IN THE 22ND JUDICIAL CIRCUIT COURT OF CITY OF ST LOUIS, MISSOURI Thdge or Divisions Case Numbers 1022-CCO17S9 DAVID L DOWD PlainiPettoner: Phin Peikioners Atomay/a dares MOKAN FREEMAN ROBERTSON BOSLEY | SUITE300 611 N TENTH STREET [ae vs, | SAINT LOUIS, MO 63101 Defendant Respondent | our Ades : BI-STATE DEV AGENCY OF THE MO-IL CIVIL COURTS BUILDING METROPOLITAN DisTRICT ION TUCKER BLVD DBA: METRO SAINT LOUIS, MO 63101 Nature of Suit me CC Breach of Contract _ : : | ie rae snp) Summons in Civil Case 2 [ The State of Missouri to:_BISTATE DEV AGENCY OF THE MO-IL METROPOLITAN DISTRICT RR c id amon a DBA: METRO. a conoseer arn pnesooer 2 SPECIAL PREGESS. SERVER Stowerno 1 Now FST Street | Stinttous, so eine a a i COURT SEAL. OF Yow are summoned to appear before tis court and to le your pleading to he potion, a copy of whieh is attached, and to serve a copy of your pleading wpon the attorney for PlaintiffPetitioner at the ‘above addres all within 30 days after recsiving this summons, exclusive ofthe day of service. Ifyou fal to file your pleading, judgment by default may be taken against you Tor the relief demanded in the petition. SZ C oo crrvorstiouis April 20, 2010 be ae ‘Marian Favazza CacuitClek Purtherinformaion: ‘Sheriffs or Server's Return Note to serving officer: Summons should be retuned tothe cour within thy days afer the date of issue. cently that Ihave served the above summons by: (check one) {C. detivering « copy ofthe summons and a copy ofthe petition to the Defendant Respondent. CO teaving a copy ofthe summons and a copy ofthe petition a the dvelling place or usual abode ofthe Defendant/Respondent with mt person ofthe Defendant’sRespondent’s family over the age af 15 yeas, Sig a fem) Orga ay of mena a coy of te etn ‘Bi State “DOA. MeTRO (ane) S hyhory Bagent (it Dother, . sveia_707 Wi Eras? SH SLawi i n_SF Gv. (CounffEiD9FSt Lows, MO, on HL = a ite) at 22S 7pm Thee. “Must be sworn before a notary public ifnot served by an authoriged officer: Subscribed and sworn ta before me on. | date, Mycomnion apts Who ) ) BI-STATE DEVELOPMENT AGENCY) ) ) ) ) ) St. Louis, Missouri 63102 _) Demand for Jury Trial Defendant, ) COMPLAINT Breach of Contract COMES NOW Plaintiffs, MOKAN and the NAACP Missouri State Conference, by and === through its attorneys of record; Freeman R=Bosley,Jr.; Daniel R- Brown, 1.C- Cater ad Bosley — and Associates, and for their cause of action against Defendant, Bi-State Development Agency of the Missouri-Iinois Metropolitan District d/b/a Metro (hereinafter “Metro”), hereby state as follows. PARTIES 1, The NAACP Missouri State Conference is a branch of the National Office of the NAACP, which is an association of citizens who have come together to work for and adéress the issues of equity, inclusion and diversity in the State of Missouri. One ofits major goals is inclusion and equity ia the expenditure of publie funds. ‘The NAACP is one of the many organizations in the St. Louis Community whosemembers have attempted to do business with Metro and has made demands on ‘Meto to be inclusive and equitable of the Aftican American business community in awarding contracts 2. MOKAN CCAC (“MOKAN”) is a Missouri not-for-profit corporation whose purpose and mission is to enhance contract and business opportunities for its members, who are predominantly Aftican American and minority contractors. ‘is members have specifically applied for, and been denied, contracts with Metro in violation of its right to be free from discrimination based on race. 3. Defendant Metro is the regional metropolitan transit authority and was at all times relevant herein a governmental entity created pursuant to the statutes and Constitutions of the States of Missouri and Ilinois, and which operated in the Bi-State region the bus and light rail transportation system known as Metrolink. Defendant may be served with service of process by this Court at its principal place of business at 707 North First Street, St. Louis, Missouri 63102. Relevant Facts 4, Beginning in February, 2003, Metro began soliciting bids for construction contracts on the project known as the Cross County Project (hereafter the “Project”), whose $550 million cost is financed by municipal bonds and through sales taxes collected through out the St. Louis Metropolitan area. 5. To remedy its discriminatory practice and discriminatory practices existing in the St. Louis metropolitan construction industry, which has resulted in African ‘American and minorities being excluded from contract opportunities, Metro id specifications for the Project a goal of 20% minority established as part of iand women business enterprise (“M/WBE?) participation, and hired a consulting firm from New Jersey to manage and monitor the achievement of the 20% goal. ‘The firm was paid $900,000 for its services. Between March and May 2003, Plaintiff MOKAN pointed out to Metro, through 6. various written communications and presentations before Metro’s Board of Commissioner, its discriminatory practices and its participation in the disctiminatory practices of the construction industry through not enforcing its M/WBE guidelines and procedures. Metro refused and has continued to refuse to change its practices. In June 2003, Metro awarded a $46 million dollar contract to a contractor despite that contractor not meeting Metro's 20% DBE goal, and despite Metro’s consultant advising that the contractor had failed to comply with Metro’s M/WBE guidelines and procedures, —___8_By March, 2003, Meiro had awarded $154 million in contracts on the Project, with minorities receiving only 3%. 9. ‘The awarding of contracts by Metro on the Project is part of the pattern and practice of Metro to engage in race discrimination in awarding contracts. 10. Asa direct result of Metro’s policies, practices, customs, procedures, acts and omissions, members of MOKAN suffered, and will continue to suffer, immediate and irreparable injury which costs them millions of dollars of lost business opportunities and capecity building. 11. On July 11,2003, MOKAN, along with other Plaintiffs, filed a lawsuit in Federal District Court alleging discrimination based on race and loss of financial12. 13. 15, opportunities. (See Plaintifis’ Exhibit A attached hereto). ‘As a demonstration of its good faith and settlement of its lawsuit, MOKAN entered into a Memorandum of Understanding (hereinafter referred to as the “MOU”) dated August 27, 2003, in order to save Metro thousands of dollars in legal fees and millions of dollars in financial exposure for failure to meet the goal setting process. ‘The MOU reaffirmed Metro’s MBE’s goal of 20% on remaining projects, committed Metro to continue to improve minority participation on existing cross county contracts, increase minority bidding opportunities on remaining contracts, establish separate MBE and WBE goals on remaining projects, identify opportunities for building capacity for minority disadvantaged businesses inthe region and launch financial and lending institution support programs targeting bonding and working capital needs of small to medium-sized minority firms within 45-90 days for Metra projects To garner fall support of the Commissioners serving on Metro’s Board, the President and CEO prepared end distributed Briefing Paper No.1, the objective of which was to “provide the Board of Commissioners with a summary of the MOU and the rationale for the Agreement.” (See Plaintiffs’ Exhibits B and C attached hereto). MOKAN cooperated in good faith and withdrew the lawsuit and refrained from bringing any legal claims against Metro and, as a result ofits forbearance, its members have lost the opportunity to participate in the public expenditure of millions of dollars.16. 7. 18. Despite numerous demands and requests that Metro meet the MBE goals and other commitments expressed in the MOU, to date Metro has failed/refused to honor any and all provisions of the MOU. COUNT! Breach of Contract Plaintiff MOKAN adopts, realleges and incorporates its allegations set forth in paragraphs 1-21 of this Complaint. ‘The above and foregoing actions of Defendant MOKAN give rise to a cause of action for breach of contract as Metro breached the MOU by: ») Failing to improve MBE participation on existing Metro contracts; ©) Failing to increase minority bidding opportunities on remaining contracts, zeae 4) Filing to identify opportunities for building capacity for minority disadvantaged businesses in the region; ¢) Failing to launch 2 financial and lending iistitution support rogram targeting bonding and working capital needs of small to medium sized firms within 45-90 days for Metro projects; f) Failing to increase minority bidding opportunities on remaining contracts by breaking them into smaller contracts; 2) Failing to bring together the major leadership groups, public and private, who are working on the supplier diversity issue and/orhave a program; 1h) Failing to take the lead in identifying all of the public and private agencies/programs and resources being allocated to the diversity supplier issue; i) Failing to advance a program beyond the “Cross County Project” that increases the participation of socially and economically disadvantaged contractors. 19. Alloftthe foregoing conduct constitutes breach of contract which has resulted in damages to members of MOKAN and to the members of the NAACP Missouri State Conference in excess of $25,000.00. COUNT I Breach of Good Faith and Fair Dealing 20. Plaintiffs MOKAN and NAACP adopt, reallege and incorporate their allegations ‘The above and foregoing actions of the Defendant MOKAN give rise to a cause of action for breach of good faith and fair dealing as Metro signed « MOU with MOKAN which constituted a contractual agreement. 22, Metro has intentionally breached all espects of the agreement and in so doing evidenced an intent of never planing on honoring its agreement with MOKAN in spite of direct, aflirmative representations to MOKAN that the agreement would be honored, all of which has resulted in damage to MOKAN.23. 24. 25, 26. 28. 29. COUNT Mt Fraud Plaintiffs MOKAN and NAACP adopt, reallege and incorporate their allegations set forth in paragraphs 1-22 of this Complaint. The above and foregoing actions of Defendant Metro give rise to a cause of action for fraud due to the knowing and intentional misrepresentations made by Metro to MOKAN regarding the performance of the commitments made by Metro under the MOU. Alll of the foregoing representations contained in the MOU were made by Metro to induce MOKAN to withdraw its lawsuit and forebear from pursuing any legal claims over its goal setting process. Alll of the foregoing affirmative representations caused MOKAN and its members, to miss the opportunity to participate in the expenditure of millions of dollars in the St_Louis region "At the time ofthe affnmative representations inthe MOU, Metro misrepresented its intentions to nieet the MBE goals and help improve opportunities for minorities inthe St. Louis region. All of the foregoing representations were for the sole purpose of inducing MOKAN to withdraw its lawsuit and save Metro thousands of dollars in legal fees and not having to address the issue of not meeting its MBE goals. Alll of the foregoing representations constitute fraud and have resulted in damages in excess of $25,000.00.WHEREFORE, in consideration of the claims presented, Plaintiff, MOKAN prays for judgment against Defendant in the following manner: A. Fine Metro for any and all contracts entered into in violation of the MOU since July 2003; B. Monetary damages arising from breach of contract in an amount to be set at the trial of this cause; C. Award Plaintiffs actual damages in excess of $25,000.00 to be placed in a trust for the use and benefit of African Americans and Minority Businesses; D. An Order requiring a $15,000,000.00 payment plus legal interest running on or afer July 11, 2003, arising from Plaintiffs’ withdrawal of its lawsuit; E. Require that Metro establish separate goals for African American minorities and ‘women in its bidding and procurement practices; F. Payment constituting what Plaintifis would have earned with a DBE goal of 20% —_____onall Fi-State Construction contracts granted since Jul 12003; G. Prejudgment and post-judgment interest, along with attomeys fees, to be set by the Court at the trial of this cause; HL For an award of punitive and/or exemplary damages to be set at the trial of this cause; J. For what other good and equitable relief that this Court deems just and proper.Respectfully submitted,! Freeman R. Bosley, Jr, #29341 611 North 10" Street, Suite 300 St. Lonis, Missouri 63101 (314) 621-1744 ~ Telephone B14) 621-1752 —Facsimile Email: bosleylle@sbeglobal net Attorney for Plaintiffs Daniel R. Brown, #59749 611 North 10® Street, Suite 300 St. Louis, Missouri 63101 B14) 621-1744 - Telephone (314) 621-1752 — Facsimile ‘Email peslevHeasboylobal-net = Attorney for Plaintiffs By: TC. Carter, # 611 North 10" Street, Suite 300 _____St_Lonis- Missouri 63101 ____ G14) 621-1744 —Telepiione (14) 621-1752 — Facsimile Email: bosleylle@sbcglobal.net Attorney for Plaintiffs— 5°e i IN THE UNITED States District court ERED EASTERN DISTRICT OF MISSOURI a 1108 (J CONCERNED CITIZENS COALITION, .) cea p a ‘MOKAN CCAC, ; , Dee asbamnae ™S OBCVG 9 31. DIS Plaintifis ; ao = aR } Case No, vs 3 denayp Foe. Soky Rite. 7 BI-STATE DEVELOPMENT AGENCY -._) e ‘OF THE MISSOURE-ILLINOIS ) METROPOLITAN DISTRICT ) fbfa METRO ) ) B) Defendant ) ) COUNT I- Seetion 1983 * COME NOW plaintiffs the Cénccmed Citizens Coalition, Mokan CCAC, and the St. Louis Minotity Contractors Association, and for their cause of action against defendant Bi State Developmient Agency of the Missouri-Iinois Metropolitan Distict d/b/a Metro (hereinafter “Metro”), state as follows. Jurisdiction and Venue 1._ This is an dotion for monetary damages and injunctive relief; Juxisdiction of this Court is invoked under the Fourteenth Amendment of the United States Consttaton and Tilé 28 U.S.C. Sections 1331 aid 1343 and Title 42 US. Section 1983. 2. Veane is proper pursuant to Title 28 U.S.C. Settion 1391 (6).e 1 ‘he Parties 3. The Concemed Citizens Coalition (“CCC”) is an association of citizens who have banded together to address the issie of the equity and diversity in the distribution of public fimds, and who have recently made demands on defendant Metro to ‘equitably award contres to Affican American and minority businesses. 4. Mokan CCAC (“Mokan”) is 2 Missouri not for profit corporation whose purpose and mission is to enhance contract ard business opportunities for its members, who are predominantly African American and minotity contractors. Its members have specifically applied for, and been denied contracts with Metro in violation of its right to be free from disézimination based on race. 5. The St. Lonis Minority Contractors Association (“SLMCA”) isa Missouri not for ‘Profit corporation whose purpose is to repiesent the interests of its members, who are mifority contractors involved in the constraction industry. Its members have specifically applied for, and been denied contracts with Metro in violation of its 6. Defendant Metro is and was at all times relevant herein a governmental entity created pursuant ti the stattites and Constitutions of the Staies of Missouti and Llinbis, and which operates in the Bi-State region the bus and light rail fransportation system knowa as MetroLink. Defendant acted under célor of law to deprive Plaintifis of their Constitutional rights, as set forth more fully below. Defendant's Wrongdoing Beginning in February;2003; Metro began soliciting bids for construction — contracts on the projéct known as the City-County MettoL ink Expansion (hereinafter the “Project”), whose $550 million cost is financed through sales taxes, To remedy its discriminatory practices and discriminatory practices extant in the St. Louis metropolitan constriction industry, which has resulted in Aftican ‘American and minorities being excluded from contract opportmities, Metro éstablished as part of its bid specifications for the Project 2 goal of 20% minority and women business enterprise (“M/WBE") participation, and hired for $900,000 a consulting firm from New Jersey to manage and monitor the achievement of the 20% goal. 9. In March 2003, Metro awarded a $75 million contract to a contractor, despite that contractor failing to meet Metro’s 20 % M/WBE goal, and despite the consulting firm's advising Metro that the contractor had not complied with Meito’s M/WBE. ‘procedares and guidelines, which were designed to eradicate the discriminatory practices.> ® > ¢ fo)when plaintiff Mokan publicly criticized Metro for excluding minorities in awarding this $75 million contract, including members of Mokan and SLMCA, ‘Metro retaliated by terminating Mokan’s subcontract to monitor the minorily ‘workforce participation on the Project. 11. Between March and May of 2008, plaintiff CCC pointed out to Metro through various writien communications and presentations before Metto’s Board of Conhinissioners its discximinatoty practices aid its pacticipation in the discriminatory practices of the construction industry through not enforcing its MIWBE guidelines and procedures. Metro refused and has refused to change its practices. 12. In Junie 2003, Metro awarded a $46 million contract to a contractor despite that couizactor not meeting Metro’s 20% goal, and despite Metro’s consultant advising that the contractor had failed to mect Metro’s M/WBE guidelines and procedures. 13: Since March 2003, Metro has awarded $154 million in contracts on the Project, ‘with minorities receiving only 3%. 7 14, The awarding of contracts by Metro on the Project is part of the pattern and practice of Metro to engage in tace discrimination in awarding contracts. 15. As a direct result of Metro’s policies, practices, customs, procedures, acts, and omissions, plaintiffs’ are and will continue to suffer immediate and imeparable injury, for which they have no adequate remedy at law. __Prayor for Relief as to Count I WILIREFORE, plaintifis Coucemed Citizens Coalition, Mokan, andthe St. Louis Minority Contractors Association pray that this court: (enjoin Metro from entering into any farther contracts on the Metro; @) award plaintiffs actual damages of $55 million to be placed in a trust for the use and benefit of African American and minority businesses; () sequite that Metro establish separate goals for Affican Americans, minorities and ‘women in its bidding and procurement practices; and © grant plaintiffs such other aad further relief as may be appropriate, including the award of attomey’s fees. Count II- Section 1981 COME NOW plaintiffs, and for their cause of action against defendant in this Count Ti, state as follows:»® e 16. Jurisdiction of this coutt is invoked puzsuant to the Thirleeath and Fourteenth Amendments to the Unites States Constitution, Title 42 U.S.C. Section 1981 and Tifle 28 U.S.C. Sections 1331 and 1343. 17. Plaintiffs reallege and incomporais herein by reference paragraphs 2 through 15 of Count : 18. The failure of Metro to enforce the 20% M/WBE goal in the bid specification is, part of the pattern, practice and custom of Metro to exclude Affican Américan and. minority contractors from entering into contracts for Metro funds because of their rave, 19. The actiouis by Metro of denying Aftican Aniericans, minorities and plainiif's members’ contracts on the Project were actions cérried out om account of race and the race of plaintifiy’ members. 20: The discrimination described hereinabove against plains by defendant was L-Wilif Wanton, malicious, and/or outrageaus becatise of defendant's evil motive and/or reckless indifference to thé rights of others, thus entitling plaintiff to exemplary damages. é Prayer for Relief as to Count 1 WHEREFORE, plaintiffs Concemed Citizens Coalition, Mokan, and the St. Louis Minority Contractors Association pray that this court: = = () enjoin Metro fromrentering into any farther contracts om the Metro; (@) award plaintifis actual dantages of $55 million to be placed in a trust for the use and beiefit of African American and minority businesses; () award a judgment in ait amount allowed by law for exemplary damages; (@ require that Metro establish separate goals for African Americans, minorities and women in its bidding and procurement practices; and (S) grant plaintiffs such other and finther rlicf'as may be appropriate, incliding ‘the aviatd of attorney's fees. Respectfully submitted, a ‘The Champagne Law Firm BY ZaeLh ofl Cy 726 ‘Lyell HL Champagne, #68068 ‘The Frisco Building 906 Olive St, Suite 1110 St Louis, MO 63101 ‘Attoméy for Plaintiis : St Louis Minority Contractor's ‘atin, Concemed Citizens Coalition, MOKAN CCACC7 707 Roth Fst Steet Metro Se Loy Mou S355 Memorandum of Understanding Between Metro MoKan C.C.A.C., Concerned Citizens Coalition and Minority Contractors Wo recognize minority contractors face a financial capacity problem in the St. Louis construction Tidustry and have agreed to work together to help. resolve it. Financial ; riers often prevent minority contractors from bidding’ on large publle projects. To jeréaso minority participation now and in the futuré, Metro and Moan C.GA.C. have agréed to work together on the following short and long-term goals: * Continue to improve minority participation on existing Cros County contracts; on remaining contracts by breaking them ‘+ Increase minority-bidding opportunities Info smaller increments of work product; + Establish soparate MBE and WBE goals én remaining projects 2.0% M1mwvs Jue Wy. + Netto fas agreed to facilitate, with cooperation of the Mayor “and Counter "Executive, the formulation’ of an Economic Review Council to addréss problems, formulate strategies, make recommendations arid identify opportunities for bullding capacity for minority disadvantage businesses in the region; and ig institution support progrant targeting bonding and mail fo medium-sized minority firms within 45 to 90 ‘+ Launch financial and lendin working capital needs of 31 days for Metro projects. Eddie Hasan MoKan C.C.A.C President &CEO fnilah Nashéad Date Dorrie Wise oticerned Citizens Coalition Minority ContractorsBriefing Paper No. 1: Memorandum of Undersianding Between Metro, Mokan, Concerned Citizens Coalition, and Minority Contractors To: Metro Commissioners From: Lamy E. Salci, President &CEO Date: September 12,2003 Objective: Provide the Board of Commissioness with 2 summary of the Memoraudim of ‘Understeding (MOU) and the rationale fof the Agreement. .A copy of the MOU is attached as reference. This memorandum will address the elements contained in the Agreement and the intended benefits fo Metro. Summary af Agreement: Preamble: “We recognize minority contiactors face 6, finanoial capacity problent in the St. Louis construction industry and have agreed to work together to help resolve it Financial barziers_offen prevent minority. contractors fiom bidding on large public. projects. To incréase minority participation now aad in the future, Metto aiid Mokan, C.C.A.C. have agreed to work ‘together on the followitig short and long-term goals.” ‘Benefit to Metro: 1) We realized we could have a greater impact working together as partners, rathet than as adversaries. We also agreed to focus on the issues which concem éach of us the most: the lack of minority contractors who can bid on large public projects such. as Cross : _—_Coumty and the financial barriers that prevent many minority contractors fiom bidding on. = publieswork ® 76 (o)wen plaintiff Mokan publicly criticized Metro for excluding minorities in awarding this $75 million contract, including members of Mokan and SLMCA, Metto retaliated by terminating Mokan’s subcontract to monitor the minority ‘workforce participation on the Project. Between March and May of 2003, plaintiff CCC pointed out to Metto through various written communications and presentations before Metro’s Board of Coniinissioners its discriminatory practices and its participation ia the disoritninatory practices of the construction industry through not enforcing its M/WBE guidelines and procedures. Metro refitsed and has refused to change its practices. In June 2003, Metro awarded a $46 million contract to a contractor despite that 2, contractor not meeting Metro”s 20% goal, and despite Metro’s consultant advising ‘that the contractor had failed to mect Metro’s M/WBE guidelines and procedures. i 13, Since March 2003, Metro has awarded $154 million in contracts on the Project, with minorities receiving only 3% ae on 14, The awarding of contracts by Metro on the Project is part of the pattem and ‘Practice of Metro to engage in race discriminatioa ia awarding contracts. 15. As.a direct result of Metro’s policies, practices, customs, procedures, acts, and ‘omissions, plaintifi’ are and will continue to suffer immediate and ineparable injury, for which they have no adequate remedy at law. Praver for Relief as to Count I WHEREFORE, plaintiff Concemed Citizens Coalition, Mokan, and the St. Louis ‘Minority Contractors Association pray that this court: (1) eajoin Metro from entering into any further contracts on the Metro; (@) awatd plaintiffs actual damages of $55 million to be placed in a trust for the use and benefit of African American and minority businesses; (3) require that Metro establish separate goals for Aftican Americans, minotities and ‘women in its bidding and procurement practices; and (* great plaintiffs such other and further relief as may be appropriate, including the award of attomey’s fees. - Count I- Section 1981 COME NOW plaintifis, and for their cause of action against defendant in this Count, I, state as follows:58 7@ 16. Jurisdiction of this comt is invoked pursuant to the Thirteenth and Fourteenth Amendments fo the Unites States Constitution, Title 42 U.S.C. Section 1981 and Tifle 28 U.S.C. Scetions 1331 and 1343. 17, Plaintiffs reallege and incorporate herein by reference paragraphs 2 through 15 of Count I 18. The failure of Metro to enfores the 20% M/WBE goal in the bid specification is part of the pattern, practice and custom of Metto to exclude African American and minority contractors from entering into contracts for Metro funds because of their race, 19. The actions by Metro of denying Afticen Americans, minorities and plainiifP's members’ contracts on the Project were actions carried out on account of race and the race of plaintiffs” members, ———- 1 discrimination described hereinabove against plaintiffs by defendant was tention, Willful, wanton, malicious, and/or outrageous becaiise of deferidant’s — evil motive and/or reckless indifference to thé rights of others, thus entitling plaintiffs to exemplary damages. Prayer for Relief as to Count 0 WHEREFORE, plaintiffs Concerned Citizens Coalition, Mokan, and the Si. Louis ‘Minority Contractors Association pray that this court: =) enjoin Metro from entering into any further contracts on the Metro; @) award plaintiffs actual daniages of $55 million to be placed in a trast for the use and benefit of African American and minority businesses; (3) award a judgmént in an amount allowed by lavi for exemplary damages; (4) require that Met establish separate goals for Affican Americans, minorities and women in its bidding and procurement practices; and (5) grant plaintiffs such other and further telief as may be appropriate, including the award of attorney's fees. Respectfully submitted, The Champagne Law Firm mel tyes 4oe Lyell H. Champagne, #68068 ‘The Frisco Building 906 Olive St, Suite 1110 St. Louis, MO 63101 Attorney for Plaintitis St Louis Minority Contractor's Concemed Citizens Coalition, MOKAN CCAC