6) of the Mississippi Rules of Civil Procedure. -
9 Holiday Duis Ticketed Firemen Save Home 160 “Hazardous” Citations and Kinslow Said the CPD Suspension, No Insurance and by Mark Rogers 91 Non-Hazardous Citations
THURSDAY, DECEMBER 29, 2011 NEWS NEWS Circuit Clerk honored for Annual Sweet Streets at retirement. Columbia Elementary. See page 2 See page 6 “Far be it from God, that he should do wickedness; and from the Almighty, that he should commit iniquity. For the work of a man shall he render unto him, and cause VOLUME 109 • NUMBER 100 ESTABLISHED 1882 every man to find according to his ways .” — Job 34:10-11 9 holiday DUIs ticketed Firemen save home 160 “hazardous” citations and Kinslow said the CPD suspension, no insurance and By Mark Rogers 91 non-hazardous citations. wrote 56 citations over the leaving the scene of a proper- Managing Editor Miller explained that the haz- long weekend. ty damage accident. ardous citations were moving “They (the citations) were Also charged Thursday by A long holiday weekend violations, such as speeding. mostly moving violations,” Columbia Police was Jennifer netted nine DUI charges and Non-hazardous citations he added. “We also made Henderson, 18, of Wiggins many other tickets in Marion include no seatbelt, no insur- numerous misdemeanor Road in Columbia. She was County. ance and no valid inspection arrests.” charged with DUI 1st, other Beginning Thursday night sticker. Marion County Sheriff's substance. and carrying into early Columbia Police Chief Jim Office deputies made five On Friday, the MCSO Monday, the Mississippi Kinslow said his department DUI arrests over the holiday charged Eric D. Jefferson of Highway Patrol Troop J in and others will be out in force weekend, the Columbia Silver Creek with DUI 1st Hattiesburg covered 10 acci- again this weekend with the Police Department made and no insurance, the MHP dents, two with injuries and New Year's holiday. -
United States District Court for the Northern District of Mississippi
Case 3:07-cr-00192-NBB-SAA Document 96 Filed 02/11/2008 Page 1 of 20 UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF MISSISSIPPI WESTERN DIVISION UNITED STATES OF AMERICA v. Case No.: 3:07CR192-NBB-SAA RICHARD F. SCRUGGS, DAVID ZACHARY SCRUGGS, SIDNEY A. BACKSTROM, MOTION FOR CHANGE OF VENUE AND COMBINED MEMORANDUM OF LAW Defendants Richard F. Scruggs, David Zachary Scruggs, and Sidney A. Backstrom hereby move this Court for a change of venue due to the extraordinary pretrial publicity of this case in the Northern District of Mississippi and throughout the State of Mississippi. I. INTRODUCTION Defendants recognize that changes of venue are not routine. But this is hardly a routine case. This case has attracted extraordinary pretrial publicity throughout Mississippi, headlining newspapers in Northern Mississippi multiple times per week. Even pre-trial motions on attorney substitutions are widely covered and hotly debated. Fueled by sensational allegations and conspiracy theories, Mississippi state officials, local bloggers and everyday citizens from across the state have strived to make Dickie Scruggs (hereinafter “Scruggs”) a poster-child for greed, attorney malfeasance and tort reform. Even a Mississippi Supreme Court Justice, ignoring the presumption of innocence, stated publicly that he was “nauseated” by Scruggs’s alleged conduct.1 The actions of State Farm, Defendants’ erstwhile enemy in hundreds of Katrina insurance fraud cases, have further poisoned the well. State Farm repeatedly sought to drag Scruggs into a 1 Justice Speaks About Bribery Accusations, WAPT.com, Jan. 26, 2008. Ex. 1. All Exhibits (“Ex.”) cited herein are exhibits to the Declaration of Brook Dooley filed herewith. -
2015 Senate Candidates District, Candidate, Party, County 1, James
2015 Senate Candidates District, Candidate, Party, County District, Candidate, Party, County District, Candidate, Party, County 1, James David Eubanks, R, Desoto 23, Briggs Hopson, R, Warren 38, Bente’ Hess Johnson, Ind 1, Chris Massey, R, Desoto 23, Bill Marcy, R, Warren 38, Daryl L. Porter Jr., D, Pike 2, David L. Parker, R, Desoto 24, David Jordan, D, Leflore 38, Dennis C. Quinn, R, Pike 3, Nickey Browing, R, Pontotoc 24, Earl G. Blackmon, Ind 38, Tammy Felder Witherspoon, D, 3, Christopher Stark, D, Pontotoc 25, William Billingsley, R, Madison Pike 4, Rita Parks, R, Alcorn 25, Will Longwitz, R, Madison 39, Mike Campbell, R, Lincoln 4, Eric Powell, D, Alcorn 26, John Horhn, D, Hinds 39, Sally Doty, R, Lincoln 5, J.P. Wilemon Jr., D, Tishomingo 26, Stephen Thompson, D, Hinds 39, Michael Smith, D, Lincoln 6, Mike Armour, R, Lee 27, Ponto Downing, R, Hinds 40, Angela Hill, R, Pearl River 6, Nancy Adams Collins, R, Lee 27, Hillman Frazier, D, Hinds 41, Reggie Blackledge, D, 6, Chad McMahan, R, Lee 27, Gerald Kucia, R, Hinds Covington 7, Hob Bryan, D, Monroe 28, Sollie Norwood, D, Hinds 41, Joey Fillingane, R, Lamar 7, Barry Strevel, R, Monroe 29, David Blount, D, Hinds 42, Johnny Ishmel Henry, D, Jones 8, Russell Jolly, D, Chickasaw 29, James Broadwater, R, Hinds 42, Chris McDaniel, R, Jones 9, Cristen Hemmins, D, Lafayette 29, Eclecius L. Franklin Sr, D, Hinds 43, Dennis DeBar, R, Greene 9, Gray Tollison, R, Lafayette 29, Kathryn Michell Drey Perry, D, 43, Philip Gandy, R, Wayne 10, Steve Hale, D, Tate Hinds 43, Towanna A. -
Activereports Document
SAMPLE Official Election Ballot STATE OF MISSISSIPPI 2015 Statewide General Election Tuesday, November 03, 2015 TO VOTE: YOU MUST DARKEN THE OVAL( ) COMPLETELY. USE ONLY A #2 PENCIL OR A DARK PEN. Do not use a red pen, felt tip pen or a red pencil! Do not cross out or erase - If you make a mistake, you may request a new ballot. For State Of Mississippi For State Of Mississippi Governor Attorney General Vote for ONE Vote for ONE Phil Bryant Republican Jim Hood Democrat Robert Gray Democrat Mike Hurst Republican Shawn O'Hara Reform Write-in Write-in For State Of Mississippi State Auditor For State Of Mississippi Vote for ONE Lieutenant Governor Vote for ONE Stacey E. Pickering Republican Tim Johnson Democrat Jocelyn 'Joce' Pepper Democrat Pritchett Tate Reeves Republican Lajena Walley Reform Ron Williams Libertarian Write-in Rosa B. Williams Reform For State Of Mississippi Write-in State Treasurer Vote for ONE For State Of Mississippi Secretary Of State Vote for ONE Lynn Fitch Republican Viola V. McFarland Reform Charles E. Graham Democrat Write-in Delbert Hosemann Republican Randy Walker Reform Write-in TURN BALLOT OVER TO CONTINUE VOTING For State Of Mississippi For Transportation Commissioner Commissioner Of Agriculture & Central District Commerce Vote for ONE Vote for ONE Addie Lee Green Democrat Mary H. Coleman Democrat Cindy Hyde-Smith Republican Dick Hall Republican Cathy L. Toole Reform Write-in Write-in For Transportation Commissioner For State Of Mississippi Northern District Commissioner Of Insurance Vote for ONE Vote for ONE Mike Tagert Republican Mike Chaney Republican Danny Woods Democrat Write-in Write-in For Public Service Commissioner For Transportation Commissioner Central District Southern District Vote for ONE Vote for ONE Brent Bailey Republican Tom King Republican Cecil Brown Democrat Chad Toney Democrat LaTrice D. -
Barber V. Bryant, No
Case 3:16-cv-00442-CWR-LRA Document 35 Filed 06/30/16 Page 1 of 60 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF MISSISSIPPI NORTHERN DIVISION RIMS BARBER; CAROL BURNETT; PLAINTIFFS JOAN BAILEY; KATHERINE ELIZABETH DAY; ANTHONY LAINE BOYETTE; DON FORTENBERRY; SUSAN GLISSON; DERRICK JOHNSON; DOROTHY C. TRIPLETT; RENICK TAYLOR; BRANDIILYNE MANGUM- DEAR; SUSAN MANGUM; JOSHUA GENERATION METROPOLITAN COMMUNITY CHURCH; CAMPAIGN FOR SOUTHERN EQUALITY; and SUSAN HROSTOWSKI CAUSE NO. 3:16-CV-417-CWR-LRA V. consolidated with CAUSE NO. 3:16-CV-442-CWR-LRA PHIL BRYANT, Governor; JIM HOOD, DEFENDANTS Attorney General; JOHN DAVIS, Executive Director of the Mississippi Department of Human Services; and JUDY MOULDER, State Registrar of Vital Records MEMORANDUM OPINION AND ORDER The plaintiffs filed these suits to enjoin a new state law, “House Bill 1523,” before it goes into effect on July 1, 2016. They contend that the law violates the First and Fourteenth Amendments to the United States Constitution. The Attorney General’s Office has entered its appearance to defend HB 1523. The parties briefed the relevant issues and presented evidence and argument at a joint hearing on June 23 and 24, 2016. The United States Supreme Court has spoken clearly on the constitutional principles at stake. Under the Establishment Clause of the First Amendment, a state “may not aid, foster, or Case 3:16-cv-00442-CWR-LRA Document 35 Filed 06/30/16 Page 2 of 60 promote one religion or religious theory against another.” Epperson v. Arkansas, 393 U.S. 97, 104 (1968). “When the government acts with the ostensible and predominant purpose of advancing religion, it violates that central Establishment Clause value of official religious neutrality, there being no neutrality when the government’s ostensible object is to take sides.” McCreary Cnty., Kentucky v. -
JSU Candlelight Vigil Set to Honor Devon Mannery
www.mississippilink.com VOL. 22, NO. 52 OCTOBER 20 - 26, 2016 50¢ Flint’s Weaver speaks at Tougaloo Fight to change state Convocation By Ayesha K. Mustafaa Contributing Writer flag continues Tougaloo College celebrat- ed its Founders’ Convocation Community forum planned Nov. 3 on several issues Oct. 16, in the historic Wood- worth Chapel. Culminating the week of activities, Tougaloo wel- comed alumna (class of 1981) and mayor of Flint, Mich., Karen Weaver, Ph.D., as the 2016 Founders’ Con- vocation guest speaker. She is also the city’s first female mayor. Karen Weaver, mayor of Flint, Weaver was born in Flint Mich., and Tougaloo alumna, where she was elected as its was the guest speaker for the mayor in November 2015, college’s Founders’ Convocation during the heat of the city’s Oct. 16. PHOTO BY JAY JOHNSON water scandal that revealed its drinking water was poi- lines and lawn mowers.” soned with high levels of lead Weaver said, “We lived un- and other toxins. der a third world dictatorship Being asked to speak at with no input about where Tougaloo’s Founders’ Con- our taxes went. All city work- vocation, Weaver said “ranks ers were fired and then some at the top of my experiences; rehired at double pay.” I’m honored and thankful to Weaver said she “put some be back at Tougaloo.” skin in the game” when she She focused on the crisis decided to run for mayor. in Flint and how the city got “Every day there was a pro- to the point of first being un- test. -
Telling Timeline of Google Guardian's Government Influence
10/25/2017 Scott Cleland, Precursor LLC Telling Timeline of Google Guardian’s Government Influence Note: Bolded entire sections spotlight likely improper Google government influence. Top Takeaways 1. Neutralization of Google’s Federal Law Enforcement Risks in Antitrust, IP, & Privacy 2. Extension of Google’s Monopoly to Android & the Mobile Ecosystem 3. Elimination of Much Direct Competition to Google 4. Winner-take-all is consumer-down-fall 2008 1. DOJ blocks Google-Yahoo Ad Agreement with threat of monopolization case against Google: November 5, 2008, the W. Bush DOJ threatened a Sherman Section 1 & 2 antitrust case against Google to block the proposed Google-Yahoo ad agreement. Importantly, the DOJ “concluded that Google and Yahoo would have become collaborators rather than competitors… materially reducing important competitive rivalry between the two companies.” [Bold added.] “The Department's investigation revealed that Internet search advertising and Internet search syndication are each relevant antitrust markets and that Google is by far the largest provider of such services, with shares of more than 70 percent in both markets. Yahoo! is by far Google's most significant competitor in both markets, with combined market shares of 90 percent and 95 percent in the search advertising and search syndication markets, respectively.” 2009 2. FTC urged Google CEO Schmidt to resign from Apple’s Board as anticompetitive: August 3, 2009, the FTC forced Google’s CEO Eric Schmidt off Apple’s board as an anti-competitive opportunity for collusion because “because Google and Apple increasingly compete with each other” (i.e. via iPhone and Android smartphone competition). 2010 3. -
In the United States Disrtict Court for the Southern District of Mississippi Northern Division
Case 3:14-cv-00981-HTW-LRA Document 103 Filed 04/29/15 Page 1 of 22 IN THE UNITED STATES DISRTICT COURT FOR THE SOUTHERN DISTRICT OF MISSISSIPPI NORTHERN DIVISION GOOGLE, INC. PLAINTIFF V. CIVIL ACTION NO. 3:14-CV-981-HTW-LRA JIM HOOD, in his official capacity as Attorney General of the State of Mississippi DEFENDANT ______________________________________________________________________________ ATTORNEY GENERAL’S MEMORANDUM IN OPPOSITION TO MOTION TO COMPEL THE PRODUCTION OF DOCUMENTS ______________________________________________________________________________ Attorney General Jim Hood, in his official capacity (the “Attorney General” or “General Hood”), files this Response in Opposition to Google, Inc.’s (“Google”) Motion to Compel the Production of Documents [Doc. No. 100]. For the reasons set forth below, Google’s motion should be denied.1 I. Introduction A. History and Background Leading to Issuance of Subpoena Google’s lawsuit in general and its motion to compel in particular misapprehends the nature in which this case arose. Google well knows and the record before this Court clearly reflects, that prior to the issuance of the disputed 1 Google’s Motion to Compel does not comply with L. U. Civ. R. 7(b)(4) which provides that “[a]t the time the motion is served, other than motions or applications that may be heard ex parte or those involving necessitous or urgent matters, counsel for the movant must file a memorandum brief in support of the motion.” Id. The instant motion is not one to be heard ex parte nor does it involve a necessitous or urgent and Google did not file a memorandum nor did it seek relief from the requirements of the Local Rule. -
Petition for Hearing En Banc
Case: 19-60133 Document: 00514907153 Page: 1 Date Filed: 04/08/2019 No. 19-60133 UNITED STATES COURT OF APPEALS FOR THE FIFTH CIRCUIT JOSEPH THOMAS; VERNON AYERS; MELVIN LAWSON, Plaintiffs – Appellees v. PHIL BRYANT, GOVERNOR OF THE STATE OF MISSISSIPPI; DELBERT HOSEMANN, SECRETARY OF STATE OF THE STATE OF MISSISSIPPI; JIM HOOD, ATTORNEY GENERAL OF THE STATE OF MISSISSIPPI, ALL IN THE OFFICIAL CAPACITIES OF THEIR OWN OFFICES AND IN THEIR OFFICIAL CAPACITIES AS MEMBERS OF THE STATE BOARD OF ELECTIONS COMMISSIONERS, Defendants – Appellants ______________________________ On Appeal from the United States District Court for the Southern District of Mississippi; USDC No. 3:18-cv-00441-CWR-FKB PETITION FOR HEARING EN BANC Michael B. Wallace (MSB #6904) Tommie S. Cardin (MSB #5863) Charles E. Cowan (MSB #104478) B. Parker Berry (MSB #104251) T. Russell Nobile (MSB #100682) BUTLER SNOW LLP WISE CARTER CHILD & CARAWAY, P.A. 1020 Highland Colony Park, Suite 1400 Post Office Box 651 Ridgeland, Mississippi 39157 Jackson, Mississippi 39205-0651 [email protected] [email protected] [email protected] [email protected] [email protected] Counsel for Appellants Case: 19-60133 Document: 00514907153 Page: 2 Date Filed: 04/08/2019 CERTIFICATE OF INTERESTED PARTIES The undersigned counsel of record for Appellants Governor Phil Bryant and Secretary of State Delbert Hosemann certifies that the following listed persons and entities as described in the fourth sentence of Rule 28.2.1 have an interest in the outcome of this case. These representations are made in order that the judges of this Court may evaluate possible disqualification or recusal. -
Catastrophic Loss
MEALEY’S LITIGATION REPORT Catastrophic Loss Hurricane Katrina And Insurance Coverage: First Words From The Bench Playing It Down The Senter by Randy J. Maniloff, Esq. White and Williams, LLP Philadelphia A commentary article reprinted from the June 2006 issue of Mealey’s Litigation Report: Catastrophic Loss MEALEY’S LITIGATION REPORT: Catastrophic Loss Vol. 1, #9 June 2006 Commentary Hurricane Katrina And Insurance Coverage: First Words From The Bench Playing It Down The Senter By Randy J. Maniloff [Editor’s Note: Randy J. Maniloff is a Partner in the sippi Farm Bureau Insurance, et al., Chancery Court Business Insurance Practice Group at White and Wil- of Hinds County, Mississippi, First Judicial District, liams, LLP in Philadelphia. He concentrates his practice No. G2005-1642); A surge of cases (and attempted in the representation of insurers in coverage disputes over class actions) filed in Mississippi by the well-known primary and excess policy obligations for various types Scruggs Law Firm, including ones on behalf of Mis- of claims, including construction defect, mold, general sissippi Senator Trent Lott, Mississippi Congressman liability (products/premises), environmental property Gene Taylor and Mississippi federal judge Louis Gui- damage, asbestos/silica and other toxic torts, first-party rola (who reportedly would have presided over Katrina property, homeowners, director’s & officer’s liability, a va- coverage cases); An attempted class action filed in fed- riety of professional liability exposures, including medical eral court in Mississippi against several major oil, coal malpractice, media liability, community associations, and chemical companies, alleging that such companies public official’s liability, school board liability, police li- are responsible for global warming, which allegedly ability, computer technology liability, managed care and created the conditions to enable Hurricane Katrina to additional insured/contractual indemnity issues. -
1 Lester Carpenter Republican Y I 2 E. Harvey Moss D
House: District Incumbent Party Running? GOP contender(s) Dem. Contender(s) 1 Lester Carpenter Republican Y i Thomas McCarley, Rex Weathers 2 E. Harvey Moss Democrat * A.L Wood, III Nick Bain (Moss qualified but says he's not running) 3 William McCoy Democrat N William Arnold Bobby Wren, Jimmy Wayne Russell, Tommy Cadle 4 Greg Ward Democrat * James Benefield, Alan Miller (Terri Stanford qualified isn't running) Steve Fisher, James Nunnally, Jody Steverson (Greg Ward qualified but says he's not running) 5 Kelvin Buck Democrat Y i 6 Eugene Hamilton Republican Y i 7 Wanda Jennings Republican Y i 8 Larry Baker Republican N John Lamar III 9 Clara Burnett Democrat Y i 10 Warner McBride Democrat N Doug Jones, Nolan Mettetal* Jordan Bankhead, Greg Hodges 11 Joe Gardner Democrat Y i 12 Noal Akins Republican N Brad Mayo Hollman "Holly" Raney, Ron Shapiro 13 Jack Gadd Democrat N Steve Massengill Billy B. Gray, Jeff King, Don Randolph, Steve Shaw, Bobby Watson 14 Margaret Rogers Republican Y i 15 Mac Huddleston Republican Y i Rick Spencer 16 Daniel Holland Democrat Y Ben Coggin III i 17 Brian Aldridge Republican Y i, Michael Stafford 18 Jerry Turner Republican Y i 19 Mark DuVall Democrat Y Randy Boyd, Alan Sheffield I, Brad Underwood, Jimmy Franks 20 Jimmy Puckett Democrat Y Chris Brown i 21 Donnie Bell Democrat Y Terry Stewart, Deborah Tierce i 22 Preston Sullivan Democrat Y i 23 Charles Beckett Republican Y i Steve Whitten 24 Sidney Bondurant Republican Y i Kevin Horan 25 John Mayo Democrat Y E.E.