Brune File

Case: 45CO1:14-cv-01131-ssr
Document #: 1
Filed: 12/10/2014
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Document #: 1
Filed: 12/10/2014
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Filed: 12/10/2014
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Filed: 12/10/2014
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Document #: 5
Filed: 01/12/2015
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Document #: 5
Filed: 01/12/2015
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Case: 25CI1:14-cv-00680-WLK
Document #: 1
Filed: 11/03/2014
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Document #: 1
Filed: 11/03/2014
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Document #: 4
Filed: 01/06/2015
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Document #: 4
Filed: 01/06/2015
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Document #: 3
Filed: 12/04/2014
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IN THE CIRCUIT COURT OF THE FIRST JUDICIAL DISTRICT

OF HINDS COUNTY, MISSISSIPPI
LINDA BRUNE
APPELLANT
V.
CAUSE NO. 251-14-680CIV
MISSISSIPPI DEPARTMENT OF
EMPLOYMENT SECURITY AND
DOWNTOWN JACKSON PARTNERS
APPELLEES
MOTION TO TRANSFER VENUE

Appellee, Mississippi Department of Employment Security (MDES), by and through
counsel of record, moves this Court pursuant to Mississippi Code Annotated Section 71-5-531,
and Rule 82 of the Mississippi Rules of Civil Procedure for an Order transferring venue to the
Circuit Court of Madison County, Mississippi, and in support of this motion shows this Court as
follows:
1.
Appellant timely filed an appeal in the Circuit Court of the First Judicial District
of Hinds County, Mississippi on November 3, 2014.

2.
Appellant is a resident of Madison County, Mississippi. .
3.
According to Mississippi Code Annotated Section 71-5-531, any aggrieved party
may secure judicial review of a decision by the MDES Board of Review by commencing an
action in the circuit court of the county in which the plaintiff resides.
Emphasis added.
Additionally, the Appellants Board of Review Decision letter states, [A]n appeal may be filed
in the Circuit Court in the county in which you reside by 11/18/2014, which is 20 calendar days
from the date this decision was mailed. Emphasis added.
4.
Therefore, venue is not proper in the Circuit Court of the First Judicial District of
Hinds County, Mississippi; and this matter should have been filed with the Madison County
Document #: 3
Filed: 12/04/2014
Page 2 of 3
Circuit Clerks office.

WHEREFORE, PREMISES CONSIDERED Appellee moves this Court for an Order
transferring this case to the Circuit Court of Madison County, Mississippi.
Respectfully Submitted,
MISSISSPPI DEPARTMENT
OF EMPLOYMENT SECURITY
BY:
OF COUNSEL:
Albert Bozeman White
Assistant General Counsel
Mississippi Department of
Employment Security
1235 Echelon Parkway
Post Office Box 1699
Jackson, Mississippi 39213
Telephone:
601.321.6344
Facsimile:
601.321.6076
/s/ Albert Bozeman White

ALBERT BOZEMAN WHITE, MSB 7132
Document #: 3
Filed: 12/04/2014
Page 3 of 3
CERTIFICATE OF SERVICE
I hereby certify that on this day I electronically filed the foregoing Motion to Transfer
Venue with the Clerk of the Court using the MEC system. There are no MEC participants in this
matter; therefore, I hereby certify that I have mailed by United States Postal Service the
document to the following non-MEC participants:
Ms. Linda Brune
6811 Old Canton Rd.
Apt. 1001
Ridgeland, MS 39157-1243
Honorable Winston Kidd
District 7 Circuit Court Judge
P.O. Box 327
Jackson, MS 39205
Sam Begley
Begley Law Firm, PLLC
P.O. Box 287
Jackson, MS 39205
This the 4th day of December, 2014.
/s/ Albert Bozeman White

Albert Bozeman White
Document #: 6
Filed: 02/09/2016
Page 1 of 1
IN THE CIRCUIT COURT OF THE FIRST JUDICIAL DISTRICT

OF HINDS COUNTY, MISSISSIPPI
PLAINTIFF
LINDA BRUNE
vs.
MISSISSIPPI DEPARTMENT OF
EMPLOYMENT SECURITY AND ZACK
DOWNTOWN JACKSON PART
L. e
cAusE No. 251-14-680CIV
FEB -9 2076
CIR
CUITCLERK
DEFENDANT
ORDER GRANTING DEFENDANT'S MOTION TO TRANSFER VENUE

THIS CAUSE came on to be heard on Defendant's Mississippi Department ofEmployment
Security's (MD ES) and Downtown Jackson Partners' Motion to Transfer Venue. Having reviewed
the submissions of the parties and being otherwise thoroughly advised in the premises, the Court
finds that Hinds County, MS is not the proper venue. And that the Court finds that Madison County,
MS would be a proper venue. Therefore, the Court is of the opinion that Defendant's Motion is welltaken, should be granted.
IT IS, THEREFORE, ORDERED and ADJUDGED that the Defendant's Motion to
ttl
Transfer Venue is hereby granted.

SO ORDERED and ADJUDGED, this
day of February, 2016.
l.LL l
WINSTON L. KIDD
CIRCUIT JUDGE

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Case: 45CO1:14-cv-01131-ssr

IN THE CIRCUIT COURT OF THE FIRST JUDICIAL DISTRICT

CAUSE NO. 251-14-680CIV

MOTION TO TRANSFER VENUE

of Hinds County, Mississippi on November 3, 2014.

Appellant is a resident of Madison County, Mississippi. .

According to Mississippi Code Annotated Section 71-5-531, any aggrieved party

Circuit Clerks office.

/s/ Albert Bozeman White

/s/ Albert Bozeman White

IN THE CIRCUIT COURT OF THE FIRST JUDICIAL DISTRICT

cAusE No. 251-14-680CIV

ORDER GRANTING DEFENDANT'S MOTION TO TRANSFER VENUE

Transfer Venue is hereby granted.

day of February, 2016.

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