dest een Ret =i =o = i Ss org = SWEET & ASSOCIATES ATTORNEYS AT LAW May 15, 2018 VIA CERTIFIED MAIL The City of Jackson ‘Attn: Chokwe Antar Lumumba, Mayor Post Office Box 17 219 South President Street Jackson, Mississippi 39205-0017 Re: Notice of Claim Dear Mayor: Scope of Representation This letter will serve as the official notice of a claim against The City of Jackson, Mississippi; the Jackson Police Department; Officer Vincent Lampkin; and John Does 1- 2 (members of the Jackson Police Department) in their personal and official capacities pursuant to Miss. Code Ann, § 11-46-11, 42 U.S.C. § 1983, any other applicable state or federal statute or constitutional provision(s), and/or any applicable state or federal common law cause(s) of action. ‘The Time and Place the Injury Occurred Our firm has been retained to represent Mr. John Knight III. This representation arises from an incident which took place on I-55 Frontage Road in Jackson Mississippi, near Olive Garden Restaurant, on or about May 13 2018, around midnight. Residence of the Person Making the Claim at the Time of the Injury wwwsweetandassociates.octMr. Knight currently resides at 5650 Concord Dr. Jackson, Mississippi 39211. ‘The Circumstances Which Brought About the Injury ‘The Extent of the Injury ‘The Names of All Persons Known to Be Involved Upon information and belief, the following occurred on or about May 13, 2018. Mr. Knight was driving on I-55 Frontage Road near Olive Garden Restaurant. Mr. Knight was driving reasonably. Officer Lampkin pulled Mr. Knight over. Officer Lampkin never stated why he made the traffic stop. Officer Lampkin drew his weapon as he approached Mr. Knight’s car. Officer Lampkin approached the car brandishing a firearm. Officer Lampkin instructed Mr. Knight to exit the car. Officer Lampkin holstered his weapon and threw Mr. Knight to the ground, Officer Lampkin brandished his weapon again, placed his foot on Mr. Knight's neck and head. Officer Lampkin placed the gun to the back of Knights head and cocked the weapon, Officer Lampkin handcuffed Mr. Knight and punched him in the face. Officer Lampkin searched Mr. Knight's car without his consent and without probable cause. Officer Lampkin did not find anything in the car. Officer Lampkin threw Mr. Knight’s phone into the grass Officer Lampkin removed the handcuffs from Mr. Knight and told him he was free to go. Officer Lampkin got into his ear and sped off. At all pertinent times, the police officer was working within the scope of his employment with the Jackson Police Department. ‘Types of Claims Likely to Be Made Amount of M a Sought John Knight III intends to file a lawsuit in this matter pursuant to Miss. Code Ann, 8 11-46-11, 42 U.S.C. § 1983 and any other applicable state or federal statute or constitutional provision. Mr. Knight asserts the following state law claims: (i) negligence, (ii) gross negligence, (iii) civil assault, (iv) civil battery, (¥) intentional infliction of emotional distress, (vi) negligent inflection of emotional distress, and (vii) reckless disregard for the rights and safety of others. Also, Mr. Knight asserts the following federal claim: (i) 42 U.S.C. § 1983 against the City of Jackson, Mississippi; the Jackson Police Department; Officer Vincent Lampkin; and John Does 1-2 (members of the Jackson Police Department) in their official capacities. ‘The actions of the City of Jackson, the Jackson Police Department, and John Does 1-2 constituted an improper show of authority which resulted in the injuries sustained by John Knight Ill, on the ‘moming in question. Claimant seeks money damages in excess of the jurisdictional amount of the Circuit Court of Hinds County, Mississippi for past, present and future medical expenses, pain and suffering, and any additional damages claimants may be entitled to by law or that the Circuit Court may deem appropriate. This Notice of Claim is made pursuant to Mississippi Code Annotated § 11-46-11 (2002), Please refer all correspondence or communication to my office relating to this claim, Should you need additional information, please contact my office.ce: Respectfully, SWEET & ASSOCIATES sy bles Sor Dennis C. Sweet Ill Dennis C. Sweet IV Interim Chief of Police Anthony L. Moore De’keither Stamps, Jackson City Council ‘Aaron Banks, Jackson City Council Kenneth I. Stokes, Jackson City Council Ashby Foote, Jackson City Council Virgi Lindsay, Jackson City Council Charles Tillman, Jackson City Council Melvin Priester, Jr, Jackson City Council