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Case: 25CI1:19-cv-00857-AHW Document #: 2 Filed: 12/30/2019 Page 1 of 6

IN THE CIRCUIT COURT OF HINDS COUNTY, MISSISSIPPI


FIRST JUDICIAL DISTRICT

fcHARD T. LAWRENCE PLAINTIFF

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CIVIL ACTION NO. jf- 8'$""J
WATKINS & EAGER, PLLC;
~ND JOHN DOES 1-5 DEFENDANTS

COMPLAINT

Trial by Jury Requested

COMES NOW the Plaintiff, RichardT. Lawrence, and files this his Complaint against

t~e Defendants, Watkins & Eager, PLLC, and John Does 1-5, and in support thereofwould
r spectfully show unto the Court the following facts to-wit:

PARTIES

1. Plaintiff, RichardT. Lawrence, is an adult resident citizen of Madison County,

lSSlSSlppl.

2. Defendant, Watkins & Eager, PLLC (hereinafter "Watkins & Eager") is a

d mestic corporation organized and existing under the laws of the State of Mississippi and doing

b siness in Mississippi. Defendant may be served with process through its registered Agent for

Service ofProcess, J. Grant Sellers, 400 E. Capitol Street, Jackson, Mississippi 39201.

4. The Defendants, John Does 1-5, are entities, companies or persons, whose names

d whereabouts at this time are unknown to the Plaintiff bu~ who may be added at a later date.

JURISDICTION AND VENUE

5. This Court has in personam jurisdiction over the Defendants because the acts and
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orissions of Defendants were committed in whole or in part in the State of Mississippi against a

r¢sident of the State of Mississippi.


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Case: 25CI1:19-cv-00857-AHW Document #: 2 Filed: 12/30/2019 Page 2 of 6

6. Venue is proper in Hinds County, Mississippi, pursuant to Miss. Code Ann. §11-

1-3, since the alleged actions of Defendants occurred in Hinds County and because one or more

fthe Defendants reside in or has their principal place ofbusiness in Hinds County.

FACTS

7. Plaintiff, RichardT. Lawrence, is an attorney who is licensed to practice law in

eState ofMississippi. He was admitted to practice law in Mississippi on May 24, 1979.

8. Defendant, Watkins & Eager, PLLC, is a full-service law firm providing legal

ervices in Mississippi.

9. On May 28, 1979, Plaintiff was hired by Watkins & Eager as an associate

ttomey. In 1984, Watkins & Eager promoted the Plaintiff to the position of equity partner.

10. Plaintiff was employed by Watkins & Eager for over forty (40) years.

11. In 2018, during Plaintiffs employment with Watkins & Eager, Plaintiff began

eporting to certain members and equity partners of Watkins & Eager that other members of the

urn were engaging in discrimination, engaging in possible unethical conduct, and failing to

ollow the firm's Operating Agreement. Plaintiff requested the firm make corrections to its

ctions and cease its improper activities. Defendant and its agents ignored Plaintiffs complaints

d requests. After Plaintiff made his complaints he was subjected to overt and covert actions by

he Defendants designed to punish and silence Plaintiff from proceeding in his request to correct

he firm's actions.

12. On or about November 21, 2019, as a result of Plaintiffs complaints and requests

or the firm to correct its actions, certain members of Watkins & Eager sent an email to the

~laintiff. The email advised the Plaintiff that certain firm members were prepared to make a
recommendation to all of the firm's members that Plaintiffs status as a member of the firm

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Case: 25CI1:19-cv-00857-AHW Document #: 2 Filed: 12/30/2019 Page 3 of 6

~ould be terminated effective December 31, 2019, unless the Plaintiff and Watkins & Eager

cruld work out a separation agreement.

I 13. On or about December 11, 2019, Plaintiff, after forty years as an acting member

o the firm, was notified he was terminated and expelled as a member by Watkins & Eager.

14. Plaintiff was terminated by Watkins & Eager as retaliation for the Plaintiff

r porting and complaining about certain members of the firm engaging in discrimination,

e gaging in unethical conduct, and not following the firm's Operating Agreement, among other

15. By terminating the Plaintiff for the reasons previously cited herein, the Defendant,

atkins & Eager, maliciously interfered with the Plaintiffs employment, and therefore is liable

the Plaintiff for this and other intentional and negligent acts and omissions.

NEGLIGENCE AND INTENTIONAL ACTS OF WATKINS & EAGER, PLLC

16. Plaintiff adopts by reference the foregoing paragraphs as if fully set forth herein.

17. Plaintiff charges that the Defendant, Watkins & Eager, PLLC, is liable to the

laintiff for:

a. Negligent and intentional acts of bad faith;

b. Negligent interference with employment;

c. Malicious and intentional interference with employment;

d. Negligently and intentionally discharging Plaintiff due to Plaintiff reporting

illegal activity occurring in the firm;

e. Negligently and intentionally discharging Plaintiff for pointing out acts of

discrimination by the firm against its minority employees and female

employees and requesting the firm correct and stop the actions;

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Case: 25CI1:19-cv-00857-AHW Document #: 2 Filed: 12/30/2019 Page 4 of 6

f. Negligently and intentionally acting in an unethical manner in an attempt to

poach other attorneys and their clients from other firms;

g. Breach of contract;

h. General acts of negligence;

1. Breach of good faith and fair dealing;

J. Negligent and intentional acts in violation ofthe company agreement;

k. Intentional interference with contractual relations;

1. Intentional interference with business relationships;

m. Breach of fiduciary duty;

n. Fraud and misrepresentation;

o. Negligent infliction of emotional distress;

p. Intentional infliction of emotional distress;

q. Interference with an advantageous business situation;

r. Property damage;

s. Conversion;

t. Libel;

u. Per se slander;

v. Slander;

w. Defamation of character;

x. Harassment

18. Plaintiff alleges that the negligent and intentional acts of Defendant, Watkins &

PLLC, were the direct and proximate cause of Plaintiffs injuries and damages. Plaintiff

specifically excludes and expressly disclaims any Federal causes of action.

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Case: 25CI1:19-cv-00857-AHW Document #: 2 Filed: 12/30/2019 Page 5 of 6

NEGLIGENCE OF JOHN DOES 1-5

19. Plaintiff adopts by reference the foregoing paragraphs as if fully set forth herein.

20. John Does 1-5 are entities, companies or persons whose names and identities are

own at this time to the Plaintiffbut who may have been working in conjunction or in a joint

v nture or as a partner with the Defendants and may be responsible for the damages caused to the

Plaintiff. The John Doe Defendants may have participated in this incident and/or may be jointly

d severally liable to the Plaintiff for his injuries and damages. Plaintiff will amend the

c mplaint to add the names of the parties who may be John Does when that information becomes

DAMAGES

21. As a proximate result of the negligent and intentional acts of Defendants alleged

a ove, the Plaintiff has suffered damages, including but not limited to, economic damages and

1 st earnings, lost profits and benefits associated with Plaintiffs position at the firm, loss of

r putation, loss of future earnings, lost work and productivity, additional incurred expenses as a

r sult of the Defendants' contractual breaches, past and future pain physical and emotional

s ffering and mental anguish, accrued medical expenses, attorney's fees, and other damages to

e proven at trial. Plaintiff reasonably anticipates future damages, proximately caused by said

egligence of Defendants, including future physical and emotional pain, suffering and mental

guish, future medical expenses, future economic damages and lost earnings, future lost work

d productivity, future incurred expenses as a result of the Defendant's contractual breaches,

tture travel expenses, future attorney's fees, and other damages to be proven at trial.

22. Plaintiff asserts the acts of the Defendants were conducted in a willful, wanton,

tpalicious, intentionally wrong, and grossly negligent manner. The actions of the Defendants

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Case: 25CI1:19-cv-00857-AHW Document #: 2 Filed: 12/30/2019 Page 6 of 6

~ere beyond the realm of negligence and evidenced a manner of willful and malicious intent,

· d gross negligence so that punitive damages may be warranted. Plaintiff claims all punitive

ages permitted by law as allowed by the court and asserts his rights to attorney fees and

WHEREFORE, PREMISES CONSIDERED, the Plaintiff, RichardT. Lawrence,

d mands a trial by jury and judgment from the Defendants, Watkins & Eager, PLLC and John

oes 1-5, individually, jointly and severally, for all actual, compensatory, consequential,

i cidental damages and all other damages in an amount that exceeds the jurisdictional minimum

its ofthis court and an amount of punitive damages in an amount which is to be determined

a jury as well as damages of any other type, for the injuries sustained by Plaintiff. Plaintiff

p ays for any general relief as required under the law and to be determined by a jury.

This the _n_ day ofDecember, 2019.


Respectfully Submitted,

RICHARD T. LAWRENCE

By:-ttds£<~ ~~
. ASHLEY OG EN

qFCOUNSEL:
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J.l ASHLEY OGDEN, MSB #9842

~
GDEN & ASSOCIATES, PLLC
0 East Capitol Street, Suite 3
J ckson, Mississippi 39201
T~lephone: (601) 969-0999
Fecsimile: (601) 969-0089
AITTORNEY FOR PLAINTIFF