THE COCHRAN 

MISSISSIPPI DELTA

306 BRANSCOME DRIVE - GRENADA, MISSISSIPPI 38901
TELEPHONE: (662) 227-9940 - FAX: (662) 227-9941

Marmara
Via Certi?ed Mail

Mayor Mario King
43 20 McInnis Avenue
Moss Point, MS 39563

City of Moss Point

Attn: Stephanie Coleman, City Clerk
4320 McInnis Avenue

Moss Point, MS 39563

Of?cer Lancen Shipman
4200 Bellview Avenue
Moss Point, MS 39563

RE: Keena Sims, Individually and on behalf of all Heirs-At-Law and Wrongful
Death Bene?ciaries of Toussaint Diamon Sims, Deceased and The Estate
Of Toussaint Diamon Sims, Deceased Notice of Claim

Date of Injury: 08/08/2019

To Whom It May Concern:

Please be advised that The Cochran Firm MS Delta has been retained to represent Keena Sims,
Individually and on behalf of all Heirs-at-Law and Wrong?il Death Bene?ciaries of Toussaint
Diamon Sims, Deceased and the Estate of Toussaint Diamon Sims, Deceased in their claims
against Mayor Mario King, City of Moss Point, Chief Brandon Ashley, and Of?cer Lancen
Shipman for injuries/damages Mr. Sims sustained on or about August 8th, 2019 in Moss Point, MS.
Mr. Sims was located in Pascagoula, MS, and pursued through Moss Point, MS Where his vehicle
was shot to the point of disabling the driving ability near 2"d Street in Moss Point, MS. Thus, Mr.
Sims exited his vehicle and proceeded to ?ee on foot. During the entire ordeal, Mr. Sims was
unarmed and posed no imminent threat to the well-being of police of?cers as he ?ed from them.
Mr. Sims was able to jump one fence before he was shot four to ?ve times in the back by Of?cer
Shipman. To date, the family of Toussaint Diamon Sims has no information on the cause of pursuit
for Mr. Sims. As a result of all the aforementioned Defendants? actions, Mr. Sims sustained severe
physical injuries and damages, which caused him to expire on August 8th, 2019. Other claims
against said defendants include but are not limited tO constitutional violations, gross negligence,
negligent/intentional in?iction of emotional distress, reckless disregard, excessive force, and
negligent/ gross negligent supervision, hiring, training, and retention of the of?cers/individuals in

question.

ATLANTA - CHICAGO - LAS VEGAS . Los ANGELEs - MEMPHIS - MIAMI - NEW ORLEANS - NEW YORK - WASHINGTON DC.

My client suffered and continues to suffer monetary losses from the injuries including mental and
emotional pain and anguish. My client hereby demands $10,000,000 from City of Moss Point, MS,
Chief Brandon Ashley, and Of?cer Lancen Shipman for both compensatory and punitive damages.
At the time of the injuries, my client was a resident citizen of Jackson County, Mississippi and is
currently a resident of Jackson County, Mississippi.

Please forward this notice of claim to your liability carrier, and have said carrier contact me as
soon as possible.

Sincerely,

THE COCHRAN FIRM MS Delta

.-,

Gal-103E: Moore, Esq;
Cc: client