Memorandum from Suitts to North Carolina Reapportionment Group

    RALPH GINGLES, C

V.

RUFUS EDMTSTEN,

***

ALAN V. PUGH, €t

v.

JA}4ES B. HUNT, J

coME NOW th

Pursuant to Rule

Procedure, propo

No. 81-803-CIV-5

interrogatories

and responded to
j-n (15) days aft

In answerin

furnish all info
tion in the pos

your behalf, and

ovm personal k

interrogatory or

diligence to s

to the extent

to ansvrer the re
You are r

of the Federal

to supplement se

question directl

Plaintiffs

t a1.,
Defendants

Plainti ffs

DEFENDANTS I FIRST SET

IN T'NITED STATES DISTRICT
FOR THE EASTERN DTSTR.ICT OF NORTH

RALEIGH DIVTSION

COURT
CAROLINA

No. 81-803-CIV-5

No. 81-1066-CIV-5

OF TNTERROGATO IES AND UESTS POR PRODUCTION (GINGLES)

Defendants in the above-styled action and,

33 and 34 of the Federal Rules of Civil
d to all Plaintiffs in the action entitled

and their attornevs of recor<l the following
d requests for production, to be ansrvered

pursuant to stipulation of the parties, v:ith-
r service hereof.

these interrogatoriesr 1lou &r€ required to
mation availabl-e to you, including informa-

ssion of your.-attorney or any person acting in
not merely such information as is known of your

Iedge. If you cannot ansvrer any particular
interrogatories in fuI1, after exercising due

re 'the informatj.on sought r so state and answer

sib1e, specifying the reasons for lzour inability
inder. '

nded that, under the provisions of Rule 26 (e)

Ies of Civil Procedure, you are under a duty

sonably your response with respect to any

addressed to (a) the identity and location of

Ralph Gj-nq1es, e al., V. Rufqg ldmisten, etc., et dI.,



upon

days

persons having

identity of each

witness at trial
testify and the

Base your r
and on which you

You are und

lf you obtain in
that the respons

or complete, and

amend the respon

Any such s

counsel of

after recei

e)-

owledge of discoverable matter, and (b) the

person expected to be called as an expert

the subject matter on which he is expected

utrstance of his testimony.

sponses on the statistics in vour possession

have based your allegations.
r a aity to amend seasonably a prior response

ormation upon the basis of which (a) you know

, though correct when made, is no longer true
the circumstances are such that a failure, to
e is, in substance, a knowinq concealment.

plemental response is to be filed and served

ecord for this Defendant rvithin fifteen (15)

t of such i-nf ormation.

to

Unless othe ise

DEFINITTONS

indicated, the following definitions
these interrogatories and requests forshall be applic

production:

You and you

attorneys, acten

acting on their

association, co

1egaI entity.

refers to the

mented.

le to

shal-l mean the Plaintiffs and each

r or representatives and all other

ha1f.

mean any

ration or

of their

Persons

Person shal individual, partnership, firm,
other business r governmental or

Address sha I mean the post office box numher, street
number, street,
state of subject

ute number, route, town, city, county and

person, business or other entity.
'Document 11 .mean any r.lritten, recor<led, transcribed,

f,dr{rlr filmed or graphic matter of any kind orpunched, taped,

description, er produced or reproduced.

Paragra our peragraph, or paragraph of your Complaint

red paragraphs of your Complaint, as supple-



-3-

Gross devia ion is the total figurer plus or

by subtrac

population

Census unit

ing the ideal population Cistrict

minus, com-

from the

of

of

IdeaI

North Carolin divided by the total number of State

s or State Senate districts,Representati

Number of ch district, number of each House district or

number of each S nate district refers to those numbers applied

puted

total

block groups and

United States Bu

to each legisla

District r
sentatives and,/

Percentage

dividing the gr

and converting

Overall ra

identical in me

Supreme Court i
percentage vari
maximum deviati

deviations is

most populous d

district and t

deviates from

embodies any ad

the basic legis

4 and 5 of the

rvithin the specific district.

shall refer to tracts, enurneration districts,

blocks as these term.s are definerl hy the

eau of the Census.

tion district or equal lation of the State

House

ve district for identification Purposes.

ers to districts vrithin the lrouse of Repre-

Senate of the State of }forth Carolina.

rvhich a district deviates from the ideal

s deviation by the ideal population clistrict

at fraction into a percentage.

e of deviations is that term usecl which is

ing to the term used b,v the United States

Mahan v. Hovrel1, 410 U,S. at 319, as "maximum

tion from that ideal" or "maximum variation or

rrr" 410 U.S. at 323. This overall range of

ual to the sum of the percentage by which the

strict deviates from the ideal population

percentage by which the least populous district

e ideal population district, ignoring the plus

of these percentages.

ustments, changes, alterations, or amendments to

ative reapportionment plans embodied in Chapters

ulation dis ict is that percentage which is computed by

and minus signs

Your revi reapportionment plan or ur revised plan or

ur plan or r revised reapportionment I or your

revised or r proposal is that plan or Proposal rvhich

tra Session Laws of L982 which the Plaintiffs



suggest as Possi

within the legis

plan or proposal

embodied in Chap

1. State

address,

the fu
place o

tiff in th-is act

2. state (a) vrh

paragraphs to th

tiff understands

under oath.

-4-

le solutions to various alleged deficiencies

ative reapportionment p1ans. Describe this

in terms of incremental changes to the plan

ers 4 and 5 of the Extra Session Larrs of L982.

***

1 name, d9€, date

birth, and place

on.

birthr Pr€s€rt residence

emPloyment of each Plain-

of

of

ther each plaint,iff has read the introductory

se interrogatories and (h) r.rhether each plain-

that these interrogatories are to he ansvrerd



3. fn Paragraph

reapportionment

of the Extra Ses

enacted vrith the

citizens of the

citizens the abi

to this allegati
a. The n

tionment pI

voting stre

b. Set out

of the plai

its composi

c. Set out

substaprtial

of the plai

this interr
1. Eac

the Leg

distric

voting

2. Eac

the Leg

distric

voting

I

r

-5-

109 of your Complaint, you allege that the

lan for the House of Representatives, Chapter 4

ion Laws of 1982, "has the effect of and was

urpose of discriminating against black

tate of North Carolinar dnd of denying black

ity to use their vote effectively." I.7ith regard

set out the follor.ring:

of each House district u,here the reappor-

n substantially dilutes or minimizes the

gth of blaeks within that House district.
specifically the objections which you or any

tiffs have to the specific House district and

ion.

in detail the effect of the House plan in
y diluting or ninimizing the voting strenqth

tiffs or members of their c1ass. In ansvrering

atory, set out, at a minimum, the follovring:

vrhole county, tovrnship or census unit which

slature i-ncluded or omitted within each House

with the effect of diluting the plaintiffst

trength.

whole county, township, or census unj-t which

slature included or omitted within each tiouse

with the purpose of dlluting the plaintiffs'

trength



4. In Paragraph

of the Extra Ses

enacted vrith the

and of diluting
of the State of

the right to use

allegation, sbt

a. The n

tionment p

voting st

b. Set out

of the pIa

and its
c. Set out

substandial

of the p1a

manner as 1

-6-

115 of your Complaint, you al1ege that Chapter

ion Lavrs of 1982, "has the effect of and was

urpose of discriminating against tlack voters

vote of plaintiffs and other black citizens
orth Carolina and of denying black citizens

their vote effectively." With regard to this

t the following:
r of each Senate district where the reappor-

n substantially dilutes or minimizes the

gth of blacks within that Senate district.

specifically the objections vrhich you or any

tiffs have to the specj-fic Senate district

sition.
in detail the effect of the Senate

y diluting or minimizing .the voting

tiffs or members of their class in

responding to interrogatory numtrer

plan in
strength

the same

3(c).



I
c 5. For each who

listed in your a

the House distri
particular whole

Legislaturets r

the Extra Sessi

-7-

countyl township, or census unit urhich you

wer to interogatory number

wherein you would propose

tcy, townshipr or census

tionment pJ.an embodied

Laws of L982.

3(c) (1), set out

to place that

unit within the

in Chapter 4 of



'{

$ rOR THE

RALPH GTNGLES, €t

IN T'NITED STATES DISTRICT COURT
DISTRICT OF NORTH CAROLINA

RALEIGH DIVISION

Pl-aintif f s
No. 81 -803-CIV- 5

a1 .,
Defendants

Plainti ffs

No. 81-1066-CIV-5
, etcret a1.
Defendants

DEFENDANTS ' FIRST SET
ES AND REQUESTS FOR PRODUCTION (GINGLES)

Defendants in the above-styled action and,

33 and 34 of the Federal Rules of Civil

d to all Plaintiffs in the action entitled

nd their attorneys of recor<l the followinq

d requests for production, to be ansrvered

pursuant to stipulation of the parties, v:ith-
service hereof.

these interrogatories, you are required to

sion of your attorney or any person acting in
ot merely such information as is knor,m of your

edge. If you cannot ansvrer any particular

nterrogatories in full, after exercising due

e the information soughtr so state and answer

ib1e, specifying the reasons for your inatility
inder.

v.

RUF.US EDI,IISTEN,

***

ALAN V. PUGH, €t

V.

JAMES B. HUNT, J

)

)
)
)

)
,)

)

Ralph Ginqles dI., V. Rufus Edmisten, etc., et dI.,

OF INTERROGATO

COt"lE NOW th

pursuant to Rule

Procedure, propo

No. 81-803-CrV-5

i-nterrogatories

and responded to,
in (15) days aft

In answeri

tion in the poss

your behalf, and

own personal kn

interrogatory or

diligence to s

to the extent po

to ansvrer the

furnish all inf tion available to you, including informa-

You are r ed that, under the provj.sions of Rule 26(e)

of the Federal es of Civil Procedure, you are under a duty

to supplement se

question directl
ably yorlr response with respect to any

addressed to (a) the identity and Location of



d

L

?.2-

ledge of discoverable matter, and (b) the

son expected to be callecl as an expert

persons having k

identity of each

witness at trial,
testify and the s

Base your re

and on which you

You are unde

if you obtain inf
that the response

or complete, and

amend the respons

Any such s

upon counsel of r

days after receip

tothe subject matter on which he is expected

tance of his testimony.

ponses on the statistics in your possession

ave hased your allegations.
a duty to amend seasonably a prior response

rmation upon the hasis of which (a) you know

though correct when made, is no longer true

he circumstances are such that a failure to

is, in substance, a knowing concealment.

lemental response is to be filed and served

rd for this Defendant rvithin fifteen (15)

of such informati-on.

DEFINITIONS

ise indicated, the following definitions

e to these interrogatori-es and requests for
Unless othe

shal1 be applicab

production:

You and your

attorneys, agents

acting on their
Person shall

association, cor

Iega1 entity.
Address shaL

number, street,

state of subject

Document sh

punched, taped,

refers to the n

mented.

shall mean the Plaintiffs and each

or representatives and all other

of their

Persons

ha1f.

mean any

ration or

lndividual, partnership, firm,

other business, governmental or

mean the post office box number, street

ute number, route, to$rn, city, county and

rson, business or other entity.

I mean any r'rritten, recortled, transcribed,

at{rlr filmect or graphic matter of any k-ind or

description, h er produced or reproduced.

laintParaqra ur paraqraph, of paraqraph of

red paragraphs of your Complaint, as supple-



e

&

-3-

Gross devia on is the total figure, plus or minus, com-

from theputed

total
by subtra ng the ideal population Cistrict
population

Census uni.t

ithin the specific district.

block groups and

hal1 refer to tracts,

locks as these term.s

United States B u of the Census.

ion district or equal population of the State

divided by the total number of State House

or State Senate districts,
h district, number of each House district or

e district for identifj-cation purposes.

rs to districts vrithin the Llouse of Repre-

Senate of the State of llorth Carolina.

rshich a district deviates from the ideal

trict deviates from the ideal popuJ.ation

percentage by which the least populous distrj-ct

ideal population district, ignoring' the plus

f these percentages.

embodies any adj

the basic legisl
stments, changes, alterations, or amendments to

tive reapportionment plans embodied in Chapters

enumeration districts,

are defined hy the

IdeaI

of North Carolin

of Representativ

Number of e

to each legislat
District re

sentatives and./o

Percentacre

number of each S ate district refers to those numbers applied

lation distr t is that percentage which is computed by

dividing the gr

and converting

deviation by the ideal population clistrict

t fraction into a percentage.

Overall ran e of deviations is that term used which is

identical in mea

Supreme Court in

percentage varia

ing to the term used by the United States

han v. Hovlell, 4I0 U.S. at 319, as "maximum

n from that ideal" or "maximum variation or

maximum deviati ," 410 U.S. at 323. This overall range of

deviations ls eq

most populous di
district and the

deviates from th

and minus signs

I to the sum of the percent,age by which the

Your revise reapportionment plan or r revised plan or

ur olan or vou revised reapportionment Proposal or your

revised sa1 or your aI is that plan or ProPosal which

4 and 5 of the ra Session Laws of L982 which the Plaintiffs



c

s suggest as Possit)

within the legisl

plan or proposal

embodied in Chapt

1. State

address,

the fu1

place of

tiff in th-is acti

2. State (a) uh

paragraphs to t
tiff understands

under oath.

-4-

solutions to various alleged deficiencies

tive reapportionment plans. Describe this

n terms of incremental ehanges to the plan

rs 4 and 5 of the Extra Session Laws of L982.

***

namer d9€, date of birth, present residence

birth, and place of employment of each plain-

her each plaintiff has read the introductory

e interrogatories and (h) r'thether each plain-

hat these interrogatories are to he ansvrerd



ir
3. In Paragraph

reapportionment P

of the Extra Sess

enacted vrith the

citizens of the S

citizens the abi

to this allegati
a. The n

tionment pI

voting str

b. Set out

of the plai

its composi

c. Set out

substantial

of the plai

this interr
1. Ila

the Leg

distric

voting

2. Eac

the Leg

distri
voting

-5-

09 of your Complaint, you alIege that the

an for the House of RePresentatives, ChaPter 4

on Laws of 1982, "has the effect of and was

urpose of discriminating against black

ate of North Carolina, and of denying blaclc

ty to use their vote effectively." !'7ith regard

, set out the follor.ring:

r of each House district v'here the reaPPor-

substantially dilutes or minimizes the

h of blacks within that House district.

pecifically the objections which you or any

iffs have to the specific House district and

10n.

in detail the effect of the House plan in

y diluting or minimizing the voting strength

tiffs or members of their c1ass. In ansvrering

gatory, set out, at a minimum, the follovring:

whole county, township or census unit which

slature included or omitted within each House

with the effect of diluting the plaintiffsr

trength.

whole county, township, or census unit which

slature included or omitted within each liouse

with the purpose of diluting the plaintiffsl

trength.



t 4. In Paragraph

of the Extra Sess

enacted vrith the

and of diluting
of the State of

the right to use

allegation, set

a. The n

tionment pI

voting stre

b. Set out

of the plai

and its
c. Set out

substantiial

of the plai

manner as i

1s

on

-6-

of your Complaint, you allege that Chapter

Lavrs of 1982, "has the effect of and was

se of discriminating against blacl'- voters

e vote of plaintiffs and other black citizens

rth Carolina and of denying black citizens

heir vote effectively." I{ith regard to this

t the following:

r of each Senate district where the reappor-

n substantially tiilutes or minimizes the

gth of blacks within that Senate district'

specifically the objections vrhich you or any

tiffs have to the specific Senate district

sition.
in detail the effect of the Senate plan in

y diluting or minimizing the voting strength

tiffs or members of their class in the same

responding to interrogatory numher 3 (c) .



E
5. For each who

listed in your

the House distri
particular whole

Legisldture I s

the Extra Session

county, township, or census unit which you

wer to interrogatory number 3(c) (1), eet out
wherein you would propose to place that

unit within the

in Chapter 4 of
Laws of L982.

ty, townshipr or census

tionment plan embodled



D

6. For each whol

listed in your an

the House di.etri
particular whole

Legislature'E rea

of the Extra Sees

-8-

county, township, or census unit which you

r to interogatory number 3(c) (2), set out

vrherein you would propose to place thit
unty, tovmship, or census unit vrithin the

rtionment plan as embodied in Chapter 4

on Laws of L982.



*
I| -s-
I

I

7. set out the rtrrorins,
a. A11 Housf ur=arrcts wherein you vrould alter the

legislative f".nroraionment plan to eorrect the alleged

deficien"rJ=l set out in your anshrer to interrogatory
number 3. I

Ib. Within eich House district cited in your response

to interroguf.orV number 7(a) set out the following:

1. rachl whole county, township, or census unit
includedl rvithin the House district under your proposal.

I2. The 
fiotaf 

population of the revised House district
under yohr proposal.

3. ,f,. lE,oa.I number of whites within the revised
I

House diptrict under your proposal.

4. ,n. 
Jaoa.l 

number of blacks rvithin the revise<l

House aif,trict under your proposal.
I5. The percentage of whites within the revised

House ai[tri"t under your proposal.
I6. fhe 
fercentage 

of blacks vrithin the revised

House diptrict under your proposal.

7. rrre Lross deviation of each revised llouse

ai"tri.l under your proposal.

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I



8. In your

your answer

same whole

revised

to int
county r

o

districts or bave

or census unit with

Set out the fol

a. A11 Senate

legislative re

deficiencies

number 4.

b. Within ea

to interrogato

1. Each w

included w

proposal.

2. The to

district
3. The to

Senate

4. The

Senate

5. The

Senate di

6. The

Senate

7. The

dis

to

dis

-t 0-

reapportionment proposal as set forth in

atory number 7, have you pLaced the

hip, or census unit within two House

omitted to place a whole county, townshiP,

a House district?

owing:

districts wherein you would alter the

correct the alleged

to interrogatory

rtionment plan to

t out in your answer

Senate district cited in your answer

number 9(a), set out the following:

Ie county, township, or census unit

thin the Senate district under your

I population of the revised Senate

der your proposal.

t number of whites within the revised

rict under your proposal.

al number of blacks within the revised

ict under your proPosal.

ntage of whites within the revised

rict under your ProPosal.

entage of blacks within the revised

rict under your proPosal.

s deviation of each revised Senate

di

I
district der your proposal.



J 10. In your reaPpor

answer to interroga

whole cowrty, tovns

districts or have yo

shipr or census unit

11. With respect

Laws of 1982, do yo

ion requires the Leg

that the overall

in the House or

ao

is

-11-

ionment proposal as set forth in your

ry numbei 9, have you pJ-aced the same

, or census unit within two Senate

omitted to place a whole county, town-

within a Senate district?

either Chapter 4 or 5 of the Special Session

contend that the Federal or State Constitut-

slature to apportion each legislative district

ange. of deviations is less than it presently

te plan?



L2.

set

ff you an

out the fol]
a. The tegi
Constitution

range of d

b. Each Hou

range of dev

c. The Fede

which you ba

d. The Legi

Constitution

range of dev

e. Each S

range of dev

f . The iPed

r,vhich you b

-L2-

ed interrogatory number 11 in the affirmatj.ve,

ing:

laturers duty under the Federal and State

with regard to maximum permissible overall
ations from the ideal population House district.

district which deviates from this overall
tions divided by two.

al and State Constitutional provisions on

e your answer to interrogatory number 12 (a).

laturets duty under the Federal and State

with regard to maximum permissible overall
ations from the ideal population Senate district.

te district which deviates from this overall

ations divided by two.

aI and State Constitutional provisions on

e your answer to interrogatory number L2 (d) .



13. Set out the

a. Name eac

contend has

equality.
b. For each

interrogato

residents a

from the ide

-13-

ollowing:

new llouse or

rmissible
Senate district which you

Iarge variances from population

district described in
number 13 (a) set out

the percentage that
1 population district

your answer to
the gross number of

each district departs

or egual population.



14. With respect

Paragraph 115 tha

have "the effect
discriminat,ing ag

of plaintiffs and

Carolina, " (a) de

descriptive terms

each House and Se

tionment plans w

dilute the voting

the effect of dil

-14-

to your allegations in Paragraph 109 and

the House and Senate reapportionment plans

f and (were) enacted with the purpose of

inst black voters and of diluting the vote

other black citizens of the State of North

ine "dj.Iuting" in toth quantitative and

(b) vrith regard to this allegation, set out

ate district within the legislatj-ve reappor-

re you allege the Legislature intended to

strength of black citizens or (c) rvhich had

ting the voting strength of black citizens.



15. If You ident

interrogatorY

a. Each

each Ilouse d

number 14 wh

district for

b. Each who

each House d

number 14 w

district whi

strength.

c. Each wh

any House dj

district li
for the Pur

d. Each wh

House distr
listed in Y

had the eff

strength.

-15-

fied any House district in your answer to

L4, set out the folIowing:

e county, township, or census unit within

strict listed in your anst'rer to interrogatory

ch was included within the identified House

the purpose of diluting black voting strength'

e county, tovrnship, or census unit rvithin

strict listed in your ansr'rer to interrogatory

ch was included r'uithin the identified House

h had the effect of diluting blacl: voting

e county, tol'mship, or census unit' vrithin

strict which was excluded from any House

qed in your answer to interrogatory number 14

se of diluting black votinq strength

county, torvnship, or census unit within any

vrhich was excluded from any House district

ans\^Ier to interrogatory number 14 which

of diluting or minimizing black voting

1e

ct

ur

ct



16. If you have

to j.nterrogatory

a. 4.11 Hous

legislative
clef iciencies
b. Within e

interrogato

1. Each

the revi

2. The

under y

3. The

House di

4. The

House di

5. The

distric

6. The

distric
7. The

under y

-16-

dentified any llouse district in your answer

umber 14 , set out the follovring:

districts wherein you would alter the

eapportionment plan to correct to alleged

set out in Paragraph 109 of your Complaint.

ch House district set out in your answer to

number 15(a), set out the followinq:

whole county, township, or census unit vrithin

ed l{ouse district under your proposal.

tal population of the revised llouse district

r proposal.

otal number of whites vrithin the revised

trict under your proPosal.

otal number of blacks rvithin the revised

trict under your proposal.

rcentage of whites within the revised House

under your proposal.

ercentage of black's vrithin the revisecl House

under your proposal.

ross deviati-on of the revised l{ouse district

proposal.



17. In your revi
your ansvrers to i

same whole county

districts or omit

census unit with

18. If you ident

lnterrogatory n

a. Each who

each Senate

tory number

Senate distr

black voting

b. Each who

each Senate

tory number

Senate distr

minimizing b

c. Fach who

any Senate d

district lis
for the pu

strength.
d. Each who

any Senate

district lis

vrhich had t

voting stren

-L7-

ed reapportionment proposal as set forth in
terrogatory number 16, have you placed the

townshipr or census unit within turo House

ed to place a whole county, township, or

a House district?

fied any Senate district in your answer to

r 14, set out the following:

e county, tor+nship, or census unit within
istrict listed in vour ansrver to interroga-

4 whicl: was included within the iclentified

ct for the purpose of diluting or minimizing

strength.

e county, tovmship, or census unit within
istrict listed in your answer to interroqa-

4 which was included vrithin the identified

ct whj-ch has the effect of diluting or

ack voting strength.

e county, township, or census unit

strict which was excluded from any

ed in your anshrer to interrogatory
e of diluting or minimizinq black

vrithin

Senate

number 14

voting

e county, township, or census unit within

strict which was excluded from any Senate

ed in your ansrr,er to interrogatory number 14

effect of diluting or minimizing black

rh.



I

II -r,-

I19. If you have |dentified 
any Senate district in your answer

to interrogatory Jrumber 14, set out the followi-ng:
Ia. A11 Senafe tlistricts wherein you vrould alter the

legislative feanportionment plan to correct the alleged

deficiencj-esl""a or.ra in Paragraph 115 of your Complaint.
I

b. Within eficfr Senate district set out in your anstrer to
Iinterrogatorf number 19 (a) , set out the follovrinq:

1. Eachlwfrofe county, township, or census unit within
I

the revifed Senate district under your proposal.

2. The total population of the revised Senate district

under voLt proposal'
I3. The fotal number of whites rvithin the revised

Senate d[strict under your proposal.
I

4. The k,otaI number of blacks v:ithin the revise<1

send I

Ee dfstrict of your proposal.

5. fhe 
fercentage 

of whites rvithin the revised

Senate a[strict under your proposal.

6. fhe 
fercentage 

of blacks rvithin the revised

Senate dflstrict under your proPosal.

?. The [ross deviation of the revised Senate district

under 
""|ut 

proposal.

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I



20. WiIl you attem

of legislators rega

Laws of 1982 were

ating against black

strength on the part

If so, set out the f
a. The name of
b. The place

c. The date of
d. The exact s

e. The source

f. The name,

g. ff reported

telephone n

The date e

Please atta

h.

I.

-19 -

to prove that contemporaneouE statements

ng Chapter 4 and 5 of the Extra Session

which indicate ttre purpose of discrimin-
ters and/or of diluting black voting

of the Legislature or any members thereof?
llowing.

each Legislator who made such a statement.

or she made the statement.

the statement.

tement he or she made.

hrough which you learned of the statement.

dress, and telephone number of such source.

in the media, the name, address, and

r of each such media outlet.
media report was made and by whom.

h a copy of each such media report.



o

21. Does either
reapportionment

or maintain the

in office? If so

the opportunity

-20-

he House of Representatives or Senate

an enacted by the Legislature in 1-gg2 enhance

rtunity of any black incumbent to continue
name the incumbent and the manner in which

s enhanced or maintained.



22. Does either
reapportionment p

the opportrurity

If Bor name the i

tunity was 1ee

he Houee of

an enacted

any black

t and

l,

-2L-

Repreeentatives or Senate

by the Legielature in L982 LeEsen

incumbent to continue ln offlce?

the manner in whieh the oppor-



c

23. Do you alleg

census units in
were traneferred

a major irupact in
where the el
a black LegisJ.ato

-ZZ'

that any whole countles, townships, or

lg82 legislative reapportionment plans

from any district where they would have had

the election of a black Legislator to one

I impact would be mlnor in the election of
?



9

24. If yo,ur a

affirmative, set

a. Identify
b. The Hous

township

The per

district
legislat

d. The n

e.

h. The n

or cens

constitu

The Hous

this who

relocat

number o

The perc

if the

The tota

if the w

switched

j-nterrog

one-man,

The Hous

county,

The gros

by distr

in whoLe

f.

g.

1.

l.

-23-

r to interrogatory number 23 r.ras in the

ut the following:
the rrhole county, township or census unit.
or Senate district wherein the whole county,

or eensus unit is now located.

ntage of blacks within the House or Senate

as presently constituted in the 1982

ve reapportionment p1ans.

of people within the district as presently

ed.

or Senate district in r.rhich you believe
e county, township, or census unit should he

, its present percentage of blacl.,s and

people.

tage of blacks within the truo districts
itch you advocated vrere

number of residents in
made.

the tvro districts
census unit werele eounty, township, or

as you advocate.

r(s) or name(s) of the whole

unit previously specified in
tory number 24(a) in order to

county, tor^rnship,

answer to
satisfy the

one-vote requirement.

or Senate district from which such v:ho1e

shipr or census unit would be removed.

devi-ations of alL llouse and Senate districts
ct as a consequence of the foregoing shifts
county, township, or census units.



e

25. If you have

reapportj.onment

Senate which you

26. If you have

please attach a

contiguous to th

advocate in res

-24-

avrn or have in your possession statewide

ps for the House of Representatives and the

efer to be adopted, please attach the same.

o maps referred to in interrogatory number 25,

arving of each ner.r district and the districts
district if such district were drarrn as you

se to interrogatory number 24.



(r

27. fn your Par

of the apporti

enacted in Chapt

are to...deny p

tively. "

a. Explain

tively,
Identif
tionmen

the rig
hovr the

b.

-25-

raph 12I you state that "the intent and effect

t of the North Carolina General Assemhly

s { and 5 of the Extra Session Lavrs of L982

ntiffs their right to use their vote effec-

e phrase I'right to use their vote effec-

as you employ it.

specifically each component of the reappor-

plans which you eontend denied the plaintiffs

t to use their vote effectively and explain

effective use of their vote was so denied.



28. In Paragrap

has a history of

voter registrati
regulations and

other black citi
their votes eff

set forth the fo
a. A11 vo

histori
plainti

from vo

A11 vot

continu

citizen
their v

All eIe

employ

black c

using t
All ele

prevent

State f

A11 reg

prevent

voting

All reg

plainti

from vo

A11 pra

State t

of this
effecti

All pra

plainti

from vo

b.

d.

e.

f.

g.

h.

-26-

127 you state that "the State of north Carolina

discrimination aqainst black citizens in its
praetices and in other electj-on larvs,

ractices rvhich have prevented plaintiffs and

ens of this State from voting or from using

tively. " with respect to your Paragraph 127 ,

lorving:

r registration practices which have occurred

a1ly in this State vrhich have prevented

fs and other black citizens of this State

ing or from usj-ng their votes effectively.

r registration practices in this State which

to prevent plaintiffs and other black

of this State from voting or from using

tes effectively.
tion laws which have historicallv been

in this State to prevent plaintiffs and other

tizens of this State from voting or from

eir votes effectively.

tion laws lrhich eontinue to be enforced v'hich

plaintiffs and other black citizens of this

voting or from using their votes effectively.
Iations which have historicalllz been used to

plaintiffs and other blacks of this State from

r from using their votes effectively.

lations which continue to be used to prevent

fs and other black citizens of thi.s State

ing or from using their votes effectively.

tices which have historically been used by the

prevent plaintiffs and other blacl: citiz.ens

State from voting or from using their votes

Iy.
continue to be used to prevent

black citizens of this State

using their votes effectiveJ-y.

tices which

fs and other

ing or from



29. Can you stat
registration pra

or practices whi

other blaek citi
thei-r votes eff
date, the occurre

and other black c
using their votes

-27-

specific instances of the use of voter
ices or other election laws r or regulat-i.ons,

have been used to prevent plaintiffs and

s of this State from voting or from using

ively? If sor list chronolooically, by

of each incident of preventing plaintiffs
tizens of this State from voting or from

effectively.



30. Your Paragr

Assembly has his
the blacL citiz
the followlng:

Clr Explain

the Sta

b. Give s

Carolina

the n

Caroli-na

-28-

h L28 states "the North Carolina General

rically been unresponsive to the needs of
of the State of North Caroli-na. " Set forth

he phrase "needs of the black citizens
of North Carolinar" as you employ it.

ific examples of occasj-ons on which the

General Assembly has been unresponsive

of the black citizens of the State of
and explain your ansler.

of

llorth
to

\rorth



31. Do your sta

House of Repre

by the Legislat
with a greater o

choosing than do

of the Extra Sess

and explain your

32. Do your stati
House of Represen

enacted by the

vided blacks uri_th

tively than do

of the Extra Sess

and explain your

-29-

stics indicate that any past North Carolina
tives or Senate reapportionment p1ans, enacted
after any decennial census, provided blacks

ortuni.ty to etect representatives of their
e current plans embodied in Chapters 4 and s

on Lar.rs of l9g2? If So, identify the plan(s)
svrer.

Sl^ref .

tics indicate that any past North Carolina
tives or Senate reapportionment plans,

islature after any decennial censusr pro-
greater opportunity to use their vote effec_

current plans embodied in Chapters 4 and 5

n Laws of 1982? If so, j.dentify the plan(s)



t'
| -30-

I

I33. Do your staflistics indicate that any past North Carolina

House of *"nr"=.{tatives or Senate reapportionment p1ans,

enacted by the r{sislature after any decennial census, provided

blacks with as S{""t an opportunity to elect representatives of
their choosing .d ao the current plans embodied in Chapters

4 and 5 of tfre mftra Session Laws of Lg82? If sor identify the

plan(s) and expl{in your answer.

I

I

I

I

I

I

I

I

I

I

I

I

I34. Do your sta]istics indicate that any past llorth Carolina

House of Renreserftatives or Senate reapportionment p1ans,

enacted by the f,JSislature after any decennial census, provide4

blacks with as g{eat an opportunity to use their vote effeci
tively as do the l"rrr"r,a plans embodied in Chapters 4 and 5

of the Extra Ses{i.on Laws of Lg82? If sor identify the plan(s)

and explain your l.r=o,"r.

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I



35. State the

of each person

of this matter

referred to in
substance of ea

-31-

, address, employment, and telephone

u will or may call as a witness at the
th the exception of those experts, if

e next interrogatory) and further state
such person's expected testinony.

number

trial
arY,

the



36. State the

and qualificati

expert witness

the subject mat

testify.

,

of

the

on

-32-

address, employm.ent, telephone number,

each person you erq)ect to call as an

trial of this matter and further state
vrhich each such expert is expected to



tt
37. As to each

number 36, state
which said expe

of the grounds fo

-33-

rt named j.n the answer to interrogatory
he substance of the facts and opinions to
are expected to testify and give a Bummary

each opinion.



i 38. Pleaee atta
true, complete,

prepared by any

39. State the n
of each expert w

in anticipation

not expected to

-34-

h to your anEwers to

correct coples of
ch e:q>erts or exPert

',-J

these interrogatories

any and all documents

reJ,ating to this action.

e, address,

you have

J.itigation

called as

telephone number, and gualifications
retained or specifically employed

or preparation of trial and who is
a witness of the trlal of this actLon.



I

e 40. fndicate ea

answers to inter
other Iegal p

tionment and des

each of those p

Respectfull

-35-

occasion on vrhich each person named in the
atories number 35 and 36 has testifiecl in
ings regarding State legislative reappor-
be the nature of his or her testimony in

eedJ-ngs.

submitted this the 29 day of t,tarch , LgB2.

RUFUS L. EDHTSTEN
ATTORNEY GENERAL

Post Office Box 629
Raleigh, North Carolina 27602Telephone: (919) 733-3377

Norma Parrell
Tiare Smiley
Assj-stant Attorney General

John Lassiter
Assocj-ate Attorney General

Jerris Leonard
Kathleen Keenan
Jerris Leonard & Assocj_ates, p.C.
900 17th Street, I.I.W.
Suite 1020
hlashington, D.C. 20006
Telephone: (202) 872-LOgs

aJ_J-ace, Jr .
Attorney Gen6ra1

Legal A.ffair's
ey General's Office. Department of Justice



t

I hereby ce

Interrogatories

Attorneys by pla

Office, postage

This the

-36-

CERTTFICATE OF SEFVTCE

ify that I have this day served the foregoing

upon Plaintif f r's

United States Post

Reguests for Production

ng a copy of same in the

epaid, addressed to:
J. Levonne Chambers
Leslie l^Iinner
Chambers, Perguson, Watt, Wa11as,

Adkins & Fuller, p.A.
951 South fndependence Boulevard
Charlotte, North Carolina 29202

Jack Greenbert
James lcl. Nabrit, fII
llapeoleon B. -Wi11iams, Jr.
10 Columbus Circle
New Yorkr Ner.r York 10019

Arthur J. Donaldson
Burke, Donaldson, Holshouser & Kererly
309 North I'tain Street
-Salisbury, North Carolina 29144

Robert }tr. llunter, Jr.
Attorney at Law
Post Office Box 3245
201 West Market Street
Greensboro, North Carolina 27402

day of lrlarch , 1982.



*

5. For each who

listed in your

the House clistri
particular whole

Legislaturets re

of the Extra Ses

-8-

county, township, or census unit which you

er to interrogatory number 3 (c) (2) , set out

vrherein you would propose to place tndt

unty, tovmship, or census unit within the

rtionment pLan as embodied in Chapter 4

ion Laws of 1982.



a

I
7. Set out the

a. All Hou

legislative
defici.encie

number 3.

b. Within

to interrog

I. Eacl

include

2, The

under y

3. The

House d

4. The

House d

5. The

House d

6. Thq

House d

7. The

distric

-9-

llowing:

e districts wherein you

eapportionment plan to
set out in your answer

would aLter the

correct the alleged

to interrogatory

ch House district cited in your response

ry number 7(a) set out the following:
whole county, township, or census unit
rvithin the House district under your proposal.

otal population of the revised House district
ur proposal.

otal number of whites within the revised

strict under your proposal.

total number of blacks rvithin the revise<1

strict under your proposal.

rcentage of whites within the revised
trict under your proposal. -

entage of blacks vrithin the revised

trict under your proposal.

ross deviation.of each revi.sed llouse

under your proposal.



8. In your revised
your answer to inter
same whole

districts
or census

county,

or have yo

unit withi

o Set out the foIl
a. All Senate

legislative rea

deficiencies se

number 4.

b. Within each

to interrogato

1. Each

included wi

proposal.

2. The tot
district

3. The to

Senate

4. The

Senate

5. The

Senate

6. The

Senate

7. The g

district un

dist

dist

Per

dist

-1 0-

rti.onment proposal as set forth in
atory nurnber 7, have you pJ_aced the

shipr or census unit within two House

omitted to place a whole county, township,

a House district?

ing:

stricts wherein you would alter the

ortionment plan to correct the alleged

out in your answer to .interrogatory

ate district cited in your answer

number 9(a), set out the following:
Ie county, townsh-ip, or census unit

the Senate district under your

I population of the revised Senate

r your proposal.

1 number of whites within the revised

ct under your proposal.

number of blacks within the revised

ct under your proposal.

ntage of whites within the revised

ct under your proposal.

ntage of blacks within the revised

ct under your proposal.

devi.ation of each revised Senate

r your proposal.



10. In your reappo

answer to interroga

whole county, twnsh

districts or have y

shipr o! census uni

11. With respect t
Laws of L982, do yo

ion requires the

that the overall

in the House or

so

is

-11-

ionment proposal as set forth in your

ry number 9, have you pJ.aced the same

pr or census unit wittrin two Senate

omitted to place a whole county, town-

within a Senate district?

ei.ther Chapter 4 or 5 of the Special Session

contend that the Federal or State Constitut-

islature to apportion each legislative district

range of deviations is less than it presently

enate plan?



12.

set

ff you an

out the foIl
a. The Legi

Constituti
range of d

b. Each Ho

range of de

e. The Fed

which you ba

d. The Legi

Constituti
range of de

e. Each S

range of de

f . The iFed

which you

-L2-

interrogatory number 11 in the affirmative,
ang:

laturers duty under the Federal and State

with regard to maximum permissible overall_

atj-ons from the ideal population House district.
e district which deviates from this overall
ations divided by two.

a1 and State Constitutional provisions on

e your answer to interrogatory number 12 (a).

laturets duty under the Federal and State

with regard to maximum permissible overall
ations from the ideal population Senate district.
te district which deviates from this overall
ations divided b1z two.

al and State Constitutional provisions on

e your answer to interrogatory number L2 (d) .



13. Set out the

a. Name ea

contend has

equality.
b. For ea

interrogato

residents

from the id

-13-

ollowing:

new llouse or Senate district whlch you

Iarge varj.ances from populationmpermissible

district described in your answer to
number 13 (a) set out the gross number of

the percentage that each district departs

I population district or equal population.



14. With respec

Paragraph 115

have "the effect

discriminating

of plaintiffs a

Carolina, " (a) d

descriptive te

each House and

tionment plans

dilute the votin
the effect of di

s

w

-14-

to your allegations in paragraph 109 and

t the House and Senate reapportionment plans

of and (were) enacted with the purpose of
ainst black voters and of diluting the vote

other black citizens of the State of North
fine "diluting" in both guantitative and

, (b) vrith regard to this allegation, set out
nate district within ilre legislative reappor-
ere you allege the Legislature intended to
strength of black citizens or (c) rvhich had

uting the voting strengrth of bl_ack citizens.



15. If you iden

inLerrogatorY

a. Each

each Ilouse

number 14 w

district fo

b. Each wh

each House

number 14 w

district w

strength.

c. Each w

any House d

district li

for tl:e pu

d. Each wh

House distr

listed in y

had the eff

strength.

-15-

fied any House district in your answer to

r J-4, set out the following:

e county, township, or census unit within

strict listed in your ans'.'rer to interrogatory

ich was included within the identified House

the purpose of diluting black voting strength'

Ie county, tovrnship, or census unit rvithin

istrict listed in your ansr'rer to interrogatory

ich was included r,sithin tire identified House

ch had the effect of diluting blacl: voting

Ie county, tolvnship, or census unit vrithin

strict which was excluded from any House

qed in your answer to interrogatory number 14

se of diluting black votinq strength

le county, torvnship, or census unit within any

ct vrhich was excluded from any House districL

ur ans\^rer to interrogatory number 14 which

ct of diluting or minimizing black voting



16.

to

If you have

interrogatory

a. A.11

legislative
def ici-encie

b. Within

interrogato

1. Eac

the rev

2. The

under y

3. The

House d

4. The

House

5. The

di stri
6. The

distric
7. The

under y

-16-

identified any llouse district in your answer

umber 14 , set out the follovring:

districts wherein you vrould aLter the
eapportionment plan to correct to alleged

set out in Paragraph 109 of your Complaint.

ch House district set out in your answer to
number 16 (a) , set out the followinq:

whole county, township, or census unit vrithin
ed llouse district under your proposal.

total population of the revised llouse district
ur proposal.

total number of whites vrithin the revised

trict under your proposal.

otal number of blacks rvithin the revised

trict under your proposal.

percentage of whites within the revised House

under your proposal.

centage of blacl'.s vrj-thin the revisecl House

under your proposal.

ross deviati-on of the revised l{ouse district
ur proposal.



L7. In your rev

your ansr.rers to j

same whole count

districts or omi

census unit withi

18. If you iden

interrogatory n

a. Each

each Senate

tory number

Senate dist

black votin

b. Each vrh

each Senate

tory number

Senate dist

minimi zlng

c. Flach w

any Senate

di-strict 1i
for the p

strength.

d. Each

any Senate

district 1i

which had t
voting stre

-17-

sed reapportionment proposal as set forth in
terrogatory number 16, have vou placed the

, township, or census unit within tvlo House

ted to place a whole county, township, or
a House district?

fied any Senate district j-n your answer to

er 14, set out the following:
e county, tor.rnship, or census unit within
istrict listed in vour anstrer to interroga-
4 whicl: was included within the identified
ct for the purpose of diluting or minimizing

strength.

le county, tovmshipr or census unit within
istrict listed in your answer to interroga-

L4 which was included vrithin the identified
ict which has the effect of diluting or

lack voting strength.

e county, township, or census unit
istrict which.-was excluded from any

ted in your answer to interrogatory
se of diluting or minimizing black

vrithin

Senate

number 14

voting

Ie county, townshipr or census unit
strict which was excluded from any

ted in your anslrrer to interrogatory

e effect of diluting or minimizing

within

Senate

number 14

black

rh.



19.

to

If you have

interrogatory

a. A11 Sena

legislatj-ve

deficienci
b. Within

interrogato

1. Eac

the rev

2. The

under

3. The

Senate

4. The

senite

5. The

Senate

6. The

Senate

7. The

under y

-18-

dentified any Senate district in your answer

umber 14 , set out the follovring:

e districts wherein you vrould alter the

apportionment plan to correct the alleged

set out in Paragraph 115 of your Complaint.

ch Senate district set out in your answer to

number 19(a), set out the follovring:

whole county, township, or census unit within

sed Senate district under your proposal.

total population of the revised Senate district

r proposal.

total number of whites r.rithin the revised

istrict under your proposal.

total number of blacks v:ithin the revised

istrict of your proposal.

percentage of whites rrrithin the revised

istrict under your proposal.

percentage of blacks rvithin the revised

istrict under your proposal.

gross deviation of the revised Senate district

ur proposal.'



20. Will you attemp

of legislators reg

Laws of L982 uere raa

ating against black

strength on the part

If so, set out the

a. The name of

b. The place

c.

d.

e.
cI.

g.

The date of
The exact s

The source

The name, a

If reported

telephone n

The date e

Please att

h.

i.

-19 -

to prove that contemporaneous statements

ing Chapter 4 and 5 of the Extra Session

which indicate ttre purpose of discrimin-
ters and,/or of diluting black voting

of the Legislature or any members thereof?

Ilowing.

each Legislator who made such a statement.

or she made the statement.

the statement.

tement he or she made.

rough which you learned of the statement.

such source.dress r and tel-ephone number of
in the media, the name, address, and

r of each such media outlet.
h media report was made and by whom.

a copy of each such media report.



21. Does either
reapportionrnent

or maintain the

in office? If s

the opportunity

the

lan

-20-

House of Representatives or Senate

enacted by the Legislature in 1982 enhance

rtunity of any black incumbent to contlnue

, name the incumbent and the manner in which

as enhanced or maintained.



22. Does either
reapportionment

the opportunity

If BOr name the

tunity was Ies

.l

-2L-

the House of Representatives or Senate

1an enacted by the Leqielature in 1982 leesen

f any b!.ack Lneumbent to continue in office?
ncumhent and the manner in which the oppor-



23. Do you aI

censua units in
lrere transfer

a major impact i
where the electo

a black Legisla

I ..,--.

'9

-22-

that any whole counties, townships, or
lg82 legislative reapportionment plans

from any district where they wou}d have had

the election of a black Lecislator to one

1 impact would be minor in the eLection of



24. If yo.ur ans

affirmative, set

a. fdenti

b. The Hou

townshi

The per

distric
legisla

d.

e.

The n

constit

The tlou

this wh

relocat

number

The per

if the

The tot

if the

swi tc

The num

or cens

interro

one-man,

The Hou

county,

The gros

by dist

in whol

f.

9.

h.

l_.

j.

-23-

r to interrogatory number 23 r'ras in the

ut the followj-ng:

the '.vho1e county, township or census unit.
or Senate district wherein the whol_e county,

r or census unit is now located.

ntage of blacks within the House

as presently constituted in the

ve reapportionment p1ans.

Ie county, townshipr or

or Senate

1982

of people within the district as presently

ed.

or Senate district in r.rhich you believe

e county, township, or census unit should he

, its present percentage of blacks and

people.

tage of blacks within the trvo districts
made.itch you advocated vrere

number of residents in the tv:o di-stricts

census unit were

as you advocate.

r(s) or name(s) of the whole county,

unit previously specified in answer

tory number 24(a) in order to satisfy

townshj-p,

to.
the

one-vote requirement.

or Senate district from which such v:hole

nshipr or sensus unit would be removed.

deviations of all llouse and Senate districts
ct as a consequence of the foregoing shifts
county, township, or census units.



25. If you have

reapportionment

Senate which you

26. If you have

please attach a

contiguous to t
advocate in res

-24-

dravrn or have in your possession statewide

Representatives and the

please attach the same.

ps for the House of
prefer to be adopted,

no maps referred to in.interrogatory number 25,

raling of each nev district and the districts
t district if such district were d,rarrn as you

e to interrogatory number 24.



27. fn your Par

of the apportio

enacted in Chapt

are to...deny pI

tively. "

cl . Explain

tively,

Identif
tionmen

the rig
hovr the

b.

-25-

raph 121 you state that "the intent and effect
t of the North Carolina General Assemhly

rs 4 and 5 of the Extra Session Lavrs of L982

intiffs Lheir right to use their vote effec-

e phrase "right to use their vote effec-
as you employ it.
specifically each component of the reappor-

plans which you contend denied the plaintiffs
to use their vote effectively and explain

ffective use of their vote was so denied.



28. In Paragrap

has a history of

voter registrati

regulations and

other black citi

thei-r votes effe
set forth the fo

a. A11 vot

histori
plainti

from vo

A11 vot

contin

ci ti ze

their v

All e1

employ

blaclr

using

A11 el

e.

prevent

State f
All reg

prevent

voting
cJ-o Al-1 r

plainti

from vo

A11 pra

State

of this
effecti

A11 pra

plainti

from vo

b.

d.

g.

h.

-26-

127 you state that "the State of north Carolina

discrimination acrainst black citizens in its
practices and in other electj.on Iaws,

ractices rvhich have prevented plaintiffs and

ens of this State from voting or from using

tively. " With respect to your Paragraph 127,

lorving:

r registration practi-ces which have occurred

ally in this State vrhich have prevented

fs and other black citizens of this State

ing or from using their votes effectively.

r registration practices in this State which

to prevent plaintiffs and other black

of this State from voting or from using

tes effectively.

tion laws which have historically been

in this State to prevent plaintiffs and other

tizens of this State from voting or from

eir votes effectively.
tion laws lrhich continue to be enforced v'hich

plaintiffs and other black citizens of this

om voting or from using their votes effectively.

lations which have historicall,y been used to

plaintiffs and other blacks of this State from

r from using'their votes effectively.

lations which continue to be used to prevent

fs and other black citizens of thi-s State

or from using their votes effectively.

tices which have historically been used by the

prevent plaintiffs and other black citiz.ens

State from voting or from using their votes

ly.

tices which

fs and other

ing or from

continue to be used to prevent

black citizens of this State

using their votes effectively.



29. Can you sta

registration pra

or practices whi

other black citi
their votes effe
date, the occurr

and other black

using their vot

-27-

e specific instances of the use of voter
ices or other election lawsr or regulat-i.ons,

h have been used to prevent plaintiffs and

ens of this State from voting or from usj.ng

tively? If sor list chronoloaically, by

ce of each incident of preventing plaintiffs
itizens of this State from voting or from

effectivefy.



30. Your Paragr

Assembly has his

the blac],- citiz
the following:

a. Explain

the Sta

b. Give sp

Carolin

the nee

Carolin

-28-

ph L28 states "the North Carolina

orically been unresponsj.ve to the
s of the State of North Carolina.

General

needs of

" 9et forth

the phrase "needs of the black citizens of
of North Carolinar,, as lrou employ it.

ific examples of occasions on vrhich the
General Assembly has heen unresponsive

llorth
to

Norths of the black citizens of the State of
and explai-n your ans$rer.



31. Do your sta

House of Represe

by the Legislatu
with a greater

choosing than do

of the Extra Ses

and explain your

32. Do your sta

House of Represen

enacted by the

vided blacks rarith

tively than do t
of the Extra Sess

and explain your

-29-

istics indicate that any past Iilorth Carolina
tatives or Senate reapportionment p1ans, enacted

after any decennial census, provided blacks
rtunity to elect representatives of their

the current plans embodiec,t in Chapters 4 and 5

ion Lar,rs of 1982? If so, identify the plan(s)

svrer.

stics indicate that any past North Carolina
atj.ves or Senate reapportionment plans,
j-slature after any decennial census, pro-
a greater opportunity to use their vote effec-
current plans embodied in Chapters 4 and 5

n Laws of 1982? If so, iclentify the plan(s)
Slrref .



33. Do your sta

House of Represe

enacted by the

blacks with as g

their choosing a

4and5oftheE
plan(s) and expl

34. Do your sta

House of Repres

enacted by the

blacks with as g

tively as do the

of the Extra Ses

and explain your

-30-

istics indicate that any past North Carolina

tatives or Senate reapportionment plans,

islature after any decennial census, provided

eat an opportunity to elect representatives of
do the current plans embodied in Chapters

tra Session Laws of L982? If sor identify the

in your ans!,rer.

istics indicate that any past llorth Carolina

tatives or Senate reapportionment p1ans,

islature after any decennial census, provideQ

eat an opportunity to use their vote effec-
current plans embodied in Chapters 4 and 5

ion Laws of L982? If sor identify the plan(s)

ans!'rer.



35. State the

of each person

of this matter (

referred to in t
substance of eac

-31-

, address, employment, and telephone

u will or may call as a witness at the

th the exception of those experts, if
e next interrogatory) and further state
such personfs expected testinony.

number

trial
ODY,

the



36. State the

and qualificati

expert witness

the subject mat

testify.

-32-

e, address, employmentl telephone number,

of each person you expect to call as an

the trial of this matter and further state

on vrhich each such expert is expected to



37. As to each

number 36, state

which said

of the grounds f

-33-

xpert named in the answer to interrogatory
the substance of the facte and opinions to

are expected to testify and give a summary

r eaeh opinion.



38. Please atta
true, complete,

prepared by any

39. State the n
of each expert w

in anticipation

not expected to

-34 -

to your answers to

corect copies of

these interrogatories
any and all documents

relating to this action.uch experts 63 €xP€rt

, address, telephone num.berr and gualifications
you have retained.or specifically employed

litigation or preparation of trial and who is
called as a vritness of the trial of this action.



40. Indicate ea

ans$rers to inter
other legal p

tionment and des

each of those p

Respectfull

-3 5-

h occasi-on on vrhich each

atories number 35 and

ings regarding State

ibe the nature of his
r-ngs.

person named in the

35 has testified in
legislative reappor-

or her testimony in

!{arch , L982.submitted this tn" 29 day of
RUFUS L. EDHTSTEIV
ATTORNEY GENERAL

Raleigh, North Carolina 27602Telephone: (919) 733-3377

Norma Parrell
Tiare Smiley
Assj-stant Attorney General

John Lassiter
Associate Attorney General

Jerris Leonard
Kathleen Keenan
Jerris Leonard & Associ.ates, p.C.
900 17th Street, lJ.W.Suite 1020
I^.rashington, D,C. 20006
Telephone: (202) BZ2-1095

aJ.J.dCe, .Tr.tf Attorney Gery6ra1
ory'Legal A.f fairs

Lgrtney General's Of fice}rc. Department of JusticePost Office Box 629



I hereby ce

fnterrogatories

Attorneys by p1a

Office, postage

This the

-36-

CERTIFICATE OT' SEFVICE

ti.fy that I have this day served the foregoing

upon Plaintif f ;'s

United States post

d Reguests for production

ing a copy of same in the

repaid, addressed to:
J. Levonne Chambers
LesLie l^Iinner
Chambers, Ferguson, Watt, Wallas,

Adkins & Fuller, p.A.
951 South Independence Boulevard
Charlotte, North Carolina 2g2oz

Jack Greenbert
James lvl. Nabrit, Iff
llapeoleon B. .Wi11j-ams, Jr.
10 Columbus CircLe
New York, Ner.r york 10019

Arthur J. Donaldson
Burke, Donaldson, Holshouser & Kererly
309 North I'lain Street
-salisbury, North Carolina 29144

Robert II. llunter, Jr.
Attorney at Law
Post Office Box 3245
201 West Market Street
Greenshoro, North Carolina 27402

day of l{arch , L982.

ace,
';/'