Former city staffer Kenya Burks is not the only person with whom Mayor Paul Winfield had an adulterous affair since 2009, according to the most recent papers filed in her sexual harassment suit against the city.

Burks “is aware of allegations of at least two other adulterous affairs Mayor Winfield allegedly had from 2009 until 2011” and he told her of one of the affairs that occurred “just before her affair with Mayor Winfield began,” Burks’ attorneys say in a four-page brief filed Monday in response to requests from the city’s and Winfield’s lawyers to keep his cell phone records out of the case.

Burks’ lawyers do not identify anyone other than the mayor in the brief, but argue that phone calls and text data “could be relevant to show a pattern of adulterous affairs by Mayor Winfield, and potentially a pattern of hostility depending on what is discovered regarding these individuals if they are deposed later” in the case.

Burks, who was Winfield’s chief of staff from July 2009 to April 18, 2011, has sought call and text data from AT&T and C Spire Wireless, formerly Cellular South, for Winfield’s cell phone and cell numbers based from Jackson and Lucedale

In the response, her lawyers say that claims of attorney-client privilege from the city’s and Winfield’s personal counsel are without merit because cell phone companies keep text messages only up to 48 hours after they are sent.

Only when and to whom a message was sent will be contained in any data turned over by the communications providers, but they could show the mayor was “actively involved” in the decision to eliminate her position with the city, her lawyers contend.

“The information requested through these subpoenas will not show any of the conversations with the aldermen or their staff; however the frequency of these contacts along with the board minutes regarding the decision to eliminate Ms. Burks position,” reads part of the filing.

Winfield abstained from the city board’s 2-0 vote to get rid of her job, which paid $72,000 annually and involved promoting the mayor’s agenda and sitting in for Winfield at various meetings around town.

Burks was paid $9,701.59 in back overtime pay approved by the board on April 4. In the suit, she says the payment was an attempt by Winfield to continue their personal relationship. City officials said she was eligible for the money because she did not serve in a supervisory role.

Burks’ suit alleges a hostile work environment, sex discrimination and retaliation due to her relationship, which she describes as consensual. She seeks damages under federal civil rights and constitutional law.

The city has until Monday to respond formally to the suit. Gary Friedman, of the Phelps Dunbar firm in Jackson, represents the city. Louis H. Watson Jr., P.A., also of Jackson, represents Burks. Winfield’s brother, Michael, has filed motions in the case on the mayor’s behalf.