COME NOW the Defendant, ERIC HAMPTON, by and through the undersigned
Pursuant to Miss. R. Civ. P. 12(b)(6) Plaintiff has failed to state a claim upon which
relief can be granted as to some or all of his claims against this Defendant.
Some or all of Plaintiff’s claims are barred or limited by the doctrine of unclean hands.
Defendant hereby asserts that Plaintiff’s Complaint must be dismissed for lack of
Defendant hereby asserts that Plaintiff’s Complaint must be dismissed for lack of
Defendant hereby asserts and affirmatively pleads that Plaintiff’s Complaint must
doctrine of immunity, laches, illegality, and/or waiver on the part of the Plaintiff.
AND NOW, having asserted his affirmative defenses, the Defendant, responds as
Plaintiff:
complaint.
Executive Committee and a friend of Defendant Jamie R. Franks, Jr., who is the Chairman
of the Mississippi State Democratic Party. Defendant denies and asserts legal privilege as
Lee County, Mississippi on the Democratic ticket, in the election of 2007, but denies the
Complaint.
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6. Defendant admits he called a meeting of the Lee County Democratic
Executive Committee for July 12, 2010, but denies all other allegations in paragraph VI of
during the July 12, 2010 meeting, but denies the remaining allegations contained in
9. Defendant admits that he sent a letter to the Plaintiff on July 13, 2010 and
that he met with the Lee County School Board, but denies all other allegations contained in
Complaint.
Complaint.
12. Defendant would assert that paragraph XIII of the Complaint does not seem
to pertain to him; however, in the abundance of caution this Defendant hereby denies the
Complaint.
Complaint.
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15. Defendant denies the allegations contained in the unnumbered paragraph
subparagraphs (1), (2), and (3). Defendant further denies that Plaintiff is entitled to any
relief whatsoever.
RESPECTFULLY SUBMITTED,
ERIC HAMPTON
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CERTIFICATE OF SERVICE
I, PAUL CHINICHE, attorney for the Defendant, do hereby certify that I have this
date served via electronic means, a true and correct copy of the above and foregoing on the
following: