IN THE CIRCUIT COURT OF COUNTY, MISSISSIPPI
, PLAINTIFF/PETITIONER
VS. NO.
REPUBLICAN/DEMOCRATIC
MUNICIPAL EXECUTIVE COMMITTEE
FOR THE CITY OF , MISSISSIPPI,
, CHAIRPERSON, DEFENDANT/RESPONDENT
INTERVENERS ANSWER
AFFIRMATIVE DEFENSES
A) That the above styled and numbered Petition for Judicial Review of Primary
Election is improperly filed in that the cause should be versus .
B) Petitioner fails to state a claim upon which relief can be granted.
C) is the duly qualified and certified City Alderman for Alderman District
of the City of , Mississippi having won the election to that office by receiving the
greatest number of votes from the electorate.
D) The voters alleged by to be ineligible are, in fact and at law,
eligible; and in the alternative, if the Court determines that any four of the six or so voters
alleged to be ineligible are, in fact and at law, eligible then, in that event, the outcome would not
change and remains the duly qualified and elected Alderman of District of the City
of , Mississippi.
6.
Respondent, City of , is without sufficient information to respond to Paragraph 6 of
the Petition and therefore denies the same and required proof thereof.
7.
Respondent, City of , is without sufficient information to respond to Paragraph 7 of
the Petition and therefore denies the same and required proof thereof.
8.
Respondent, Intervener, City of , denies the allegations contained in Paragraph 8
and subsections a,b,c,d,e and f.
9.
Respondent, City of , admits the allegations in Paragraph 9.
10.
Respondent, City of , denies the allegations in Paragraph 10.
11.
Respondent, City of , admits that two attorneys have signed affidavits with regard
to this matter but is not possessed with sufficient facts to know whether or not and to what extent
they have investigated this matter and therefore must deny the same as to content.
12.
Respondent, City of , denies the allegations contained in Paragraph 12. of the
Petition.
WHEREFORE, PREMISES CONSIDERED, Respondent, City of , requests that
this action be dismissed with prejudice and that all costs of Court and attorney fees for the
defense of this action be assessed to the Plaintiff and that no relief be granted to the Plaintiff.
That the decision of the Municipal Republican Election Committee be affirmed and
upheld; that judgment be entered confirming and re - establishing that the victory was duly held
and the finding of the City of Executive Committee should be confirmed for District
of the City of , Mississippi and if mistaken in the relief herein sought, then
Respondent prays for such other further and general relief as in equity or law that the City of
may be entitled to receive; all of which shall be at the cost of Petitioner, with attorney fees
for Respondent, City of .
RESPECTFULLY SUBMITTED,
CITY OF
_________________________________________
BY:
CERTIFICATE
I, , do hereby certify that I have on this day
mailed, postage prepaid, a true and correct copy of the above and foregoing to the following:
Dated, this the day of , .
_________________________________________
ATTORNEYS AT LAW