Gingles Plaintiffs' Response to Defendants' Requests for Admission

Public Court Documents
February 1, 1983

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Matter
- Gingles
Case
- Thornburg v. Gingles
U.S. state
- North Carolina
Collection
- Case Files
Taxonomy
Identifier
- 3c228d08-d492-ee11-be37-00224827e97b

Cite this item

Case Files, Thornburg v. Gingles Hardbacks, Briefs, and Trial Transcript. Gingles Plaintiffs' Response to Defendants' Requests for Admission, 1983. 3c228d08-d492-ee11-be37-00224827e97b. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/2ac6e21f-97d1-4616-8bca-9e06b4ea038d/gingles-plaintiffs-response-to-defendants-requests-for-admission. Accessed December 07, 2025.

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

RALEIGH DIVISION

MLPH GINGLES, et 4I.,
Plaintiffs,

v.

RUFUS L. EDMISTEN, €t al.,
Defendants.

No.81-803-CIV-5

ALAN V. PUGH, et al.,
Plaintiffs,

v.

JAMES B. HUNT, JR., et 41.,
Defendants.

No. 81-1066-CIV-5

JOHN J. CAVANAGH, €t 4L.,
Plaintiffs,

v.

ALEX K. BROCK, et a1.,
Defendants.

and

RALPH GINGLES, €t al.,
Defendant - Intervenor s .

No. 82-545-CIV-5

GINGLES PLAINTIFFS' RESPONSE TO
DEFENDANTS' REQUESTS FOR ADMISSION

1. Gingles plaintiffs admit that as of January 1, L982

2 of the 5 members of the North Carolina Board of Election
were black. Gingles plaintiffs specifically deny that 2 out

of the 5 members of the Board were black at any time prior
to the filing of this action.



2. Gingles plaintiffs admit that as of January, 1983

ll members of the House of Representatives and 1 member of

the Senate are black. Plaintiffs specifically deny that there

have ever been as many as L2 black members of the General Assembly

at any time prior to the filing of this action.

3. Gingles plaintiffs admit Request for Admission ll3.

4. Gingles plaintiffs deny that black members in the 1983

North Carolina General Assembly represent every major metropoli-
tan area in North Carolina with significant concentrations of
black voters. Examples of areas not so represented include, but

are not limited to, Wilson and Rocky Mount in the House of
Representatives and Charlotte and Fayetteville in Ehe Senate.

rhis / dayor Zl ,1e83.
I

"11u,!.a- h )r-,,^---
LESLIE J. WINNER
Chambers, Ferguson, Watt, Wallas,

Adkins & Fu11er, P.A.
Suite 730 East Independence PLaza
951 South Independence Boulevard
Charlotte, North Carolina 28202
704 / 37 s-846L

JACK GREENBERG
LANI GUINIER
Suite 2030
10 Columbus Circle
New York, New York 10019

Attorneys for Defendant-Intervenors

-2-



a

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CERTIFICATE OF SERVICE

I certify that I have served the foregoing document on all
other parties by placing a copy thereof enclosed in a postage

prepaid properly addressed wrapper in a post office or official
depository under the exclusive care and custody of the United

States Postal Service, addressed to:

Kathleen Heenan
Jerris Leonard & Associates, P.C.
900 lTth Street, N.W.
Suite 1020
Washington, D.C. 20006

Arthur J. Donaldson
Burke, Donaldson, Holshouser & Kenerly
309 N. Main Street
Salisbury, North Carolina 28L54

Robert N. Hunter, Jr.
Attorney at Law
201 W. Market Street
Post Office Box 3245
Greensboro, North Carolina 27402

Wayne T. Elliott
Southeastern Legal Foundation
1800 Century Boulevard, Suite 950
Atlanta, Georgia 30345

Hamilton C. Horton, Jr.
450 NCNB PLaza
Winston-Salem, North Carolina 27L0L

James Wa1lace, Jr.'Deputy Attorney General for Legal Affairs
Attorney General's Office
North Carolina Department of Justice
Raleigh, North Caroliaa 27602

This I ary 6 kkual--, , 1983.

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Gingles Plaintiffs' Response to Defendants' Requests for Admission

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