VIRGINIA: IN THE CIRCUIT COURT FOR THE CITY OF NORFOLK

ROY L. PERRY-BEY and

RONALD M. GREEN

Plaintiffs, Case No: CL19-3928

v.

CITY OF NORFOLK

Defendants.

AFFIDAVIT OF ROY L. PERRY-BEY

Roy L. Perry-Bey, being duly sworn, deposes and states as follows:

1. I am a named Plaintiff in the above stated action.

2. I am a citizen and registered voter in the Commonwealth of Virginia,

and have suffered and will continue to suffer irreparable harm to my First

Amendment and Fourteenth Amendment constitutional rights as a citizen

who resides in the State of Virginia, and utilized the machinery of State and

Local Government and the City Hall Government Building.

3. Plaintiff’s injuries are continuing and repeated each day the Display is

permitted to remain in violation of the Constitution of Virginia and the

United States Constitution and/or otherwise by law.

4. Plaintiff is offended by defendants inaction to abide by their official decision

to remove or relocate its (“public nuisance”), and (“symbol of inhumanity”),

its Confederate Monument honoring the treasonous Southern Confederate

States of America.
5. I have personal knowledge of Defendants failure to meet its enforcement

obligations on or after August 22, 2019, until present, under the city’s power,

to the exclusion of the citizens and public, to remove and/or relocate its

Confederate Monument, that plaintiff has an interest in challenging the city’s

official failure to enforce it’s authority, and continued threat to the public

safety.

6. Plaintiff’s injury can fairly be traced to the challenged action or inaction

of Defendants and by the Court ordering defendants to remove or relocate its

Confederate Monument Honoring the Confederate States of America, that the

injury is likely to be redressed by a favorable decision.

7. Defendants has consistently denied Plaintiff’s petition to remove or relocate

its (“public nuisance”), Confederate Monument as a continued reminder to

Plaintiff of historical deprivation of their rights on account of race, sex, color,

religion, or previous condition of servitude but not limited thereto; it’s tacit

approval of Jim Crow, lynching, segregation and public display of the hate,

violence, discrimination, discord, disfranchisement, political, economic and

judicial exclusion, racial oppression, religious bigotry, subjugation, secondary

citizenship, intimidation, and white supremacy, directed at Plaintiff and treason

that the Confederate monument represents in Virginia.

AFFIDAVIT OF ROY L. PERRY-BEY
Page 3,
# Case No: CL19-3928

8. The Confederate Monument is a constant reminder to Plaintiff of the

murder of Harry Tyson Moore, assassination of Dr. Martin Luther King,

Jr., Mrs. Alberta Christine Williams King, the mother of Dr. Martin Luther

King, Jr., the murder of Medgar Wiley Evers, Emmett Till, Michael Schwerner,

Andrew Goodman, James Chaney, Michael Donald, and Vernon Ferdinand

Dahmer, Sr., and the nine men and women killed at the Charleston Emanuel

AME Church by an assassin who had posted pictures of himself online with

the Confederate flag, and so many unnamed precious souls who have suffered

and continue to suffer today, from political exclusion, police killings, murder,

institutional abuse, and the unprovoked assaults to victims of unwelcome hate

crime.

MR. ROY L. PERRY-BEY

________________________

SWORN TO AND SUBSRIBED BEFORE ME, this ___day of April, 2019

______________________
NOTARY PUBLIC

My Commission Expires:

______________________