Case: Harris v. DeSoto County, Mississippi

Harris v. Desoto County, Mississippi

COMPLAINT, Filing fee $ 405, receipt number AMSNDC-2437029, filed by Delta Sigma Theta Sorority, Inc., Harold Harris, Robert Tipton, Jr, DeSoto County MS NAACP Unit 5574. (Attachments: # 1 Civil Cover Sheet) (zdg)

1 Civil Cover Sheet

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Summons Issued as to DeSoto County Board of Supervisors, DeSoto County Election Commission, DeSoto County, Mississippi, Dale Thompson. Counsel is instructed to download and print for service. (zdg)

NOTICE OF ASSIGNMENT. Case assigned to Judge Brown and Magistrate Judge Percy. (zdg)

NOTICE of Attorney Appearance by Mohammed Amir Badat on behalf of All Plaintiffs (Badat, Mohammed)

MOTION to Appear Pro Hac Vice ; Attorney Victor M. Jones,(Paid $150 PHV fee; receipt number AMSNDC-2437289) by DeSoto County MS NAACP Unit 5574, Delta Sigma Theta Sorority, Inc., Harold Harris, Robert Tipton, Jr. (Attachments: # 1 Exhibit Certificate of Good Standing) (Badat, Mohammed) (Main Document 4 replaced on 9/16/2024 with flattened pdf version of same) (jla).

1 Exhibit Certificate of Good Standing

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NOTICE of Attorney Appearance by Joshua Fiyenn Tom on behalf of All Plaintiffs (Tom, Joshua)

ORDER granting 4 Motion to Appear Pro Hac Vice; Attorney VIctor M. Jones. Signed by Magistrate Judge Roy Percy on 9/16/24. (bnd)

MOTION to Appear Pro Hac Vice ; Attorney Victor Genecin,(Paid $150 PHV fee; receipt number AMSNDC-2438106) by DeSoto County MS NAACP Unit 5574, Delta Sigma Theta Sorority, Inc., Harold Harris, Robert Tipton, Jr. (Attachments: # 1 Exhibit Certificate of Good Standing, # 2 Exhibit Certificate of Good Standing for Morenike Fajana) (Badat, Mohammed)

ORDER granting 7 Motion to Appear Pro Hac Vice; Attorney Victor Genecin. Signed by Magistrate Judge Roy Percy on 9/17/24. (bnd)

MOTION to Appear Pro Hac Vice ; Attorney Daniel Jacob Hessel,(Paid $150 PHV fee; receipt number AMSNDC-2439770) by DeSoto County MS NAACP Unit 5574, Delta Sigma Theta Sorority, Inc., Harold Harris, Robert Tipton, Jr. (Attachments: # 1 Exhibit A - MA Certificate of Good Standing, # 2 Exhibit B - NY Certificate of Good Standing) (Tom, Joshua)

MOTION to Appear Pro Hac Vice ; Attorney Ruth Merewyn Greenwood,(Paid $150 PHV fee; receipt number AMSNDC-2439781) by DeSoto County MS NAACP Unit 5574, Delta Sigma Theta Sorority, Inc., Harold Harris, Robert Tipton, Jr. (Attachments: # 1 Exhibit A - MA Certificate of Good Standing, # 2 Exhibit B - NY Certificate of Good Standing) (Tom, Joshua)

EXHIBIT re 9 MOTION to Appear Pro Hac Vice ; Attorney Daniel Jacob Hessel,(Paid $150 PHV fee; receipt number AMSNDC-2439770) . (Tom, Joshua)

CLERK'S NOTICE re 9 MOTION to Appear Pro Hac Vice ; Attorney Daniel Jacob Hessel,(Paid $150 PHV fee; receipt number AMSNDC-2439770): Attorney directed to file a certificate of good standing from New York licensing authority as required by L.U.Civ.R. 83.1 (d)(4). It appears the wrong certificate was included. Please use the civil event "Exhibits to Other Document" and link to the original motion. (lgm)

ORDER granting 9 Motion to Appear Pro Hac Vice; Attorney Daniel Hessel. Signed by Magistrate Judge Roy Percy on 9/25/24. (bnd)

ORDER granting 10 Motion to Appear Pro Hac Vice; Attorney Ruth Merewyn Greenwood. Signed by Magistrate Judge Roy Percy on 9/25/24. (bnd)

SUMMONS Returned Executed by Joshua Fiyenn Tom on behalf of Delta Sigma Theta Sorority, Inc., Harold Harris, Robert Tipton, Jr, DeSoto County MS NAACP Unit 5574 DeSoto County, Mississippi served on 9/17/2024. (Tom, Joshua)

SUMMONS Returned Executed by Joshua Fiyenn Tom on behalf of Delta Sigma Theta Sorority, Inc., Harold Harris, Robert Tipton, Jr, DeSoto County MS NAACP Unit 5574 DeSoto County Board of Supervisors served on 9/18/2024. (Tom, Joshua)

SUMMONS Returned Executed by Joshua Fiyenn Tom on behalf of Delta Sigma Theta Sorority, Inc., Harold Harris, Robert Tipton, Jr, DeSoto County MS NAACP Unit 5574 Dale Thompson served on 9/17/2024. (Tom, Joshua)

SUMMONS Returned Executed by Joshua Fiyenn Tom on behalf of Delta Sigma Theta Sorority, Inc., Harold Harris, Robert Tipton, Jr, DeSoto County MS NAACP Unit 5574 DeSoto County Election Commission served on 9/16/2024. (Tom, Joshua)

SUMMONS Returned Executed by Joshua Fiyenn Tom on behalf of Delta Sigma Theta Sorority, Inc., Harold Harris, Robert Tipton, Jr, DeSoto County MS NAACP Unit 5574 (Tom, Joshua)

NOTICE of Attorney Appearance by Ruth Merewyn Greenwood on behalf of All Plaintiffs (Greenwood, Ruth)

NOTICE of Attorney Appearance by Daniel Hessel on behalf of All Plaintiffs (Hessel, Daniel)

MOTION to Appear Pro Hac Vice ; Attorney Brenda Wright,(Paid $150 PHV fee; receipt number AMSNDC-2443875) by DeSoto County MS NAACP Unit 5574, Delta Sigma Theta Sorority, Inc., Harold Harris, Robert Tipton, Jr. (Attachments: # 1 Exhibit Certificate of Good Standing) (Badat, Mohammed) (Main Document 21 replaced on 10/1/2024) (zdg). (Attachment 1 replaced on 10/1/2024) (zdg). Modified on 10/1/2024 to replace documents with flatened PDF versions (zdg).

NOTICE of Attorney Appearance by Victor Genecin on behalf of All Plaintiffs (Genecin, Victor)

NOTICE of Attorney Appearance by Victor M. Jones on behalf of All Plaintiffs (Jones, Victor)

ORDER granting 21 Motion to Appear Pro Hac Vice; Attorney Brenda Wright. Signed by Magistrate Judge Roy Percy on 10/1/24. (bnd)

NOTICE of Attorney Appearance by David Michael Hurst, Jr on behalf of All Defendants (Hurst, David)

NOTICE of Attorney Appearance by Nicholas Francis Morisani on behalf of All Defendants (Morisani, Nicholas)

MOTION for Extension of Time to File Answer by DeSoto County Board of Supervisors, DeSoto County Election Commission, DeSoto County, Mississippi, Dale Thompson. (Morisani, Nicholas)

NOTICE of Attorney Appearance by William T. Siler, Jr on behalf of All Defendants (Siler, William)

NOTICE of Attorney Appearance by Andrew W. Coffman on behalf of All Defendants (Coffman, Andrew)

RESPONSE to Motion re 27 MOTION for Extension of Time to File Answer filed by DeSoto County MS NAACP Unit 5574, Delta Sigma Theta Sorority, Inc., Harold Harris, Robert Tipton, Jr. (Hessel, Daniel)

ORDER OF RECUSAL. District Judge Debra M. Brown recused. Case reassigned to Senior Judge Glen H. Davidson for all further proceedings. Signed by District Judge Debra M. Brown on 10/4/2024. (jwr)

NOTICE of Attorney Appearance by Adam B. Emerson on behalf of All Defendants (Emerson, Adam)

RESPONSE in Support re 27 MOTION for Extension of Time to File Answer filed by DeSoto County Board of Supervisors, DeSoto County Election Commission, DeSoto County, Mississippi, Dale Thompson. (Morisani, Nicholas)

ORDER granting 27 Motion for Extension of Time to Answer re 27 MOTION for Extension of Time to File Answer All Defendants. Signed by Magistrate Judge Roy Percy on 10/4/24. (bnd)

INITIAL ORDER - RULE 16.1 Case Management Conference set for 12/13/2024 10:00 AM in Oxford Tele-Conference before Magistrate Judge Roy Percy. Signed by Magistrate Judge Roy Percy on 10/7/24. (rtc)

MOTION to Dismiss by DeSoto County Board of Supervisors, DeSoto County Election Commission, Dale Thompson, DeSoto County, Mississippi. (Hurst, David) Modified on 11/25/2024 (jla).

MEMORANDUM IN SUPPORT re 36 MOTION to Dismiss filed by DeSoto County Board of Supervisors, DeSoto County Election Commission, Dale Thompson, DeSoto County, Mississippi. (Hurst, David) Modified on 11/25/2024 (jla).

MOTION to Allow Discovery to Proceed by DeSoto County MS NAACP Unit 5574, Harold Harris, Robert Tipton, Jr, Delta Sigma Theta Sorority, Inc.. (Hessel, Daniel)

MEMORANDUM IN SUPPORT re 38 MOTION to Allow Discovery to Proceed filed by DeSoto County MS NAACP Unit 5574, Harold Harris, Robert Tipton, Jr, Delta Sigma Theta Sorority, Inc.. (Hessel, Daniel)

ORDER STAYING CASE DUE TO JURISDICTIONAL MOTION. Signed by Magistrate Judge Roy Percy on 11/25/24. (bnd)

TEXT NOTICE Cancelling Case Management Conference set for 12/13/24 re 40 Order Staying Case (no document attached) (rtc)

MOTION to Appear Pro Hac Vice ; Attorney Maia Cole,(Paid $150 PHV fee; receipt number AMSNDC-2466988) by DeSoto County MS NAACP Unit 5574, Harold Harris, Robert Tipton, Jr, Delta Sigma Theta Sorority, Inc.. (Attachments: # 1 Exhibit Certificate of Good Standing) (Badat, Mohammed) (Main Document 42 replaced with flattened pdf version of same on 12/3/2024) (jla).

ORDER granting 42 Motion to Appear Pro Hac Vice; Attorney Maia Cole. Signed by Magistrate Judge Roy Percy on 12/3/24. (bnd)

RESPONSE in Opposition re 36 MOTION to Dismiss filed by DeSoto County MS NAACP Unit 5574, Harold Harris, Robert Tipton, Jr, Delta Sigma Theta Sorority, Inc.. (Hessel, Daniel)

MEMORANDUM IN SUPPORT re 44 Response in Opposition to 36 Motion filed by DeSoto County MS NAACP Unit 5574, Harold Harris, Robert Tipton, Jr, Delta Sigma Theta Sorority, Inc.. (Hessel, Daniel) Modified on 12/9/2024 to link to underlying motion (jwr).

DISREGARD ENTRY - ATTORNEY DIRECTED TO REFILE NOTICE of Attorney Appearance by Brenda Wright on behalf of All Plaintiffs (Wright, Brenda) Modified on 12/10/2024 (jwr).

DISREGARD ENTRY - ATTORNEY DIRECTED TO REFILE NOTICE of Attorney Appearance by Maia Cole on behalf of All Plaintiffs (Cole, Maia) Modified on 12/10/2024 (jwr).

DISREGARD ENTRY - ATTORNEY DIRECTED TO REFILE RESPONSE in Opposition re 38 MOTION to Allow Discovery to Proceed filed by DeSoto County Board of Supervisors, DeSoto County Election Commission, Dale Thompson, DeSoto County, Mississippi. (Morisani, Nicholas) Modified on 12/10/2024 (jwr).

CLERK'S NOTICE re 45 Memorandum in Support, 44 Response in Opposition to Motion : Counsel is instructed to include complete case number in case style on all future filings. (jwr)

NOTICE of Attorney Appearance by Brenda Wright on behalf of All Plaintiffs (Wright, Brenda)

NOTICE of Attorney Appearance by Maia Cole on behalf of All Plaintiffs (Cole, Maia)

RESPONSE in Opposition re 38 MOTION to Allow Discovery to Proceed filed by DeSoto County Board of Supervisors, DeSoto County Election Commission, Dale Thompson, DeSoto County, Mississippi. (Morisani, Nicholas)

MEMORANDUM IN SUPPORT re 51 Response in Opposition to 38 Motion filed by DeSoto County Board of Supervisors, DeSoto County Election Commission, Dale Thompson, DeSoto County, Mississippi. (Morisani, Nicholas) Modified on 12/11/2024 to link to motion (jwr).

CLERK'S NOTICE re 46 Notice of Attorney Appearance, 47 Notice of Attorney Appearance: Each attorney directed to refile and include their electronic signature on the "Attorney's signature" line. Further, the signature of the resident attorney must be included on each filing as required by L.U.Civ.R. 83.1(d)(3). (jwr)

CLERK'S NOTICE re 48 Response in Opposition to Motion : Attorney directed to refile response and memorandum brief as separate documents as required by L.U.Civ.R. 7(b)(2) and 7(b)(4). (jwr)

MOTION for Extension of Time to File Response/Reply as to 36 MOTION to Dismiss, 44 Response in Opposition to Motion by DeSoto County Board of Supervisors, DeSoto County Election Commission, Dale Thompson, DeSoto County, Mississippi. (Morisani, Nicholas)

BRIEF re 53 MOTION for Extension of Time to File Response/Reply as to 36 MOTION to Dismiss, 44 Response in Opposition to Motion . (Morisani, Nicholas)

ORDER granting 53 Motion for Extension of Time to File Response/Reply Replies due by 12/20/2024. Signed by Senior Judge Glen H. Davidson on 12/12/2024. (tlr)

REPLY to Response to Motion re 38 MOTION to Allow Discovery to Proceed filed by DeSoto County MS NAACP Unit 5574, Harold Harris, Robert Tipton, Jr, Delta Sigma Theta Sorority, Inc.. (Hessel, Daniel)

NOTICE of Attorney Appearance by Victor M. Jones on behalf of All Plaintiffs (Jones, Victor)

NOTICE of Attorney Appearance by Victor Genecin on behalf of All Plaintiffs (Genecin, Victor)

REPLY in Support re 36 MOTION to Dismiss filed by DeSoto County Board of Supervisors, DeSoto County Election Commission, Dale Thompson, DeSoto County, Mississippi. (Morisani, Nicholas) Modified on 12/23/2024 (jwr).

ORDER granting 38 Motion to Lift Stay of Discovery. Signed by Magistrate Judge Roy Percy on 1/22/25. (bnd)

NOTICE of Conference: Case Management Conference set for 2/19/2025 11:00 AM in Oxford Tele-Conference before Magistrate Judge Roy Percy. (rtc)

NOTICE OF SERVICE of Plaintiffs' First Set of Interrogatories and Requests for Production of Documents by Joshua Fiyenn Tom on behalf of DeSoto County MS NAACP Unit 5574, Harold Harris, Robert Tipton, Jr, Delta Sigma Theta Sorority, Inc. to All Defendants. (Tom, Joshua)

NOTICE OF SERVICE of Plaintiffs' Initial Disclosures by Joshua Fiyenn Tom on behalf of DeSoto County MS NAACP Unit 5574, Delta Sigma Theta Sorority, Inc., Harold Harris, Robert Tipton, Jr to All Defendants. (Tom, Joshua)

NOTICE OF SERVICE of Defendant's Initial Disclosures by Nicholas Francis Morisani on behalf of DeSoto County Board of Supervisors, DeSoto County Election Commission, DeSoto County, Mississippi, Dale Thompson to Plaintiff. (Morisani, Nicholas)

Unopposed MOTION for Extension of Time to Respond to Written Discovery by DeSoto County Board of Supervisors, DeSoto County Election Commission, DeSoto County, Mississippi, Dale Thompson. (Morisani, Nicholas)

Minute Entry for proceedings held before Magistrate Judge Roy Percy: Case Management Conference held on 2/19/2025. (rtc)

CASE MANAGEMENT ORDER. Final Pretrial Conference set for 3/23/2026 10:00 AM in Judge Percy Chambers before Magistrate Judge Roy Percy. Discovery due by 9/26/2025. Amendments/Joinder of Parties due by 3/19/2025. Plaintiffs Designation of Experts due by 4/18/2025. Defendants Designation of Experts due by 6/6/2025. Motions due by 10/10/2025. Signed by Magistrate Judge Roy Percy on 2/19/25. (rtc)

ORDER 67 granting 65 Motion for Extension of Time. Signed by Magistrate Judge Roy Percy on 2/19/25. (rtc)

NOTICE of Trial: Non-Jury Trial set for 4/27/2026 09:30 AM in Oxford Courtroom 1 before Senior Judge Glen H. Davidson. (tlr)

NOTICE OF SERVICE of First Supplemental Initial Disclosures by Nicholas Francis Morisani on behalf of DeSoto County Board of Supervisors, DeSoto County Election Commission, DeSoto County, Mississippi, Dale Thompson to Plaintiffs. (Morisani, Nicholas)

NOTICE of Conference: Final Pretrial Conference set for 3/23/2026 10:00 AM in Judge Percy Chambers before Magistrate Judge Roy Percy. (rtc)

ORDER Governing Pretrial Conference and Preparation of Final Pretrial Order. Signed by Magistrate Judge Roy Percy on 2/25/25. (rtc)

NOTICE OF SERVICE of Plaintiffs' First Supplemental Initial Disclosures by Joshua Fiyenn Tom on behalf of DeSoto County MS NAACP Unit 5574, Delta Sigma Theta Sorority, Inc., Harold Harris, Robert Tipton, Jr to All Defendants. (Tom, Joshua)

MOTION to Appear Pro Hac Vice ; Attorney Breanna Williams,(Paid $150 PHV fee; receipt number AMSNDC-2501763) by DeSoto County MS NAACP Unit 5574, Delta Sigma Theta Sorority, Inc., Harold Harris, Robert Tipton, Jr. (Attachments: # 1 Exhibit A - Certificate of Good Standing) (Tom, Joshua)

MOTION to Expedite Trial Date by DeSoto County MS NAACP Unit 5574, Delta Sigma Theta Sorority, Inc., Harold Harris, Robert Tipton, Jr. (Attachments: # 1 Exhibit Exhibit A - Order from state legislative case, # 2 Exhibit Exhibit B - Brief from state legislative case) (Hessel, Daniel)

1 Exhibit Exhibit A - Order from state legislative case

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2 Exhibit Exhibit B - Brief from state legislative case

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BRIEF re 74 MOTION to Expedite Trial Date . (Hessel, Daniel)

ORDER granting 73 Motion to Appear Pro Hac Vice; Attorney Breanna Williams. Signed by Magistrate Judge Roy Percy on 3/7/25. (bnd)

NOTICE of Attorney Appearance by Breanna Della Williams on behalf of All Plaintiffs (Williams, Breanna)

NOTICE by Joshua Fiyenn Tom on behalf of DeSoto County MS NAACP Unit 5574, Delta Sigma Theta Sorority, Inc., Harold Harris, Robert Tipton, Jr Intent to Serve Subpoena Duces Tecum (Attachments: # 1 Exhibit 1 - SDT to Bridge and Watson, Inc, # 2 Exhibit 2 - SDT to Christopher Watson) (Tom, Joshua)

Unopposed MOTION for Extension of Time to Object and Respond to Plaintiff's First Set of Interrogatories and Requests for Production of Documents by DeSoto County Board of Supervisors, DeSoto County Election Commission, DeSoto County, Mississippi, Dale Thompson. (Morisani, Nicholas)

ORDER granting 79 Motion for Extension of Time to respond to discovery requests. Signed by Magistrate Judge Roy Percy on 3/17/25. (bnd)

Unopposed MOTION for Extension of Time to Respond to Plaintiffs' First Set of Interrogatories and Requests for Production by DeSoto County Board of Supervisors, DeSoto County Election Commission, DeSoto County, Mississippi, Dale Thompson. (Morisani, Nicholas)

RESPONSE in Opposition re 74 MOTION to Expedite Trial Date filed by DeSoto County Board of Supervisors, DeSoto County Election Commission, DeSoto County, Mississippi, Dale Thompson. (Attachments: # 1 Exhibit 1: Feb. 5, 2025, E-mail from Hessel to Chambers, # 2 Exhibit 2: Feb. 5, 2025, E-mail from Hurst to Chambers) (Morisani, Nicholas)

1 Exhibit 1: Feb. 5, 2025, E-mail from Hessel to Chambers

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2 Exhibit 2: Feb. 5, 2025, E-mail from Hurst to Chambers

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MEMORANDUM IN SUPPORT re 82 Response in Opposition to Motion as to 74 MOTION to Expedite Trial Date filed by DeSoto County Board of Supervisors, DeSoto County Election Commission, DeSoto County, Mississippi, Dale Thompson. (Morisani, Nicholas) Modified on 3/27/2025 to link to underlying motion (jla).

ORDER granting 81 Motion for Extension of Time. Signed by Magistrate Judge Roy Percy on 3/21/25. (bnd)

MEMORANDUM IN SUPPORT re 74 MOTION to Expedite Trial Date . (Tom, Joshua)

CLERK'S NOTICE re 83 Memorandum in Support, : All related filings to motion must be linked back to the original motion instead of a responsive pleading. Court staff has made the correction. (jla)

PROOF OF SERVICE OF SUBPOENA served on Bridge and Watson, Inc. c/o Christopher Watson, Principal on 3/21/25 by Joshua Fiyenn Tom on behalf of DeSoto County MS NAACP Unit 5574, Delta Sigma Theta Sorority, Inc., Harold Harris, Robert Tipton, Jr. (Tom, Joshua)

PROOF OF SERVICE OF SUBPOENA served on Christopher Watson on 3/21/25 by Joshua Fiyenn Tom on behalf of DeSoto County MS NAACP Unit 5574, Delta Sigma Theta Sorority, Inc., Harold Harris, Robert Tipton, Jr. (Tom, Joshua)

NOTICE OF SERVICE of Responses to Interrogatories by Nicholas Francis Morisani on behalf of DeSoto County Board of Supervisors, DeSoto County Election Commission, DeSoto County, Mississippi, Dale Thompson to Plaintiffs. (Morisani, Nicholas)

NOTICE OF SERVICE of Response to Request for Production of Documents by Nicholas Francis Morisani on behalf of DeSoto County Board of Supervisors, DeSoto County Election Commission, DeSoto County, Mississippi, Dale Thompson to Plaintiffs. (Morisani, Nicholas)

ORDER granting 74 Plaintiff's Motion to Expedite Trial. Signed by Senior Judge Glen H. Davidson on 4/10/2025. (tlr)

NOTICE of Conference: Final Pretrial Conference reset for 12/17/2025 10:00 AM in Judge Percy Chambers before Magistrate Judge Roy Percy. (rtc)

NOTICE of Trial: Non-Jury Trial RESET for 1/26/2026 09:30 AM in Oxford Courtroom 1 before Senior Judge Glen H. Davidson. (tlr) (Main Document 92 replaced on 4/11/2025) (tlr).

NOTICE OF SERVICE of Plaintiffs' Expert Disclosures by Daniel Hessel on behalf of DeSoto County MS NAACP Unit 5574, Delta Sigma Theta Sorority, Inc., Harold Harris, Robert Tipton, Jr to All Counsel of Record. (Hessel, Daniel)