Supplemental Answers of Plaintiff John LeFlore to Defendants' Interrogatories

    a 3' )t')''-

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTR.ICT OF NORTH CAROLTNA

RALEIGH DIVTSION

RALPH GINGLES, €t aI.,
Plaintiffs No. 81-803-CIV-5

V.

RUFUS EDMfSTEN, €t aI.,
Defendants

ALAN V.

v.

JA.I4ES B.

***

PUGH, €t d1.,
Plaintiffs

No. 81-1066-CIV-5
HLINT, JR., etc,, et dI.,

Defendants

DEFENDANTS I FTRST SET
OF INTERROGATORIES AND REQUESTS FgR PRODUCTTON (GINGLES)

COME NOW the Defendants in the above-styled action and,

pursuant to Rules 33 and 34 of the Federal Rules of Civil
Procedure, propound to all Plaintiffs in the action entitled
Ralph Gj-ngles, et al., V. Rufus Edmisten, etc., et a1.,

No. 81-803-CIV-5 and their attornevs of record the following
interrogatories and requests for production, to l:e ansr.rered

and responded to, pursuant to stipulation of the parties, v:ith-
in (15) days after service hereof.

In answering these interrogatoriesr 1lou are required to

furnish all information available to you, including informa-

tion j-n the possession of your._attorney or any person acting in
your behalf, and not merely such information as j-s knor,m of your

ovm personal knowledge. ff you cannot ansvrer any particular
interrogatory or interrogatories in ful1, after exercising due

diligence to secure the information soughtr so state and answer

to the extent po.ssible, specifying the reasons for lzour inatlility
to ansvrer the remainder.

You are reminded that, under the provisions of Rule 26(e)

of the Federal Ru1es of Civil Procedure, you are under a duty

to supplement seasonaLrly your response rvith respect to any

question directly addressed to (a) the identity and locati-on of



?2-

persons having knowledge of discoverable matter, and (b) the

identity of each person expected to be called as an expert

witness at trial, the subject matter on which he is expected to
testify and the substance of his testimony.

Base your responses on the statistics in vour possession

and on which you have kased your allegations.
You are under a arity to amend seasonably a prior response

if you obtain information upon the hasis of which (a) you know

that the response, though correct when made, is no longer true

or complete, and the circumstances are such that a failure,to
amend the response is, in substance, a knowinq concealment.

Any such supplemental response is to be filed and served

upon counsel of record for this Defendant rvithin fifteen (15)

days after receipt of such information.

DEFINTTIONS

Unless otherwise indicated, the followj-ng definitions
shall be applicable to these interrogatories and requests for
production:

You and your sha1l mean the Plaintiffs and each of their
attorneys, agrentsr or representatives and all other persons

acting on their behalf

Person shal1 mean any individual, partnership, fi-rm,

association, corporation or other business, governmental or

1egal entity

Address sha11 mean the post office box number, street
number, street, route number, route, town, city, county and

state of subject person, business or other entity.
'Document shall mean any r.rritten, recorded, transcribed,

punched, taped, drarm, filmed or graphic matter of any kind or

description, however produced or reproduced

Paragraph, your pgragraph, or paragraph of your Complaint

refers to the numbered paragraphs of your Complaint, as supple-

mented.



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Gross deviation is the total figure, Plus or minus, com-

from theputed by subtracting the ideal population Cistrict

total population rvithin the specific district.

census unit shalI refer to tracts ' enumeration districts '

block groups and blocks as these terms are defined hy the

United States Bureau of the Census.

Ideal population district- or equal population of the State

of North Carolina divided by the total number of State House

of Representatives or State Senate districts.

number of each Senate district refers to those numbers applied

to each legislative district for identification purPoses.

District refers to districts vrithin the Fouse of Repre-

sentatives and/or.Senate of the State of llorth Carolina.

Percentage by rvhich a district 4eviates from the ideal

population district j-s that percentage which is computed by

dividing the gross deviation by the ideal population district

and converting that fraction into a Percentage.

Overall range of deviations is that term usecl which is

identical in meaning to the term used t'V the United States

Supreme Court in Mahan v. Hovrell, 410 U.S. at 319, as "maximum

percentage variation from that ideal" or "maximum variation or

maximum deviationr" 410 U.S. at 323. This overall range of

deviations is equal to the sum of the percentage by which the

most populous district deviates from the ideal population

district and the percentage by which the least PoPulous district

deviates from the ideal population district, ignorino the plus

and minus signs of these Percentages.

Your aevised reapPortionment P_Ian or your revised Plan or

,orrt lilro,rt t".rr="u t.uoootaror,*.ta otont=t' ot ,o"
revised proposal or your proposal j-s that plan or ProPosal rvhich

emboclies any adjustments, changes, alterations, of amendments to

the basic legislative reapportionment plans ernbodied in Chapters

4 and 5 of the Extra Session Laws of 1982 which the Plaintiffs

Number of each district, number of each House district or



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suggest as possible solutions to various alleged deficiencies

within the legislative reapportionment plans. Describe this

plan or proposal in terms of incremental changes to the plan

embodied in Chapters 4 and 5 of the Extra Session Latars of L982.

***

1. State the full name, d9e, date

address, place of birth, and place

tiff in th-is action.

birthr Pr€s€Dt residence

employment of each plain-
of

of

2. State (a) whether each plaintiff has read the introductory

paragraphs to these interrogatorj-es and (b) trhether each plain-

tiff understands that these interrogatories are to te ansvrerd

under oath.



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3. fn Paragraph 109 of your Complaint, you alIege that the

reapportionment plan for the House of Representatives, Chapter 4

of the Extra Session Laws of 1982, "has the effect of and was

enacted vrith the purpose of discriminating against black

citizens of the State of North Carolina, and of denying blacl<

citizens the ability to use their vote effectively.u !.fith regard

to this allegation, set out the follorving:

a. The numher of each House district v,here the reappor-

tionment plan substantially dilutes or minimizes the

voting strength of blacks within that House district.
b. Set out specifically the objections vrhich you or any

of the plaintiffs have to the specific House district and

its composition.

c. Set out in detail the effect of the House plan in
substantially diluting or minimizing the voting strength

of the plaintiffs or memhers of their c1ass. In ansvrering

this interrogatory, set out, at a minimum, the foIlor^ring:

1. Flach v.rhole county, tovrnship or census unit which

the Legislature included or omitted within each House

district with the effect of diluting the plaintiffs'

voting strength.

2. Each whole county, township, or census unit which

the Legislature included or omitted within each liouse

district with the purpose of diluting the plaintiffs'

voting strength



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4. In Paragraph 115 of your Complaint, you allege that Chapter 5

of the Extra Session Lavrs of L982, "has the effect of and was

enacted vrith the purpose of discriminating against h,lack voters

and of diluting the vote of plaintiffs and other black citizens
of the State of North Carolina and of denying black citizens

the right to use their vote effectively." With regard to this

allegation, set out the following:

a. The number of each Senate district where the reappor-

tionment plan substantially dilutes or minimizes the

voting strength of blacks wi-thin that Senate district.

b. Set out specifically the objections vrhich you or any

of the plaintiffs have to the specific Senate district

and its composition.

c. Set out in detail the effect of the Senate plan in

substantially diluting or minimizing the voting strength

of the plaintiffs or members of their class in the same

manner as in responding to interrogatory number 3 (c) .



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5. For each whole countyl township, or census unit which you

listed in your answer to interrogatory number 3 (c) (1) , set out

the House district wherein you would propose to place that
particular whoLe county, township, or eensus unit within the

Legisldture's reapportionment plan embodied in Chapter 4 of

the Extra Session Laws of 1982.



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6. For each whole county, township, or census unit which you

listed in your answer to interrogatory number 3 (c) (2), set out

the House dlistrict vrherein you would ProPose to place tfrit
particular whole county, tovmship, or census unit within the

Legislature's reapportionment plan as embodied in Chapter 4

of the Extra Session Laws of 1982.



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7. Set out the following:
a. A11 House districts wherein you u.rould alter the

legislative reapportionment plan to correct the alleged

deficienci.Js set out in your answer to interrogatory
number 3.

b. Within each House district cited in your response

to interrogatory number 7(a) set out the following:
1. Each whole county, township, or census unit
included rvithin the House district under your proposaL.

2. The total population of the revj-sed House district
under your proposal.

3. The total number of whites within the revised

House district under your proposal.

4. The total number of blacks rvithin the revise<l

House district under your proposal.

5. The percentage of whites within the revised
House district under your proposal.

6. The percentage of blacks vrithin the revised

House district under your proposal.

7. The gross deviation of each revised llouse

district under your proposal.



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8. rn your revised reapporti.onment proposal as set forth in
your answer to interrogatory nurnber 7, have you placed the
same whole county, townstrip, or census unit within two House

districts or have you omitted to place a whole county, township,

or census turit within a House district?

9. Set out the following:
a. A11 Senate districts wherein you would alter the

legislative reapportionment plan to correct the alreged

deficiencies set out in your answer to interrogatory
number 4.

b. Within each Senate district cited in your answer

to interrogatory number 9(a), set out the following:
1. Each whole county, township, or census unit
included within the Senate district under your

proposal.

2. The total population of the revised Senate

district under your proposal.

3. The total nr:rnber of whites within the revised

Senate district under yorrr proposal.

4. The total number of blacks within the revised

Senate district under your proposal.

5. The percentage of whites within the revised

Senate district under your proposal.

5. The percentage of blacks within the revised

Senate district under your proposal.

7. The gross deviation of each revj-sed Senate

district under your proposal.



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10. In your reapportionment proposal as set forth in your

answer to interrogatory number 9, have you placed the s:rme

whole county, twnship, or census unit within two Senate

districts or have you omitted to Place a whole county, town-

shipr oE census unit within a Senate district?

1I. With respect to ei.ther Chapter 4 or 5 of the Special Session

Laws of Lg82, do you contend that the Federal or State Constitut-

ion requires the Legislature to apportion each legislative district

so that the overall range of deviations is less than it presently

is in the House or Senate Plan?



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L2. ff you answered interrogatory number 11 in the affirmati-ve,
set out the follovring:

a. The Legislaturers duty under the Federal and State

Constitutions with regard to maximum permissible overall
range of deviations from the ideal population House district.
b. Each House district which deviates from this overall
range of deviations divided by two.

c. The Federal and State Constitutional provisions on

which you base your answer to interrogatory number 12 (a) .

d. The Legislature's duty under the Federal and State

Constitutj-ons with regard to maximum permissible overall
range of deviations from the ideal population Senate district.
e. Each Senate district which deviates from this overall
range of deviations divided b1z two.

t. The :Federal and State Constitutional provisions on

which you base your answer to interrogatory number 12 (d) .



o
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13. Set out the following:

a. Name each new llouse or Senate district whieh you

contencl has imlrerm.issible Iarge variances from population

equality.

b. For each district described in your answer to

interogatory number 13 (a) set out the gross number of

residents and the percentage that each distriet departs

from the ideal population district or equal population.



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14. With respect to your allegatiOns in paragraph 109 and

Paragraph 115 that the House and senate reapportionment plans

have "the effect of and (were) enacted with the purpose of
discriminating against black voters and of diluting the vote

of plaintiffs and other black citizens of the state of North

Carolinar " (a) define "diluting" in both guantitative and

descriptive terms, (b) with regard to this allegation, set out
eacl: House and senate district within ilre legislative reappor-
tionment plans where you a11ege the Legj.slature intended to
dilute the voting strength of black citizens or (c) rvhich had

the effect of diluting the voting strength of black citizens.



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15. If you identified any House district in your answer to

interrogatory nr:mber L4 , set out the f olIor"'ing:

a. Each vrhole county, township, or census unit within

each House district listed in your ansl+er to interrogatory

number 14 which was included within the identified House

district for the Purpose of diluting black voting strength'

b.Eachwholecounty,tovrnship,orcensusunitrvithin
each House district listed in your ansr+er to interrogatory

number 14 which was included rvithin ti:e identified House

district which had the effect of diluting blacl: voting

strength.

c.Eachwholecountyrtownshiprorcensusunitvrithin
anyHousedistrictwhichwasexcludedfromanyHouse

district listed in your answer to interrogatory number 14

for tl:e purpose of diluting black voting strength

d. Each whole county, torvnship, or census unit within any

House district vrhich rvas excluded from any House district

listed in your ansr.rer to interrogatory number 14 which

had the effect of diluting or minimizing black voting

strength.



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16. rf you have identified any llouse district in your answer

to j-nterrogatory number 14, set out the follovring:

a. A.11 House districts wherein you vrould alter the

legislative reapportionment plan to correct to alleged

cleficiencies set out in Paragraph 109 of your complaint.
b. within each House district set out in your answer to
interrogatory number 16 (a) , set out the followine:

1. Each whole county, township, or census unlt vrithin
the revised House district under your proposal.

2. The total population of the revised llouse district
under your proposal.

3. The total number of whites vrithin the revised

House district under your proposal.

4. The total number of blacks rvithin the revised

Ilouse district under your proposal.

5. The percentage of whites within the revised House

district under your proposal.

6. The percentage of blacl,,s vrithin the revised House

district under your proposal.

7. The gross deviation of the revised llouse district
under your proposal.



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L7. In your revised reapportionment proposal as set forth in
your ansr.rers to interrogatory number L5, have vou placed the

same whole county, tow:nshi.p, or census unit within tvro House

districts or omitted to place a whole county, township, or

census unit within a House district?

18. If you identified any Senate district in your answer to
interrogatory number 14, set out the following:

a. Each whole county, tovrnship, or census unit within
each Senate district listed in your ans$rer to j-nterroga-

tory number 14 which was included within the identified
Senate district for the purpose of diluting or minimizing

black voting strength.

b. Each vrhole county, tor.mship, or census unit within
each Senate district listed in your answer to interroga-
tory number 14 which was included vrithin the identified
Senate district which has the effect of diluting or

minimizing black voti-nq strength.

c. Pach whole county, township, or census unit vrithin

any Senate district which.-was excluded from any Senate

district listed in your ans\^rer to interrogatory number 14

for the purpose of diluting or minimizinq black voting

strength.

d. Each whole county, township, or census unit within

any Senate district which was exclude<l from any Senate

district listed in your anshrer to interrogatory number 14

which had the effect of diluting or mj-nimizing black

voting strength.



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19. If you have identified any Senate district in your ansvrer

to interrogatory number 14, set out the fo1lowing:

a. A1l Senate districts wherein you vrould alter the

legislative reapportionment plan to correct the alleged

deficiencies set out in Paragraph 115 of your Complaint.

b. Within each Senate district set out in your anst.rer to

interrogatory number 19(a), set out the following:

1. Each whole county, township, or census unit within

the revised Senate district under your proposal.

2. The total population of the revised Senate district

under your proposal.

3. The total number of whites r.rithin the revised

Senate district under your proposal.

4. The total number of hrlacks v:ithin the revise<1

sendte district of your proposal.

5. The percentage of whites rvithin the revised

Senate district under your proposal.

6. The percentage of blacks rvithin the revised

Senate district under your proposal.

?. The gross deviation of the revised Senate district

under your ProPosal.



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20. Will you attempt to prove that contemporaneous statements

of legislators regarding chapter 4 and 5 of the Extra session

Laws of 1982 rere made which indicate ttre purpose of discrimin-
ating against black voters andr/or of diluting black voting
strength on the part of the Legislature or any members thereof?

If so, set out the following.
a. The name of each Legislator who made such a statement.

b. The place he or she made the statement.

c. The date of the statement.

d. The exact statement he or she made.

e. The source through which you learned of the statement.

f. The name, address, and telephone number of such source.

g. If reported j-n the media, the name, address, and

telephone number of each such media outlet.
h. The date each media report was made and by whom.

i. Please attach a copy of each such media report.



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21. Does either the House of Representatives or senate

reapportionment plan enacted by the Legislature in 1982 enhance

or maintain the opportunity of any black incumbent to continue
in offj-ce? rf so, name the incumbent and the manner in which
the opportunity was enhanced or maintained.



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22. Does either the House of Representatives or Senate

reapportionment plan enacted by the Lecislature in L982 lessen

the opportunity of any brack incumbent to continue in office?
ff sor name the incumhent and the manner in which the oppor-

tunity was lessened.



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23. Do you al.lege that any whole counties, townships, or
census units in the 1982 legislative reapportionment prans

rrere transferred from any district where they would have had

a major impact in the election of a bLack Leeislator to one

where the electoral impact would be minor in the eLection of
a black Legislator?



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24. rf yo.ur answer to interrogatory number 23 r.ras in the

affirmative, set out the following;
a. fdentify the '.rhole county, township or census unit.
b. The House or Senate district wherein the whole county,

township t ot census unit is now l_ocated.

c. The percentage of blacks rvithin the House or senate

district as presently constituted in the I9g2

legislative reapportionment plans.

d. The number of people within the district as presently
constituted.

e. The tlouse or Senate district in r^/hich you believe
this whole county, township, or census unit should he

relocated, its present percentage of blacks and

number of people.

f. The percentage of blacks within the trvo districts
if the svritch you advocated vrere made.

g. The total number of residents in the tv:o districts
if the whole county, township, or census unit were

switched as you advocate.

h. The number(s) or name(s) of the vrhole county, tor.vnship,

or census unit previously specified in answer to
interrogatory number 24(a) in order to satisfy the

one-man, one-vote requirement.

i. The House or Senate district from which such v:hoIe

county, tovrnship, or eensus unit would be removed.

j. The gross deviatj-ons of all Ilouse and senate districts
by district as a consequence of the foregoing shifts
in whole county, township, or census units.



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25. rf you have dravrn or have in your possession statewide

reapportionment maps for the House of Representatives and the

senate which you prefer to be adopted, prease attach the same.

26. If you have no maps referred to in.interrogatory number 25,

please attach a drarving of each new district and the districts
contiguous to that district if such district vrere dratyn as you

advocate in response to interrogatory number 24.



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27. In your Paragraph 12I you state that "!he intent and effect
of the apportionment of the North Carolina General Assemhly

enacted in Chapters { and 5 of the Extra Session Lavrs of 1982

are to...deny plaintiffs ttreir right to use their vote effec-
tively. r

B. Explain the phrase rright to use their vote effec-
tivelyro as you employ it.

. b. Identify specifieally each component of the reappor-

tionment plans whieh you contend denied the plaintiffs
the right to use their vote effecti,veLy and explain

hovr the effective use of their vote was so denied.



-26-

28. In Paragraph 127 you state that "the State of north Carolina

has a history of discrimination against black citizens in its

voter registration practices and in other election lawsr

regulations and practices rvhich have prevented plaintiffs and

other black citizens of this State from voting or from using

their votes effectively. " with respect to your Paragraph 127,

set forth the follorving:

a. All voter registration practices which have occurred

hj-storically in this SEate vrhich have prevented

plaintiffs and other black citizens of this State

from voting or from using their votes effecti-vely.

b. A11 voter registration practices in this State which

continue to prevent plaintiffs and other black

citizens of this State from voting or from using

their votes effectively.

c. All election laws which have historj-caI1v been

employed in this State to prevent plaintiffs and other

blacl'. citizens of this State from voting or from

using their votes effectively.
d. A11 election laws which continue to be enforced v'hich

prevent plaintiffs and other black citizens of this

State from voting or from using their votes effectively.

e. All regulations which have historicalllr been used to

prevent plaintiffs and other blacks of this State from

voting or from using their votes effectively.
f. All regulations which continue to be used to prevent

plaintiffs and other black citizens of thj-s State

from voting or from using their votes effectively.
g. All practices which have historically been used by the

State to prevent plaintiffs and other blacl: citiz.ens

of this State from voting or from using their votes

effectively.

h. AII practices which continue to be used to prevent

plaintiffs and other black citizens of this State

from voting or from us5-ng their votes effectively.



29. Can you state specific instances of the use of voter
registration practices or other election lawsr oE regulations,
or practices which have been used to prevent plaintiffs and

other black citizens of this state from voting or from using

their votes effectively? If sor list chronolooical.ly, by

date, the occurrence of each incident of preventing plaintiffs
and other black citizens of this state from voting or from

using their votes effectively.



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30. Your Paragraph L28 states "the North carorina General

Assembly has historically been unresponsive to the needs of
the blac]'- ci-tizens of the state of North carolina." 9et forth
the following:

a- Exprain the phrase "needs of the black citizens of
the State of North Carolinar,, as lrou employ it.

b. Give specific examples of occasions on whieh the llorth
carolina General Assembly has been unresponsive to
the needs of the black citizens of the state of North

Carolina and explain your anst{er.



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31. Do your statistj.cs indicate that any past lrlorth Carolina
House of Representatives or Senate reapportionment p1ans, enacted
by the Legislature after any decennial census, provided blacks
with a greater opportunity to erect representatives of their
choosing than do the current plans embodiect in Chapters 4 and 5

of the Extra session Lar.rs of Lgg2? rf So, identify the plan(s)
and explain your ansvrer.

32. Do your statistics indicate that any past North carolina
House of Representatives or senate reapportionment prans,
enacted by the Legislature after: any decennial censusr pro-
vided blacks with a greater opportunity to use their vote effec-
tively than do the current plans embodied in chapters 4 and 5

of the Extra session Laws of t9g2? rf so, i-dentify the plan(s)
and explain your anshrer.



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33. Do your statistics indicate that any past North Carolina

House of Representatives or Senate reapportionment plans,

enacted by the LegisLature after any decennial census, provided

blacks with as great an opportunity to elect representatives of

their choosing as do the current plans embodied in Chapters

4 and 5 of the Extra Session Laws of L982? If sor identify the

plan(s) and explain your answer.

34. Do your statistics indicate that any past Uorth Carolina

House of Representatives or Senate reapportionment p1ans,

enacted by the Legislature after any decennial census, provide{

blacks with as great an opportunity to use their vote effec!
tively as do the current plans embodied in Chapters 4 and 5

of the Extra Session Laws of L982? If sor ictentify the plan(s)

and explain your answer.



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35. State the name, address, employment, and telephone number

of each Person you t ill or may call as a witness at the trial
of this natter (rvith the exception of those experts, if any,

referred to in the next interrogatory) and further state the
substance of each such personts expected testinony.



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36. state the name, address, employm'ent, telephone number,

and qualifications of each Person you exPect to call as an

expert witness at the trial of this matter and further state

the subject matter on vrhich each such expert is expected to

testify.



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37. As to each expert named in the answer to interrogatory
number 36, state the substance of the facts and opinions to
which said experts ate expected to testify and give a summary

of the grounds for each opinion.



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38. Please attach to your answers to these interrogatories
true, complete, and correct copies of any and all documents

prepared by any such experts 6a €Xpert re}ating to this action.

39. State the name, address, telephone nurnlcer, and qual-ifications
of each expert whom you have retained or specifically employed

in anticipation of litigation or preparation of trial and who is
not expected to be cal1ed as a v'itness of the trial of this action.



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40. rndieate each occasion on vrhich each person named in the
answers to interrogatories number 35 and 36 has testified in
other legal proceedings regarding state legislative reappor-
tionment and describe the nature of his or her testimony in
each of those proceedingfs.

Respectfully submitted this *" 29 day of !,tarch , Lg82.

RUFUS L. EDHTSTEN
ATTORNEY GENERAL

Post Office Box 629
Raleigh, North Carolina 27602Telephone: (9I9) 733-3377

Norma Parrell
Tiare Smiley
Assistant Attorndy General

John Lassiter .

Associate Attorney General

Jerris Leonard
Kathleen KeenanJerris Leonard & Associates, p.e.
900 17th Street, I{.W.
Suite L020
$.rashington, D.C. 20006
Telephone: (202) 872-1095

;

{

aJ-Iace, .Tr.
Attorney Geg6ral

Legal ^e.ffair'sey General's Office. Department of Justj.ce



-36-

CERTTFICATE OF SEFVICE

r hereby certify that r have this day served the foregoing
InteEogatories and Reguests for Production upon plaintif f :'s

Attorneys by placing a copy of same in the united states post

Office, postage prepaid, addressed to:
,J. Levonne Chambers
Leslie l^Iinner
Chambers, Ferguson, Watt, Wallas,

Adkins & Fu11er, p.A.
951 South Independence Boulevard
Charlotte, North Carolina 29202

Jack Greenbert
James I"1. Nabrit, Iff
tlapeoleon B. .Wi11iams, Jr.
10 Columbus Circle
New York, Ner.r york 10019

Arthur J. Donaldson
Burke, Donaldson, Holshouser & Kererly
309 North t'Iain Streeti: -salisbury, North Carolina 2g144

Robert Il. llunter, Jr.
Attorney at Law
Post Office Box 3245
201 West Market Street
Greensboro, North Carolina 27402

This the 4- day of t{arch , lgl2.