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Mississippi Burning MIBURN Case — Part 9
Page 21
21 / 87
south of Philadelphia, Mississippi, to the vicinity
of the construction site of an earthen dam, located
near Highway 21, approximately 5 miles southwest of
Philadelphia, Mississippi.
"In violation of Section 371 of Title 18 of the
United States Code.
SECOND COUNT
"On or about June 21, 1964, in Neshoba County,
Mississippi, and within the Southern District of
Mississippi, Lawrence Andrew Rainey, sheriff of
Neshoba County, Mississippi, Cecil Ray Price, deputy
sheriff of Neshoba County, Mississippi, Richard Andrew
Willis, a patrolman of the Police Department of
Philadelphia, Mississippi, 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,
Aiton Wayne Roberts, Jerry McGrew Sharpe, Jimmy Snowden,
Jimmy Lee Townsend and Herman Tucker, while acting
under color of the laws of the State of Mississippi,
did wilfully assault, shoot and kill Michael Henry
Schwerner, an inhabitant of the State of Mississippl,
then and there in the custody of Cecil Ray Price,
for the purpose and with the intent of punishing
Michael Henry Schwerner summarily and without due
process of law and for the purpose and with the
intent of punishing Michael Henry Schwerner for
conduct not so punishable under the Laws of
Mississippi, and did thereby wilfully deprive
Michael Henry Schwerner of rights, privileges and
immunities secured and protected by the Constitution
and the laws of the United States, namely, the
right not to be deprived of his life and liberty -
re
without due process of law, the right and privilege 4) /
Prt A eras ae nde coe mem a Ct eae I bee ap pee
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