Case: 61CH1:25­cv­01941 Document #: 1 Filed: 12/23/2025 1FIT1LE&)

Page 1 of 7

DEC 23 2025
IN THE CHANCERY COURT OF RANKIN COUNTY, MISSIS~:ffl< S. SCARBOR
hancery Clerk R . OLJGH
, ank,n Cou ty
JEFF MAYNARD; SYLVIA KNIGHT; n
SK ENTERPRISES, INC.; AND LAI, LLC PLAINTIFFS

vs. CAUSENo.2'.3 - 144\L\"1,)

COUNTY LINE BAPTIST CHURCH (RANKIN COUNTY);

COUNTY LINE BAPTIST CHURCH OF RANKIN COUNTY, INC.;
AND JOHN DOES 1-10 DEFENDANTS

COMPLAINT FOR NUISANCE, PRELIMINARY INJUNCTION AND PERMANENT

INJUNCTION

J EFF MAYNARD, SYLVIA K.1'\JIGHT, SK ENTERPRISES, INC. and LAI, LLC

("Plaintiffs") by and through their attorney, files this Complaint for uisance, Preliminary Injunction

and Permanent Injunction as a result of acts interfering with the enjoyment of the Plaintiffs' property

against COUNTY LINE BAPTIST CHURCH (RANKIN COUNTY) aka COUNTY LINE

BAPTIST CHURCH OF RANKIN COU TY, INC. AND JOHN DOES 1-10 ("Defendants")

and in support of this Complaint, Plaintiffs would show unto the Court the following:

1. Plaintiff Jeff Maynard ("Jeff') is an adult resident citizen of Rankin County, Mississippi who

resides at 1159 County Line Road, Mendenhall, MS 39114.

2. Plaintiff Sylvia Knight ("Sylvia") is an adult resident citizen of Rankin County, Mississippi

who resides at 1159 County Line Road, Mendenhall, MS 39114. Sylvia owns the property

located at 1159 County Line Road, Mendenhall, MS. 39114.

3. Plaintiff SK Enterprises, Inc. is a Mississippi corporation in good standi ng located in Rankin

County, Mississippi.

4. Plaintiff LAI, LLC is a Mississippi limited liability company in good standing located in

Rankin County, Mississippi.

5. D efendant, County Line Baptist Church (Rankin County), is located at 1132 County Line
Case: 61CH1:25­cv­01941 Document #: 1 Filed: 12/23/2025 Page 2 of 7

Road, Mendenhall, MS 39114 and is a Mississippi non-profit corporation in good standing,

who may be served through its registered agent, Danny Stevens at 11 04 County Line Road,

Mendenhall, MS 39114.

6. Defendant, County Line Baptist Church of Rankin County, Inc., is located at 1132 County

Line Road, Mendenhall, MS 39114 and is a Mississippi non-profit corporation in good

standing, who may be served through its registered agent, Ray Williams at 1132 County Line

Road, Mendenhall, MS 39114.

7. John D oes 1-10 are unknown defendants acting in concert with Defendants County Line

Baptist Church (Rankin County) and Cou nty Line Baptist Church of Rankin County, Inc.

8. Mickey Ferguson is the pastor of County Line Road Baptist Church and he may be served

wherever he may be found.

9. Upon information and belief County Line Baptist Church (Rankin County) and County Line

Baptist Church of Rankin County, Inc. are the same entity operating as County Line Baptist

Church in Rankin County, Mississippi.

10. The acts subject to this Complaint, hereinafter referred to as the "interfering acts," involve

the Defendants' usage of the property known as Co un ty Line Road Baptist Church located

at or near 1132 County Line Road, Mendenhall, MS 39114, described as follows:

a. Using electronic speakers and sound systems to play electronic bell sounds every hour
from 8:00am to 8:00pm seven days a week.

b. Using electronic speakers and sound systems to play music at 12:00pm seven days a

week and during meetings of the congregation.

11. These interfering acts disturb the Plaintiffs' enjoyment of the property at 1159 County Line

Road, Mendenhall, Mississippi 39114.

12. The interfering acts interrupt the business conducted by the Plaintiffs at 1159 County Line
Case: 61CH1:25­cv­01941 Document #: 1 Filed: 12/23/2025 Page 3 of 7

Road, Mendenhall, Mississippi 3911 4.

13. Plaintiff Sylvia Knight owns and has a legal interest in the real property located at 1159 County

Line Road, Mendenhall, Mississippi 39 114, and has the right to the quiet use and enjoyment

of said property.

14. The subj ect property interferes with the Plaintiff Sylvia Knight's enjoyment of her property.

15. Plaintiff J eff Maynard lives at 1159 County Line Road, Mendenhall, Mississippi 39114 with

Sylvia, and he has the right to the quiet use and enjoyment of said property.

16. Both Sylvia and J eff conduct business on behalf of their respective companies at 1159 County

Line Road, Mendenhall, Mississippi 39114, and they each have the right to conduct their

respective businesses free from the interference of the nuisance activity of D efendants.

17. D efendants' conduct as described herein substantially and unreasonably in terferes with th e

Plaintiffs' use and enjoyment o f their property, exceeding the bounds of what a reasonable

person in the community would tolerate.

18. The interfering acts by the D efendants reach 16 to 32 times the normal background sound

outdoors and 4 to 8 times the background sound indoors.

19. The interfering acts described herein are continuous, recurring, and ongoing, having persisted

since approximately September 2024 despite Plaintiffs' repeated requests that such conduct

cease.

20. D efendants' interfering ac ts are the direc t and proximate cause of the substantial interference

with the Plaintiffs' use and enj oyment o f their property and the disruption of their business

operations.

21. Plaintiffs are suffering and will continue to suffer irreparable harm and injury for which there

is no adequate remedy at law, in that the continuing interference with the Plaintiffs' property
 Case: 61CH1:25­cv­01941 Document #: 1 Filed: 12/23/2025 Page 4 of 7

rights and business operations cannot be adequately compensated by monetary damages

alone.

22. The harm to Plaintiffs from the continuation of the defendant's interfering acts substantially

outweighs any harm to the D efendant that might result from an injunction prohibiting such

acts.

23. Plaintiffs have no speedy, adequate remedy at law to prevent the irreparable injury resulting

from D efendant's continuing interference with Plaintiffs' property rights.

24. D espite Plaintiffs making it clear to the D efendants that the Plaintiffs property located at

1159 County Line Road, Mendenhall, Mississippi 39114 is negatively impacted by the

interfering acts, and demanding the interfering acts cease immediately, the Defendants have

wrongfully continued the interfering acts and refuse to cease such interfering acts.

25. The Plaintiffs are entitled to a preliminary and permanent injunction of the interfering acts,

plus damages, court costs and attorney's fees.

WHEREFORE, JEFF MAYNARD, SYLVIA KNIGHT, SK ENTERPRISES, INC., and

LAI, LLC, pray that the Court will issue a preliminary injunction enjoining and restraining the

D efendants from continuing the intervening acts described herein, pending the final determination

of this cause. After final hearing, the Plaintiffs pray this Court will award them damages, court costs

and attorney fees and issue a permanent injunction enjoining and restraining the Defendants from

continuing said interfering acts. In the alternative, should the Court find that a complete cessation is

not warranted, enter an order Limiting the times, duration, and volume levels of any such sounds.

Plaintiffs pray for any other and further relief that this Court may deem just and proper as a result of

this action.
 Case: 61CH1:25­cv­01941 Document #: 1 Filed: 12/23/2025 Page 5 of 7

RESPECTFULLY SUBMITTED, this the 23 rd day of D ecember, 2025.

JEFF MAYNARD, SYLVIA KNIGHT, SK ENTERPRISES, INC.,

and LAI, LLC, Plaintiffs

BY: Isl Matt A. Baldridge

MATT A. BALDRIDGE, MSB#: 102636

OF COUNSEL:
BALDRIDGE LAW FIRM, PLLC
736 MAGNOLIA ST. STE. C.
MADISON, MISSISSIPPI 39110
PHONE: 601-706-9063
E-MAIL: MATT@[Link]
 Case: 61CH1:25­cv­01941 Document #: 1 Filed: 12/23/2025 Page 6 of 7

COUNTY OF l'v1J\DISON
STATE OF MISSISSIPPI

AFFID1\ V IT

Personally appeared before me, the undersigned authority the within named, JEFFERY
BRYAN MAYNARD, individua111Jy and as member of LAI, LLC, then, who, having first been
duly sworn by me states on his oath that the information and allegations set forth in the above
~nd foregoing Complaint are true and correct to the best of his know!

Witness my signature this th e l ':Jvo. day of---::::::-lo,""-"---'--"-'-

SWORN TO AND SUBSCRIBED before me this th e 23.J._ day of D~LJJMc!U-:Y , 2025.

NOTARY PUBLIC, in and for the State

of Mississippi

(SEAL)
 Case: 61CH1:25­cv­01941 Document #: 1 Filed: 12/23/2025 Page 7 of 7

COUNTY OF MAD ISON

ST1\TE OF MISSISS IPPI

AFFIDAVIT

Personally appeared before me, the undersigned authority the within named, SYLVIJ\
KNIGHT, individually and on behalf of SK Enterprises, LLC, then, who, having first been duly
sworn by me states on her oath that the information. and [Link] set forth in the above and
foregoing Complaint are true and correct to the best of her knowledge.

Witness my signature this the 13vJday of--1~ ............,~"""-'- - - • 2025.

AFFIA T
SWORN TO AND SU13SCRIB£D before me this the 26..,,.A day of -~¼:(ls:'A-\'.2£. V , 2025.

cw...J.. wo/Woc
NOTARY PUBLIC, in and for the State
of Mississippi

(SEAL)
 Case: 61CH1:25­cv­01941 Document #: 1­1 Filed: 12/23/2025 Page 1 of 3
Court Identification Case Year Docket Number
COVER SHEET Docket Number
Civil Case Filing Form 1ll I \ I \ IC[1 I 11--10 I?-10 1 1110/ 14 111
(To be completed by Attorn ey/Party
Prior to Filing of Pleading)
County # Judicial Court ID
District (CH, Cl, CO)
I I I Local Docket ID

Mississippi Supreme Cou rt Form AOC/0 1 Month Date Yea r

Adm inistrative Office of Courts (Revised 1/1/2001) Case Number if filed prior to 1/1/94
This area to be coR1pleled by clei:L<
IN TH E CHANCERY COURT OF _RANKIN
_ _ _ _ _ _ __ COUNTY
Short Style of Case: Jeff M aynard et. al. vs. County Line Baptist Church (Rankin County) et. al.
Party Filing Initial Pleading: Type/Print Name Matt Baldridge MS Bar No. l 02636
Check( ✓ ) if Not an Attorney C h eck(✓ ) if Pro Hae Vice Signature_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ _ _ _ __
Compensatory Damages Sought: $ _ _- _- _- _______ Punitive Damages Sought: $ _ _ _ _ _ _ _ _ __
Is Child Support contemplated as an issue in this suit? __ Yes v No If "yes" is checked , please submit a completed Child Support
-- Information Sheet with Final Decree/Judgment
P LAINTIFF - P ARTY( IES) INITIALLY BRINGING SUIT SHOULD BE ENTERED FIRST ( FIRST NAME IN SHORT STYLE) - E NTER A DDITIONAL PLAINTIFFS ON SEPARATE F ORM
Individual M aynard Jeff 1 _______ )
Last Name First Name Maiden Name, if Applicable Middle lnit. Jr/Sr/Il l/IV
Address of Plaintiff 736 Magnolia Street Madison MS 39110
__ C heck(✓ ) if Individual Plaintiff is actinq in capacity as Executor(trix) or Administrator(trix) of an Estate, and enter style:
Estate of - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
__ C he ck (✓ ) if Individual Plaintiff is acting in capacity as Business Owner/Operator (d/b/a) or State Agency, and enter entity:
D/B/A / Agency
Business - - - - - - - - - . . . . , . . - - , - - - , - - - - , - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
Enter legal name of bu siness, corporation, partnersh ip, age ncy~ If Corporation, indicate state where in corporated
_ _ Che ck (✓ ) if Business Plaintiff is filing suit in the name of an entity other than the above, and enter below:
D/B/A:
D EFENDANT- N AME OF D EFENDANT (FIRST NAME IN SHORT STYLE)- ENTER A DDITIONAL DEFENDANTS ON SEPARATE F ORM
Individual _ _ _ _ _ _ _ _ _ _ _ _ _ ____________ ( _______ )
Last Name First Name Maiden Name , if Applicable Middle lnit. Jr/Sr/Ill/IV
__ Che ck (✓ ) if Individual Defendant is actinq in capacitv as Executor(trix\ or Administrator(trix\ of an Estate, and enter stvle:
Estate of - - - - - - - - - - - - - - - - - - - - - - -- - - - - - - - - - - - - - - - - - - - - - - - - - -
__Check (✓ ) if Individual Defendant is actina in capacitv as Business Owner/Operator (d/b/a\ or State Aoencv. and enter entitv:
D/B/A / Agency _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
Business County Ljne Road Baptist Church [Rankin County)
Enter legal name of business, corporation, partnership, agency - If Corporation, indicate state where incorporated
_ _ Che ck (✓ ) if Business Defendant is being sued in the name of an entity other than the above, and enter below:
D/B/A:
Bar No. or Name: Pro Hae Vice( ✓ )_
ATTORNEY FOR THI S D EFENDANT :
(If known
-----
In left hand column, check one (1) box th at best describes

~~
Probate Ch ildren and Minors• [Link]
the nature of this suit. In right hand column check all Accounting (Probate) Adoption - Noncon tested
boxes which indicate secondary claims. Birth Certificate Correction Consent to Abortion for Minor
Bu siness/Com mercial Commitme nt Removal of Minority
Accounting (Business) Conservators hip Other
Bankruptcy Guardianship To rts-Pers on al Injury
Business Dissolution - Corporation Heirship Bad Faith
Business Dissolution - Partnership Intestate Estate Fraud
Debt Collection Minor's Settlement Loss of Consortium
Employment Muniment of Title Malpractice - Legal
Examination of Debtor Name Change Malpractice - Medical
Execution Power of Attorney Negligence - General
Foreign Judgment Testate Estate Negligence - Motor Vehicle
Garn ishment Wi ll Contest Products Liability
Pension Other Wro ngful Death
---=s-ta_t_u-te-s""
/R,..u""'l-
es_ _ _ __ _ __
Receivership Other
Replevin Bond Va lidation Mass Tort

ii
Stockholder Suit Civil Forfeiture
Other Declaratory Judgment ~~~:i:a~ Spill
Domestic Relatio ns ERISA
Child CustodyNisitation Eminent Domain ~ ~:~~Arm Vibration
Child Support Extraordinary Writ Hearing Loss
Contempt Federal Statutes Radioactive Materials
Injunction or Restraining Order Other _ _ _ _ _ _ _ _ _ _ _ _ _ __
Divorce: Fault
Divorce: Irreconci lable Differences Municipal An nexation Rea l Property
Domestic Abuse Racketeering (RI CO) Adve rse Possession
Emancipation Ra ilroad Ejectment
Modification Seaman Eminent Domain
Other _ _ _ _ _ _ _ _ _ _ _ _ _ __ Judicial Foreclosure
Paternity
Property Division Appeals Lien Assertion
Separate Maintenance Administrative Agency Partition
Tennination of Parental Rights County Court Receiver Appointme nt
UIFSA (formerly URESA) Hardship Petition (Driver License ) Tax Sale: Confinnation/Cancellation
Other Justice Court Title , Boundary &/or Easement
- - - - - ~ C ~o-n~tr-a-ct_ _ _ _ _ _ __ MS Employmt Security Comm'n Other

~~
~::~:~~~~:~~~~t

~~
Municipal Court
Elections Civ il Rig hts
Oil & Gas Board
Workers ' Compensation Habeas Corpus
Other _ _ _ _ _ _ _ _ _ _ _ _ _ __ P~st Conviction Relie f
~r:~~:t~iability under Contract
Specific Performance Pnsoner
Other _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ Other
 Case: 61CH1:25­cv­01941 Document #: 1­1 Filed: 12/23/2025 Page 2 of 3
IN THE CHANCERY COURT OF _RAN-'--_KIN
_ _ _ _ _ _ _ COUNTY, MISSISSIPPI

_ _ _ _ _ _ _ _ JUDICIAL DISTRICT, CITY OF _ _ _ _ _ _ __

Docket No._ _ __ Docket No. If Filed

File Yr Chronological No. Clerk's Local ID Prior to 1/1/94 _ _ _ _ _ _ _ _ _ _ _ _ _ __

PLAINTIFFS IN REFERENCED CAUSE - Page 1 of j _ Plaintiffs Pages

IN ADDITION TO PLAINTIFF SHOWN ON CIVIL CASE FILING FORM COVER SHEET

Plaintiff #2:
Individual : ~Kn=i=gh=t~...,...,,"'."TT=,,...-----
- Last Name ..:aS:...Y..:..lv'-'i=-a--~-----
First Name ( ~M..-a...,1d,...en....,N..,.a_m_e_, 1~fA..-p-p.,..hc_a..,bl_
e_ Middle lrnt. Jr/Sr/Iii/IV

_ Check(✓) if Individual Plaintiff is acting in capacity as Executor(trix) or Administrator(trix) of an Estate, and enter style :

Estate of - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
_Check(✓) if Individual Plaintiff is acting in capacity as Business Owner/Operator (D/B/A) or State Agency, and enter that name below:
D/B/A

Busines s---------------------~--~-~~~~-----~---------
Enter lega l name of business, corporation , partnership, agency - II Corporation, 1nd1ca te state where incorpora ted

_Check( ✓ ) if Business Plaintiff is fil ing suit in the name of an entity other than the name above , and enter below :

D/B/A - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
or Name: - - - - - - - - - - - - Pro Hae Vice( ✓ )_ Not an Attorney(✓)_
ATTORNEY FOR THIS PLAINTIFF: _ _ _ _ Bar#

Plaintiff #3:
Ind iVidual : - - - - . - ca=s-r,1N"'a=m=e- - - - - -----,,Fe-=
1rs""t..,Nr=-
am=-e
, ,...------( Maiden Name, 1f Applicable Middle lrnt. Jr/Sr/Ill/IV

_ Check (✓) if Individual Plaintiff is acting in capacity as Executor(trix) or Administrator(trix) of an Estate, and enter style :

Estate o f - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
_ Check (✓ ) if Individual Plaintiff is acting in capacity as Business Owner/Operator (D/B/A) or State Agency, and enter that name below:
D/B/A
Business SK Entemrises, Inc.
Enter legal name of business, corporation, partnership, agency - If Corporation, indicate state where incorporated

_Check( ✓ ) if Business Plaintiff is filing su it in the name of an entity other than the name above , and enter below:

D/B/A - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
or N a m e : - - - - - - - - - - - - Pro Hae Vice ( ✓)_ Not an Attorney(✓)_
ATTORNEY FOR THIS PLAINTIFF : _ _ _ _ Bar#

Plaintiff #4:
Individual : ________________________ ( . . .
Last Name First Name Maiden Name, 1f Applicable Middle lnit. Jr/Sr/Ill/IV

_Check(✓) if Individual Plaintiff is acting in capacity as Executor(trix) or Administrator(trix) of an Estate, and enter style:
Estate of
_Check( ✓) if Individual Plaintiff is acti ng in capacity as Business Owner/Operator (D/B/A) or State Agency, and enter that name below:

D/B/A - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
Business LAI, LLC
Enter legal name of business, corporation , partnership, agency - If Corporation, indica te state where incorporated

_Chec k(✓ ) if Business Plaintiff is filing suit in the name of an entity other than the name above , and enter below:

D/B/A - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
or Name: - - - - - - - - - - - - Pro Hae Vice ( ✓)_ Not an Attorney(✓)_
ATTORNEY FOR TH IS PLAINTIFF: _ _ _ _ Bar#
 Case: 61CH1:25­cv­01941 Document #: 1­1 Filed: 12/23/2025 Page 3 of 3
COURT OF RANKIN
IN THE CHANCERY
----------- COUNTY, MISSISSIPPI
----------JUDIC IAL DISTRICT, CITY OF
Docket No._ _ __ Docket No. If Filed
File Yr Chronological No. Clerk's Local ID Prior to 1/1/94 _ _ _ _ _ _ _ _ _ _ _ _ __

PLAINTIFFS IN REFEREN CED CAUS E - Page_ of L Plaintiffs Pages

IN ADDITION TO PLAINTIFF SHOWN ON CIVIL CASE FILING FORM COVER SHEET

Plaintiff #
1nd iVidual : - - - - - c a -s,....tN~a_m_e_ _ _ _ _ ----~F-ir""
st_N_a_m_e_ _ _ _ ( ~M-a,....1d-en""N~a-m-e""
, 1-1A-p-p-hc_a,....ble-- Middle !nit. Jr/sr/111/lv

_Check( ✓) if Individual Plaintiff is acting in capacity as Executor(trix) or Administrator(trix) of an Estate, and enter style:

Estate o f - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
_ Check ( ✓) if Individual Plaintiff is acting in capacity as Business Owner/Operator (D/B/A) or State Agency, and enter that name below:

D/B/A - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

_Check( ✓) if Business Plaintiff is filing suit in the name of an entity other than the name above, and enter below:

D/B/A - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
or Name: _ _ _ _ _ _ _ _ _ _ _ _ Pro Hae Vice( ✓ )_ Not an Attorney(✓)_
ATTORNEY FOR TH IS P LAINTIFF: _ _ _ _ Bar#

Plaintiff#
1nd
ividual : ----,...,ca=s..,tN'"'a=m=e----- ----~F..,.,ir""
sf'""N""'a=m=e---- ( Maiden Name , ,t Applicable Middle lnit. Jr/Sr/Ill/IV

_Check ( ✓) if Individual Plaintiff is acting in capacity as Executor(trix) or Administrator(trix) of an Estate, and enter style:

Estate of - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
_Check( ✓ ) if Individual Plaintiff is acting in capacity as Business Owner/Operator (D/B/A) or State Agency, and enter that name below:

D/B/A - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
Bu s iness - - - - E - n
.t-er..,.le_g_a,-1n_a_m_
e....,
ol...,.6-
u-sin- e-ss- .-co- r-po-ra..,.t1-
on- ,-p-art.,.n-
er_s,....h1-p,-a-ge-n-
cy- -..,.11..,c,...o-rp-o-ra.,.t10
- n-. -1n""'d1_
ca..,.
te_s..,.
ta..,.te- w
""h-e-re_in_c_o_
rp_or-at,-e..,.d- - - - - - - - - -

_Check( ✓) if Business Plaintiff is filing suit in the name of an entity other than the name above, and enter below:

D/B/A - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
or Name: - - - - - - - - - - - - Pro Hae Vice( ✓ )_ Not an Attorney( ✓)_
A TTORNEY FOR THIS P LAI NTIFF: _ _ _ _ Bar#

Plaintiff# _ :
Individual : ______________________ ( . . .
Last Name First Name Maiden Name, 1f Applicable Middle !nit. Jr/Sr/llltlV

_Check( ✓) if Individual Plaintiff is acting in capacity as Executor(trix) or Admin istrator(trix) of an Estate, and enter style:
Estate of
_ Check ( ✓)
--------------------------------------------
if Individual Plaintiff is acting in capacity as Business Owner/Operator (D/B/A) or State Agency, and enter that name below:
D/B/A

Bu siness ---....,..En""'t.,...
er~,e~g~a,~n..,..
am - e ""'
of~b-
us,....in~e.,...
ss,....,..,..
co,....rp.,...o-ra=t1-
on- , -pa.,...rt=n-er=sh~1p-,-ag_e.,...n-
cy- -~,1-c~o-rp-o-ra-t10.,...n-
, 1-nd~1ca
~fe- s~fa~te_w
..,.h-
e-re_in.,...c-or-p-or~a1~ea- - - - - - - - - -

_Check (✓) if Business Plaintiff is filing suit in the name of an entity other than the name above , and enter below:

D/B/A - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
or Name: - - - - - - - - - - - - Pro Hae Vice ( ✓)_ Not an Attorney( ✓)_
A TTORNEY FOR TH IS P LAINTIFF : _ _ _ _ Bar#
 Case: 61CH1:25­cv­01941 Document #: 11 Filed: 02/25/2026 Page 1 of 6

IN THE CHANCERY COURT OF RANKIN COUNTY, MISSISSIPPI

JEFF MAYNARD; SYLVIA KNIGHT;

SK ENTERPRISES, INC.; AND LAI, LLC PLAINTIFFS

v. CAUSE NO. 25-1941 (M)

COUNTY LINE BAPTIST CHURCH (RANKIN COUNTY);

COUNTY LINE BAPTIST CHURCH OF RANKIN COUNTY, INC.;
AND JOHN DOES 1-10 DEFENDANTS

ANSWER AND AFFIRMATIVE DEFENSES

COMES NOW, Defendants County Line Baptist Church of Rankin County, Inc. and

County Line Baptist Church (Rankin County) (“Church Defendants”), by and through

undersigned counsel, submit this Answer and Affirmative Defenses to the Complaint filed by

Plaintiffs, and state as follows:

I. INTRODUCTION AND GENERAL DENIAL

1. Except as expressly admitted herein, Church Defendants deny each and every material

allegation of the Complaint and demands strict proof thereof according to law.

2. Church Defendants deny that they committed or are committing any violation of Mississippi

nuisance law, whether public or private, statutory or common law.

II. ANSWER

1. Church Defendants lack knowledge or information sufficient to form a belief as to the truth

of the allegations concerning the Plaintiffs’ residence, standing, or capacity and therefore

deny the allegations contained in Paragraphs 1, 2, 3 and 4 of the Complaint.

2. Church Defendants admit the allegations in Paragraphs 5 and 6 of the Complaint.

3. Church Defendants deny the allegation contained in Paragraph 7 of the Complaint.

4. Church Defendants admit that Mitchell “Mickey” Ferguson is the pastor of County Line

Baptist Church; however, the remaining allegations contained in Paragraph 8 are denied.

1
 Case: 61CH1:25­cv­01941 Document #: 11 Filed: 02/25/2026 Page 2 of 6

5. With respect to the allegations contained in Paragraph 9 of the Complaint, Church

Defendants are reflected as separate entities in the records of the Mississippi Secretary of

State; however, County Line Baptist Church (Rankin County) is a duplicate filing. In all

respects the proper defendant is County Line Baptist Church of Rankin County, Inc., a/k/a

County Line Baptist Church, Rankin County, Mississippi 1. The remaining allegations in this

paragraph not otherwise admitted are denied.

6. Church Defendants deny engaging in any “interfering acts” and further deny the stated

frequency of the playing of bell sounds and further deny that music is played as described

during meetings of the congregation. The remaining allegations contained in Paragraph 10 of

the Complaint not expressly admitted herein are denied.

7. Church Defendants deny the allegations contained in Paragraph 11 of the Complaint.

8. Church Defendants deny the allegations contained in Paragraph 12 of the Complaint.

9. Church Defendants are unaware of the ownership of the referenced property and further deny

that any right of the referenced Plaintiff has been violated and accordingly deny the

allegations contained in Paragraph 13 of the Complaint.

10. Church Defendants deny the allegations contained in Paragraph 14 of the Complaint.

11. Church Defendants are unaware of the residency of the referenced Plaintiffs and further deny

that any right of the referenced Plaintiffs has been violated and accordingly deny the

allegations contained in Paragraph 15 of the Complaint.

12. Church Defendants are unaware of any business conducted on the referenced property and

further deny that any right of the referenced Plaintiffs has been violated and accordingly deny

the allegations contained in Paragraph 16 of the Complaint.

1 In reference to “Church Defendants” in this Answer, the same incorporates the qualifications stated herein.

2
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13. Church Defendants deny the allegations contained in Paragraph 17 of the Complaint.

14. Church Defendants deny any contention that they engaged in any “interfering acts” and deny

the allegations contained in Paragraph 18 of the Complaint.

15. Church Defendants deny the allegations contained in Paragraphs 19, 20, 21, 22, 23, 24, and

25 of the Complaint.

16. The paragraph beginning with WHEREFORE does not require a response; however, to the

extent one is required, Church Defendants deny the same in all respects.

1. And further, to the extent Church Defendants have omitted any response to any allegation

and/or admitted or denied any allegation, any part of which the Plaintiffs may rely, in whole

or in part, to obtain any relief against them, the same is an inadvertent omission and/or error

and this Answer is amended accordingly to reflect Church Defendants’ complete and total

denial of any allegations in this respect and any requested relief by Plaintiffs.

III. AFFIRMATIVE DEFENSES

Without assuming any burden not imposed by law, and expressly reserving the right to

assert additional defenses as they become known through discovery, Church Defendants

assert the following affirmative and other defenses:

FIRST DEFENSE

The Complaint fails to state a claim upon which relief may be granted.

SECOND DEFENSE

Church Defendants affirmatively plead all defenses applicable and available under Rule

12(b) and Rule 8(c) of the Mississippi Rules of Civil Procedure, including but not limited to

accord and satisfaction, arbitration and award, assumption of risk, comparative and/or

contributory negligence, discharge and bankruptcy, duress, judicial, equitable and/or collateral

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estoppel, failure of consideration, election of remedies, failure to mitigate damages, failure to

join necessary parties, fraud, illegality, injury by fellow servant, laches, license, payment,

preexisting injuries or damages, release, res judicata, statute of frauds, statute of limitations,

waiver, set off, recoupment and any other matter constituting an avoidance or affirmative

defense.

THIRD DEFENSE

Plaintiffs are not entitled to preliminary or permanent injunctive relief because inter alia

they cannot demonstrate: (a) a substantial likelihood of success on the merits; (b) that they will

suffer irreparable harm absent an injunction; (c) that the balance of hardships favors an

injunction; or (d) that an injunction would serve the public interest.

FOURTH DEFENSE

Church Defendants affirmatively plead all protections afforded religion and religious

institutions, including Christian churches, under the U.S. Constitution and the laws thereof and

the Constitution of the State of Mississippi and the laws thereof, including but not limited to:

1. Free Exercise of Religion (U.S. Const. amend. I; Miss. Const. art. III, § 18).

2. Freedom of Assembly (U.S. Const. amend. I).

3. Establishment Clause (U.S. Const. amend. I).

4. Equal Protection (U.S. Const. amend. XIV; Miss. Const. art. III, § 14).

5. Due Process (U.S. Const. amend. XIV; Miss. Const. art. III, § 14).

6. Due Process (U.S. Const. amend. XIV; Miss. Const. art. III, § 14).

7. Mississippi Religious Freedom Restoration Act, Miss. Code Ann. § 11-61-1 et. seq.

FIFTH DEFENSE

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Church Defendants deny that Plaintiffs have suffered cognizable damages proximately

caused by any conduct of the Church Defendants.

SIXTH DEFENSE

Due to the fact that discovery in this matter has not yet begun, the Church Defendants are

without knowledge or information sufficient to form a belief at this time as to whether other

Affirmative Defenses may apply in this action. However, contingent on the facts revealed

by investigation, the Church Defendants expressly reserve all rights to raise any additional

Affirmative Defenses which may be applicable in this matter, and do hereby assert the same,

as if fully set forth herein.

IV. PRAYER FOR RELIEF

WHEREFORE, the Church Defendants respectfully request that the Court:

A. Dismiss the Complaint with prejudice;

B. Deny all relief requested by Plaintiffs;

C. Award the Church Defendants their costs, expenses, and reasonable attorneys’ fees;

and

D. Grant such other and further relief as the Court deems just and proper.

Respectfully submitted,

COUNTY LINE BAPTIST CHURCH (RANKIN

COUNTY) and COUNTY LINE BAPTIST CHURCH OF
RANKIN COUNTY, INC., Defendants

By: /s/ Adrian W. Mills

Adrian W. Mills, One of their Attorneys

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OF COUNSEL:

MARK C. BAKER, SR. (1717)

ADRIAN W. MILLS (103776)
MARK C. BAKER, JR. “CHASE” (106611)
BAKER LAW FIRM, P.C.
Post Office Box 947
Brandon, MS 39043
mark@[Link]
adrian@[Link]
chase@[Link]

CERTIFICATE OF SERVICE

I, Adrian W. Mills, do hereby certify that I have, this day, electronically filed the
foregoing with the clerk of Court using the MEC filing system which sent notification to all
counsel/parties of record.

THIS the 25th day of February 2026.

/s/ Adrian W. Mills

Adrian W. Mills