Plaintiffs' Response to Pickens County Motion to Dismiss for Filing with Cover Letter

Public Court Documents
January 21, 1986

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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
- bc0389f2-b8d8-ef11-a730-7c1e5247dfc0

Cite this item

Case Files, Dillard v. Crenshaw County Hardbacks. Plaintiffs' Response to Pickens County Motion to Dismiss for Filing with Cover Letter, 1986. bc0389f2-b8d8-ef11-a730-7c1e5247dfc0. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/2d0aad41-ee8a-4ed5-ad2f-26bfb8d2301f/plaintiffs-response-to-pickens-county-motion-to-dismiss-for-filing-with-cover-letter. Accessed November 29, 2025.

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    BLACKSHER, MENEFEE & STEIN, P.A. 

ATTORNEYS AT LAW 

  

405 VAN ANTWERP BUILDING 

P. D0. BOX 105) 

MOBILE, ALABAMA 36633-1051 

JAMES LI. BLACKSHER TELEPHONE 

LARRY T. MENEFEE January 15 : 1986 (205) 433-2000 

GREGORY B. STEIN 

WANDA J. COCHRAN 

Honorable Thomas C. Caver 
Clerk, Middle District of Alabama 
P?. 0. Box 711 
Montgomery, AL 36101 

RE: John Dillard, et al. v. Crenshaw County, Alabama, 

et al.; Civil Action No. 85-T-1332-N         

Dear Mr. Caver: 

Please file the enclosed response of plaintiffs to Pickens 
County motion to dismiss in connection with the above-subject 
cause. 

Best regards. 

Sincerely, 

BLACKSHER, as EE & STEIN, P.A. 

Eo C. rd ; 

net Pa a By > Ch { ZH 

SY J. Codbf-an 

WJC :nwp 

Encl 

cc {(w/encl) Alton L. Turner, Esq. 
Jack Floyd, Esq. 
DP. .L.. Martin, Esq. 
David R. Boyd, Esq. 
W. OQ. Kirk, Jr. 84. 

3 

Warren Rowe, Esq 

All Calhoun County Defendants 
All Escambia County Defendants 
All Talledega County Defendants 

 



  

IN THE UNITED STATES DISTRICT COURT FOR THE 
MIDDLE DISTRICT OF ALABMA 

NORTHERN DIVISION 

JOHN DILLARD, et al., on behalf of 
themselves and other similarly * 
situated persons, % 

Plaintiffs, * 

vs. * CA NO. 85-T-1332-N 

CRENSHAW COUNTY, ALABAMA, gua COUNTY, * 
et al., 

Defendants. * 

PLAINTIFFS’ RESPONSE TO a 

COUNTY MOTION TO DISMISS 

Presently before the court is the Pickens County defendants’ 

motion to dismiss. These defendants assert, without citation or 

analysis, some thirty grounds in support of their motion. 

Defendants’ motion should be denied because it violates the 

provisions of rule 7(b)(1) of the Federal Rules of Civil 

Procedure which mandates that motions "shall state with 

particularity the grounds therefor.” 

Further, inasmuch as this motion appears to have been 

interposed only for delay, or to cause needless expense, 

plaintiffs move the court pursuant to rule 11 of the Federal 

 



  

Rules of Civil Procedure for an order striking these grounds and 

imposing appropriate sanctions. See, Sidney Cox v. Geneva 

County Board of Education, No. CV 85-H-1209-S (M.D.Ala., Nov. 26, 

1985) (Hobbs, J.). 

In the alternative, plaintiffs should not be required to 

respond to this motion until the Pickens County defendants submit 

a brief in support of this motion. Plaintiffs would then respond 

by brief only to those grounds briefed by the defendants 

according to the schedule set by the court. 

Respectfully submitted this Js of January, 1986. 

BLACKSHER, MENEFEE & STEIN, P.A. 
405 Van Antwerp Building 
P. O. Box 1081 

Mobile, Alabama 36633 

{ 
oy  E Z 

7 Hi 9 
7 | V4 / \ \ - -~ J A 

BY: ON srt rte OCH Pn 
  

WANDA J. COQHRAN 
LARRY T. MENEFEE 
JAMES U. BLACKSHER 

TERRY DAVIS 
Seay and Davis 
732 Carter Hill Road 
P. 0. Box 6315 
Montgomery, Alabama 36104 

JULIUS IL. CHAMBERS 
DEBORAH FINS 
Legal Defense Fund 
99 Hudson Street 

16th Floor 

New York, New York 10013 

 



¥. 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 

Attorneys for Plaintiffs 

CERTIFICATE OF SERVICE 

I do hereby certify that on this /© day of January, 1986, a 

copy of the foregoing pleading was served upon counsel of record: 

Alton L. Turner, Esq. 
404 Glenwood Avenue 
P. O. Box 20% 
Luverne, AL 36048 Attorney for Defendants Pickens County, et al. 
(205) 335-3302 

Jack Floyd, Esq. 
Floyd, Keener & Cusimano 
816 Chestnut Street 
Gadsden, AL 35099 Attorney for Defendants Etowah County, et al. 
(205) 547-6328 

D. L. Martin, Esq. 
215 South Main Street 

Moulton, AL 35650 

David R. Boyd, Esq. 
Balch and Bingham 
P. O. Box 78 
Montgomery, AL 36101 Attorneys for Defendants Lawrence County, 
(205) 834-6500 et al., 

¥. O. Kirk, Jr., Esq. 
Attorney at Law 
P. O. Box A-B 
Carrollton, AL 35447 Attorney for Defendants Pickens County, 
(205) 367-8125 et al.  



  

Warren Rowe, Esq. 
P. 0. Box 150 
Enterprise, AL 36331 

and the following parties who do not yet have record counsel: 

Calhoun County 
Calhoun County Courthouse 
Anniston, AL 36201 

Mr. R. Forrest Dobbins 

Clerk, Calhoun County 
P. O. Box 1830 
Anniston, AL 36201 

Escambia County 
Escambia County Courthouse 
Brewton, AL 36426 

Mr. James D. Taylor 
Escambia County Courthouse 
Brewton, AL 36426 

Talladega County 
Talladega County Courthouse 
Talladega, AL 35160 

Mr. Sam Grice 
Talladega County Courthouse 
Talledga, AL 35160 

by depositing same in the United States mail, postage prepaid. 

Honorable Arthur C. Murray 
Calhoun County Courthouse 
Anniston, AL 36201 

Mr. Roy Snead, Jr. 
Calhoun County Courthouse 
Anniston, AL 36201 

Hon. Martha Kirkland 
Escambia County Courthouse 
Brewton, AL 36426 

Mr. Timothy A. Hawsey 
Escambia County Courthouse 
Brewton, AL 36426 

Hon. Derrell Hann 
Talladega County Courthouse 
Talladega, AL 35160 

Mr. Jerry Studdard 
Talladega County Courthouse 
Talladega, AL 35160 

al 

: # 7. / 
1; at yy. ’ cA {/ 1H 2 7 Lora 
  

ATTORNEY FOR PLAINTIFFS Neat 

Attorney for Defendants Coffee County, et al.; 

/

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Plaintiffs' Response to Pickens County Motion to Dismiss for Filing with Cover Letter

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