Joint Motion for Notice and Approval of Proposed Compromise and Settlement

    IN THE UNITED STATES DISTRICT COURT FOR THE 

SOUTHERN DISTRICT OF ALABAMA 

SOUTHERN DIVISION 

WILEY L. BOLDEN, ot al ., ) 

Plaintiffs, ) 

and 

UNITED STATES OF AMERICA, ) 

Plaintiff-Intervenor, ) 

vs. ) CIVIL ACTION NO. 75-297-P 

CITY OF MOBILE, ALABAMA, ) 
et al., 

Defendants. ) 

JOINT MOTION FOR NOTICE AND APPROVAL OF 
PROPOSED COMPROMISE AND SETTLEMENT 
  

Plaintiffs Wiley L.Bolden, et al., the Defendant City of 

Mobile and Defendants Lambert Mims, Robert Doyle and Gary 

Greenough jointly move the Court tentatively to approve the 

proposed consent decree, order and notice to the class 

attached to this motion and, following notice to the 

plaintiff class and an opportunity for the objections of 

class members to be heard by the Court, finally to approve 

the proposed compromise and settlement proposed herein. 

The signature of counsel for the United States 

 



  

represents its agreement with the terms of the proposed 

consent decree, with the exception of postponement of the 

election until 1985. 

that the remedial elections should be held as soon as 

possible. 

It is the view of the United States 

Respectfully submitted this —2/ day of 

1933, 

BY: 

         . BLACKSHER 
RRY T. MENEFEE 

405 Van Antwerp Bldg. 
P.. 0. Box 1051 
Mobile, Alabama 36633 

EDWARD STILL 
REEVES & STILL 

Suite 400, Commerce Center 
2027 First Avenue, North 

Birmingham, Alabama 35203 

JACK GREENBERG 
NAPOLEON B. WILLIAMS, Jr. 
Legal Defense Fund 
Suite 2030 
10 Columbus Circle 

New York, New York 10019 

Attorneys for Plaintiffs 

  

LACKSHER, MENEFEE & STEIN, P.A.



  

BY: 
GERALD W. JONES 
PAUL F. HANCOCK 
J. GERALD HEBERT 
ELLEN M, WEBER 
Department of Justice 
Civil Rights Division 
10th & Pennsylvania Avenue, N.W. 
Washington, D. C. 20530 

  

Attorneys for the Plaintiffs-Interveno 
rs 

BY: 

CHARLES B. ARENDALL, Jr. 
WILLIAM C. TIDWELL 

RAYFORD L. ETHERTON, Jr. 

HAND, ARENDALL, BEDSOLE, GREAVES 
& JOHNSTON 

P.. 0. Box 123 
Mobile, Alabama 36601 

  

BY: 
ROG-RICKP. STOUT 

City Attorney 
Suite 3210 
First National Bank Bldg. 
Mobile, Alabama 36602 

  

Attorneys for Defendants 

CERTIFICATE OF SERVICE 
  

I do hereby certify that on January 31, 1983 a copy of the 

foregoing document was served upon counsel of record: 

Charles B. Arendall, Jr., Esquire, William C. Tidwell, 111, 

Esquire, Hand, Arendall, Bedsole, Greaves & Johnston, P. 0. 

Box 123, Mobile, Alabama 36601, Barry Hess, Esquire, City 

Attorney, City Hall, Mobile, Alabama 36602, Charles S. 

Rhyne, Esquire, and William S. Rhyne, Esquire, 1000 

 



  

Connecticut Avenue, N.W., Suite 800, Washington, D.C. 20036, 

Paul fF. Hancock, Esquire and J. Gerald Hebert, Esquire, 

Civil Rights Division, Department of Justice, 10th and 

Constitution Avenue, N.W., Washington, D.C. 20530 and Drew 

S$. Days, 111, Esquire, Assistant Attorney General, 

Department of Justice, Washington, D.C. 20530, by depositing 

same in the United States mail, postage prepaid or by hand. 

  ATTORNEY FOR PLAINTIFFS