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Uva ack fa oo te ee Bo ee we bees : eo, oe et a a eae ee en alll i at lt a ga a Aer alae "2. Commencing on or about January 1, 1964, and continuing to on or about December 4, 1964, Cecil Ray Price, Bernard L, Akin, Jimmy Arledge, Horace Doyle Barnette, Travis Maryn Barnette, Olen Lovell Burrage, James T. Harris, Frank J. Herndon, James E. Jordan, Edgar Ray Killen, Billy Wayne Posey, Lawrence Andrew Rainey, Alton Wayne Roberts, Jerry McGrew Sharpe, Jimmy Snowden, Jimmy Lee Townsend, Herman Tucker, and Richard Andrew Willis, within the Southern District of Mississippi, conspired together, with each other, and with other persons to the Grand Jury unknown, to commit an offense against the United States in violation of Section 242 of Title 18 of the United States Code, that is to say that they conspired to wilfully subject Michael Henry Schwerner, James Earl Chaney and Andrew Goodman, each an inhabitant of the State of Mississippi, to the deprivation of their right, privilege and immunity secured and protected by the Fourteenth Amendment to the Constitution of the United States not to be summarily punished without due process of law by persons acting under color of the laws of the State of Mississippi. "3, It was a part of the plan and purpose of the conspiracy that Cecil Ray Price, while having Michael Henry Schwerner, James Earl Chaney and Andrew Goodman in custody in the Neshoba County Jail located in Philadelphia, Mississippi, would release them from custody at such time that he, Cecil Ray Price, Jimmy Arledge, Horace Doyle Barnette, Travis Maryn Barnette, _Alton Wayne Roberts, Jimmy Snowden, James E. Jordan, Billy Wayne Posey, Jerry McGrew Sharpe and Jimmy Lee Townsend could and would intercept Michael Henry Schwerner, James Earl Chaney and Andrew Goodman upon their leaving the area of the Neshoba County Jail, 4 \ and threaten, assault, shoot and kill them. 4 |