High Court Acts in Rape Case of Negro Who Cited Bias Study
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January 25, 1967

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Brief Collection, LDF Court Filings. Green v. Andrews Printed Record, 1965. 716e2b39-b49a-ee11-be36-6045bdeb8873. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/eb735b59-f554-473e-87a3-fa4e5f86622d/green-v-andrews-printed-record. Accessed August 19, 2025.
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UNITED STATES C O U R T OF A P P E A L S FIFTH CIRCUIT. No. 22,911 JAMES GREEN, ET AL., Appellants, versus A. L. ANDREWS, RUTH COLEMAN ANDREWS, and W. B. ANDREWS, Appellees. Appeal from the United States District Court for the Northern District of Mississippi. PRINTED RECORD. INDEX. Page Petition for Removal ............... 1 Writ of Injunction .......................... ............................... 5 Motion to Vacate Ex Parte Injunction ...................... 9 Memorandum in Support of Motion to Vacate Ex Parte Injunction ........... 10 Motion to Remand ........................................................... 11 Order Setting Hearing at Oxford ............................... 12 Order Remanding the Case to the Chancery Court of Washington County, Mississippi ................. 13 Notice of Appeal ............................................................. 14 Motion for Stay Pending Appeal ............................... 15 Transcript of Proceedings ............................................. 17 Complainants’ Exhibit No. 1, Original Bill of Com plaint ...................................................................... 26 Chancellor’s Fiat ..................................................... 37 Exhibit A-1—Letter dated May 31, 1965, to James Green, from A. L. Andrews ..................... 39 Exhibit A-2—Letter dated May 31, 1965 to Wallice Green, from A. L. Andrews . . . . 41 Exhibit A-3—Letter dated May 31, 1965, to T. B. Green, from A. L. Andrews .................... 42 Exhibit A-4—Letter dated May 31, 1965, to Wm. Earl Martin, from. A. L. Andrews .......... 44 Exhibit A-5—Letter dated May 31, 1965, to John H. Sylvester, from A. L. Andrews............. 45 Exhibit A-6—Letter dated May 31, 1965, to James Martin, Jr., from A. L. Andrews .............. 47 Exhibit A-7—Letter dated May 31, 1965, to Gerther Lee Martin, from A. L. Andrews 48 Exhibit A-8—Letter dated May 31, 1965, to Wallace Green, Jr., from A. L. Andrews 50 Exhibit A-9—Letter dated May 31, 1965, to Clarence Sylvester from A. L. Andrews . . 51 INDEX—(Continued): Page Complaintants’ Ehibit No. 1—(Continued): Exhibit A-10—Letter dated May 31, 1965, to Mack Ingram, from A. L. A n d re w s .......... 53 Exhibit A -ll—Letter dated May 31, 1965, to Johnnie Johnson, Jr., from A. L, Andrews 54 Exhibit A-.12—Letter dated May 31, 1965, to George Lee Martin, from A. L. Andrews 56 Exhibit “B”—Letter dated May 31, 1965 to A. L. Andrews ................................... ............... 57 Complainants’ Exhibit No. 2, Injunction Bond ........ 59 Complainants’ Exhibit No. 3, Writ of Injunction........ 62 Complainants’ Exhibit No. 4, Order on Removal Bonds 67 II PETITION FOR REMOVAL. F iled Jun. 2, 1965. IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF M ISSISSIPPI, G REEN V ILLE DIVISION. No. GC 6528. A. L. ANDREWS, RUTH COLEMAN ANDREWS, and W. B. ANDREWS, C om plainants-R espondents, versus JAM ES G R EEN , WALLICE G REEN , T. B. G REEN , WILLIAM EA RL MARTIN, JOHN H. SYLVES TER, JAM ES MARTIN, JR ., G ERTH ER L E E MARTIN, WALLACE GREEN , JR ., CLARENCD SYLVESTER, MACK INGRAM, JOHNNIE JOHN SON, JR ., GEORGE L E E MARTIN, VINCE FER R A R , PAT VAIL, STEVE DUNLOP, LARRY WALKER and SAM A PPLEW H ITE, and COUN CIL OF FED ER A TED ORGANIZATIONS, DEL TA MINISTRY and M ISSISSIPPI FREED O M DEMOCRATIC PARTY, W ashington County C hapter, D efendants-Petitioners. I. Ju risd iction of the Court is invoked pursuan t to 28 U. S. C. Section 1443. II. On M ay 31, 1965, a t approxim ately 5:30 A. M., D efendants-Petitioners Jam es G reen, Wallice G reen, 2 T. B. G reen, W illiam E a r l M artin, John H. Sylvester, Jam es M artin , J r . , G erther Lee M artin , W allace G reen, J r . , C larence Sylvester, Mack Ingram , John nie Johnson, J r . , and George Lee M artin , N egro p lan ta tion w orkers, m ade the la st of a series of de m ands for h igher w ages of th e ir employer, M r. A. L. A ndrew s. When A ndrew s refused to increase the ir wages, they went on strike. L a te r th a t day, they w ere notified to vacate th e ir hom es on the Andrews property . The following day, a t approx im ately 6:00 A.M., som e of the above m entioned D efendants- P etitioners began to peacefully picket the Andrews P lan ta tion on the public road abutting the p lan ta tion. In the afternoon of June 1, 1965, the C hancery Court of W ashington County, M ississippi, in V acation, is sued an ex p a rte w rit of injunction against the De- fendants-Petitioners, enjoining them , in te r alia, from doing any of the following: (A) Using loud language incident t 0 picketing; (B) Stationing m ore than four pickets a t any one time; (C) P ark ing m ore than two cars on the side of the public road a t any one tim e: (D) C arry ing m ore than one sign per picket; (E ) C arrying a sign exceeding th irty inches square in size. 3 III. D efendants-Petitioners a re denied th e ir fed e ra l righ ts of free speech and peaceful picketing, secured to them by 42 U. S. C. Section 1983 and the 14th A m endm ent to the Constitution of the U nited S tates, by this ex p a rte injunction. This injunction has a chilling effect on free speech activ ities and eo ipso prevents D efendants-Petitioners from enforcing the ir federa l rights in the M ississippi s ta te Courts. IV. D efendants-Petitioners a re being held to an sw er in the s ta te Court system for acts done under color of authority derived from 42 U. S. C. Section 1983 and the 14th A m endm ent to the Constitution of the U nited S tates. W herefore, D efendants-Petitioners p ray th is cause be removed from the C hancery Court of W ashington County, M ississippi to this Court. Respectfully subm itted , ANTHONY G. AMSTERDAM, (Anthony G. A m sterd am ). 3400 Chestnut S treet, Philadelphia. Pennsylvania. CARSIE A. HALL, JACK YOUNG, HENRY M. ARONSON. 538 1/2 N orth F a rish S treet, Jackson, M ississippi. JACK GREEN BERG , MELVYN ZARR, A ttorneys for D efendants- P etitioners. 10 Columbus Circle, New York, New York. 4 V erification. I, M elvyn Z arr, of law ful age firs t being duly sworn upon oath, depose and say: That I am a m em ber of the B ar of the S tate of M assachusetts and am associated w ith Young and Hall, m em bers of the B ar of the S tate of M ississippi and of this Court; That I am one of the duly authorized attorneys for defendants-petitioners herein , authorized to p repare and verify the annexed petition; That I have read the annexed petition and know the contents thereof; That I know of m y personal knowledge th a t all facts sta ted there in are true except such as a re s ta ted on inform ation and belief and as to them I believe them to be true ; That I sign this .verification on behalf of the De- fendan ts-P etitioners because the annexed petition deals chiefly w ith m atte rs of law and legal inference to be draw n from facts alleged and of which I as an atto rney have m ore knowledge than the D efendauts- P etitioners, and for the fu rth e r reason th a t there a re tw enty D efendant-Petitioners herein, m any of whom cannot be shortly found and time is of the essence. MELVYN ZARR. 5 Sworn to and subscribed before m e this 2nd day of June 1965. WILLIAM T.f ROBERTSON, Clerk, By DAN D. ESTES, (Seal) Deputy. W RIT OF INJUNCTION. (Title O m itted.) To: All of the D efendants Above N am ed: W hereas, A. L. Andrews, R uth Colem an Andrews, and W. B. A ndrew s, as Com plainants, have filed th e ir bill in the above Court against you praying for a p re lim inary injunction, both m andato ry and pro hibitory; and W hereas, the Honorable S. B. Thom as, Judge of the C hancery Court of W ashington County, M issis sippi, has this date in said cause, by o rder en tered this date, has d irected th a t said injunction issue against you as p rayed for in said original bill of com plaint and as fu rth er specified in said order, said injunction having issued upon the posting of bond in the am ount of $5,000.00, as set by said order, and conditioned according to law ; Now, Therefore, you a re hereby enjoined and com m anded as follows: 1 (1) The above nam ed D efendants, nam ely , Jam es G reen, Wallice G reen, T. B. G reen, W illiam E a r l 6 M artin, John H. Sylvester, Jam es M artin , J r . , Ger- th e r Lee M artin , W allace G reen, J r . , C larence Syl vester, Mack In g ram , Johnnie Johnson, J r . , and George Lee M artin , fo rm erly em ployees of said Com plainants, shall im m edia te ly v aca te from the houses located on C om plainants’ fa rm lands as de scribed in the bill of com plaint and im m ediately re move therefrom th e ir fam ilies, p roperty and p e r sonal effects; and upon th e ir fa ilure to do so in s tan te r , the Sheriff of W ashington County, M ississippi, or his authorized deputy, shall be and hereby is directed to evict them im m ediately . (2) The D efendants, Jam es G reen, W allice G reen. T. B. G reen, W illiam E a r l M artin , John H. Sylvester, Jam es M artin , J r . , G erther Lee M artin , W allace G reen, J r . , Clarence Sylvester, Mack Ingram , John nie Johnson, J r . , and George Lee M artin , shall not re-en ter the fa rm prem ises or any house, barn , shed, p riva te way, p riv a te easem ent, or other p a rt of Com p la in an ts’ fa rm lands, exclusive of public roads only, for any purposes w hatsoever, until the fu rther order of th is Court. (3) All D efendants above nam ed and th e ir agents, represen ta tives, confederates, and all other persons acting1 in concert w ith them shall not en ter or re en ter the fa rm prem ises or any house, barn , shed, p riva te way, p rivate easem ent or other p a r t of Com- n la in an ts’ fa rm lands, exclusive of public roads only, for any purposes until the fu rth e r o rder of th is Court. 4. All D efendants above nam ed and all agents, persons and organizations acting in concert w ith them are prohibited from either directly or ind irec t 7 ly th rea ten ing , in tim idating or coercing, e ither by w ords or conduct, the C om plainants, A. L. Andrews, R uth Colem an A ndrew s, and W. B. Andrews, or other employees of Com plainants still working on said fa rm lands, or any other persons em ployed by Com plainants to w ork on th e ir fa rm property , and th is injunction shall continue in full force and effect until the fu rth er o rder of th is Court. 5. All D efendants herein nam ed and all other p er sons, rep resen ta tiv es and organizations acting in concert w ith them are , until the fu rth e r o rder of this Court, prohibited from engaging in or em ploying any conduct or w ords am ounting to coercion or in tim ida tion as an incident to picketing and they a re specifi cally prohibited from using loud language, cat-calls, jeers, unruly and boisterous conduct, as well as d irect th rea ts of violence and bodily h a rm either to C om plainants, and other em ployees, or any person engaged by C om plainants to work on th e ir farm lands n ear Tribbett, M ississippi, or m em bers of the public; and D efendants or other persons, agen ts or organizations acting in concert w ith them are pro hibited from getting on any p a rt of the fa rm lands of Complainants, including any house, barn, shed, or other fa rm buildings or p riva te w ay, or p riva te ease m en t ap p u rtenan t thereto , exclusive of public roads, and all D efendants, or other persons and organiza tions acting in concert w ith them a re hereby re stra ined and prohibited from conducting any picket ing of C om plainants or C om plainants’ aforesaid property , except and unless such picketing com plies with the following standards: 8 (a) P ersons picketing shall not exceed four in num ber a t any one time, and they shall s tand or w alk only along the sides of the public road in front of C om plainants’ fa rm h ead q u arte rs so as not to im pede, block or otherw ise in te rfe re w ith tra ffic upon said public road, not more: than two cars of said picketers to be parked on the side of said public road a t any one tim e. (b) Picketing, if engaged in, m ust be conducted only in a quiet and orderly m an n er a t a ll tim es. (c) P ersons p icketing shall be allowed to carry one sign, not exceeding in size th irty inches by th irty inches, and m ay p lace thereon p rin ted m a tte r or m a te ria l calcu lated only to persuade and not otherw ise unlawful. Given under m y hand and official seal, th is 1st day of June, 1965. W. L. KENT, (W. L. K ent), (Seal) C hancery Clerk. To the Sheriff or any Lawful Officer of W ashington County, M ississippi: You Will Execute the above w rit of injunction against pll D efendants nam ed and m ake your re tu rn thereof im m ediately to th is office. W. L. KENT, (W. L.. K ent), Chalncery Clerk.(Seal) 9 MOTION TO VACATE EX PARTE INJUNCTION. Filed Jun. 2, 1965. (Title Omitted.) D efendants-Petitioners hereby m ove the Court to vacate the ex p a rte injunction issued by the C hancery Court of W ashington County, M ississippi June 1, 1965, and rem oved this day to th is Court and will show un to the Court the following: 1. The ex p a rte injunction issued by the C hancery Courts prevents defendants-petitioners from , in ter a lia: A. Using loud language incident to picketing; B. Stationing m ore than four pickets a t any one tim e ; C. P ark ing m ore than two cars on the side of the public road a t any one tim e; D. Carrying more than one sign per picket; E. C arrying a sign exceeding th irty inches square in size. 2. The ex p a rte injunction has a chilling effect on free speech activities and constitutes a p rio r re s tra in t on the exercise of federally protected rights secured them by the F ourteen th A m endm ent to the Constitution of the United S tates and 42 U. S. C. Section 1983. 10 This 2nd day of June, 1965. ANTHONY G. AMSTERDAM,, (Anthony G. A m sterdam ). 3400 C hestnut S treet, Philadelphia, P ennsylvania. CARSIE A. HALL, JACK YOUNG, HENRY M. ARONSON. 538 1/2 North F a rish S treet, Jackson, M ississippi. JACK G R EEN B ER G , I MELVYN ZARR, A ttorneys for Defendants, P etitioners. 10 Colum bus Circle, New York, New York. MEMORANDUM IN SUPPORT OF MOTION TO VACATE EX PARTE INJUNCTION. (Title O m itted.) 1. This Court has ju risd iction to vacate a s ta te Court injunction offensive to the Constitution of the United S tates. City of Selma v. SNCC, S. D. A labam a, A pril 16, 1965. 2. The ex p a rte injunction issued by the Chancery Court has a “ chilling effect” (D om browski v. Pfis- te r .......... U. S............. 33 U. S. L. W. 4321, April 26, 11 1965) on free speech activ ities. Thornhill v. A labam a, 310 U. S. 88 (1940), E dw ards ,v. South Carolina, 372 U. S, 229 (1963), F ields v. South Carolina, 375 U. S. 44 (1963). ANTHONY G. AMSTERDAM, (Anthony G. A m sterdam ). 3400 C hestnut S treet, Philadelphia, Pennsy lvan ia. CARSIE A. HALL, JACK YOUNG, HENRY M. ARONSON. 538 1/2 N orth F a rish S treet, Jackson, M ississippi. JACK G REEN BERG , MELVYN ZARR, Attorney's for D efendants- Petitioners. 10 Columbus Circle, New York, New York. MOTION TO REMAND. Filed Jun. 2, 1965. (Title O m itted.) Now come A. L. Andrews, R uth Colem an Andrews and W. B. Andrews, C om plainants, by th e ir under signed counsel, and m ove the Court to rem an d the above entitled cause to the C hancery Court of W ash ington County, M ississippi, for the reason th a t this Court is w ithout jurisd iction over e ither the sub ject 12 m a tte r or the p a rtie s, and for o ther grounds to be shown a t the hearing. W. C. KEADY, (W. C. R eady). 119 N orth B roadw ay, G reenville, M ississippi. Of Counsel: KEADY, CAMPBELL & DeLONG, 119 N orth Broadw ay, G reenville, M ississippi. ORDER. (Title O m itted.) This action having been rem oved to th is Court from the Chancery Court of W ashington County, Mis sissippi, p u rsu an t to 28 U. S. C. § 1443, defendants having filed in this Court a m otion to vacate the ex p a rte injunction issued by the Chancery Court, and plaintiffs having moved th a t this cause be rem anded to the said Chancery Court, it is, Ordered: (1) That these m a tte rs shall be, and they hereby are , set for hearing a t 10:00 o’clock in the forenoon of 18 June, 1965, a t the United S tates Courthouse in Oxford, M ississippi, in the following m anner: (a) Consideration shall f irs t be given to this C ourt’s jurisdiction upon the p lain tiffs’ m otion to re m and. 13 (b) If the m otion to rem and should be overruled, consideration will then be given to defendants’ mo tion to v aca te the injunction. (c) Any other m a tte rs requiring th is C ourt’s dis position which shall have accrued by the date of the hearing shall be considered in such order as m ay be deem ed appropria te a t th a t time. (2) That the clerk of th is Court shall serve copies of this order upon all counsel of record, by certified mail. This the 4th day of June, 1965. CLAUDE F . CLAYTON, (Claude F . C layton), District Judge. ORDER. (Title O m itted.) For the reasons w hich will be shown by the re p o rte r’s notes of the action taken th is day by the Court, it is, O rdered: (1) This cause shall be and hereby is rem anded to the C hancery Court of W ashington County, M issis sippi. (2) The respondents a re aw arded costs as they m ay in course be taxed. 14 (3) The c lerk of th is Court is d irec ted to serve a certified copy of th is O rder on the C lerk of the Chan cery Court of W ashington Cou,nty, M ississippi 'by certified m ail, noting such action on the docket. This the 16th day of June, 1965. CLAUDE F. CLAYTON, (Claude F. C layton), U nited S tates D istrict Judge. NOTICE OF A PPEA L. F iled June 17, 1965. In the United S tates D istric t Court for the N orthern D istric t of M ississippi, G reenville Division. A. L. A ndrew s, R uth Coleman A ndrew s, and W. B. A ndrew s, C om plainants-R espondents, vs. No. GC6528 Jam es G reen, W allice G reen, T. B. G reen, W illiam E a r l M artin, John H. Sylvester, Jam e s M artin , J r . , G erther Lee M artin , W allace G reen, Jr;., C larence Sylvester, Mack In g ram , Johnnie John son, J r . , George Lee M artin, Vince F e rra r , P a t Vail, S teve Dunlop, L a rry W alker and S am Ap plew hite, arid Counscil of F e d e ra ted O rganiza tions, D elta M inistry and M ississippi F reedom D em ocratic P a rty , W ashington County C hapter, D efendants-Petitio 'ners. 15 D efendants-Petitioners hereby appeal to the U nited S tates Court of Appeals for the F ifth C ircuit from the order of the U nited S tates D istrict Court for the N orthern D istric t of M ississippi, the (Honorable Claude F . Clayton, D istric t Judge, en tered June 16, 1965, rem anding the case to the Chancery Court of W ashington County. MELVYN ZARR, (M elvyn Z arr) , JACK G R EEN B ER G . 10 Columbus Circle, New York, New York. CARSIE A. HALL, JACK H. YOUNG, HENRY M. ARONSON. 538-1/2, North F a rish S treet, Jackson, M ississippi. ANTHONY G. AMSTERDAM. 3400 C hestnut S treet, Philadelphia, Pennsylvania. MOTION FOR STAY PENDING A PPEA L. F iled June 17, 1965. (Title O m itted.) P u rsu an t to Rule 62(d) of the F ed e ra l R ules of Civil P rocedure, petitioners hereby move the Court for a stay pending appeal of the Court’s order of rem and en tered in th is case to the United S tates Court of A ppeals for the Fifth C ircuit, and would show unto the Court the following: 1. On June 16, 1965, the United S tates D istric t Court for the N orthern D istrict of M ississippi, the 16 Honorable Claude F. Clayton, D istrict Judge, en tered an o rder rem anding the cause to the Chancery Court of W ashington County, M ississippi. 2. P etitioners requ ire a s tay of the C ourt’s re m and o rd er in o rder to p reserve on appeal to the U nited S tates Court of A ppeals for the F ifth Circuit the im p o rtan t constitu tional issues p resen ted herein. 3. “By doing all the acts necessary to p e rfec t an appeal and by giving a proper supersedeas bond an appellan t m ay obtain a s tay as of right, ‘subject to the exceptions contained in subdivision (a ) ’ of rule 62.” Moore’s Federal Practice, 1162.06. W herefore, petitioners p ray the Court to issue a s tay of its rem an d order, sub ject to approval by the Court of pe titioners’ supersedeas bond. R espectfully subm itted , MELVYN ZARR, CARSIE A. HALL, JACK H. YOUNG, HENRY M. ARONSON. 538-1/2 North F a rish S treet, Jackson, M ississippi. 17 Filed Jul. 12, 1965. In the United S tates D istrict Court for the N orthern D istrict of M ississippi, G reenville Division. A. L, Andrews, E t Al., Com plainants-R espondents. v. Civil Action No. GC6528. Jam .es G reen, E t Al., D efendants-Petitioners. Proceedings had and evidence taken in the above- entitled cause on the 16th day of June, 1965, a t 10 a. m., in the U nited S tates D istric t Court for the N orthern D istrict of M ississippi, G reenville Division, a t Oxford, M ississippi, before the Honorable Claude F. Clayton, United S ta tes D istric t Judge. [2] A ppearances: F o r the C om plainants-R espondents: K eady, Camp bell and DeLong, by W. C. R eady, E squire , and F red C. DeLong, J r . , E squ ire , 119 N orth B road way, G reenville, M ississippi. For the D efendants-Petitioners: H enry M. Aron son, Esquire, and Melvyn Zarr, Esquire, 538-1/2 North Farish Street, Jackson, Mississippi. [4] Proceedings. The Court: You m ay be seated . Andrews and others against G reen and others, G reenville Civil 6528. Are you gentlem en ready to proceed? 18 Mr. Keady: Yes, sir, if the Court please. Mr. Aronson: Your Honor, as a p re lim inary m atter, I would like to introduce Mr. M elvyn Z a rr to th is Court and, whichever is the Court’s p leasure , e ither m ove his adm ission pro hac vice, for th is m a tte r , and then m ove his adm ission in the Court subsequently, if you would ra th e r— The Court: Does he have a certificate of cu rren t good standing in the D istric t Court? Mr. Aronson: Yes; he does, Your Honor, dated June 7, 1965, the D istric t Court for the D istrict of M assachusetts, m em ber of the S ta te B ar of M ississippi, the F ifth C ircuit, and a g radua te of the H arv ard Law School. The Court: All right. I will be glad to adm it him generally a t this tim e. He can deal w ith the Clerk insofar as ta k ing the oath and paying the usual fee a t his conven ience la te r in the day. Will you gentlemen, for the record , announce your [5] appearances to be sure th a t we have the house in order in th a t regard before we proceed? Mr. Z arr: F o r the plaintiffs, M elvyn Z a rr and H enry Aron son. 19 Mr. Keady: For the com plainants-respondents, I believe w e’re entitled, th a t is to say A. L. A ndrew s, R uth Andrews and others, W. C. K eady and Fred DeLong, G reen ville, M ississippi. The Court: In accordance w ith the C ourt’s order of June the 4th in th is m a tte r, the firs t o rder of business th is m orn ing is the motion to rem and. Are you ready to proceed on tha t, M r. Keady? Mr. Keady: Yes, sir, if the Court p lease ; we are. At this tim e, in o rder to m ake the record of the rem oving proceeding com plete, I offer in evidence a certified copy of the original bill of com plaint, w ith C hancellor’s file, as it app ears in the C hancery Court, Cause N um ber 25,861 in the docket of the Chancery Court of W ashington County, M ississippi, a certified copy of the injunction bond entered in said cause and a certified copy of the w rit of injunction as is sued by the Chancery Clerk of th a t county. The Court: All right. Let these docum ents be [6] received and filed. Mr. Keady: I now offer these as Exhib it 1, 2 and 3. (The certified copy of the original bill of com plain t re fe rred to w as m arked and received in evi 20 dence as C om plainants-R espondents-E xhib it 1; the certified copy of the injunction bond re fe rre d 'to w as m arked and received in evidence as Complain- an ts-R espondents’ Exhibit 2, and the certified copy of the w rit of injunction re fe rred to w as m arked and received in evidence as Com plainants-Respond- en ts’ Exhib it 3.) Now, if the Court p lease, I believe th e re ’s no ques tion here but th a t the am ount deposited for the re moval of this cause is the sum of $235, and we desire to call to the Court’s atten tion the standing order of th is Court th a t [7] the rem oval bond shall be $500. We a re p repared to m ake proof of tha t, as to the am ount, unless counsel stipulates to the s ta tem en t ju s t m ade. Mr. Z arr: The petitioners a t the tim e of the filing of the re moval petition filed a bond in the sum of $250, Your Honor. Mr. Keady: I correct m y sta tem en t. It w as filed in the amount of $250. The Court: All right. Mr. Keady: Now, we have, if the Court please, the order of this Court requ iring all rem oval bonds to be in the am ount of $500. If the C lerk would p resen t tha t, we would like to m ake th a t p a r t of the record. 21 The Court: Of course, to have bearing on this m a tte r , it should be p a rt of the record ; but, as a m a tte r of law, the Court can note judicially— Mr. Keady: Yes, sir. The Court: —its own orders. M r. K eady: Yes, sir. The Court: For convenience, let it be received and filed in this case. (A certified copy of the o rder [8] re fe rred to w as m ark ed and received in evidence as C om plainants- R espondents’ E xhib it 4.) Mr. Keady: Your Honor, th a t’s all of the evidence th a t the m ovants offer on the m otion to rem and . We understand th a t will be taken up a t this tim e. The Court: All right. Is there anything for the defendant-petitioners on the motion to rem and? Any evidence? Mr. Z arr: At this tim e, Your Honor, we have no evidence. 22 The Court: All right. Do you w ish to be h eard on this m otion, Mr. R ea dy? M r. DeLong: We do, Your Honor. The Court: All right. Mr. DeLong: Is it the Court’s w ish th a t the petitioners on th is m otion now proceed w ith the argum ent? The Court: On your m otion to rem and . Mr. DeLong: Yes, sir. The Court: Yes, sir. Mr. DeLong: If the Court will indulge me just one m om ent— [9] The Court: All right, sir. (Opening argum ent in behalf of the com plainants- respondents w as m ade by Mr. DeLong.) (A rgum ent in behalf of the defendants-petitioners w as m ade by Mr. Z a rr .) 23 (Closing argum ent in behalf of com plainants- respondents w as m ade by Mr. K eady.) (F u rth e r a rgum ent in behalf of the defendants- pe titioners w as m ade by Mr. Z a rr.) The, Court: In dealing w ith the m otion to rem and , the ease m ade by the record here is a labor dispute betw een the em ployees or fo rm er employees and th e ir em ployer or fo rm er em ployer. In assaying the question of w hether this Court has jurisdiction of such a dispute or not, the question of w hat original ju risd iction the Court would have had in this situation m ust be considered. To say it differently , as it has been expressed , the Court’s original ju risd iction in such a dispute is ra th er severely lim ited by the N orris-La G uard ia sta tu te . Considering it as a labor dispute for the tim e being and as such, it is perfectly obvious to me, as counsel have pointed out, th a t it would be a ra th e r curious [10] situation for th is Court to assum e jurisdiction which, in effect, would im m ediately , w ithout a h ear ing, w ithout consideration of the rem oving petitioners’ motion to dissolve, am ount to a dissolution of the injunction previously issued by the C hancery Court of M ississippi. Again limiting consideration solely to the question of this being a labor dispute, since th is Court would have had no original jurisdiction, it can have no de rivative jurisdiction on rem oval. Secondly, considering w hether or not a federa l ques tion as distinguished from a civil righ ts question is involved so as to give this Court jurisdiction, c learly there is none'. 24 This is a p riva te civil litigation betw een p riva te citizens, and in no way does it involve a fed era l question such as of itself would confer jurisd iction on this Court. Now, considering the question of w hether this is such a civil righ ts case as would requ ire this Court to say th a t R achel ag ain st G eorgia w as controlling, I cannot see th a t it is such a case. In m any cases filed in s ta te Courts, tried in s ta te Courts,, th e re a re constitutional questions, fe d e ra l constitutional questions, involved as an incident to the [11] litigation. There is no such constitutional question involved here , no such civil rights question involved here, as would m ake it the param oun t ques tion for consideration by the Court m aking final de term ination of the issues tendered by the complaint filed in the State C hancery Court. This is not, in m y opinion, such a civil righ ts case as would m ake R achel ag ain st Georgia dispose of th is question in th is Court. As a m a tte r of fact, I can ’t visualize in this p a rticu la r case the application of Rachel a t all. There is no state agency involved, o ther th an a forum to which the issues tendered by the bill of com plaint w ere offered. There is no rac ia l ovlejrtone as such. There is no question of voting righ ts involved, as m entioned by Mr. Z a rr in a hypo thetical case. I t sim ply does not m eet the fac tual situation p resen t in Rachel. On none of those grounds does this Court consider th a t it has jurisdiction of th is action which the pe titioning defendants have a ttem p ted to rem ove. Finally, another question w ith which (this C ourt has been concerned, not dealt w ith by counsel in m aking th e ir presentation: When the rem oval pro- 25 eedure w as changed in 1948, w hat is now Section 1446 (d) of Title 18 specifically requ ired th a t bond be afforded or filed by the [12] rem oving defendant in the D istric t Court. Acting under au thority w hich he felt th is Court had, which view I share , Judge A lan Cox, who then w as the D istrict Judge,, en tered an order on Septem ber 18th, 1948, requ iring th a t w ith any petition for rem oval of a civil action such as th is there would be posted a bond by the rem oving petitioners in the am ount of $500 or in such la rg er am ount as m ight be fixed by the C lerk of the Court. This procedural s ta tu te , Section 1446 of Title 18, covers the p rocedure to be followed in all rem oved actions. According to m y view, th is w as a valid order, a reasonab le regulation, a reasonable ru le, p rom ul gated by this Court in 1948, and in this instance, ac cording to the stipulation m ade by counsel th is m orn ing, the only bond filed w as a two-hundred-and-fifty- dollar bond, and in th a t situation the C lerk of th is Court had no au thority to accept and file and docket the petition tendered for rem oval. F o r the reasons stated , the m otion to rem and should be and is sustained. The cause will be re m anded to the Chancery Court of W ashington County, M ississippi. The order will be p rep ared and signed to ca rry th is into effect this afternoon. This hearing shortly will be recessed, and Court [13] shortly will be adjourned. There is another m a tte r. Counsel are p resen t on both sides. I would like to see them on the G reen ville Mills case in cham bers and off the record for a brief conference. 26 Court is now adjourned. (Thereupon, a t 2:40 p. m ., the) Court adjourned.) COMPLAINANTS’ EXH. # 1 . In the C hancery Court of W ashington County, Mis sissippi, in Vacation, 1965. A. L. A ndrew s, R uth Colem an A ndrew s, and W. B. A ndrew s, Com plainants, vs. Cause No. 25,861. Jam e s G reen, W allice G reen, T. B. G reen, W illiam E a r l M artin , John H. Sylvester, Jam es M artin, 'J r ., G erther Lee M artin , W allace G reen, J r . , C larence Sylvester, Mack Ingram , Johnnie John son, J r . , George Leje M artin , Vince F e rra r , P a t Vail, Steve Dunlop, L a rry W alker, and Sam Ap plewhite, and Council of F edera ted O rganiza tions, D elta M inistry and M ississippi F reedom D em ocratic P a rty , W ashington County C hapter, D efendants. O riginal Bill of Com plaint. To the C hancery Court of said County: Now come A. L. A ndrew s, R uth C olem an Andrews, and W. B. A ndrew s, a partn e rsh ip operating farm property in W ashington County, M ississippi, known as Andrews B rothers P lan tation , Com plainants here in, and rep resen t unto the Court as follows: 27 1. Com plainants, A. L, Andrews and R uth Colem an A ndrew s, husband and wife, a re adu lt residen ts of W ashington County, M ississippi, and Com plainant, W. B. Andrews, is a residen t of O ktibbeha County, M ississippi. The individual D efendants a re all re s i dents of W ashington County, M ississippi, except Vince F e rra r , a p ro jec t d irec to r of Council of F ed er ated Organizations, is a non-resident of the S ta te of M ississippi, whose place of p e rm an en t address is unknown to C om plainants, but who is p resently so journing in W ashington County, M ississippi; P a t Vail, a project d irc to r of Council of F ed era ted Or ganizations, is a non-resident of the S tate of M issis sippi, whose place of p e rm an en t address is unknown to Complainants, but who is presently sojourning in W ashington County, M ississippi; Steve Dunlop and L a rry W alker, a re non-residents of the S ta te of M ississippi, whose places of pe rm an en t address are unknown to Com plainants, but who a re p re s ently sojourning in W ashington County, M ississippi, and a re rep resen ta tiv es in charge of D elta M inistry; and Sam Applewhite, is a non-resident of the State of M ississippi, whose place of p e rm an en t address is unknown to C om plainants, but who is presen tly sojourning in W ashington County, M ississippi, and who is a rep resen ta tiv e of the W ashington County C hapter of M ississippi Freedom Dem ocratic P arty . The organizational D efendants herein sue, Council of F ed e ra ted O rganizations, D elta M inistry and and W ashington County C hapter of M ississippi F re e dom D em ocratic P a rty , m ain ta in offices or head q u arte rs in W ashington County, M ississippi, a t G reen 28 ville, and carry on in W ashington County, M issis sippi, sep a ra te p ro g ram s p u rsu an t to the purposes for which they w ere organized. 2. Com plainants own, or lease, and a re in possession of fa rm lands in W ashington County, M ississippi, com prising approxim ately 1350 acres, m ore p a rtic u larly described as being those certa in fa rm lands known as Andrews B rothers P lan ta tion , approxi m ate ly nine m iles sou theast of Leland, M ississippi, and situated in Sections 4, 5, 6, 8, 9, and 17, Town ship 17 North, R ange 6 W est. Said fa rm lands con ta in various im provem ents thereon, including ap proxim ately fourteen ten an t houses, barns, sheds, and other fa rm buildings; th a t a t the p resen t tim e C om plainants have approx im ately 1335 acres of said land under cultivation and in growing crops, of which approx im ate ly 860 acres a re p lan ted skip-row in cot ton, 175 acres in beans, 111 acres in fee-id g ra in p ro g ram , and approxim ately 12,5 or 130 acres in oats. Com plainants show th a t said crops a re in a high s ta te of cultivation, m uch labor and effort thereon having been expended; th a t the cotton crop is now in such condition th a t it is necessa ry for sam e to be both plowed and hoed im m edia te ly ; th a t the bean crop is up and will have to be w orked within the next w eek; and the oat crop is now in process of being harvested . A large and su b stan tia l p a r t of the to tal cost of m aking the 1965 crop has a lready been invested in bringing the crop to its p resen t stage of cultivation. 29 3. Com plainants show th a t to assis t them in making the 1965 crop they have heretofore em ployed v a ri ous day laborers, specifically Jam e s G reen, W allice G reen, T. B. G reen, W illiam Earl M artin , John H. Sylvester, Jam es M artin , J r . , G erther Lee M artin, W allace G reen, J r ., Clarence Sylvester, Mack In gram , Johnnie Johnson, J r . , and George Lee M artin, and various m em bers of th e ir fam ilies, the wages for the aforesaid named individual Defendants being fixed a t $6.00 per day for each day w orked, except in the case of W illaim E a rl M artin and George Lee M artin, whose daily com pensation w as fixed a t $5.50, and in addition to such compensation, C om plainants p ro vided, as an incident to the ir em ploym ent and not otherw ise, houses for said individual D efendants and the ir fam ilies to live in while em ployed by Com plainants, and w ithout ren t or any other charge being m ade of them for such houses. All of the houses in question w ere and a re located upon C om plainants’ above described fa rm lands in W ashington County, M ississippi. The said individual nameld D efendants em ployed by Com plainants, and m em bers of the ir fam ilies, worked for Com plainants through the w ork week ending S aturday , May 29, 1965 and w ere paid all com pensation due them through th a t said day. On Monday, M ay 31, 1965, a t the beginning of the work day, said individual D efendants em ployed by Com plainan ts notified A. L. Andrews, m anaging p a rtn e r of Com nlainants, th a t they refused to re tu rn to work except for higher w ages, which dem and w as declined. 30 Thereupon the said individual nam ed D efendants, acting in concert w ith and upon the advice of the said D efendants, Vince F e rra r , P a t Vail, Steve Dun lop and L arry W alker, and the respective organiza tions rep resen ted by said parties, failed and refused to do any work on C om plainants’ fa rm . Thereupon C om plainants, acting through the said A. L. Andrews, notified the individual D efendants em ployed by Com plainants, th a t th e re w as no w ork for them to do any longer on the property and he dem anded im m ediate possession of the houses occupied by the individual D efendants and th e ir fam ilies. The individual De fendants refused to leave the prem ises and stayed on the property . At approx im ately 3:00 o’clock P. M. A. L. Andrews, m anag ing p a rtn e r of Com plainants, requested his attorney, W. C. K eady, to ta lk to the individual D efendants employed by C om plainants, which he did, in the presence of all of them and th e ir project adv isers from D elta M inistry and Council of F ed e ra ted O rganizations. Thereupon the said a tto r ney gave the individual D efendants em ployed bv Com plainants an opportunity e ither to re tu rn to w ork at the sam e com pensation or to v aca te the houses oc cupied by them and leave the fa rm property and remove them selves, the ir fam ilies and effects from the fa rm property . A fter th is s ta tem e n t of Complain a n ts ’ counsel, the individual D efendants em ployed bv C om plainants re tired to consider w hat th e ir de cision would be and then reported in the presence of A. L. Andrews, m anaging p a rtn e r of C om plain ants, and his said counsel, they they w ere not going back to work. Thereupon. Com plainants, acting through the ir said m anaging p a rtn e r, delivered to each individual defendants previously em ployed by 31 them a w ritten notice of eviction which w as in each case e ither personally served upon the ex-em ployee or posted on the front door of his house, in those in stances w here such ex-em ployees had tem porarily absented them selves from the p roperty . Com plain ants filed herew ith a true copy of the eviction notices given to the individual D efendants once em ployed by Com plainants and which notices a re hereto a t tached as Exhibit A-l through A-12. 4. C om plainants show to the Court th a t despite the term ination of the em ploym ent re la tions w ith its above nam ed individual ex-em ployees, and after the aforesaid fo rm al notice of te rm ina tion and eviction had been m ade to each of said employees, they have m ade no move to remove them selves, th e ir fam ilies, th e ir goods apd effects from C om plainants’' farm: properties and have on the con trary asse rted a righ t to stay in the houses occupied by them as an inci dent to th e ir em ploym ent through legal proceedings. A copy of w ritten refusal to v aca te on the p a rt of the said ex-employees is a ttach ed hereto as E xhib it “ B” and m ade a p a rt heireof by reference. Com plainants would show to the Court th a t the occupancy of the ir farm houses by the aforesaid ex-em ployees was solely incident to th e ir em ploym ent, and was, a t law, a tenancy a t will term inable w ith th e ir em ploym ent as day laborers. C om plainant fu r th e r shows tha t it is necessary in o rder to properly fa rm said lands, due to their location 9 miles southeast of Leland, Mississippi, and fa rth e r from la rg e r centers of population having farm laborers available, th a t the said houses be oc 32 cupied by those persons who w ork for C om plainants’ fa rm and not otherw ise. The stubborn and obstinate re fu sa l of the ex-pmployees^ to deliver im m ediate possession of said houses and to rem ove therefrom their families, their goods and effects, and to quit Com plainants’ fa rm prem ises, constitu tes a tre s pass which continues from day to day, and in te r feres w ith C om plainants’ p roperty rights, and depri vation of the righ ts safeguarded by law to Com plainants. F u rth e r, said stubborn and obstinate r e fusal effectively p reven ts C om plainants from obtain ing rep lacem ent labor needed im m edia te ly to w ork the crops on said farm s, since housing is not avail able to be furnished such rep lacem en t labor, and the actions of ex-em ployee D efendants in the p rem ises constitu tes a case of extrem e urgency and unless enjoined will inflict irrep a rab le and im m easurable in juries in the cultivation and harvesting of the ir valuable crops. C om plainants show th a t the g ranting of a m an d ato ry injunction in th is cause against said D efendant ex-em ployees requiring them to im m edi ately vacate from said fa rm properties aforesaid , is accom panied by an occasion of g rea te s t em ergency and is im m ediately necessary in o rder to p reven t an otherw ise irrep a rab le in ju ry to C om plainants. Complainants show th a t they do not have a full, com plete or adequate rem edy a t law. 5. C om plainants fu rth er charge on inform ation and belief th a t the D efendants F e rra r , Vail, Dunlop, W alk er and Applewhite acting for th e ir respective orga nizations, Council of F ed e ra ted O rganizations, D elta 33 M inistry and W ashington County C hapter of M issis sippi Freigdqm D em ocratic Party ,, have counseled and advised w ith the individual D efendants fo rm erly em ployed by Com plainants w ith a view of in te rfe r ing w ith th e ir con tractual relations w ith Complain ants, to cause them to go on strike and to advise them not to yield possession of the houses occupied by the ex-em ployee D efendants and not to quit the fa rm prem ises of Complainants. C om plainants fu r ther charge th a t today, June 1, 1965, all of said De fendants nam ed herein, both individually and as rep resen ta tives of th e ir respective organizations, have re tu rn ed to C om plainants’ fa rm prem ises and they have a ttem p ted to set up a picket line on a public road abutting said fa rm prem ises, but a t a tim e w hen none of the ex-employee D efendant have re m oved their goods, th e ir fam ilies or them selves from the houses occupied by them and located upon Com p la inan ts’ fa rm land. C om plainants charge and show unto the Court th a t they had today, June 1, 1965, procured itineran t rep lacem en t labor to w ork the crops, but th a t due to the loud shouts, ca t calls, jee rs and abusive language by D efendants pa rtic i pating in the picketing, who gathered in large num bers, said rep lacem ent labor w as in tim idated, th rea tened , and consequently out of fe a r and ap prehension left C om plainants’ fields and a re unwill ing to re tu rn to w ork as long as such in terference continues from the p icketers. C om plainants charge th a t the actions of the D efendants today constitutes an illegal and unlaw ful exercise of the right of peace able picketing, and amounts to an unlaw ful depriva tion of C om plainants’ rights, an illegal in terference w ith th e ir property rights safeguarded by law , and 34 C om plainants show th a t unless D efendants a re en joined by order of this Court which will define the perm issib le lim its of peaceable picketing and order ing the term s under which peaceful p icketing m ay be carried out, D efendants will continue to engage in th e ir illegal actions from day to day and thereby accom plish an unlaw ful purpose of destroying the righ t of C om plainants to cultivate, m ake and h a rv est th e ir 1965 crops, and to contract w ith other individ uals for the purpose of doing so. These continuing actions on the p a rt of D efendants known to them to be illegal and co n tra ry to law continue t 0 con-, s titu te irrep a rab le in jury to the righ ts of Com plain an ts and only the aid of a Court of equity by w ay of injunction will p reven t irrep a rab le in jury to Com plainants. C om plainants show th a t none of the De fendants a re solvent or capable of responding in dam ages to Com plainants for the loss p roxim ately caused by the ir actions, so th a t Com plainants have no full, com plete or adequate rem edy a t law in the prem ises. W herefore, P rem ises Considered, Complainants p ray th a t the Court will, im m ediately upon the filing of th is original bill, t r e a t the sam e prelim inarily as an application for the issuance of an injunction, w ithout notice, against the D efendants and any and all of them , and any and all persons, agents, re p re sentatives, and organizations acting in concert w ith them in te rm s as follows: (1) A p re lim inary m andatory injunction, a ffirm a tive in character, requiring all of the individual D e fendants, who are! ex-em ployees of the Com plain 35 ants, to im m ediately v aca te from the houses located on C om plainants’ fa rm lands and to im m ediately rem ove therefrom their fam ilies, p roperty and p e r sonal effects; and upon the ir fa ilu re so to do, the Sheriff shall im m ediately ev ict them ; (2) An injunction prohibitory in ch arac te r req u ir ing and com m anding the said individual D efendants, who a re ex-employees of C om plainants, not to re enter the fa rm prem ises or any house, barn, shed, p riva te way, private easem ent, or o ther part of Com plainan ts’ fa rm lands, exclusive of public roads, for any purposes w hatsoever until fu rth er order of this Court; (3) An injunction prohibitory in ch arac te r against all o ther D efendants th an the individual Defendants who a re ex-employees of C om plainants, and their agents, represen tatives, confederates, and all other persons acting in concert w<ith them, not to re-enter the fa rm prem ises or any house, barn , shed, private way, p riva te easem ent, or other p a rt of Complain an ts’ fa rm lands, exclusive of public roads, for any purposes w hatsoever un til fu rth e r o rder of th is Court; (4) An injunction prohibitory in character re strain ing and enjoining any and all of the D efend ants and all agents, persons, and organizations act ing in concert w ith them from d irectly or 'indirectly th rea ten ing , intim idating, or coercing, e ither by words or conduct, the Com plainants, and other en r ol ovees still working on th e ir said farm property , and any other persons employed by C om plainants to work 36 on th e ir farm property , th a t th is injunction shall con tinue in full force and effect until the fu rth er o rder of th is Court; , (5) An injunction prohibitory in c h a rac te r re strain ing the D efendants and all other persons, rep resen ta tives and organizations acting in concert w ith them , until the fu r th e r o rder of this Court, from en gaging in or employing any conduct or w ords am ount ing to coercion or ‘intim idation as an incident to picketing, specifically prohibiting all loud language, cat-calls, jee rs , unru ly and boisterous conduct on the part of the p icketers, as well as d irec t th re a ts of violence and bodily h a rm , e ither to C om plainants, and other employees, or any persons engaged by Com plainants to w ork on th e ir said farm lands, or o ther m em bers of the public; to prohibit any persons picketing from getting on any p a rt of the fa rm lands of Com plainants, including any house, barn , shed, other fa rm building, or on any priva te w ay or p ri vate easem en t ap p u rtenan t thereto , exclusive of pub lic roads; to prohibit picketing in unreasonably large num bers, as defined by the o rder of the Court; and to prohibit sa id p icketers from blocking or im peding use of the public road and free, easy and open access upon and from all of the properties owned by Com plainan ts as aforesaid. And, on final hearing, th a t said p re lim inary in junctions as m ay be issued by the Court m ay be m ade final and perpetual. If C om plainants have p rayed for w rong or im proper re lief then they pray f o r all of the full re lief th a t they a re in law and equity entitled. 37 As in Duty Bound, Com plainants will ever pray . KEADY, CAM PBELL & DeLONG, By W. C. READY, Solicitors for Com plainants. S tate of M ississippi, County of W ashington. P ersonally appeared before m e, the undersigned N otary Public, (in and for the S tate and County afore said, A. L. Andrews, one of Com plainants, who afte r firs t being duly sworn, stated on oath th a t he has read the foregoing bill of complaint; that the allega-< tions there in contained are true and correct except as to such allegations m ade on inform ation and be-i lief he believes to be true according to his best knowl edge, inform ation and belief. A. L. ANDREWS, (A. L. A ndrew s). Sworn To and subscribed before me, this 1st day of June, 1965. [ILLEGIBLE] (Seal) Notary Public. My Com m ission E xpires: 10-20-65. Chancellor’s F ia t. #25,861. To the C lerk of the Chancery Court of W ashington County, M ississippi: You are hereby D irected and O rdered t 0 issue the w rit of p re lim inary injunction as p rayed for in the 38 foregoing bill of complaint, except th a t any p icket ing conducted by the D efendants or any of them shall be held in accordance w ith the following: (1) P ersons picketing shall not exceed four in num ber a t any one time and shall w alk only along the sides of the public road in fron t of farm head q u arte rs , so as not to im pede, block, or otherw ise in te rfe re w ith tra ffic upon said public road; (2) Picketing shall be conducted only in a quiet and orderly m anner a t all tim es; (3) Each person picketing shall be allowed to carry one sign, the size of said sign not to exceed 30 inches by 30 inches, so long as the m a tte r or m a te ria l displayed upon said dign is such as is calculated to persuade only, and is not otherw ise unlawful. 'Complainant shall en ter into and file bond in the am ount of F ive Thousand D ollars ($5,000.00), prior to issuance of w rit of injunction. O rdered, Adjudged and D ecreed this, the 1st day of June, 1965. (S.) S. B. THOMAS, (Seal) Chancellor. #25861. S tate of M ississippi, County of W ashington. I, W. L. Kent, C lerk of the Chancery Court in and for said County and S tate hereby certify that the w ithin and foregoing instrum ent is a tru e and correct 39 copy of C hancellor’s F ia t as the sam e app ears on file and of record in C hancery M inute Book #-6& page 21 of the records in m y office, a t G reenville, Miss. W itness m y hand and official seal, th is the 11 day of June A. D., 1965. W. L. KENT, Clerk of Chancery Court of Washington County, Miss., By M. F. WILSON, (Seal) D. C. EXHIBIT A-l. M ay 31, 1965 Jam e s G reen Route 1 Leland, M ississippi D ear Jam es: Since the beginning of th is crop y ear you have been employed by Andrews B ro thers P lantation, a p a r t nership, consisting of W. B. Andrews and A. L. A ndrew s, as a fa rm day laborer working for wages fixed a t $6.00' per day plus a house on our farm dur ing the period of your em ploym ent. L ast Saturday, M ay 29, 1965, you w ere paid your wages due you for the preceding w eek’s work. Today, M onday, May 31, 1965, a t the beginning of the w ork day, you refused to go to w ork unless you w ere paid higher w ages. The w rite r thereupon told you tha t you would w ork just like you had been working or th e re would be no w ork a t all for you. When you refused to work, the 40 w rite r notified you th a t he w as dem anding posses sion of the house w hich you occupy. This afternoon a t approx im ate ly 3:00 o’clock P.M. my atto rney , W. C. Keady, w ith my consent and ap proval, again gav’e you an opportunity e ither to re tu rn to w ork or to vacate the house. A t th a t tim e you w ere notified th a t you had the bight to s trike if you so desired but th a t unless you re tu rn ed to w ork im m ediately the em ploym ent w as te rm in a ted . A fter consideration you advised m e and my a tto rney that you w ere not going to re tu rn to work. Thereupon, possession of the house you occupy w as again de m anded. The object of th is le tte r is to notify you in writing th a t the em ploym ent re la tions existing betw een us has been term inated , effective im m ediately, and you a re hereby notified to im m ediately quit and vacate from the house th a t you occupy on our p roperty and get off of our fa rm lands. Y our fu rth er presence on our fa rm property will co n stitu te ,a tresp ass . Yours very tru ly , ANDREW S BROTHERS PLANTATION, By A. L. ANDREWS, (A. L. A ndrew s), P a rtn e r . 41 EXHIBIT A-2. W allice G reen Route 1 Leland, M ississippi D ear Wallice: Since the beginning of th is crop year you have been employed by A ndrew s B ro thers P lan ta tion , a p art nership, consisting of W. B. A ndrew s and A. L. Andrews, as a fa rm day labo rer working for w ages fixed a t $6.00 per day plus a house on our fa rm du r ing the period of your em ploym ent. Last Saturday, May 29, 1965, you w ere paid your w ages due you for the preceding w eek’s work. Today, M onday, M ay 31, 1965, a t the beginning of the w ork day, you refused to go to w ork unless you w ere paid higher wages. The w rite r thereupon told you th a t you would work just like you had been w orking or th e re would be no w ork a t all for you. When you refused to work, the w rite r notified you tha t he w as dem anding posses sion of the house which you occupy. This afternoon a t approxim ately 3:00 o’clock P.M. my attorney , W. C. Keady, w ith m y consent and ap proval, again gave you an opportunity e ither to re tu rn to w ork or to vaca te the house. At th a t time you w ere notified that you had the right to s trike if you so desired but th a t unless you re tu rned to work im m ediately the em ploym ent w as term inated . A fter consideration you advised m e and m y atto rney th a t you w ere not going to re tu rn to work. Thereupon, possession of the house you occupy w as again de manded. V I M ay 31, 1965 42 The object of th is le tte r is to notify you 'in w riting th a t the em ploym ent re la tion existing betw een us has been te rm in a ted , effective im m ediately, and you a re hereby notified to im m ed ia te ly quit and vacate from the house th a t you occupy on our property and get off of our farm lands. Y our fu rth e r presence on our fa rm p roperty will constitu te a tresp ass . Yours very tru ly , ANDREWS BROTHERS PLANTATION, By A. L. ANDREWS, (A. L. A ndrew s), P a rtn e r. EXHIBIT A-3. T. B. G reen Route 1 Leland, M ississippi M ay 31, 1965 Dear T. B.: Since the beginning of th is crop y ear you have been em ployed by A ndrew s B ro thers P lantation, a p a r t nership , consisting of W. B. A ndrew s and A. L. A ndrew s, as a farm day labo rer working for w ages fixed a t $6.00 p e r day plus a house on our farm du r ing the period of your em ploym ent. L ast Saturday, M ay 29, 1965, you w ere paid your wages due you for the preceding w eek’s work. Today, M onday, M ay 31, 1965, at the beginning of the w ork day, you refused fo go to w ork unless you w ere paid h igher wages. The w rite r thereupon to ld you th a t you would work 43 ju s t like you had been working or th e re would be no work a t all for you. W hen you refused to work, the> w rite r notified you that he w as dem anding posses sion of the house w hich you occupy. This afternoon at approxim ately 3:00 o’clock P. M. m y attorney , W. C. K eady, w ith m y consent and ap proval, again gaye you an opportunity e ither to re tu rn to w ork or to v aca te the house. At th a t time you w ere notified th a t you had the rig h t to s trike if you so desired but th a t unless you re tu rn ed to w ork im m ediately the em ploym ent was term inated . A fter consideration you advised m e and m y a tto rney that you w ere not going to re tu rn to work. Thereupon, possession of the house you occupy w as again de manded. The object of th is le tte r is to notify you in w riting that the em ploym ent re la tion existing betw een us has been term inated , effective 'im m ediately, and you a re hereby notified to im m ediately quit and vacate from the house th a t you occupy on our p roperty and get off of our farm lands. Your fu rth e r presence on our farm property will constitu te a trespass. Yours very tru ly , ANDREWS BROTHERS PLANTATION, By A. L. ANDREWS, (A. L. A ndrew s), P a rtn e r . 44 EXHIBIT A-4. W illiam E a r l M artin Route 1 Leland, M ississippi M ay 31, 1965 D ear W illiam E arl; Since the beginning of th is crop y ear you have been employed by A ndrew s B ro thers P lan ta tion , a p a rt nership , consisting of W. B. A ndrew s and A. L. Andrews, as a fa rm day lab o re r working for w ages fixed a t $5.50 p er day plus a house on our fa rm dur ing the period of your employment. Last S aturday , M ay 29, 1965, you w ere paid your wages due you for the preceding w eek’s work. Today, M onday, May 31, 1965, a t the beginning of the w ork day, you refused to go to w ork unless you w ere paid higher wages. The w rite r thereupon told you tha t you would w ork just like you had been w orking jor there would be no w ork at all for you. W hen you refused to work, the w rite r notified you th a t he w as dem anding posses sion of the house which you occupy. This afternoon a t approx im ate ly 3; 00 o’clock P. M. m y atto rney , W. C. K eady, w ith my consent and ap proval, again gave you an opportunity e ither to re tu rn to w ork or to vacate the house. At th a t tim e you were' notified th a t you had the rig h t to s trik e if you so desired but th a t unless you re tu rned to w ork Im m ediately the em ploym ent w as term inated . A fter consideration you advised me and m y a tto rn ey th a t you v/ere not going to re tu rn to work. Thereupon, possession of the house you occupy was again de-* m anded. 45 The object of th is le tte r is to notify you in writing th a t the em ploym ent relations existing betw een us has been te rm ina ted , effective im m ediately, and you are hereby notified to 'im m ediately quit and vacate from the house th a t you occupy on our property and get off of our fa rm lands. Y our fu rth e r presence on our fa rm property will constitute a trespass. Yours very tru ly , ANDREWS BROTHERS PLANTATION, By A. L. ANDREWS, (A. L. A ndrew s), P a rtn e r. EXHIBIT A-5. John H. Sylvester Route 1 Leland, M ississippi M ay 31, 1965 D ear John: Since the beginning of th is crop year you have been employed by A ndrew s B ro thers P lantation , a p a r t nership, consisting of W. B. Andrews and A. L. Andrews, as a farm day laborer working for wages fixed a t $6.00 per day plus a house on our fa rm du r ing the period of your em ploym ent. L ast Saturday, M ay 29, 1965, you w ere paid your wages due you for the preceding w eek’s work. Today, Monday, May 31, 1965, a t the beginning of the w ork day, you refused to go to w ork unless you w ere paid h igher w ages. The w rite r thereupon told you th a t you would work 46 ju s t like you had been working or there would be no w ork a t all for you. W hen you refused to work, the w rite r notified you tha t he w as dem anding posses sion of the house w hich you occupy. This afternoon a t approx im ate ly 3:00 o’clock P. M. m y attorney, W. C. Keady, w ith my consent and ap proval, again gave you an opportunity e ither to re tu rn to w ork or to vacate the house. At th a t tim e you w ere notified th a t you had the right to s trike 'if you so desired but th a t unless you re tu rn ed to w ork im m ediately the em ploym ent w as term inated . A fter consideration you advised me and m y attorney th a t you w ere not going to re tu rn to work. Thereupon, possession of the house you occupy w as aga'in de m anded. The object of th is le tte r is to notify you in w riting th a t the em ploym ent re la tion existing betw een us has been te rm in a ted , effective im m ediately, and you a re hereby notified to im m ediately quit and vacate from the house that you occupy on our property and get off of our fa rm lands. Your fu rth e r presence on our fa rm property w ill constitu te a tresp ass . Yours very tru ly , ANDREWS BROTHERS PLANTATION, By A. L. ANDREWS, (A. L. A ndrew s), P a rtn e r. 47 EXHIBIT A-6. Jam es M artin , J r . Route 1 Leland, M ississippi D ear Jam es M artin: Since the beginning of th is crop y ear you have been em ployed by Andrews B ro thers P lan ta tion , a p a r t nership, consisting of W. B. A ndrew s and A. L. Andrews, as a farm day lab o re r working for wages fixed a t $6.00 per day plus a house on our farm d u r ing the period of your em ploym ent. Last S aturday , M ay 29, 1965, you w ere paid your w ages due you for the preceding w eek’s work. Today, M onday, M ay 31, 1965, a t the beginning of the w ork day, you refused to go to w ork unless you w ere paid h igher wages. The w rite r thereupon told you th a t you would w ork ju s t like you had been working or there would be no w ork a t all for you. W hen you refused to work, the w rite r notified you th a t he w as dem anding posses sion of the house which you occupy. This afternoon a t approxim ately 3:00 o’clock P. M. mv attorney , W. C. K eady, with’ m y consent and at>- proval, again gave you an opportunity e ither to re tu rn to w ork or to vacate the house. At th a t time you w ere notified th a t you had the rig h t to strike if you so desired but th a t unless you re tu rn ed to w ork 'im m ediately the em ploym ent w as term inated . A fter consideration you advised m e and my a tto rney that you w ere not going to re tu rn to work. Thereupon, possession of the house you occupy w as again de m anded. .M ay 31, 1965 48 The object of this le tte r is to notify you in w riting th a t the em ploym ent re la tion existing betw een us has been te rm in a ted , effective im m ediately, and you are hereby notified to im m edia te ly quit and vacate from the house th a t you occupy on our property and get off of our fa rm lands. Your fu rth e r presence on our fa rm property will constitute a trespass. Yours very tru ly , ANDREWS BROTHERS PLANTATION, By A. L. ANDREWS, (A. L. A ndrew s), P a rtn e r. EX H IBIT A-7. G erther Lee M artin Route 1 Leland, M ississippi May 31, 1965 D ear G erther Lee: Since the beginning of th is crop year you have been em ployed by Andrews B ro thers P lantation, a p a rt nership, consisting of W. B. Andrews and A. L. Andrews, as a farm d ay labo rer working for wages fixed a t $6.00 per day plus a house on our fa rm du r ing the period of your em ploym ent. L ast Saturday, May 29, 1965, you w ere paid your wages due you for the preceding w eek’s work. Today, M onday, M ay 31. 1965, a t the beginning of the w ork day, you refused to go to w ork unless you w ere paid higher w ages. The w hiter thereupon told you th a t you would w ork just like you had been working or there would be no 49 w ork a t all for you. W hen you refused to work, the w rite r notified you th a t he was dem anding posses sion of the house w hich you occupy. This afternoon at approxim ately 3:00 o’clock P. M. m y attorney, W. C. K eady, w ith m y consent and ap proval, again gave you an opportunity e ither to re tu rn to w ork or to v aca te the house. At th a t time you w ere notified th a t you had the righ t to s trike if you so desired but tha t unless you re tu rn ed to w ork im m ediately the em ploym ent was te rm in a ted . A fter consideration you advised m e and m y a tto rney th a t you w ere not going to re tu rn to work. Thereupon, possession of the house you occupy w as again de m anded. The object of this le tte r is to notify you in w riting th a t the em ploym ent relation existing betw een us has been term inated , effective im m ediately, and you are hereby notified to im m ediately quit and vacate from the house th a t you occupy on our p roperty and get off of our fa rm lands. Your fu rth e r presence on our fa rm property will constitu te a trespass. Y ours very tru ly , ANDREWS BROTHERS PLANTATION, By A. L. ANDREWS, (A. L. Andrews), P a rtn e r. 50 EXHIBIT A-8. W allace G reen, J r . Route 1 Leland, M ississippi May 31, 1965 D ear W allace: Since the beginning of the crop y ear you have been employed by Andrews B ro thers P lantation , a p a r t nership , consisting of W. B. Andrews and A. L. Andrews, as a fa rm day laborer working for wages fixed a t $6.00 per d ay plus a house on our farm du r ing the period of your em ploym ent. L ast Saturday, M ay 29, 1965, you w ere paid your wages due you for the preceding w eek’s work. Today, M onday, May 31, 1965, at the beginning of the w ork day, you refused to go to w ork unless you w ere paid higher wages. The w rite r thereupon told you th a t you would work ju s t like you had been working or there would be no w ork a t all for you. W hen you refused to work, the w rite r notified you th a t he w as dem anding posses sion of the house which you occupy. This afternoon a t approxim ately 3:00 o’clock P.M . my attorney, W. C. K eady, w ith m y consent and ap proval. again gave you an opportunity e ither t 0 re tu rn to w ork or to vacate the house. At th a t time you w ere notified th a t you had the righ t to strike if you so desired but th a t unless you re tu rn ed to w ork im- m ed ia telv the em ploym ent w as te rm ina ted . A fter consideration you advised m e and my attorney th a t von w ere not going to re tu rn to work. Thereupon, possession of the house you occupy w as again de m anded. 51 The object of th is T etter is to notify you in w riting that the em ploym ent re la tion existing betw een us has been term inated , effective im m ediately , and you a re hereby notified to im m ediately quit and vacate from the house th a t you occupy on our p roperty and get off of our fa rm lands. Your fu rth e r presence on our fa rm p roperty will constitute a trespass. Yours very tru ly , ANDREWS BROTHERS PLANTATION, By A. L. ANDREWS, (A. L. A ndrew s), P a rtn e r. EXHIBIT A-9. M ay 31, 1965 Clarence Sylvester R oute 1 Leland, M ississippi D ear Clarence: Since the beginning of th is crop y ear you have been em ployed by A ndrew s B rothers P lan ta tion , a part nership, consisting of W. B. Andrews and A. L. Andrews, as a farm day labo rer working for wages fixed a t $6.00 per day plus a house on our farm du r ing the period of your em ploym ent. L ast Saturday, May 29, 1965, you w ere paid your w ages due you for the preceding w eek’s work. 'Today, Monday, May 31, 1965, a t the beginning of the w ork day, you refused to go to w ork unless you w ere paid h igher wages. 52 The w rite r thereupon told you th a t you would w ork ju s t like you had been working or th e re would be no w ork a t all for you. When you refused to work, the w rite r notified you th a t he w as dem anding posses sion of the house which you occupy. This afternoon at approx im ately 3:00 o’clock P. M. m y atto rney , W. C. K eady, w ith m y consent and ap proval, again gave you an opportunity e ither to re tu rn to w ork or to vacate the house. At th a t time you w ere notified th a t you had the right to s trike if you so desired but th a t unless you re tu rn ed to w ork im m ediately the em ploym ent was te rm in a ted . A fter consideration you advised m e and m y a tto rney th a t you w ere not go'ing to re tu rn to work. Thereupon, possession of the house you occupy w as again de manded. The object of this le tte r is to notify you in w riting th a t the em ploym ent relation existing betw een us has been term inated , effective im m ediately , and you a re hereby notified to im m ediately quit and vacate from the house th a t you occupy on our property and get off of our fa rm lands. Y our fu rth e r presence on our fa rm property will constitute a tresp ass . Yours very tru ly , ANDREWS BROTHERS PLANTATION, By A. L. ANDREWS, (A. L. A ndrew s), P a rtn e r . 53 EX H IB IT A-10. M ack Ingram Route 1 Leland, M ississippi M ay 31, 1965 D ear M ack: Since the beginning of th is crop y ear you have been em ployed by Andrews B ro thers P lantation, a p a r t nership, consisting of W. B. A ndrew s and A. L. Andrews, as a farm day lab o re r working for wages fixed a t $6.00 p er day plus a house on .ou r fa rm dur-i ing the period of your em ploym ent. Last S aturday , M ay 29, 1965, you w ere paid your w ages due you for the preceding w eek’s work. Today, Monday, May 31, 1965, a t the beginning of the w ork day, you refused to go to w ork unless you w ere paid Higher w ages. The w rite r thereupon told you th a t you would w ork ju s t like you had been w orking or th e re would be no w ork a t all for you. W hen you refused to work, the w rite r notified you th a t he w as dem anding posses sion of the house which you occupy. This afternoon a t approx im ately 3:00 o’clock P. M. my atto rney , W. C. Keady, w ith m y consent and ap proval, again gave you an opportunity e ither to re tu rn to w ork or to v aca te the house. A t th a t time you w ere notified th a t you had the right to s trike if you so desired but th a t unless you re tu rn ed to w ork im m ediately the em ploym ent w as term inated . A fter consideration you advised m e and my a tto rney th a t you w ere not going to re tu rn to work. Thereupon, possession of the house you occupy w as again de manded. 54 The object of th is le tte r is to notify you in writing: th a t the em ploym ent re la tion existing betw een us has been te rm ina ted , effective 'im m ediately, and you are hereby notified to im m ediately quit and vacate from the house that you occupy on our p roperty and get off of our fa rm lands. Y our fu rth e r presence on our fa rm property will constitute a trespass. Y ours very tru ly , ANDREW S BROTHERS PLANTATION, By A. L. ANDREWS, (A. L. A ndrew s), P a rtn e r . EXHIBIT A -ll. M ay 31, 1965 Johnnie Johnson, J r . Route 1 Leland, M ississippi D ear Johnnie: ; Since the beginning of th is crop y ear you have been em ployed by Andrews B ro thers P lan tation , a part- nership , consisting of W. B. Andrews and A. L. Andrews, as a fa rm day lab o re r working for w ages fixed a t $6.00 per day plus a house on our fa rm du r ing the period of your employment. L ast Saturday, May 29, 1965, you w ere paid your w ages due you for the preceding w eek’s work. Today, Monday, M ay 31, 1965, a t the beginning of the w ork day, you refused to go to w ork unless you w ere paid h igher wages. 55 The w rite r thereupon told, you th a t you would w ork ju s t like you had been working or there would be no w ork a t all for you. W hen you refused to work, the w rite r notified you th a t he w as dem anding posses sion of the house w hich you occupy. This afternoon a t approxim ately 3:00 o’clock P. M. my attorney , W. C. Keady, w ith m y consent and ap proval, again gave you an opportunity e ither to re tu rn to w ork or to v aca te the house. At th a t tim e you w ere notified th a t you had the right to s trik e if you so desired but that unless you re tu rn ed to w ork im m ediately the em ploym ent w as te rm in a ted . A fter consideration you advised m e and my a tto rney th a t you w ere not going to re tu rn to work. Thereupon, possession of the house you occupy w as again de m anded. The object of th is le tte r is to notify you in w riting th a t the em ploym ent re la tion existing betw een us has been te rm in a ted , effective im m ediately, and you a re hereby notified to im m ediately quit and vacate from the house that you occupy on our property and get off of our fa rm lands. Your fu rth er p resence on our farm p roperty will constitu te a trespass. Yours very truly, ANDREWS BROTHERS PLANTATION, By A. L. ANDREWS, (A. L. A ndrew s), P artn e r. 56 EXHIBIT A-12. M ay 31, 1965 George Lee M artin Route 1 Leland, M ississippi D ear George Lee: Since the beginning of th is crop y ear you have been employed by A ndrew s B ro thers P lan ta tion , a p a rt nership, consisting of W. B. A ndrew s and A. L. Andrews, as a fa rm day lab o re r working for w ages fixed a t $5.50' p er day plus a house on our farm dur-‘ ing the period of your em ploym ent. L ast Saturday, May 29, 1965, you w ere paid your w ages due you for the p receding w eek’s work. Today, M onday, M ay 31, 1965, a t the beginning of the w ork day, you refused to go to w ork unless you w ere paid higher wages. The w rite r thereupon told you th a t you would w ork ju s t like you had been w orking or th e re would be no w ork a t all for you. W hen you refused to work, the w rite r notified you th a t he w as dem anding posses sion of the house which you occupy. This afternoon a t approxim ately 3:00 o’clock P. M. my attorney , W. C. K eady, w ith my consent and ap proval, again gave you an opportunity e ither to re tu rn to w ork or to vaca te the house. At tha t tim e you w ere notified th a t you had the righ t to strike if you so desired but that unless you re tu rn ed to w ork im m edia tely the em ploym ent w as te rm ina ted . A fter consideration you advised me and my a tto rney th a t you w ere not going to re tu rn to work. Thereupon, possession of the house you occupy w as again de m anded. 57 The object of th is le tte r is to notify you in w riting that the em ploym ent re la tions existing betw een us has been term inated , effective im m ediately , and you a re hereby notified to im m ediately quit and vacate: from the house th a t you occupy on our property and get off of our fa rm lands. Your fu rth e r presence on our fa rm property will constitu te a trespass. Y ours very tru ly , ANDREW S BROTHERS PLANTATION, By A. L. ANDREWS, (A. L. A ndrew s), P a rtn e r. EXHIBIT “B ” . Mr. A. L. A ndrew s Leland M ississippi May 31, 1965 D ear Sir: The undersigned rep resen ting your em ployees give notice they intend to p ro tec t the ir property righ ts in th e ir homes through judicial proceedings by law. N am es Jam es G reen Wallice G reen T. B. G reen W illiam E a r l M artin John H. Sylvester Jam e s M artin , J r . G erther Lee M artin W allace G reen, J r . C larence Sylvester M ack In g ram Johnnie Johnson, J r . George Lee M artin State of M ississippi, County of W ashington. I, W. L. Kent, C lerk of the Chancery Court in and for sa id County and S tate hereby certify th a t the w ithin and foregoing in s tru m en t is a tru e and cor re c t copy of O riginal Bill of Com plaint, Chancel lor’s Fiat & Exhibits A1-A12 Inc. & Exhibit B as the same appears filed in C hancery Docket Book 36 page 305 of the records in m y office, a t G reenville, Miss. W itness my hand and official seal, th is the 11 day of June A. D., 1965. W. L. KENT, Clerk of the Chancery Court of W ashington County, Miss., By M. F . WILSON, D. C. 58 (Seal) 59 COMPLAINANTS’ EXH. °2. In the C hancery Court of W ashington County, Mis* sissippi, in Vacation, 1965. A. L. A ndrew s, R uth Coleman A ndrew s, and W. B. A ndrew s, C om plainants, vs. Cause No. 25861. Jam es G reen, W allice G reen, T. B. G reen, W illiam E a r l M artin, John H. Sylvester, Jam es M artin , Jr.> G erther Lee M artin, W allace G reen, J r . , Clar-. ence Sylvester, Mack Ingram , Johnnie Johnson, J r ., George Lee M artin, Vince F e rra r , P a t Vail, Steve Dunlop, L arry W alker, and Sam Apple- white, and 'Council of F ed era ted Organizations, D elta M inistry, and M ississippi Freedom Demo cra tic P a rty , W ashington County C hapter, De fendants. In junction Bond. Know All. Men by These P resen ts: T hat We, A. L. Andrews, R uth Coleman A ndrew s, and W. B. An drew s, P rincipals, and E. E. Cooper, D. B. F lanagan and J. M. Dean, Sureties, do hereby bind ourselves, our heirs, legatees and personal rep resen ta tives, un to Jam es G reen, W allice G reen, T. B. G reen, W illiam E arl M artin, John H. Sylvester, Jam es M artin, J r ., G erther Lee M artin, Wallace G reen, J r ., C larence Sylvester, M ack Ingram , Johnnie Johnson, J r ., George Lee M artin, Vince F e rra r , P a t Vail, S teve Dunlop, L a rry W alker and Sam Applewhite, and Council of F edera ted O rganizations, D elta M inistry, and M ississippi Freedom Democratic P a rty , W ash 6b ington County C hapter, Obligees, in the penal sum of $5,000.00. The Condition of th is bond is th a t, w hereas, the above bounden Principals have applied to the Chan cery Court of W ashington County, M ississippi, in vacation, for the issuance, w ithout notice, of a p re lim inary injunction, both m andatory and prohibi tory against the above nam ed Obligees. Now, Therefore, if said injunction shall be a t any time declared to be w rongfully issued by a C ourt of com petent jurisdiction, the condition of th is bond is that the above bounden principals and th e ir sureties shall pay all dam ages resu lting from the wrongful issuance of said injunction; otherw ise th is bond shall be void and of no effect. W itness Our S ignatures this, the 1st day of June, 1965. A. L. ANDREWS, RUTH COLEMAN 'ANDREW S, W. B. ANDREWS, Principals, By A. L. ANDREWS, (A. L. Andrews), M anaging 'P a rtn e r of An drew s B ro thers P la n ta tion. (S.) E . E. COOPER, (S.) D. B. FLANAGAN, (S.) J . M. DEAN, Sureties. 61 The Foregoing Bond is approved by m e, this, the 1st day of June, 1965. (S.) W. L. KENT, (W. L. K ent), C hancery Clerk. S tate of M ississippi, County of W ashington. I, W. L. Kent, C lerk of the Chancery Court (in and for said County and S tate hereby certify th a t the w ithin and foregoing in s tru m en t is a true and cor rec t copy of Injunction Bond as the sam e appears on file and of record in Chcy M inute Book 69 page 21 of the records in my office, at G reenville, Miss. W itness m y hand and official seal, th is the 11 day of June A.D., 1965. W. L. KENT, (Seal) C lerk of Chancery Court of Washington County, Miss., By M. F. WILSON, D. C. 62 COMPLAINANTS’ EXH. #S . In the C hancery Court of W ashington County, Mis sissippi, 'in V acation, 1965. A. L. A ndrew s, R uth Coleman Andrews, and W. B. Andrews, Com plainants, vs. Cause No. 25861. Jam es G reen, Wallice G reen, T. B. G reen, W illiam E a rl M artin, John H. Sylvester, Jam e s M artin , J r . , G erther Lee M artin, W allace G reen, J r ., Clar ence Sylvester, M ack Ingram , Johnnie Johnson, J r . , George Lee M artin, Vince F e rra r , P a t Vail, Steve Dunlop, L a rry W alker, and Sam Apple- white, and Council of F ed e ra ted O rganizations, Delta M inistry, and M ississippi F reedom Demo cra tic P a rty , W ashington County C hapter, De fendants. W rit of Injunction. To: All of the D efendants Above Named: W hereas, ;A. L. Andrews, R uth Colem an Andrews, and W. B. Andrews, as C om plainants, have filed the ir bill in the above Court against you praying for a p re lim inary injunction, both m an dato ry and prohibi tory; and W hereas, the Honorable S. B. Thomas, Judge of the C hancery Court of W ashington County, M ississippi, has th is da te in said cause, by o rder en tered th is date, has directed th a t said injunction issue against you as p rayed for in said original bill of complaint and as 63 fu rth er specified in said order, said in ju n c tio n having issued upon the posting of bond in the am ount of $5,000.00, as set by said order, and conditioned ac cording to law ; Now, Therefore, you a re hereby enjoined and com m anded as follows: (1) The above nam ed D efendants, nam ely, Jam es G reen, W allice G reen, T. B. G reen, W illiam E arl M artin, John H. Sylvester, Jam es M artin, J r ., Ger- ther Lee M artin, W allace G reen, J r . , C larence Syl vester, Mack Ingram , Johnnie Johnson, J r . , and George Lee M artin, form erly em ployees of said C om plainants, shall im m ediately vacate from the houses located on Com plainants’ fa rm lands as de scribed in the bill of com plaint and immediately re m ove therefrom th e ir fam ilies, p roperty and p er sonal effects; (and upon th e ir fa ilu re to do so in stan t- e r , the Sheriff of W ashington County, M ississippi, or his authorized deputy, shall be and hereby is d irec ted to evict them im m ediately. (2) The D efendants, Jam es G reen, W allice G reen, T. B. G reen, W illiam E arl M artin , John H. Sylvester, Jam es M artin, J r ., G erther Lee M artin , W allace G reen, J r ., C larence Sylvester, Mack Ingram , John nie Johnson, J r . , and George Lee M artin , shall not re-en ter the fa rm prem ises or any house, barn , shed, p riva te way, private easem ent, or other p a r t of Com p la inan ts’ farm lands, exclusive of public roads only, for any purposes w hatsoever, until the fu rth er order of th is Court. 64 (3) All D efendants above nam ed and the ir agents, rep resen ta tives, confederates, and all other persons acting i n ' concert w ith them shall not en ter or re-en te r the fa rm prem ises or any house, barn, shed, p ri vate way, p rivate easem en t or o ther p a rt of Com p la in an ts’ farm lands, exclusive of public roads only, for any purposes until the fu rth er order of this Court. 4. All D efendants above nam ed and all agents, persons and organizations acting in concert w ith them a re prohibited from e ith e r d irectly or indirectly th rea ten ing , intim idating or coercing, e ither by w ords or conduct, the C om plainants, A. L. Andrews, R uthiC olem an A ndrew s, and W. B. Andrews, or other em ployees of Com plainants still working on said farm lands, or any other persons em ployed by Com plain ants to w ork on th e ir farm property , and th is injunc tion shall continue in full force and effect until the fu rth er order of th is Court. 5. All D efendants herein nam ed and all other per sons, rep resen ta tiv es and organizations acting in concert w ith them are, until the fu rth e r o rder of this Court, prohibited from engaging in or em ploying any conduct or w ords am ounting to coercion or in tim i dation as an incident to picketing and they are spe cifically prohibited from using loud language, cat calls, jee rs , unruly and boisterous conduct, as well as d irect th rea ts of violence and bodily harm e ither to Com plainants, and other employees, or any person engaged by C om plainants to w ork on th e ir fa rm lands n ear T ribbett, M ississippi, or m em bers of the public; and D efendants or o ther persons, agen ts or organizations acting in concert w ith them are pro 65 hibited from getting on any p a rt of the farm lands of Com plainants, including any house, barn , shed, or other farm buildings or p riva te way, or p riva te ease m ent appurtenan t thereto , exclusive of public roads, and all D efendants, or other persons and organiza tions acting in concert w ith them are hereby re s tra ined and prohibited from conducting any picket ing of C om plainants on Com plainants’ aforesaid property , except and unless such picketing complies w ith the following standards: (a) P ersons picketing shall not exceed four in num ber a t any one tim e, and they shall s tand or w alk only along the sides of the public road in front of Com plainants’ fa rm h ead q u arte rs so as not to impede, block or otherw ise in te rfe re w ith tra ffic upon said public road, not m ore than two cars of said picket- e rs to be parked on the side of said public road a t any one tim e. (b) P icketing, if engaged (in, m ust be conducted only in a quiet and orderly m anner a t all times. (c) P ersons picketing shall be allowed to ca rry one sign, not exceeding in size th irty inches by th irty inches, and m ay place thereon prin ted m atte r or m a te ria l calcu lated only to persuade and not otherw ise unlawful. Given under my hand and official seal, this 1st day of June, 1965. (S.) W. L. KENT, (W. L. K ent), C hancery Clerk. To the Sheriff or any Law ful Officer of W ashington County, M ississippi: You Will E xecu te the above w rit of injunction against all D efendants nam ed and m ake your re turn thereof im m ediately to th is office. (S.) W. L. KENT, (W. L. K ent), C hancery Clerk. S tate of M ississippi, County of W ashington. I, W. L. Kent, C lerk of the Chancery Court in and for said County and S ta te hereby certify that the w ith in and foregoing in s tru m en t is a true and correct copy of W rit of Injunction as the sam e appears on file C hancery Docket Book # 3 6 page 305 of the re c ords in m y office, a t G reenville, Miss. W itness my hand and official sea l, this the 11 day of June A.D., 1965. W. L. KENT- (Seal) C lerk of C hancery Court of Washington County, Miss., By M. F. WILSON, D. C. 67 COMPLAINANTS’ EXH. # 4 . In the United States D istrict Court for the N orthern D istric t of M ississippi. O rder. In all cases rem oved to the D istric t Court of the United S tates for the N orthern D istrict of Mississippi, from State Courts the bonds to be filed by rem oving defendant or defendants shall be in the penal sum of $500.00, or such la rg e r am ount as the Clerk of the Court m ay deem proper and necessary , and said: bond shall be w ith good and sufficient su reties and to be approved by the C lerk when the said C lerk is sa tisfied as to the sufficiency of the su re ties th e re on. A copy of this ru le is o rdered spread on the m inutes of the Court a t A berdeen, C larksdale, and Oxford. O rdered this Septem ber 18, 1948. ALLEN COX, United S tates D istric t Judge. Ent. M.B.24, page 839—W estern Division. I hereby certify th a t the foregoing is a true copy of the original thereof now in m y office. A ttest: June 16, 1965. WILLIAM T. ROBERTSON, (Seal) Clerk, By SHIRLEY S. LUMPKIN, D. C. E. S. Upton Printing Co., New Orleans — 61398