FILED IS JUN 11 PH 3:46 JOSEPHINE GRIFFIN CHICOT CO. CIRCUIT CLERK odtrosco Pr. IN THE CIRCUIT COURT OF CHICOT COUNTY, ARKANSAS CIVIL DIVISION STATE OF ARKANSAS PLAINTIFF vs. No. cv-2019- 4 TRAVIS L. COLLINS DEFENDANT COMPLAINT FOR REMOVAL NOW COMES the State of Arkansas, and for its complaint for removal against the defendant, states as follows: 1, The Circuit Court of Chicot County, Arkansas, has subject matter jurisdiction and personal jurisdiction in this matter, which is an action for removal of the defendant from public office. 2. The defendant, Travis L. Collins, a resident of Chicot County, Arkansas, was convicted of hot check fraud, a Class C felony, on December 16, 1999, in Saline County, Arkansas. 3. The defendant was subsequently elected as a member of the Board of Directors of the Lakeside School District in Chicot County, Arkansas, and as mayor of the City of Eudora in Chicot County, Arkansas. 4, The defendant continues to serve in the above elective positions, which constitute offices of trust or profit within the State of Arkansas. 5. The defendant's conviction of a felony offense constitutes a conviction of an infamous crime under § 9 of Article 5 of the Arkansas Constitution, and the defendant is accordingly constitutionally ineligible to hold any office of trust or profit within the State of Arkansas. 6. The defendant, Travis L. Collins, should be removed from office as a member of the Board of Directors of the Lakeside Schoo! District, and removed from office as the Mayor of the City of Eudora, Arkansas.WHEREFORE, the State of Arkansas prays that the court's judgment be issued forthwith removing the defendant from office as a member of the Board of Directors of the Lakeside School District, and as the Mayor of the City of Eudora, Arkansas; and for all other relief to which the State STATE OF ARKANSAS. hon OQ | = THOMAS D. DEEN | may be entitled. Prosecuting Attorney Tenth Judicial District 506 South Main St, Monticello, Arkansas 71655 | Telephone: (870) 367-9896 PLAINTIFF