Correspondence from Winner to Williams; Winner to Dupree; Winner to Leonard; Gingles v. Edmisten, Pugh v. Hunt, Cavanaugh v. Brock Discovery Stipulations

Correspondence
August 18, 1981

Correspondence from Winner to Williams; Winner to Dupree; Winner to Leonard; Gingles v. Edmisten, Pugh v. Hunt, Cavanaugh v. Brock Discovery Stipulations preview

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  • Case Files, Thornburg v. Gingles Working Files - Williams. Correspondence from Winner to Williams; Winner to Dupree; Winner to Leonard; Gingles v. Edmisten, Pugh v. Hunt, Cavanaugh v. Brock Discovery Stipulations, 1981. aa62f287-d992-ee11-be37-6045bdeb8873. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/0c0b6225-ae90-41de-9630-1b9965e7cada/correspondence-from-winner-to-williams-winner-to-dupree-winner-to-leonard-gingles-v-edmisten-pugh-v-hunt-cavanaugh-v-brock-discovery-stipulations. Accessed May 21, 2025.

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    JULIUS LEVONNE CHAMBERS

JAMES E. FERGUSON. II

MELVIN L. WATT

JONATHAN WALLAS

KARL AOKINS

JAMES C. FULLER. JR.

YVONNE MIMS EVANS

JOHN W. GRESHAM

RONALD L, GIBSON

GILOA F. GLAZER

LESLIE J, WINNER ,
JOHN T, NOCKLEBY'

. OF O. C. BAR ONLY

CHAMBERS, FERGUSON, WATT, WALLAS, ADKINS & FULLER, P.A
ATTORNEYS AT LAW

SUITE 730 EAST INOEPENDENCE PLAZA

951 SOUTH INDEPENOENCE BOULEVARD

CHARLOTTE. NORTH CAROLINA 2A2O2
TELEPHONE (704' 375.A461

August 18, L982

Mr. Napoleon Williams
Ms. Lani Guinier
NAACP Legal Defense Fund
Suite 2030
10 Columbus Circle
New York, New York 10019

Mr. Steve Suitts
Southern Regional Council
75 Marietta Street
Atlanta, Georgia 30303

Re: Gingles v. Edmisten

Dear Friends:

This is the person that Bernie Grofmanreferr-edme to. I
have not read these yet but I forward them Eo you for your
information. Perhaps we can discuss it in a few days after
we have all had a chance to read it.
Peace.

LJW: ddb
Enclosure

Sincere

Winner



JULIUS LEVONNE CHAMBERS

JAMES E, FERGUSON, II

MELVIN L, WATT

JONATHAN WALLAS

KARL ADKINS

JAMES C, FULLER, JR,

YVONNE MIMS EVANS

JOHN W. GRESHAM
RONALO L. GIBSON

GILDA F. GLAZER

LESLIE J. WINNER

JOHN T. NOCKLEBY'

. OF O. C, BAR ONLY

CHAMBERS, FERGUSON, WATT, WALLAS, ADKINS & FULLER, P.A
ATTORNEYS AT LAW

SUITE 730 EAST INDEPENDENCE PLAZA

95,I SOUTH INOEPENDENCE BOULEVARO

CHARLOTTE, NORTH CAROLINA 2A2O2
TELEPHONE (704) 375-e46r

August 18, L982

J. Winner

HonorabLe F. T. Dupree, Jr.
United States District Court
Eastern District of North Carolina
Post Office Drawer 27585
Raleigh, North Carolina 276LL

Re: Gingles v. Edmisten; Pugh v.
Hunt

Dear Judge Dupree:

Enclosed is a copy of the proposed Discovery Stipulation
upon which the parties to these three consolidated actions
have agreed. The rather lengthy discovery time in the Gingles
and Pugh cases was felt to b-e needed because of the changes
in both the apportionment plans in question and in 52 of the
Voting Rights Acr.

On behalf of all counsel, I appreciate your patience in
giving us the time to get together and agree on this. If you
have any questions about it, f am sure that counsel for any
party would be happy to answer them.

Sincerely,

h/)*"-,.,

LJW: ddb
Enclosure
cc : Mr. James l,rlallace, Jr.

Mr. Jerris Leonard
Mr. Robert N. Hunter, Jr.
Mr. Arthur J. Donaldson
Mr. Hamilton C. Horton, Jr.
Mr. J. Rich Leonard

Leslie



CHAMBERS, FERGUSON, WATT, WALLAS, ADKINS & FULLER. P.A

SUITE 73O EAST INDEPENOENCE PLAZA

951 SOUTH INOEPENDENCE BOULEVARO

CHARLOTTE, NORTH CAROLINA 2A2O2
TELEPHONE (7O4) 375.846I

August 18, L982

JULIUS LEVONNE CHAMBERS

JAMES E, FERGUSON. II
MELVIN L, WATT

JONATHAN WALLAS

KARL ADKINS

JAMES C. FULLER. JR.

YVONNE MIMS EVANS

JOHN W, GRESHAM

RONALD L, GIBSON

GILDA F. GLAZER

LESLIE J, WINNER

JOHN T, NOCKLEBY'

. OF O, C, E|AR ONLY

Mr. J. Rich Leonard
United States District Court
Eastern District of North Carolina
Post Office Box 25670
Raleigh, North Carolina 2761L

Re: Gingles v. Edmisten; Pugh v.
Hunt & Cavanagh v. Brock

Dear Mr. Leonard:

Enclosed are ten copies of the proposed Discovery Stipulation
which the parties to these three consolidated actions have
signed. Six of the copies are for your use. I have enclosed
the other four copies with the request that you send a "filed"
stamped copy to each party.
under separate cover r am sending a copy of this to Judge Dupree.
rt is my understanding that he must approve it in order for it
to have any effect. rf there is anything else which r need to
do, please let me know.

Thank you for your cooperation.

h/r*^,-
Les I^linner

LJW: ddb
Enclosures
cc: Mr. James Wallace, Jr.

Mr. Jerris Leonard
Mr. Robert N. Hunter, Jr.
Mr. Arthur J. Donaldson
Mr. Hamil-ton C. Horton, Jr.



IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF NORTH CAROLINA

RALEIGH DIVISION

RALPH GfNGLES, et a1.,
Plaintiffs

v

RUFUS EDMISTEN, et dI.,
Defendants

ALAN V. PUGH, €t a1.,
Plaintiffs

v

JAMES B. HUNT, JR., etc., €t aI.,
Defendants

JOHN J. CAVANAGH, JOHN W. FARE,
et a1.,

v

)
)

) uo. B1-803-crv-s
)

)
)

NO. B2-545-CrV-5

NO. B1-1066-CrV-s

Plaintiffs )

)

)
ALEX K. BROCK, etc., et a1., )

Defendants )

DISCOVERY STIPULATIONS

counsel for all parties in the above captioned actions
have conferred and have agreed on the folrouring schedule for
completion of discovery:

1. The parties to cavanagh v Brock wirl complete dis-
covery by October B, 1982.

2. The parties to pugh v Hunt and g:ng!€E v Edmisten

will complete discovery by March J-, 1983.

3 - The parties to pugh v Hunt and Gingles v Edmisten

will be prepared to go to trj-al ty April l, 1993.



f

-2-

4. The parties to Cavanagh v Brock will be prepared to

go to trial as to those issues which are not disposed of by

summary judgment by April L, 1983.

DateW
Date

Date ?A*rru

PIaint iffs

Attorney for Cavana

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