Answer to Request for Admissions of Defendants

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

NORTHERN DIVISION 

JOHN DILLARD, et al., * 

PLAINTIFFS * 

VS: * C.A.# 85-T-1332-N 

CRENSHAW COUNTY, ALABAMA, * 

et al., 
* 

DEFENDANTS 

OF DEFENDANTS, ETOWAH COUNTY ET ALS 

Come now the defendants Etowah County, Alabama; Lee Wofford, 

in his official capacity as Probate Judge; Billy Yates, in his 

official capacity as Circuit Clerk; and Roy McDowell, in his 

official capacity as Sheriff of Etowah County, and for answer to 

the plaintiffs request for admissions say: 

l. The answering parties in Etowah County cannot truthfully 

admit nor deny this request for admissions. Said parties have 

made reasonable inquiry and the information known to them or 

readily obtainable to them is insufficient to either admit or 

deny. They have no knowledge of what the habit or conduct of the 

State of Alabama, or other counties in the State of Alabama, 

was, and can speak only concerning Etowah County, Alabama. On 

the above basis, these defendants respectfully object to Request 

for Admission 1. 

 



  

  

2. The answering parties in Etowah County cannot truthfully 

admit nor deny this request for admissions. Said parties have 

made reasonable inquiry and the information known to them or 

readily obtainable to them is insufficient to either admit or 

deny. They have no knowledge of what the habit or conduct of the 

State of Alabama, or other counties in the State of Alabama, 

was, and can speak only concerning Etowah County, Alabama. On 

the above basis, these defendants respectfully object to Request 

for Admission 2. 

3. The answering parties in Etowah County cannot truthfully 

admit nor deny this request for admissions. Said parties have 

made reasonable inquiry and the information known to them or 

readily obtainable to them is insufficient to either admit or 

deny. They have no knowledge of what the habit or conduct of the 

State of Alabama, or other counties in the State of Alabama, 

was, and can speak only concerning Etowah County, Alabama. On 

the above basis, these defendants respectfully object to Request 

for Admission 3. 

4. The answering parties in Etowah County cannot truthfully 

admit nor deny this request for admissions. Said parties have 

made reasonable inquiry and the information known to them or 

readily obtainable to them is insufficient to either admit or 

deny. The Request for Admission calls for an interpretation of 

a law, statutue or legal decision of a court. They are not 

learned in the law. On the above basis, these defendants object 

to Request for Admission 4. 

 



  

5. The answering parties in Etowah County cannot truthfully 

admit nor deny this request for admissions. Said parties have 

made reasonable inquiry and the information known to them or 

readily obtainable to them is insufficient to either admit or 

deny. The Request for Admission calls for an interpretation of a 

law, statute or legal decision of a court. They are not learned 

in law. On the above basis, these defendants object to Request 

for Admission 5. 

6. The answering parties in Etowah County cannot truthfully 

admit nor deny this request for admissions. Said parties have 

made reasonable inquiry and the information known to them or 

readily obtainable to them is insufficient to either admit or 

deny. The Request for Admission calls for an interpretation of 

a law, statute or legal decision of a court. They are not 

learned in law. On the above basis, these defendants object to 

Request for Admission 6. 

7. The answering parties in Etowah County cannot truthfully 

admit nor deny this request for admissions. Said parties have 

made reasonable inquiry and the information known to them or 

readily obtainable to them is insufficient to either admit or 

deny. The Request for Admission calls for an interpretation of 

a law, statute or legal decision of a court. They are not 

learned in law. On the above basis, these defendants object to 

Request for Admission 7. 

 



8. The answering parties in Etowah County cannot truthfully 

admit nor deny this request for admissions. Said parties have 

made reasonable inquiry and the information known to them or 

readily obtainable to them is insufficient to either admit or 

deny. The Request for Admission calls for an interpretation of a 

law, statute or legal decision of a court. They are not learned 

in the law. On the above basis, these defendants object to 

Request for Admission 8. 

9. The answering parties in Etowah County cannot truthfully 

admit nor deny this request for admissions. Said parties have 

made reasonable inquiry and the information known to them or 

readily obtainable to them is insufficient to either admit or 

deny. They have no knowledge of what the habit or conduct of the 

State of Alabama, or other counties in the State of Alabama, 

was, and can speak only concerning Etowah County, Alabama. On 

the above basis, these defendants respectfully object to Request 

for Admission 9. 

10. The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admissions. Said 

parties have made reasonable inquiry and the information known 

to them are readily obtainable to them is insufficient to either 

admit or deny. The Request for Admission calls for an 

interpretation of a law, statute of legal decision of a court. 

They are not learned in the law. On the above basis, these 

defendants respectfully object to Request for Admission 10.  



ll. The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admissions. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to either 

admit or deny. The Request for Admission calls for an 

interpretation of a law, statute or legal decision of a court. 

They are not learned in the law. On the above basis, these 

defendants object to Request for Admission 11. 

12. The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admissions. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to either 

admit or deny. The Request for Admission calls for an 

interpretation of a law, statute or legal decision of a court. 

They are not learned in the law. On the above basis, these 

defendants object to Request for Admission 12. 

13. The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admissions. Said 

parties have made reasonable inquiry and the information known 

to them are readily obtainable to them is insufficient to either 

admit or deny. The Request for Admission calls for an 

interpretation of a law, statute or legal decision of a court. 

They are not learned in the law. On the above basis, these 

defendants object to Request for Admission 13.  



  

14. The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admissions. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to either 

admit or deny. The Request for Admission calls for an 

interpretation of a law, statute or legal decision of a court. 

They are not learned in the law. On the above basis, these 

defendants object to Request for Admission 14. 

15. The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admissions. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to either 

admit or deny. The Request for Admission calls for an 

interpretation of a law, statute or legal decision of a court. 

They are not learned in the law. On the above basis, these 

defendants object to Request for Admission 15. 

16. The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admissions. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to either 

admit or deny. The Request for Admission calls for an 

interpretation of a law, statute or legal decision of a court. 

They are not learned in the law. On the above basis, these 

defendants object to Request for Admission 16. 

 



  

17. The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admissions. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to either 

admit or deny. The Request for Admission calls for an 

interpretation of a law, statute or legal decision of a court. 

They are not learned in the law. On the above basis, these 

defendants object to Request for Admission 17. 

18. The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admissions. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to either 

admit or deny. The Request for Admission calls for an 

interpretation of a law, statute or legal decision of a court. 

They are not learned in the law. On the above basis, these 

defendants object to Request for Admission 18. 

19. The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admissions. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to either 

admit or deny. The Request for Admission calls for an 

interpretation of a law, statute or legal decision of a court. 

They are not learned in the law. On the above basis, these 

defendants object to Request for Admission 19. 

 



  

® » 5 

20. The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admissions. Said 

parties have made reasonable inquiry and the information known 

to them are readily obtainable to them is insufficient Lo elther 

admit or deny. The Request for Admission calls for an 

interpretation of a law, statute or legal decision of a court. 

They or not learned in the law. On the above basis, these 

defendants object to Request for Admission 20. 

21. The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admissions. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to either 

admit or deny. The Request for Admission calls for an 

interpretation of a law, statute or legal decision of a court. 

They are not learned in the law. On the above basis, these 

defendants object to Request for Admission 21. 

22, The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admissions. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to either 

admit or deny. The Request for Admission calls for an 

interpretation of a law, statute or legal decision of a court. 

They are not learned in the law. On the above basis, these 

defendants object to Request for Admission 22. 

 



  

23. The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admissions. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to either 

admit or deny. The Request for Admission calls for an 

interpretation of a law, statute or legal decision of a court. 

They are not learned in the law. On the above basis, these 

defendants object to Request for Admission 23. 

24. The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admissions. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to either 

admit or deny. The Request for Admission calls for an 

interpretation of a law, statute or legal decision of a court. 

They are not learned in the law. On the above basis, these 

defendants object to Request for Admission 24. 

25. The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admissions. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to either 

admit or deny. The Request for Admission calls for an 

interpretation of a law, statute or legal decision of a court. 

They are not learned in the law. On the above basis, these 

defendants object to Request for Admission 25. 

 



  

® 10 

26. The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admissions. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to either 

admit or deny. The Request for Admission calls for an 

interpretation of a law, statute or legal decision of a court. 

They are not learned in the law. On the above basis, these 

defendants object to Request for Admission 26. 

27. The answering parties in Etowah County cannot truthfully 

admit nor deny this request for admissions. Said parties have 

made reasonable inquiry and the information known to them or 

readily obtainable to them is insufficient to either admit or 

deny. The Request for Admission calls for an interpretation of 

a law, statute or legal decision of a court. They are not 

learned in the law. On the above basis, these defendants object 

to Request for Admission 27. 

28. The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admissions. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to either 

admit or deny. The Request for Admission calls for an 

interpretation of a law, statute or legal decision of a court. 

They are not learned in the law. On the above basis, these 

defendants object to Request for Admission 28. 

 



29. The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admissions. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to either 

admit or deny. The Request for Admission calls for an 

interpretation of a law, statute or legal decision of a court. 

They are not learned in the law. On the above basis, these 

defendants object to Request for Admission 29. 

30. The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admissions. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to either 

admit or deny. The Request for Admission calls for an 

interpretation of a law, statute or legal decision of a court. 

They are not learned in the law. On the above basis, these 

defendants object to Request for Admission 30. 

3l. The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admissions. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to either 

admit or deny. The Request for Admission calls for an 

interpretation of a law, statute or legal decision of a court. 

They are not learned in the law. On the above basis, these 

defendants object to Request for Admission 31.  



  

32. The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admissions. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to either 

admit or deny. The Request for Admission calls for an 

interpretation of a law, statute or legal decision of a court. 

They are not learned in the law. On the above basis, these 

defendants object to Request for Admission 32. 

33. The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admissions. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to either 

admit or deny. The Request for Admission calls for an 

interpretation of a law, statute or legal decision of a court. 

They are not learned in the law. On the above basis, these 

defendants object to Request for Admission 33. 

34. The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admissions. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to either 

admit or deny. The Request for Admission calls for an 

interpretation of a law, statute or legal decision of a court. 

They are not learned in the law. On the above basis, these 

defendants object to Request for Admission 34. 

12 

 



  

13 

. » 

35. The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admissions. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to either 

admit or deny. The Request for Admission calls for an 

interpretation of a law, statute or legal decision of a court. 

They are not learned in the law. On the above basis, these 

defendants object to Request for Admission 35. 

36. The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admissions. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to either 

admit or deny. The Request for Admission calls for an 

interpretation of a law, statute or legal decision of a court. 

They are not learned in the law. On the above basis, these 

defendants object to Request for Admission 36. 

37. The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admissions. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to either 

admit or deny. The Request for Admission calls for an 

interpretation of a law, statute or legal decision of a court. 

They are not learned in the law. On the above basis, these 

defendants object to Request for Admission 37. 

 



  

14 

38. The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admissions. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to either 

admit or deny. The Request for Admission calls for an 

interpretation of a law, statute or legal decision of a court. 

They are not learned in the law. On the above basis, these 

defendants object to Request for Admission 38. 

39. The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admissions. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to either 

admit or deny. The Request for Admission calls for an 

interpretation of a law, statute or legal decision of a court. 

They are not learned in the law. On the above basis, these 

defendants object to Request for Admission 39. 

40. The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admissions. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to either 

admit or deny. The Request for Admission calls for an 

interpretation of a law, statute or legal decision of a court. 

They are not learned in the law. On the above basis, these 

defendants object to Request for Admission 40. 

 



  

15 

41. The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admissions. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to either 

admit or deny. The Request for Admission calls for an 

interpretation of a law, statute or legal decision of a court. 

They are not learned in the law. On the above basis, these 

defendants object to Request for Admission 41. 

42. The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admissions. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to either 

admit or deny. The Request for Admission calls for an 

interpretation of a law, statute or legal decision of a court. 

They are not learned in the law. On the above basis, these 

defendants object to Request for Admission 42. 

43. The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admissions. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to either 

admit or deny. The Request for Admission calls for an 

interpretation of a law, statute or legal decision of a court. 

They are not learned in the law. On the above basis, these 

defendants object to Request for Admission 43. 

 



44. The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admissions. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to either 

admit or deny. The Request for Admission calls for an 

interpretation of a law, statute or legal decision of a court. 

They are not learned in the law. On the above basis, these 

defendants object to Request for Admission 44. 

45. The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admissions. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to either 

admit or deny. The Request for Admission calls for an 

interpretation of a law, statute or legal decision of a court. 

They are not learned in the law. On the above basis, these 

defendants object to Request for Admission 45. 

46. The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admissions. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to either 

admit or deny. The Request for Admission calls for an 

interpretation of a law, statute or legal decision of a court. 

They are not learned in the law. On the above basis, these 

defendants object to Request for Admission 46.  



47. The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admissions. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to either 

admit or deny. The Request for Admission calls for an 

interpretation of a law, statute or legal decision of a court. 

They are not learned in the law. On the above basis, these 

defendants object to Request for Admission 47. 

48. The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admissions. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to either 

admit or deny. The Request for Admission calls for an 

interpretation of a law, statute or legal decision of a court. 

They are not learned in the law. On the above basis, these 

defendants object to Request for Admission 48. 

49. The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admissions. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to either 

admit or deny. The Request for Admission calls for an 

interpretation of a law, statute or legal decision of a court. 

They are not learned in the law. On the above basis, these 

defendants object to Request for Admission 49.  



  

138 

50. The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admissions. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to either 

admit or deny. The Request for Admission calls for an 

interpretation of a law, statute or legal decision of a court. 

They are not learned in the law. On the above basis, these 

defendants object to Request for Admission 50. 

51. The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admissions. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to either 

admit or deny. The Request for Admission calls for an 

interpretation of a law, statute or legal decision of a court. 

They are not learned in the law. On the above basis, these 

defendants object to Request for Admission 51. 

52. The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admissions. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to either 

admit or deny. The Request for Admission calls for an 

interpretation of a law, statute or legal decision of a court. 

They are not learned in the law. On the above basis, these 

defendants object to Request for Admission 52. 

 



  

Fl 19 

53. The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admissions. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to either 

admit or deny. The Request for Admission calls for an 

interpretation of a law, statute or legal decision of a court. 

They are not learned in the law. On the above basis, these 

defendants object to Request for Admission 53. 

54. The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admissions. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to either 

admit or deny. The Request for Admission calls for an 

interpretation of a law, statute or legal decision of a court. 

They are not learned in the law. On the above basis, these 

defendants object to Request for Admission 54. 

55. The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admissions. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to either 

admit or deny. The Request for Admission calls for an 

interpretation of a law, statute or legal decision of a court. 

They are not learned in the law. On the above basis, these 

defendants object to Request for Admission 55. 

 



  

20 

56. The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admissions. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to either 

admit or deny. The Request for Admission calls for an 

interpretation of a law, statute or legal decision of a court. 

They are not learned in the law. On the above basis, these 

defendants object to Request for Admission 56. 

57. The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admissions. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to either 

admit or deny. The Request for Admission calls for an 

interpretation of a law, statute or legal decision of a court. 

They are not learned in the law. On the above basis, these 

defendants object to Request for Admission 57. 

58. The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admissions. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to either 

admit or deny. The Request for Admission calls for an 

interpretation of a law, statute or legal decision of a court. 

They are not learned in the law. On the above basis, these 

defendants object to Request for Admission 58. 

 



  

59. The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admissions. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to either 

admit or deny. The Request for Admission calls for an 

interpretation of a law, statute or legal decision of a court. 

They are not learned in the law. On the above basis, these 

defendants object to Request for Admission 59. 

60. The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admissions. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to either 

admit or deny. The Request for Admission calls for an 

interpretation of a law, statute or legal decision of a court. 

They are not learned in the law. On the above basis, these 

defendants object to Request for Admission 60. 

61. The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admissions. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to either 

admit or deny. The Request for Admission calls for an 

interpretation of the writings of Myrdal. On the above basis, 

these defendants object to Request for Admission 61. 

 



62. The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admissions. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to either 

admit or deny. The Request for Admission calls for an 

interpretation of a law, statute or legal decision of a court. 

They are not learned in the law. On the above basis, these 

defendants object to Request for Admission 62. 

63. The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admissions. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to either 

admit or deny. The Request for Admission calls for an 

interpretation of a law, statute or legal decision of a court. 

They are not learned in the law. On the above basis, these 

defendants object to Request for Admission 63. 

64. The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admissions. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to either 

admit or deny. The Request for Admission calls for an 

interpretation of a law, statute or legal decision of a court. 

They are not learned in the law. On the above basis, these 

defendants object to Request for Admission 64.  



  

% 1 23 

65. The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admissions. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to either 

admit or deny. The Request for Admission calls for an 

interpretation of a law, statute or legal decision of a court. 

They are not learned in the law. On the above basis, these 

defendants object to Request for Admission 65. 

66. The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admissions. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to either 

admit or deny. The Request for Admission calls for an 

interpretation of a law, statute or legal decision of a court. 

They are not learned in the law. On the above basis, these 

defendants object to Request for Admission 66. 

67. The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admissions. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to either 

admit or deny. The Request for Admission calls for an 

interpretation of a law, statute or legal decision of a court. 

They are not learned in the law. On the above basis, these 

defendants object to Request for Admission 67. 

 



  

& 24 

68. The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admissions. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to either 

admit or deny. The Request for Admission calls for an 

interpretation of a law, statute or legal decision of a court. 

They are not learned in the law. On the above basis, these 

defendants object to Request for Admission 68. 

69. The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admissions. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to either 

admit or deny. The Request for Admission calls for an 

interpretation of a law, statute or legal decision of a court. 

They are not learned in the law. On the above basis, these 

defendants object to Request for Admission 69. 

70. The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admissions. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to either 

admit or deny. They have no knowledge of Myrdal, his writings, 

books or observations. On the above basis, these defendants 

object to Request for Admission 70. 

 



  

& » i 

71. The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admissions. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to either 

admit or deny. The Request for Admission calls for an 

interpretation of a law, statute or legal decision of a court. 

They are not learned in the law. On the above basis, these 

defendants object to Request for Admission 71. 

72. The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admissions. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to either 

admit or deny. The Request for Admission calls for an 

interpretation of a law, statute or legal decision of a court. 

They are not learned in the law. On the above basis, these 

defendants object to Request for Admission 72. 

73. The answering parties in Etowah County cannot 

truthfully admit or deny this request for admission. Said 

parties have made reasonable inquiry and the information known 

to them are readily obtainable to them is insufficient to either 

admit or deny. The Request for Admission calls for an 

interpretation of a law, statute or legal decision of a court. 

They are not learned in the law. On the above basis, these 

defendants object to Request for Admission 73. 

 



  

74. The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admissions. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to either 

admit or deny. The Request for Admission calls for an 

interpretation of a law, statute or legal decision of a court. 

They are not learned in the law. On the above basis, these 

defendants object to Request for Admission 74. 

75. The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admissions. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to either 

admit or deny. The Request for Admission calls for an 

interpretation of a law, statute or legal decision of a court. 

They are not learned in the law. On the above basis, these 

defendants object to Request for Admission 75. 

76. The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admissions. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to either 

admit or deny. They have no knowledge of the informationn 

requested in Admission 76. On the above basis, these defendants 

object to Request for Admission 76. 

26 

 



  

77. The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admissions. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to either 

admit or deny. The Request for Admission calls for an 

interpretation of a law, statute or legal decision of a court. 

They are not learned in the law. On the above basis, these 

defendants object to Request for Admission 77. 

78. The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admissions. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to either 

admit or deny. They have no knowledge of the information 

requested in Admission 78. On the above basis, these defendants 

object to Request for Admission No. 78. 

79. Admitted. 

80. Admitted. 

81. Denied. 

82. The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admissions. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to either 

admit or deny. They have no knowledge of the information 

requested in Admission 82. On the above basis, these defendants 

object to Request for Admission No. 82. 

27 

 



83. The answering parties in Etowah County cannot 

truthfully admit or deny this request for admission. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to each to 

either admit or deny. They have no knowledge of the information 

contained in Request for Admission 83. On the above basis, 

these defendants object to Request for Admission 83. 

84. The answering parties in Etowah County cannot 

truthfully admit or deny this request for admission. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to each to 

either admit or deny. They have no knowledge of the information 

contained in Request for Admission 84. On the above basis, 

these defendants object to Request for Admission 84. 

85. The answering parties in Etowah County cannot 

truthfully admit or deny this request for admission. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to each to 

either admit or deny. They have no knowledge of the information 

contained in Request for Admission 85. On the above basis, 

these defendants object to Request for Admission 85. 

86. The answering parties in Etowah County cannot 

truthfully admit or deny this request for admission. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to each to 

either admit or deny. They have no knowledge of the information  



  

29 

contained in Request for Admission 86. On the above basis, 

these defendants object to Request for Admission 86. 

87. The answering parties in Etowah County cannot 

truthfully admit or deny this request for admission. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to each to 

either admit or deny. They have no knowledge of the information 

contained in Request for Admission 87. On the above basis, 

these defendants object to Request for Admission 87. 

88. The answering parties in Etowah County cannot 

truthfully admit or deny this request for admission. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to each to 

either admit or deny. They have no knowledge of the information 

contained in Request for Admission 88. On the above basis, 

these defendants object to Request for Admission 88. 

89. The answering parties in Etowah County cannot 

truthfully admit or deny this request for admission. Said 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to each to 

either admit or deny. They have no knowledge of the information 

contained in Request for Admission 89. On the above basis, 

these defendants object to Request for Admission 89. 

 



  

31 

e — 

90. The answering parties in Etowah County cannot truthfully 

admit or deny this request for admission. Said parties have 

made reasonable inquiry and the information known to them or 

readily obtainable to them is insufficient to each to either 

admit or deny. They have no knowledge of the information 

contained in Request for Admission 90. On the above basis, 

these defendants object to Request for Admission 90. 

91. The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admission. The 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to either 

admit or deny. They have no knowledge of the information 

contained in Request for Admission 91. On the above basis, 

these defendants object to Request for Admission 91. 

92. The answering parties in Etowah County cannot 

truthfully admit nor deny this request for admission. The 

parties have made reasonable inquiry and the information known 

to them or readily obtainable to them is insufficient to either 

admit or deny. They have no knowledge of the information 

contained in Request for Adnission 92. On the above basis, 

these defendants object to Request for Admission 92. 

93. Admitted. 

94, Denied. 

95. Admitted. 

96. Admitted. 

97. Admitted. 

 



  

al J 

98. The answering parties in Etowah County cannot 

truthfully admit or deny this request for admission. Said 

parties have made reasonable inquiry and the information known 

to them are readily obtainable to them as insufficient to either 

admit or deny. They have no knowledge of what Empirical Studies 

published by reputable political scientist say: On the above 

basis, these defendants object to request for admission 98. 

99. Denied 

100. These defendants object to request for admission 100 

as the information requested calls for opinion only. 

101. These defendants object to request for admission 100 

as the information requested calls for opinion only. 

FLOYD, KEENER & CUSIMANO 
ATTORNEYS FOR DEFENDANTS 

Etowah County, Alabama; Lee 
Wofford; Billy Yates; and 
Roy McDowell 

STE 
BOR 
816 Chestnut Crass 
Gadsden, AL 35999-2701 
(205) 547-6328 

  

I hereby certify that a copy of the foregoing has been 
mailed Larry. T. Menefee, Attorney, P. O. Box 1051, Mobile, 
Alabama 36633; Terry G. Davis, P. O. Box 6215, Montgomery, 
Alabama 36104; Deborah Fins; Julius L. Chambers, 99 Hudson 
Street, 16th Floor, New York, New York 10013; Edward Still, 714; 
South 29th Street, Birmingham, AL 35233; and Reo Kirkland, Jr., 
P. O. Box 646, Brewton, AL 36427, this the y of January, 
1986. 

    

OF COUNS