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

Public Court Documents
January 22, 1986

Cite this item

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

4 pages

Document text

The following text has been generated automatically during the document scanning process. It may contain errors, omissions, or incorrect formatting. Please refer to the PDF document if this text is not usable.

Download

By downloading, publishing, or reusing the Materials outside of the Website, you hereby confirm and attest that you have read and agree to the LDF Archival Collection Terms of Use linked below. We draw your attention to the following:

For those Materials owned by LDF, your use of the Material outside the Site is solely for one or more of the following (the “Permitted Purposes”):

Non-commercial research and private study;
Teaching, scholarship and instruction (including distance learning);
Non-commercial print and non-commercial online use;
Criticism, comment or news reporting; or
For people with visual disabilities (See Section 121 of the Copyright Act).
For those Materials not owned by LDF you understand that:
- It is your responsibility to determine whether the way you plan to use the materials falls within the copyright exception of Fair Use.
- For any use outside of Fair Use, it is your responsibility to seek and obtain all required permissions from any existing rights holders.

LDF hereby grants you the right to use LDF owned Materials for the Permitted Purposes without seeking further permission from LDF.

If you publish or redistribute any Materials (including excerpts and quotes), you must include a credit line and/or proper citation to the source of the Material. However, you may not use the name of LDF in any manner which creates any false association between you and LDF or that incorrectly implies any sponsorship or endorsement of you by LDF.

NOTICE: Uses that do not comply with these Terms or that do not fall under Fair Use (or another exception) may make you liable for copyright infringement.

Read the full LDF Archival Collection Terms of Use Here.

I agree to the terms and conditions for use of this content.

If you would like to use this content in other ways, contact us at

Impact area
- Political Participation
Topic
- Voting Rights
LDF Attorneys
Cooperating Attorneys
Organizations
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 April 06, 2025.

Copied!

    : pe » 

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

Copyright notice

This collection and the tools to navigate it (the “Collection”) are available to the public for general educational and research purposes, as well as to preserve and contextualize the history of the content and materials it contains (the “Materials”). Like other archival collections, such as those found in libraries, LDF owns the physical source Materials that have been digitized for the Collection; however, LDF does not own the underlying copyright or other rights in all items and there are limits on how you can use the Materials. By accessing and using the Material, you acknowledge your agreement to the Terms. If you do not agree, please do not use the Materials.

Additional info

To the extent that LDF includes information about the Materials’ origins or ownership or provides summaries or transcripts of original source Materials, LDF does not warrant or guarantee the accuracy of such information, transcripts or summaries, and shall not be responsible for any inaccuracies.

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

Impact area

Topic

LDF Attorneys

Cooperating Attorneys

Organizations

Matter

Case

U.S. state

Collection

Taxonomy

Identifier

Cite this item

Copyright notice

Additional info

You may also be interested in