The chronicle-star. (Pascagoula, Miss.) 1920-1941, 1941-01-03
BILL OF COMPLAINT. As
AMENDED And EXHIBITS

AalkNDkD And EXHTBITs
IN THE CHANcERY COURT OPP
JACKSON COUNTY. MISSISSIPPI
WALTER r. GuILEY EFT AIS
VS. M gan
BOARD OF MAYOR AND COIN
CTLMEE OF THE CITY OF PAS
CAooULA MISSISSIPPI, ET
AIS
BILL o. COMPLAINT
Now come Walter r GaIley. s
II Frederic ard Lee Beckhau. ress-
cents and ctttzens OF the CITY az
PascAgouia- jackson County. Atssts-
1ppl and complain Of the Board Of
Mayor and Councilman q the CITY.
q Pascagoala MlSsisapp. tie City
q PAscaeoulA MizzlnstpA. : MINI.
clpAl corporation. p s Cansy. Mayog
Of said city. P e. Walker. Council
mar thereof. V p DeJean. Council
man thereof. and Clerk and Treas
urer Of the said CITY, al also being
residents and citizens Of the said
City, county and state. and respect
fully ShoS unto the Court the fol-
lowing facts. bo-wit;
I
The Conplasnann and al Of them
are residents and citizens Of the City
Of Pascagoula, Jackson County Mis-
siS1ppi. and Own real and personal
property within the corporate limits
Of the said city. which Is subject 70
municipal taxation and upon which
the ad vaiorem taxes of the said
city AN levied; they are therefore
taxpayers q said municipality
whose personal and property rights
VII be adversely affected b. the
matters hereinafter Get forth. That
al Of the facts hereinafter set forth
are fully known 70 the said indi-
vsdual defendants IN their official
capacity. that IN spite q such
knowlecge they intend 70 act here
matter alleged. and hence Il would
Be useless % request them 20 bring
this suit against themselves. but
would merely D. preclptated into
earlier action b. such request into
doing the act1 herein set forth which
vii be done II the Injunction herein
prayed Is not granted
The ComplaI1anG are also the
newly elected Mayer and Council
men ~ the said City q Paseagouia.
whose term q office VIII begin OF
January tn. ie4i. having been
elected b. the citizenS o. said city
At the regular August election. 1870
- Mayor and Coug1cllnen. respec-
lively That this suit Is brought
II behalf q al taxpayers q said
city who may stsh 70 JON herein.
and the same : invited 30 TO DO,
the Compiaan2ntS bringing sans
individually and Ia their capacity
IS citizens and taxpaysrz ard Of
flcerS elect a. Aforesaid
Thai the City Of P4srAeouA. Ms
Eak1pp- u . municipal corporation
witch l. organized and n0w bend
administered undex Tie prgsAa0ns o.
ne Code q Mlsizipfa q 1850. a
amended aeEtlzs up Ire Conmh.
son form q government. and has-
Hag been oaIy adopted Is uN form
Of government CT the sid munlc1.
paiHy on ox abouf October z 1919
under tire UUAiezls q Chapter ~
q TIE Iax4 q 1917 - amended
I'D municipality berg located Il
JeekBon County. MiAz4Kas INA
he governing bard q ne SAX
municipality Is uae Boszd = Mayo
and CyHne11anen q t3 CsEY q Pas
eaE0zA. MN44ppA NzeA i here
matter called ne Board that ?
8 canty i Ne duly sketad an
qualified M4fM q TIE sd Cts
and p II walker ard :. p IL
Lean are - ely eieetea az3 quail
fed CozuHzanHn uMrea1. Al 9
shom are serving u aAeb cNus
axzd al q WIaas8 terms - xftas -
n4re On January Ell ISz1
II
That % NzT z ieta he Lgzaa
tire q n& SITE q A1aawl
nzsec = Eaasl ard Pirate A.
kr1su &C designated - Haz@ -
No fit4 H1sa Is Ia ~ - -
bsz-
AN ACT 70 AUTHORIZE tn
CITY @ rASCA0ouIA MfA
sEaSErT 70 BORROW hoNE'
~ THE TOTAL AMOUNT =
NCT EXCEEDING a&1f0 20
TIE FuEuoEE O. EUHCfAk
no III NECESSARY ~