Our firm has been retained to represent Mr. John Knight III in an incident which took place on 1-55 Frontage Road in Jackson Mississippi, on or about May 13, 2018, around midnight.
Our firm has been retained to represent Mr. John Knight III in an incident which took place on 1-55 Frontage Road in Jackson Mississippi, on or about May 13, 2018, around midnight.
Our firm has been retained to represent Mr. John Knight III in an incident which took place on 1-55 Frontage Road in Jackson Mississippi, on or about May 13, 2018, around midnight.
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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.octMr. 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