Notice of Taking Depositions

Public Court Documents
April 5, 1991

Notice of Taking Depositions preview

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  • Case Files, Thornburg v. Gingles Working Files - Guinier. Correspondence from Hunter to Bradford Reynolds; Envelope to Guinier, 1982. eac9dc85-de92-ee11-be37-6045bdeb8873. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/dd54cb6d-befd-4fb8-abed-ac6550ce2224/correspondence-from-hunter-to-bradford-reynolds-envelope-to-guinier. Accessed August 19, 2025.

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Huxren. Hopcuex. GneExe & GooDMAN RECE'UEU
ATTOFINEYS AT I..A\^'

sutTE 4l o
GATE CIT\'SAVINOS & LOAN BUILDINO

20 I \\.EST MARKET STREET

cREE};SBORO. ^-CtRTH CAROLIN.A 2 7 40?' 3" 16
ROBERT N. HUNTER. JR.
ROIJT]RT SA\T'\'ETI HODG!.TAN
RIC}I.{RD M. (lREENE
G-A.R\'lj. COODMA\'

J. Bradforo Reynolds
Assistant Attorney GeneraL
Department of Justice
Civi I iri gi-rts Dirri sion
Iiashington, D. C.

P. O. BOX 0245
(9 r 9) 373-O9C.1
(9 t 9) 276- 134 r

JUN-gH
ffit 3!G.E-ftrrErn rfrrrn*

June B, 1982

DF" Pugh vs. Hunt, l!o. 81 E. 1066 Civ. 5
Eastern District, N.C

Dear i/rr. Rei;nolcs :

I represent the plaintiffs in a Voting Rights Act suit which
nas been brought aoainst the State of North Carolina for intentional-
racia1 discrimination in apportioning certain multimember districts
in the State of iiorth Carol-ina. The Department of Justi-ce earlier
this year interpcsed objections to reapportionment plans in the
State of il-orth Carolina in 40 "Section 5" counties where concentration
of ininoritlz memDers hat,e been submeroed into larger multimember
oistricts. Iicwever, in the remaining sixti, counties of i'iorth Carol-j-na
not covereo b]'section 5 of the Voting Riqhts Act, the irlorth Carolinaj.egislature reoistricted the state in such a v/ay that concentration
of r.rinority voters in four areas have been submerged into large
mul-timember districts. These areas are Forsyth, Wake, I,iecklenburg
anc Durham counties.

Our suit nas been brought by four Republican plaintiffs who are
ver)'concerneo about the adverse effects of this redistricting on both
poli-tical and raciaL minorities. We have previouslr, provided a 1ot of
information and data regaroing this matter to the staff of the Voting
P.ights Section in preparinE responses to the State of i'iorth Carolina's
l-'ians.

I am requesting that the Department of Justice intervene in the
suit as an amicus curia to be of assistance in proving our case of
intentional voter afscrimination. I fear without such assi-stance and
material- help in terms of legal time, expert witnesses ano financial
abilitlt to conouct depositions that we will be unable to ful1y and
aoequately litj-gate this matter. Our request is of an urgent nature.
The voting rights of many minority raciaL and political- elements of
r.lorth Carolina will be adversely effected should our cause not be
sustained in the court. For the next ten (10) )rears large segments
of iriorth Carolina's voting population will- be ef fectively unable to
exercise their franchise. Although T have not asked them to wrj-te



J. Bradford Reynolds
Page Two
June 8, 1982

such a letter, I am sure the NAACP counsel in this matter would
join in this request. I trust you will give this matter your prompt
attention ano I urge you to authorize your staff to intervene as amicus
curia in tire above-captioned lawsuit so that we might have the beneEft
Eno'-Essistance of the United States Department of Justice in litigating
this very important matter

With kindest personal regards, f drirr

RNHJT,/ms

ly,



CHAMBERS, FERGUSON. WATT, WALLAS, ADKINS & FULLER. PA

SUITE 73O EAST INOEPENDENCE PUZA

951 SUTH INDEPENOENCE rcULEVARD

CHARLOTTE. NORTH CAROLINA 2A2O2 . --\i l
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Ms. Lani Guinier
Legal Defense Fund
Suite 2030
10 Coltrmbus Circle
New York, New York 10019

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