Mayor Paul Winfield once envisioned a new title for his former chief of staff and a reorganized city government before the job she had was eliminated in April 2011, according to an affidavit filed in Kenya Burks’ lawsuit against Winfield and the City of Vicksburg.

Burks, who is suing for more than $1.5 million in federal court, was to become director of Business and Economic Development and helped Winfield craft a new model of the city’s departments, according to the affidavit completed in May. The brief accompanied a request from Burks’ lawyers that the court compel Winfield to create a privilege log that would identify conversations from cellphone records the court ordered him in August to produce.

In the affidavit, Winfield said Burks “was aware” that her position was being cut from city government and assisted him in drafting a new organizational chart, but gives no time element. Winfield said his plans didn’t have enough support on the full, three-person city board.

“…Ms. Burks is aware that my office only carries (1) vote on the Board of Mayor and Aldermen,” read part of Winfield’s affidavit. “It is evident that I did not receive a second vote to accomplish that end.”

In August, Winfield proposed merging the city’s right of way, cemetery and landscape departments, the first specific plan for departmental reorganization since he took office in July 2009. He mentioned eliminating individual positions in the past, namely the public works superintendent for utilities and assistant director of inspection positions, both done in December 2009, as examples of moves similar to the one in which Burks lost her position.

The affidavit doesn’t specify what Burks’ salary would have been with a new job description. No position in city government carries the title of recruiting business or any sort of economic development.

In court briefs, Burks, 39, claims she was subjected to a hostile work environment and retaliation after what she says was a consensual affair soured. Winfield has denied claims of sexual relations. Burks held her job title from July 2009 to April 2011. A trial date has been set for Aug. 5, 2013.

Part of Burks’ case has been tied to obtaining Winfield’s cellphone records. The federal bench has said Winfield must produce about 21½ months of call and text data, from the time Winfield took office to when Burks’ job was eliminated by the city board.

Burks is represented by Nick Norris and Louis H. Watson Jr. of Jackson. Winfield is represented by attorneys Robert Gibbs and Vikki J. Taylor, and the city is represented by attorney Gary Friedman, all of Jackson. The first-term mayor has said the city’s defense costs will be reflected in premiums paid to its insurance carrier and that no city funds will pay Friedman directly.