Answers to Plaintiffs' Interrogatories and Motion to Produce by County Commissioner Jack Pate

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UNITED STATES DISTRICT COURT 
FOR THE MIDDLE DISTRICT OF ALABAMA 

NORTHERN DIVISION 

JOHN DILLARD, ET AL, 
PLAINTIFFS 

VS. CIVIL ACTION #85-T-1332-N 

CRENSHAW COUNTY, ALABAMA, 
ET AL, 

DEFENDANTS. 

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ANSWERS TO PLAINTIFFS' INTERROGATORIES 

AND MOTION TO PRODUCE 

BY JACK PATE, PICKENS COUNTY COMMISSIONER 

  

  

  

Comes Jack Pate, Commissioner, Pickens County and for answer 

to Plaintiff's Interrogatories and Motion to Produce Documents 

says as follows: 

l. Reverend James Corder, Mrs. Dunner Hill, Mr. Bandi, 

la. Pickens County Commission (Corder), Pickens County Board of 

Education, (Bantum and Hill). 

lb. Don't know. 

lc. Defeated. 

2. Not admitted. 
a 

3a. Walter Jones, black male, appointed to Board of Registrars, 

date unknown; Voncile Wright, female black, appointed to Board of 

Registrars, date unknown. 

4a. Pickens County Hospital Board, Pickens County Water, Sewer 

and Fire Protection Authority, Pickens County Industrial 

Development Board, Pickens County Library Board. Procedure is 

review of all qualifications. 

4b. See response in answers of Pickens County Probate Judge. 

 



  

PAGE TWO 
  

4c. See response in answers of Pickens County Probate Judge. 

4d. See response in answers of Pickens County Probate Judge. 

5a. See response in answers of Pickens County Probate Judge. 

5b See response in answers of Pickens County Probate Judge. 

5c. See response in answers of Pickens County Probate Judge. 

5d. See response in answers of Pickens County Probate Judge. 

6. Not that I know of. | 

7a. No. 

7b. No. 

8. N/A 

9. See Affirmative Action Plan that was adopted by Commission on 

April 22, 1980, and a copy is attached to response of Probate 

Judge. 

10. Not that I know of. 

ll. Do not know of any. 

l2a.Richard Walters, District One Commissioner, White; Jerry 

Fitch, District Four Commissioner, White; Garvin Bryant, District 

Two Commissioner, White; Jack Pate, District Three Commissioner, 

White; W. H. Lang, Jr., Probate Judge, White; Louie Coleman, 

Sheriff, White; James Floyd, Circuit Clerk, White. 

l12b.See response in answers of Pickens County Probate Judge. 

l3a.See attached records. 

l3ai.See attached records. 

13b. None 

13c. See attached records. 

13d. See attached records. 

 



  

PAGE THREE 
  

13e. See attached copies of campaign literature. 

13f. None 

13£1. N/A 

13f2. N/A 

13g. McShan Community Club, Palmetto Community Club, Chamber of 

Commerce Political Rally, Gordo, AL. 

13gl. Political Rally - made a 2peethe 

13g2. Richard Walters, white, Edward Wheat, white; Kat Craft, 

white; Billy Ray Cook, white; Ernest Chappell, white; Jimmy 

Wilson, white: Chester James, white; and Ganus Gray, white. 

13h. None. 

131i. None. 

133. Made an appeal to all people in my district, black or 

white, through personal contact, newspapers and radio 

advertising. 

13k. None. 

131. None. 

13m. None. 

13n. None. 

130. None. 

13p. None. 

14. Jack Pate, Gordo, AL, my attorney W. O. Kirk, Jr., 

Carrollton, AL, Chief Clerk of Probate Court, Mrs. Glenda Ryan, 

Carrollton, AL: Clerk of Commissioners' Court, Verbon Atkins, 

Carrollton, AL: all records in my custody or Chief Clerk's 

custody or Verbon Atkins' custody or Probate Judge's custody. 

 



  

PAGE FOUR 

15. No. 

15a. County involved in litigation in case styled Corder vs. 

Kirksey, which resulted in an approved plan of election 

Pickens County. 

15b. See response in answers of Pickens County Probate Judge. 

15bl. See response in answers of Pickens County Probate Judge. 

15b2. See response in answers of Pickens County Probate Judge. 

15b3. See response in answers of Pickens County Probate Judge. 

16. I do not know. 

17a. N/A. 

17b. N/A. 

18. At one time schools were racially segregated. 

19. N/A. 

20. I do not know. 

21. See response in answers of Pickens County Probate Judge. 

el Elmore Center United Methodist Church, Pickens County 

Cattleman's Association, Gordo Lions Club. 

23. See response in answers of Pickens County Probate Judge. 

24. See response in answers of Pickens County Probate Judge. 

25. See response in answers of Pickens County Probate Judge. 

26. See response in answers of Pickens County Probate Judge. 

27. See response in answers of Pickens County Probate Judge. 

28. See response in answers of Pickens County Probate Judge. 

29. See response in answers of Pickens County Probate Judge. 

30a. No expert witnesses obtained at present but information 

  

will be supplied if and when an expert is obtained. 

 



  

PAGE FIVE 
  

30b. N/A. 

30c. : N/A. 

Clb fale 
JACK PATE 
  

STATE OF ALABAMA 

COUNTY OF PICKENS 

Before me, the undersigned authority in and for said County and 
said State, personally appeared Jack Pate, who after being first 
duly sworn, deposes and says that he is cognizant of the facts as 
set forth in the foregoing Answers to Interrogatories and Motions 
to Prcduce and he further states that the facts as stated therein 
are true and correct according to the best of his knowledge, 
information and belief. 

Given under my hand and seal this 3/ day of January, 1986. 

227%): 
NOTARY PUBLIC 
  

ATTORNEY FOR JACK PATE 

DEFENDANT 

ry EAT 
  

W. OT KIRK,“JR. 
CURRY & KIRK 
P. O. BOX A-B 
CARROLLTON, AL 35447 
TELEPHONE: (205) 367-8125 

 



  

upon: 

PAGE SIX 
  

CERTIFICATE OF SERVICE 
  

I hereby certify that I have served the foregoing 

Wanda J. Cochran 

Larry T. Menefee 
James U. Blacksher 

Blacksher, Menefee & Stein, P. A. 

405 Van Antwerp Building 
« Ou Box 1051 

Mobile, AL 36633 

Terry Davis 
Seay and Davis 
732 Carter Hill Road 
P. O. Box 6215 
Montgomery, AL 36104 

Julius L. Chambers 

Deborah Fins 
Legal Defense Fund 
99 Hudson Street 

léth Floor 

New York, New York 10013 

W. Edward Still 

Reeves and Still 

714 South 29th Street 

Birmingham, AL 35233 

Reo Kirkland, Jr. 

Attorney at Law 

P. O. Box 646 

Brewton, AL 36427 

Answers 

by placing copies of the same in the United States Mail properly 
addressed and postage paid this 5 day of February, 1986. 

E2474 
W. O. KIRK/ JR., ATTORNEY FOR 

1986. 

  

PICKENS COUNTY DEFENDANTS 

 



  

PAGE SEVEN   

CERTIFICATE OF SERVICE 
  

I hereby certify that I have served the foregoing Answers on 
the other Defendants by 
record: 

Jack Floyd 
Floyd, Kenner & Cusimano 
816 Chestnut Street 
Gadsden, AL 35999 
(ETOWAH COUNTY ) 

D. L. Martin 
215 South Main Street 
Moulton, AL 35650 
and 
David R. Boyd 
Balch and Bingham 
P..Q. Box 78 
Montgomery, AL 36101 
(LAWRENCE COUNTY) 

H. R. Burnum 

P. OQ. Box 1618 

Anniston, AL 36202 

(CALHOUN COUNTY) 

Alton L. Turner 

404 Glenwood Avenue 

P. O. Box 207 

Luverne, AL 36049 

(CRENSHAW COUNTY) 

Warren Rowe 

P. 0. Box 150 

Enterprise, AL 36331 
(COFFEE COUNTY) 

serving the following attorneys of 

Barry D. Vaughn 
Proctor and Vaughn 
121 North Norton Avenue 
Sylacauga, AL 35150 
(TALLADEGA COUNTY) 

James W. Webb 

Webb, Crumpton, McGregor, 
Schmaeling & Wilson 
166 Commerce Street 

Montgomery, AL 36101 
and 

Lee M. Otts 

Otts & Moore 

P. 0. "BOX 467 

Brewton, AL 36427 

(ESCAMBIA COUNTY) 

by placing copies of the same in the United States Mail properly 
addressed and postage paid this 3 day of February, 1986. 

W. > Ls 7s 7. ATTORNEY FOR 
  

PICKENS COUNTY DEFENDANTS 

 



  

   Brown Punting Co. Muntgomeuy, "'® » ~ HPT PS 
{ ~) ; CD XE Foi { 

PEXPENSE ACCOUNT OF CANDIDATE Ct Li 

(To Be Filed Within 1§ Days After the . Election) 

NAME .ooiv. so rJack To Pate 

MAILING ADDRESS _ Route 4, Box 241 

is tn im rerraee AGO EAC -ALABANR.—35R66....... oe oereee oe 

Pursuant to Title 17, Sections 278, 279 and 400 of the Code of Alabama as amended, defining the Corrupt 

Practices Act, I herewith submit a full, correct, detailed and itemized statement of all expenses made directly 

or indirectly in sums over $5.00 and of all obligations, debts, or liabilities assumed or Incurred at the time of filing 

this statement, together with the names of all contributors of amounts in ¢xcess of $10.00, with the amounts given 

by each, and a list of all gifts, loans or contributions made in connection with my campaign as a candidate in the 

Election held on Tuesday, November 6 1884 for the office of 

Pickens County Commission District 3 
-L: A —.—_— kk] 

(Enter Name of Office) 
  

      

CONTRIBUTIONS . 4 
June + 5, 1984 Mrs. Martha P, Strickland Campaign Cards & Posters 

| (Donated ?) 

  

  

  

      

TOTAL... . SR AA ih 

EXPENSES INCURRED 

June 5, 1984 Pickens Co. Demo. Exc. Committee $ 168.00 

June 1984 Kirk Vol. Fire Dept. $ 25.00 
June 1984 Pickens! County Herald § 75.00 

June 1984 West Ala. Ad-Visor 2 SES 260400 
July 2, 1984 W.R.A,G, Radio $ 25,00 
Aug. 20, 1984 Pickens County Herald $ 30,00 

Aug, 23, 1984 Pickens Co. High School Band Day $ 10.00 

Aug. 21, 1984 Weat Ala, Ad-Visor $ 35.00 
Aug, 24, 1984 McShan Political Rally $§ 61,00 
Aug. 25, 1984 Gordo Chamber of Commerce Political Rally $ 30,00 

Aug. 28, 1984 Pickens County Herald $ 30.00 
Aug. 28, 1984 West Ala. Ad-Visor $35.00 

Aug. 28, 1984 Pickens County Broadcasters $ 60,00 

Aug. ©1984  Beard's Super Service (Estimated gas) $ 80.00 

Sept. 1, 1984 Palmetto Political Rally $ 57.00 
Sept. 4, 1984 Pickens County Herald $§ 20.00 

Nov, | 5, 1984 Pickens County Broadcasters $ 35.00 
Nov. 16, 1984 West Ala. Ad-visor $§ 94.00 

Nov. 16, 1984 Pickens County Herald $ 109.60 

Nit | 

| $1079.60 

Signature of Candidate. as a le wi AA 

STATE OF ALABAMA, COUNTY OF eee ee. NE eR Ea 7 i 

PI TE WON EE, EP Se. a Notary Public tj snd for suid ceuuiy in sand 

state, hereby certify that == 4 Rear A i TO a : © whut Bane i 
    

signed to the foregoing statement, who is known to me, he personally appeared before me on this duy and bein 

first duly sworn deposes and says that the statement hereinabove made is in all respects true, and tha the sae 

is a full and detailed statement of all monies, securities or equivalents for.money coming under the control ov cus- 

tody of said committee and by it expended directly or indirectly. 

Sworn to and subscribed before me this /Z day ie lodmbat?. i. RR". 4 oF 

Gmogene 2. Koos gt, Notary Pablhic 

Title 17§ 400. Expente account of candidate must be made and filed.- Any candidate for any office clected by the votes of 

more than ope county, except candidates for the office of state senate, shall file with the secretary of state, and every candidate 

for a county office and candidates for the state senate and house of representatives shall file with the judge of probate of the 

county or counties in which said election is held, a sworn statement, setting out and itemizing the expenses of his canvass in such 

election within fifteen days after such election. and any candidate who fails to so file und swear to such statement within said 

tune, shall be guilty of a misdemeanor, and, on conviction, must he fined not less than one hundred nor more than one thousand 

dollars.” 
— ee Arp Sordi A aie Bh lh ie A 4A 

  

Drawn Printing ns Mantonmery. Alabama     

 



    

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PICKENS COUNTY 
COMMISSION 
DISTRICT 3 
(GORDO DISTRICT) 

Pd. Pol. Adv. by Jack T. Pate, Rt. 4, Gordo, AL ®-sgs3. 

   



"VOTE FOR 
  

ELECT ® 4 ; JRcK T.PATE i 
| FOR the 

JACKT.PATE | | bens COUNTY > 
PICKENS COUNTY | © COMMISSION hes 

DISTRICT 3 

  

COMMISSION DISTRICTS 

    
  

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Bobbie « Jay - Susan ; Jack ' Rv Bobbie - Jay - Susan - Jack 

; My family and | appreciate the vote i 

Dedicated t to a better way of life boo | of confidence the people of District te 
1 7 | 3gavemeinthe Sept.4,1984 for every Pickens County family] 111 | Democratic Primary for the Pickens | 

(Pd, Pol. Adv.by =" "11 | County Commission. We now ask all       

Juok T, Pate, Gordo, Ala) - 1 | the people of Pickens County for your — A . | vote and support in the General 

“1 | Election on Tuesday, Nov. 6, 1984. 
WIE BW m 

i : A Be sure to mark an Xby JACK T, PATE | # 

| for Pickens County Commission 
District 3 under the Democratic ticket. 

VOTE FOR 

    

  

in rt (Pd. Pol. Adv. by Jack T. Pate, , = BU oe 3 Gordo, Ala.) 
PICKEN COUNTY COMMISSION DISTRICT 3 ea | Bn as i ____(GORDODISTRICT) = °° 
Not vote and influence will be appreciated 
SUBJECT TO THE ACTION OF THE DEMOCRATIC PRIMAF RIES, 
Pd Pol. Adv. by Jack T Pate, Rt. 4, Gordo, AL 

      
    

SEPT. 4 8 25,1984