Motion to Dismiss or Affirm

    -r
CHAMBERS, FERGUSON, WATT, WALLAS, ADKINS & FULLER. P.A

ATTORNEYS AT LAW
SUITE 73O EAST INDEPENDENCE PLAZA

95I rcUTH INDEPENDENCE BOULEVARD

CHARLOTTE, NORTH CAROLINA 2A2O2
TELEPHONE (704) 375-a461

October 29, 1981

JULIUS LEVONNE CHAMBERS

JAMES E. FERGUSON, II

MELVIN L. WATT

JONATHAN WALLAS

KARL AOKINS

JAMES C. FULLER. JR.

YVONNE MIMS EVANS

JOHN W. GRESHAM
RONALD L. GIBSON
GILDA F. GLAZER

LESLIE J. WINNER

JOHN T, NOCKLEBY'

. OF O. C, BAR ONLY

Dear Rich:

Mr. J. Rich Leonard, Clerk
United States District Court
Eastern District of North Carolina
Post Office Box 25610
Raleigh, North Carolina 276Lt

Re: Gingles, €t al. v. Edmisten,et a1., Civ No. 81-803-CIV-5

r am encLosing- for filing a Notice of Depositions inconnection with the above case. r would- appreciate yourreturning a file stamped copy of that Noticl to me. '

ll r.sponse to the Discovery order of september 29, 19gl_,Jim and r have conferred anE l3r-" ag-reed- on a discoverydeadline of March 15, L982. Alrhou[tr uoth Jim-;;e-i-wou1dl-ik-e to_ expidite the ultimate decisfon oi trli, ""iio", andalthough we_wi1l both endeavor to compLete aiscoveiv
::b:I?"tia11y sooner rhan rhar , becauie oi ah; -;;;iexiry
of the case and the uncertainty of the effect of futureactions of the General Assembly and the united st"i""
Pepartment of Justice, we cannot agree to an earlierdeadline.

Thank you for your cooperation in this Batter.
Sineerely,

LJtrI:md
Enclo sures
cc: Mr. James C.

Mr. Napoleon
Wallace, Jr.
B. Williams



t*.*,

IN
FOR THE

RALPH GINGLES, €t

v.

RUFUS L. EDMISTEN,

TO COI]NSEL FOR T

James C. Wallace,
Deputy Attorney G

for Legal- Affa
Attorney General'
North Carolina
Post Office Box 6
Raleigh, North C

PLEASE TAKE NOTI

of North Carolina,

Raleigh, North Ca

before an authori

of Civil Procedure

will take the dep

and Terence Sul1i

By agreeme

will attend with

tions and produce

attached to this
Such deposi

compLeted. You

This 29th

\o -'Lq-ol

UNITED STATES DISTRICT
TERN DISTRICT OF NORTH

RAI,EIGH DIVISION

COURT
CAROLINA

Civil No. 8L-803-CIV-5

aintiffs,

NOTICE OF DEPOSITIONS

ete., €t 41.,

fendants.

ABO\IE.NA},TED DEFENDANTS:

r.
raI

s
Office
rtmenE of Justice

lina 27602

that, dt the office of the Attorney General

North Carol.ina Supreme Court Building,
Lina, orr Monday, November 9, 1981-, 8t
d officer and pursuant to the Federal

, the plaintiffs in the above captioned

itions upon oraL examination of William
n.

with the attorney for defendants, the

formal subpoena and will bring to said

9:30 a.m.

RuLes

action

HaLe

deponents

deposi-

or examination and copying a1_1 documents

tice as Exhibit A.

ions sha1l continue from day to day until
invited Eo attend and cross-exanine.

y of October, 1981.

(att*\L

-q 
rvrt.tu v

LESLIE J. WI

Adkins & Fuller, P.A.
Suite 730 East Independence Plaza
951 South Independence Boulevard
Charlotte, North Carol-ina 28202
704/375-8451

Attorneys for Plaintiffs



!- -*.

The folLow

you have access w

during the 1981 r
As sembly:

1.

meet

4. A11

or

6. A11 c

and t

8.

7. A11 s

9. Corre

Gov

2.

3.

5.

and t

EXHI IT A TO NOTICE OF DEPOSITIONS

ng requests apply Eo all documents to which

ich contain information about redistricting
gular and special Sessions of the General

s from the legislative staff or
other
conce
redist
guideli s, background information, etc.

uEes of the House, Senate, or joint
icting cornmittees and subcommilteesistricting the General Assembly or
sional Districts.
f the conmittee or subcommittee
s and any transcriptions of those

s- or plans for redisLricEing con-
by the cornmittees or subcommittees
lame of the person submitting the
1-an plus all-- supporting docurnents
staff analysis of the p1an.

tate employees to legisLators
ing legislative or congressional
icting including instructions,

The mi
redist
for re
Congre

Tapes

tapes.

A11 ma
sidere
and t
map or
and an

A11 do
of or
tion o

prePar
state
1egis1

Congre
the 1e
House,
commit

of the
comrnit

Any wr
member
redist

to the

anyone
as si st

nts which contain an analysis
ta concerning the racial composi-
counties or proposed legislative
essional districts which were

d by legislative staff or other
vernment empLoyees for use by
ors.

espondence from North CaroLina
n or members of their staff

slative staff, the Speaker of
he Lieutenant Governor, or the
e chairman or subcommittee chairman
responses to this correspondence.

dards and guidelines adopted by any
edistricting cornmittees or subl

ten statements or requests made byof the public and submitted to acting cornmittee or subcommittee.

ndence to the legislative staff or
peaker of the House, the Lieutenant
r oE Ehe committee chairman from
ffering technical or computer
ce to the legislature for redistricting
responses to those offers.

to
the



ot. .

10. The re
House
bilL w
each
or not

11. AlL re
conce
distri
toa
staff'

L2. Al_1
Lieute
tricti
congre

13. Memos
comnit
routi

rd of the vote on the floor of the
d of the Senate on each redistricting
ch was proposed or adopted and on
ndment to each of the bills whether
he amendment was adopted.

sts for information or for assistance
ng legislative or congressional re-
lng fqom any member of the legisLaLure
ber of the iegislative staff ind the
response to the requesEs.

s from the Speaker of the House or the
t Governor to members of the redis-
cormnittees or subconrrittees concerningional or state legis1-ative redistricting.

om the redistricting committee
e chairman to commiEtee members
notices of committee meetings.

or sub-
excluding



ot*.i

The undersi

served copies of t
counsel for the de

copies of s€rme in
addressed to:

This 29t}:.

CERTIFICATE OF SERVICE

endants and

certifies that he has this day

NOTICE OF DEPOSITIONS upon

the named deponents by depositing

d hereby

foregoing

he United States mail, postage prepaid,

James C. Wallace, Jr.
Deputy Attorney General

for Legal Affairs
North Carolina Department

of Justice
Post Office Box 629
Raleigh, North Carolina 27602

William Hal-e
Office of Legislative Services
North Carolina General Assembl-y
Jones Street
Raleigh, North Carol-ina

Terence Sullivan
Office of LegisLative Services
North CaroLina General Assembly
Jones Street
Raleigh, North Carolina

y of October, 1981.

Etorney