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Cease and Desist for Mother Randle

This letter from Damario Solomon-Simmons, attorney for Lessie Benningfield Randle, demands that the 1921 Tulsa Race Massacre Centennial Commission cease using Ms. Randle's name and likeness without authorization. The letter cites a specific instance where the Commission's project director referenced Ms. Randle during a panel discussion. The letter asserts that the Commission has not genuinely supported Ms. Randle and rejects her requests to meet and for transparency regarding the Commission's records. Ms. Randle does not consent to the Commission using her story and renews her request to discuss tangible support for the survivors.
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100% found this document useful (1 vote)
3K views3 pages

Cease and Desist for Mother Randle

This letter from Damario Solomon-Simmons, attorney for Lessie Benningfield Randle, demands that the 1921 Tulsa Race Massacre Centennial Commission cease using Ms. Randle's name and likeness without authorization. The letter cites a specific instance where the Commission's project director referenced Ms. Randle during a panel discussion. The letter asserts that the Commission has not genuinely supported Ms. Randle and rejects her requests to meet and for transparency regarding the Commission's records. Ms. Randle does not consent to the Commission using her story and renews her request to discuss tangible support for the survivors.
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DAMARIO SOLOMON-SIMMONS

601 S. Boulder, Ste 600


Tulsa, Oklahoma, 74119
Telephone: (918) 551-8999
Facsimile: (918) 582-6106
E-Mail: [email protected]

April 14, 2021

VIA E-MAIL AND CERTIFIED MAIL

Phil Armstrong ([email protected])


Project Director
1921 Tulsa Racial Massacre Centennial
Commission
10 N. Greenwood Ave
Suite 102
Tulsa, OK 74120

Re: Lessie Benningfield Randle

Dear Mr. Armstrong:

My firm, along with my co-counsel Schulte Roth & Zabel LLP, represents Lessie
Benningfield Randle (“Mother Randle”), a survivor of the 1921 Tulsa Race Massacre. We write
to demand the 1921 Tulsa Race Massacre Centennial Commission (“the Commission”) cease-and-
desist from further unauthorized use of Mother Randle’s name or likeness in promotion of the
Greenwood Rising project and all other activities of the Commission.

We write this letter because on March 23, 2021, you participated as a panelist for an event
entitled “Better Conversations – Reconciliation, Resilience, and Public Memory,” hosted by the
Oklahoma City National Memorial & Museum. The event was live streamed, and the recording
remains available on YouTube. You were identified by the host of the event as the “Project
Manager for Greenwood Rising.”

While describing the experience visitors would have at Greenwood Rising, you expressly
referenced Mother Randle. Specifically, you stated:

By the way, we do know … she’s affectionately called Mother Randle and she’s
what we know as the last known living survivor in Tulsa, and I think there may be
another 1, but unfortunately you know we’re at that point where … I think she’s 106
years old, but we are dedicating much this work to their lives.

1
There are actually three known living survivors—106-year-old Viola Fletcher, 106-year-old-Lessie Benningfield
Randle, and 100-year-old Hughes Vann Ellis.

1
Mother Randle is indeed one of the last living survivors of the 1921 Tulsa Race Massacre,
but as you know, she has no association with the Commission or the Greenwood Rising Project
(“Rising”). If the Commission were genuine in its words regarding Mother Randle, it would be
revealed through tangible actions supporting her, which are notably missing. For example, the
Commission did not allow Mother Randle (or the other two known survivors), any input regarding
the formation, membership, and/or goals of the Commission. To-date the Commission has never
invited Mother Randle to any Commission meetings or events. To-date the Commission has not
discussed with Mother Randle how she feels about the Commission pushing narratives that
“Greenwood is Rising,” “Tulsa Triumphs,” or that “Tulsa is leading America’s journey to racial
healing,” while she still lives in poverty because of the Massacre and its continued harm.

Further, you are aware that the Commission refused to meet with Mother Randle and her
representatives despite repeated requests for meetings and dialogue. You are also aware that the
Commission rejected Mother Randle’s request that the Commission utilize some of the $30M the
Commission raised “leveraging the rich history of the Tulsa Race Massacre” and/or revenue
generated by the Rising museum to directly benefit the living survivors and descendants of those
who suffered because of the Massacre. You are also aware that on February 16, 2021 the
Commission rejected Mother Randle’s request to inspect the Commission’s records under the
Oklahoma Open Records Act.

Given this treatment, Mother Randle and her family were shocked to hear you say the
Commission is “dedicating” much of your work to her. Additionally, by invoking Mother Randle’s
name without her consent and stating that the Greenwood Rising project is “dedicated” to her, the
Commission created the false impression that it supports Mother Randle’s quest for justice and
reparations and that Mother Randle is a direct beneficiary of the Commission’s work. This is
another example of third parties with no association to Mother Randle improperly co-opting her
experiences and life story for their own purpose.

To that end, until the Commission is prepared to at least listen and discuss how it can best
work on her behalf she will not participate in any Commission events related to the centennial or
otherwise, she does not authorize the use of her name or likeness in connection therewith, and she
wants to impress upon the Commission that it does not speak for her or her family.

In closing, please note that Mother Randle specifically renews her request for the
Commission to meet with her and her representatives to discuss how the Commission could
tangibly support her and the other two known survivors who have waited 100 years for justice.
And she again urges the Commission to allow her and her family to review the Commission’s
records.

Sincerely,

Damario Solomon-Simmons, Esq., M.Ed.


FOR THE FIRM

2
cc: Michael E. Swartz, Esq.
Spencer Bryant, Esq.
Steven Terrill, Esq.
Eric Miller, Esq.
Maynard Henry, Esq.
Lashandra Peoples-Johnson, Esq.
Cordal Cephas, Esq.
TRMCC Commissioners

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