JEFFERY P. REYNOLDS, ESQ.

*
188 E. Capitol Street
Suite 1360
Jackson, Mississippi 39201
jeff@rklitigators.com

April 10, 2025

Via E-Mail (Letter & Declarations Only)

Caroline Crawley Moore Commer
Municipal Court Prosecutor
City of Starkville
P.O. Box 947
Louisville, MS 39339
c.moore@cityofstarkville.org
caroline@thecrawleylawoffices.com

Re: City of Starkville/State of Mississippi v. DeMonte Quinshun Russell

Simple Assault; Victim: Lester Riley Howell, III (“Trace”)

Dear Prosecutor Commer:

I am writing to you on behalf of my client, Mr. Lester Riley Howell, III (“Trace”), who
was the victim of a vicious, unprovoked attack by Mr. DeMonte Russell. Mr. Russell’s arraignment
is set for April 16, 2025, and my client will be in attendance.

As you know, Trace was brutally assaulted on May 8, 2024, by Mr. Russell, who at the
time was a red-shirt senior defensive end for Mississippi State University, listed as being 6’4” and
280 pounds. Trace (who, by contrast, weighed around 150 pounds) was also a student at MSU,
having just completed his junior year on the Dean’s List. He was a political science major on
MSU’s pre-law track, the President of MSU’s Pre-Law Society (two years running) and had also
served as the Vice President of the Lambda Chi Alpha Fraternity. Trace had also served as a MSU
Student Association Senator all three years of school and was recently elected by the Senate to be
the Speaker of the Senate for the coming school year. Trace had never encountered Mr. Russell
before the attack, which was a random act of violence.

Trace was sucker-punched by Mr. Russell as he was leaving Two Brothers Smoked Meats
in Starkville. The attack, which was observed by several witnesses (whose Declarations are
enclosed), occurred around 11:30 p.m. Trace was punched with such force that he was knocked
out cold and, having no control of his body, fell backwards and struck his head on the concrete. As
a result of the assault, Trace was left with a grossly swollen jaw and suffered head trauma requiring
the placement of staples in the back of his head. Trace first received help from first responders
before being transported by ambulance to Oktibbeha County Hospital (“OCH”), where he
underwent tests that showed he had (a) bleeding in two areas in his right frontal brain lobe and (b)

ONE JACKSON PLACE

188 EAST CAPITOL ST | SUITE 1360 | JACKSON, MISSISSIPPI 39201
(601) 355-7773 | www.rklitigators.com (coming soon)
Prosecutor Commer
April 10, 2025
Page 2 of 4

two bulging discs. The doctors at OCH placed three staples in Trace’s head wound to close it up
and diagnosed him with a traumatic brain injury (“TBI”). After further testing and consultations
with a neurologist at Methodist University in Memphis (“Methodist”), the treatment team decided
that Trace needed to be immediately transported to Methodist via ambulance to receive better care
under the head trauma team there. On Saturday (May 11, 2024), new testing confirmed the bulging
discs but showed that the bleeding in the frontal brain lobe to have finally stopped and Trace was
discharged that afternoon. Trace could not chew for several days due to his injured jaw, and over
the summer of 2024 continued to suffer extensive pain from the attack, very significant fatigue,
and lost his sense of smell. Trace submitted an Affidavit on November 30, 2024, nearly seven
months after the attack, that stated in part:

¶ 8. To this day, I am still recovering from the attack and continuing to face hurdles
directly caused by Mr. Russell. For example, I have only recently regained my sense of
smell, which I completely lost for months after the attack. Additionally, I still have
numbness in my fingers, tingling sensation throughout my arms and body, and periodic
headaches—none of which I encountered prior to the attack. Further, my thinking slowed
dramatically in the weeks and months after the attack, and I am just now regaining a
semblance of the clarity of thought I used to enjoy. All of these things have been plaguing
me for over six whole months

¶ 12. As stated earlier, I have had improvement but continue to experience numbness in
my hands, tingling in my body, neck pain (some days worse than others), and headaches.
What is scariest to me is that I still have scar tissue in my brain. My parents and I have read
the medical literature on what types of problems I could potentially face in the future due
to this scar tissue, which essentially creates a barrier that “prevents complete tissue
recovery” and “significantly impacts brain function,” and from having suffered a TBI in
general. For example, “changes initiated by TBI can persist for months or years after injury
and significantly affect quality-of-life issues in these patients.” In fact, a single TBI, like I
had as a result of Mr. Russell’s attack on me, can lead to other conditions such as seizures,
sleep disorders, neurodegenerative diseases like dementia, and psychiatric problems

See, T. Howell Affidavit. Trace still suffers from lingering effects of the attack today, nearly one
full year later, and will forever face the risk of further damage due to his bulging discs and TBI
suffered at the hands of Mr. Russell.

Grand Jury #24-D-133 has already found probable cause for the crime of simple assault
and has remanded the matter to Municipal Court for disposition of the charge. Miss. Code Ann. §
97-3-7(a) states:

A person is guilty of simple assault if he or she (i) attempts to cause or purposely,

knowingly or recklessly causes bodily injury to another; (ii) negligently causes bodily
injury to another with a deadly weapon or other means likely to produce death or serious
bodily harm; or (iii) attempts by physical menace to put another in fear of imminent serious
bodily harm; and, upon conviction, he or she shall be punished by a fine of not more than
Prosecutor Commer
April 10, 2025
Page 3 of 4

Five Hundred Dollars ($500.00) or by imprisonment in the county jail for not more than
six (6) months, or both

There is absolutely no question that Mr. Russell meets the standard for simple assault. In fact, Mr.
Russell admitted to his actions in a direct message sent to Trace via Instagram just days after the
attack:

Miss. Code Ann. § 99-19-153 provides general guidelines to consider when imposing a
criminal sentence:

(a) Protection of the public, restitution to the crime victim and the crime victim’s family
and just punishment for the harm inflicted are primary objectives of the sentencing
process;
(b) The financial, emotional and physical effects of a criminal act on the victim and the
victim’s family are among the essential factors to be considered in the sentencing of
the person responsible for the crime;
Prosecutor Commer
April 10, 2025
Page 4 of 4

(c) In order to impose a just sentence, the court must obtain and consider information about
the adverse impact of the crime upon the victim and the victim’s family as well as
information from and about the defendant; and
(d) The victim of the crime or a relative of the victim is usually in the best position to
provide information to the court about the direct impact of the crime on the victim
and the victim’s family.

(Emphasis added). Due to the serious injuries inflicted upon Trace, that he still suffers from to this
day, Trace—the victim—requests as follows:

1. In the event of a plea agreement:

a. The requirement to serve a minimum of 90 days in jail, day for day, with no early
release. For comparison, a 6-month sentence was upheld for a simple assault charge
in a case involving an unprovoked attack similar to what occurred here in Odom v.
State, 767 So. 2d 242 (Miss. Ct. App. 2000).
b. Restitution to be paid to Trace for all medical bills incurred as a result of the attack.
As of today’s date, that amount is $48,741.11. Restitution in the form of repayment
of medical bills has been reviewed with favor by both the Mississippi Supreme
Court and Court of Appeals. See, e.g., Powell v. State, 536 So. 2d 13 (Miss. 1988);
Smith v. State, 146 So. 3d 376 (Miss. Ct. App. 2014) (“The restitution ordered
[payment of medical expenses] was directly related to damages the victims
sustained as a result of the accident—an accident clearly caused by Smith….”).
2. In the event of a trial resulting in a conviction:
a. The requirement to serve the full 6-month sentence provided by statute, day for
day, with no early release.
b. Full restitution as stated above.

Please do not hesitate to contact me with any questions or needs.

Sincerely,

REYNOLDS | KIRSCHBERG

JPR/cht
Encl.
cc. Mr. Trace Howell (via e-mail)
Mr. Les Howell (via e-mail)