Case: 61CH1:13-cv-01844 Document #: 8 Filed: 12/05/2013 Page 1 of 3

IN THE CHANCERY COURT OF RANKIN COUNTY, MISSISSIPPI

IN THE MATTER OF THE ENLARGEMENT

AND EXTENSION OF THE BOUNDARIES
OF THE TOWN OF PELAHATCHIE, MISSISSIPPI CIVIL ACTION NO. 13-1844

AMENDED
COMPLAINT IN THE NATURE OF A PETITION FOR RATIFICATION, APPROVAL
AND CONFIRMATION OF AN ORDINANCE EXTENDING AND ENLARGING THE
BOUNDARIES OF THE TOWN OF PELAHATCHIE, MISSISSIPPI

COMES NOW the Town of Pelahatchie, Mississippi, a municipality organized and

existing under and by virtue of the laws of the State of Mississippi, situated in the County of

Rankin, State of Mississippi, by and through its Town Attorney, Craig L. Slay, and files this

Amended Complaint in the Nature of a Petition for the Ratification, Approval and Confirmation

of an Ordinance Extending and Enlarging the Boundaries of the said Town of Pelahatchie, said

Amended Complaint being filed to revise the scope of the annexation to eliminate a portion of

real property to be annexed and in support thereof would respectfully show unto the Court the

following facts to-wit:

1.

That at a regular meeting of the Board of Aldermen of the Town of Pelahatchie,

Mississippi, on December 2, 2013, the governing authorities of the Town of Pelahatchie,

Mississippi, duly and legally adopted an Amended Ordinance extending and enlarging the

corporate limits and boundaries of the City, a copy of said Amended Ordinance being hereto

attached and marked Exhibit "A", the same being made a part of this Petition as if copied herein

in words and figures, with publication thereof to be accomplished as provided by Section

21-1-31, Mississippi Code of 1972.

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2.

That said Amended Ordinance reflects that the prior Ordinance adopted by the Town of

Pelahatchie Board of Aldermen on April 17, 2013, enlarging and extending the boundaries of the

Town of Pelahatchie has been amended to remove a portion of real property identified as the

“Ruby Lake Addition” from the scope of the annexation, said property no longer being

considered for annexation by the Town of Pelahatchie. That in and by said Amended

Ordinance, the territory situated in Rankin County, Mississippi, and specifically described in

Section 1 of said Amended Ordinance is proposed to be included in the corporate limits and

boundaries of the said Town of Pelahatchie, Mississippi.

3.

That said Amended Ordinance in Section 2 thereof defines the corporate limits and

boundaries of the Town of Pelahatchie, Mississippi as extended and enlarged and fixed by said

Amended Ordinance.

4.

That said Amended Ordinance (Exhibit "A") further describes, in general terms, the

proposed improvements to be made in the annexed territory, the amount and extent of such

improvements and the approximate time within which said improvements are to be made; that

said Amended Ordinance also contains a statement of the municipal or public services which the

said Town proposes to render in such annexed territory.

5.

There will be provided to the Court at the hearing on ratification and made a part of this

Petition a map and plat of the municipal boundaries of the Town of Pelahatchie as they will exist

in the event said Amended Ordinance is ratified, approved and confirmed by this Court and
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becomes effective.

6.

Petitioner would show unto the Court that such extension, enlargement and modification

of the limits and boundaries of the said Town of Pelahatchie are reasonable and are required by

the public convenience and necessity and that said Amended Ordinance should be ratified,

approved and confirmed by the decree of this Court.

WHEREFORE, PREMISES CONSIDERED, Petitioner prays that this Petition be

received and filed, that this Court will fix a date certain for the hearing of this its Petition and

that, as provided by law, notice of said hearing shall be given to all parties interested in, affected

by, or having objection to the inclusions of said proposed territory within the corporate limits of

the Town of Pelahatchie, Mississippi, and the modification of the boundaries of said City as set

forth in said Amended Ordinance hereto attached as Exhibit "A", and requiring that objections,

answers or other pleadings, if any, should be presented to this Court at said time, answer under

oath being hereby expressly waived.

And Petitioner prays that upon the final hearing of this Petition that this Court will enter

its decree ratifying, approving and confirming the proposed extension, enlargement and

modification of the limits and boundaries of the Town of Pelahatchie, Mississippi, as set forth in

said Amended Ordinance hereto attached as Exhibit "A".

And if Petitioner be mistaken in the relief prayed for, then that this Court will grant such

other, further, different and more general relief as may be just and proper in the premises.

Town of Pelahatchie, Mississippi

By: /s/ Craig L. Slay, Attorney

MSB 10272
307 Creston Cove
Brandon, MS 39042
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