Defendant's Response to Interrogatories, Timothy A. Hawsey

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

NORTHERN DIVISION 

JOHN: DILLARD, ET AL.) 

Plaintiffs, 

va, CIVIL ACTION NO. 85-T-1332-N 

CRENSHAW COUNTY, ALABAMA, 
ET ALLS 

Defendants. C
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RESPONSE TO INTERROGATORIES BY DEFENDANT, TIMOTHY A, HAWSEY 
  

Defendant, Timothy A. Hawsey as Sheriff of . Escambia County, 

Alabama, responds to plaintiff's interrogatories as follows: 

1. I have no personal knowledge, however, on information and 

belief 1. adopt . the answer to this question: submitted by Martha 

Kirkland, Probate Judge of Escambia County. 

2. I have no personal knowledge, however, on information and 

belief 1 adopt the answer to this question submitted by Devon Wiggins, 

Chairman of the County Commission. 

3. 1 have no personal knowledge, however, on information and 

belief I adopt the answer to this question submitted by Devon Wiggins, 

Chairman of the County Commission. 

4. I have no personal knowledge, however, on information and 

belief I adopt the answer to this question submitted by Devon Wiggins, 

Chairman of the County Commission. 

6. 4d adopl the response submitted by Martha Kirkland, Judge of 

 



  

Probate. 

6. Not to my knowlege, 

7. On information and pelief I adopt the response submitted by 

Devon Wiggins, Chairman of the County Commission. 

8. On information and pelief I adopt the response submitted Dy 

Devon Wiggins, Chairman of the County Commission. 

9. On information and belief I adopt the response submitted by 

Devon Wiggins, Chairman of the County Commission. 

10. On information and pelief I adopt the response submitted by 

Devon Wiggins, Chairman of the County Commission. 

11. Not to my knowledge 

12." TT. adopt "the response submitted by Martha Kirkland, Judge of 

Probate. 

13. iA: * See records and reports attached to the response by 

Martha Kirkland, Judge of Probate. 

B. « None, 

C. See record of contributions attached to the response by 

the Probate Judge. 

D. See record of contribution attached to response by Judge 

of Probate. 

E. Note campaign literature attached. 

F. I attended the Brewton ADC and the Atmore ADC meeting at 

the Southern Normal School. 

(1) I attended and sought votes. 

(2) aA) ls other candidates were there. 

 



  

G. I attended the Indian Porch Community Gathering but no 

white church, club or facility. 

H. No special issue. 

Il... None, 

did «No, 

K. None. 

L+ «None. 

M. Not known. 

N.: ADC endorsed me. 

O." Not avallable, 

P. See reports of campaign expenditures attached to response 

by Judge Kirkland. 

14, I was assisted by my attorney and by the records of the Judge 

of Probate. 

15. I have no personal knowledge, however, on information and 

belief I adopt the answer to the question submitted by Devon Wiggins, 

Chairman of the County Commission. 

16. I know of no election characterized by racial polarization. 

17. Various candidates have sought and received the ADC backing 

for many years. I know of no elections that have been characterized 

by racial polarization. 

18. This depends upon your definition of the "recent past". The 

school system to my knowlege in the recent past has been racially 

integrated. 

19. 1 do not maintain documents and have no personal knowledge of 

 



  

the names of witnesses regarding this fact. 

20. I do not know the answer to this question. 

21. I have no personal knowledge, however, on information and 

belief I adopt the response submitted by Devon Wiggins, Chairman of 

the County Commission. 

25." TT am.a members. of the  First'. Baptist Church ‘in Flomaton, 

The National Rifle Association, The Fraternal Order of Police, The 

National Sheriffs Association, Alabama Sheriffs Association, The 

Alabama Peace Officers Association and the Alabama Boys and Girls 

Sheriffs Ranch. 

23. On information and belief I adopt the response 0 this 

question submitted by Devon Wiggins, Chairman of the County 

Commission. 

24. On information and “belief I “adopt the . response to this 

question submitted by Devon Wiggins, Chairman of the County 

Commission. 

25. “On information and belief I adopt the response to this 

question submitted by Devon Wiggins, Chairman of the County 

Commission. 

26. On information and belief "I"¥adopt’ the -.response to this 

question submitted by Devon Wiggins, Chairman of the County 

Commission. 

27. On information and *belief 1. adopt the response fo this 

question submitted by Devon Wiggins, Chairman of the County 

 



  

Commission. 

28. I adopt the response of Martha Kirkland, Judge of Probate. 

29. I adopt the response of Martha Kirkland, Judge of Probate. 

AD ATE mL. Ll i 
TIMOTHY (Epunty Sherif 

30. "Not known at this time. 

  

Escambia\Ceounty 

this "the =o day of 
  

  

SWORN ““to =and “SUBSCRIBED bYefore nie 
Felner y 1986. 

NOTARY PUBLIC 
  

  

| JAMES W. WEBB 
Attorney for Escambia County 

OF COUNSEL: 

WEBB, CRUMPTON, McGREGOR, SCHMAELING & WILSON 
166 Commerce Street, P.O. Box 238 
Montgomery, Alabama 36101 
(205) 834-3176 

OTTS & MOORE 
P.C." Box. 467 
Brewton, Alabama 36427 
(205) 867-7724 

CERTIFICATE OF SERVICE 

I hereby certify that copies of the foregoing response 
to interrogatories by defendant, Timothy A. Hawsey have been mailed to 

Larry T. Menefee, Esquire, James U. Blacksher, Esquire and Wanda J. 
Cochran, Esquire, Blacksher, Menefee & Stein, 405 Van Antwerp 
Building, P.O."Box .1051, "Mobile, : Alabama 36633, Terry. G. : Davis, 
Esquire, Seay & “Davis, «732: Carter Hill. Road,’ P.O. Box .'6125, 
Montgomery, Alabama 36106, Deborah Fins, Esquire and Julius L. 
Chambers, Esquire, NAACP Legal Defense Fund, 99 Hudson Street, 16th 
Floor, New York, New York, 10013, Jack Floyd, Esquire, Floyd, Kenner & 
Cusimano, 816 Chestnut Street, Gadsden, Alabama 35999, Alton Turner, 

 



  

Esquire, Turner & Jones, P.O. Box 207, Luverne, Alabama 36049, D.L. 

Martin, Esquire, 215 S. Main Street, Moulton, Alabama 35650, David R. 

Boyd, Esquire, Balch & Bingham, P.O. Box 78, Montgomery, Alabama 

36101, W.0. Kirk, Jr., Esquire, Currys & Kirk, :;.Phoenlx Avenue 
Carrollton, Alabama 35447, Barry D. Vaughn, Esquire, Proctor & Vaughn, 

121 N. Norton Avenue, Sylacauga, Alabama 35150, H.R. Burnham, Esquire, 
Burnham, Klinefelter, Halsey, Jones & Cater, 401 SouthTrust Bank 

Building, “P.0, ‘Box+ 1618, Anniston, ‘Alsbama 36202, * Warren: Rowe, 
Esquire, Rowe, Rowe & Sawyer, P.O. Box 150, Enterprise, Alabama 36331, 

Edward Still, Esquire, T14 South 29th Street, Birmingham, Alabama 
35233-2810, Reo Kirkland, Jr., Esquire, P.O. Box 646, Brewton, Alabama 
36427, and all defendants not represented by counsel by placing copies 
of the same in the United States Mail, postage prepaid this the J 
day of February, 1986. 

  

got   

Webb James W.