Defendants' Answer to Plaintiffs' Response to Defendants' Motion to Dismiss

Public Court Documents
January 22, 1986

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Defendants' Answer to Plaintiffs' Response to Defendants' Motion to Dismiss preview

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Impact area
- Political Participation
Topic
- Voting Rights
Matter
- Dillard v. Crenshaw County
Case
- Dillard v. Crenshaw County
U.S. state
- Alabama
Collection
- Case Files
Taxonomy
Identifier
- 59994edf-b7d8-ef11-a730-7c1e527e6da9

Cite this item

Case Files, Dillard v. Crenshaw County Hardbacks. Defendants' Answer to Plaintiffs' Response to Defendants' Motion to Dismiss, 1986. 59994edf-b7d8-ef11-a730-7c1e527e6da9. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/19ed13c4-8295-4cea-8208-862a67e2688c/defendants-answer-to-plaintiffs-response-to-defendants-motion-to-dismiss. Accessed November 22, 2025.

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UNITED STATES DISTRICT COURT 

FOR THE MIDDLE DISTRICT OF ALABAMA 

NORTHERN DIVISION 

JOHN DILLARD, ET AL, 

PLAINTIFFS 

VS. CIVIL ACTION #85-T-1332-N 

CRENSHAW COUNTY, ALABAMA, 

ET AL, 

DEFENDANTS 

PICKENS COUNTY DEFENDANTS' ANSWER TO 

PLAINTIFFS' RESPONSE TO PICKENS COUNTY DEFENDANTS 

MOTION TO DISMISS 
  

Now comes the attorney for the Pickens County 

Defendants and for answer and response to Plaintiffs’ 

response to Pickens County's motion to dismiss, say under 

oath as follows: 

That the motion to dismiss filed by said Pickens County 

Defendants was made in good faith, and is an attempt to 

assert each and every legal right of the said Defendants, 

and states with particularity the grounds that constitute 

defensive matter to the amended complaint filed by the 

Plaintiffs. 

That said motion to dismiss was not filed for delay or 

to cause needless expense, but, to the contrary, was filed 

to end this litigation quickly, insofar as the said 

 



  

PAGE TWO 
  

Defendants are concerned. 

Said Defendants have previously filed a request of the 

Court for a briefing schedule and oral argument and would 

re-request said briefing schedule and oral argument, so that 

said Defendants may present its defenses fully and 

completely to the Court. 

Respectfully submitted this A) day of January, 1986. 

ATTORNEY FOR PICKENS COUNTY DEFENDANTS 

2, r 

(HP FAN 
We OO. KIRK, JR. 

CURRY & KIRK 

P. O. BOX A-B 

CARROLLTON, AL 35447 

TELEPHONE: 205/367-8125 

  

Sworn to and subscribed before me the undersigned Notary 
J. 

Public, this 2/5 day of January, 1986. 

  

W.. 0. KIRK; JR. 

an 
  

NOTARY PUBLIC 

 



  

PAGE THREE 
  

CERTIFICATE OF SERVICE 
  

I hereby certify that I have served the foregoing 
Answer upon: 

Wanda J. Cochran 

Larry T. Menefee 
James U. Blacksher 

Blacksher, Menefee & Stein, P.A. 

405 Van Antwerp Building 

P. OO. Box: 1051 

Mobile, AL 36633 

Terry Davis 
Seay and Davis 
732 Carter Hill Road 
P.O. Box 6215 
Montgomery, AL 36104 

Julius L. Chambers 

Deborah Fins 

Legal Defense Fund 

99 Hudson Street 

leth Floor 

New York, New York 10013 

W. Edward Still 

Reeves and Still 

714 South 29th Street 

Birmingham, AL 35233 

Reo Kirkland, Jr. 

Attorney at Law 

P. O. Box 646 

Brewton, AL 36427 

by placing copies of the same in the United States Mail 
properly addressed and postage paid this A / day of 
January, 1986. 

~ 

a 7 4 
  

W. O. KIRK, JR., ATTORNEY 
FOR PICKENS COUNTY DEFENDANTS 

 



  

PAGE FOUR 
  

CERTIFICATE OF SERVICE 
  

I hereby certify that I have served the foregoing Answer on 
the other Defendants 

record: 

Jack Floyd 

by 

Floyd, Kenner & Cusimano 
816 Chestnut Street 

Gadsden, AL 35999 

(ETOWAH COUNTY ) 

P. L. Martin 

215 South Main Street 
Moulton, AL 35650 
and 
David R. Boyd 
Balch and Bingham 
P.O... Box 78 
Montgomery, AL 36101 
(LAWRENCE COUNTY) 

H. R. Burnum 

P. O. Box 1618 

Anniston, AL 36202 

(CALHOUN COUNTY) 

Alton L. Turner 

404 Glenwood Avenue 

P. O. Box 207 

Luverne, AL 36049 

(CRENSHAW COUNTY) 

Warren Rowe 

B.. OC. Box 150 

Enterprise, AL 36331 
(COFFEE COUNTY) 

serving the following attorneys 

Barry D. Vaughn 
Proctor and Vaughn 

121 North Norton Avenue 

Sylacauga, AL 35150 
(TALLADEGA COUNTY) 

James W. Webb 

Webb, Crumpton, McGregor, 
Schmaeling & Wilson 
166 Commerce Street 

Montgomery, AL 36101 
and 

Lee M. Otts 

Otts & Moore 

P. O. Box 467 

Brewton, AL 36427 

(ESCAMBIA COUNTY) 

of 

by placing copies of the same in the United States Mail properly 
addressed and postage paid this 21st day of January, 1986. 

or 
  

W. O. KIRK, ‘JR., ATTORNEY FOR 
PICKENS COUNTY DEFENDANTS

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Defendants' Answer to Plaintiffs' Response to Defendants' Motion to Dismiss

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