Defendant's Answer to Plaintiff's Request for Admission

    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. 

V
a
r
”
 

N
a
s
t
”
 
N
i
 

N
u
i
 

N
u
i
t
”
 

“
w
t
”
 

“
w
a
t
”
 
“
m
t
 

ANSWER OF PICKENS COUNTY DEFENDANTS TO 

PLAINTIFFS' REQUEST FOR ADMISSION 
  

  

Questions 1 through 11, 13 through 78, 82 through 98. 

These requests for admissions are objected to by the said 

Defendants on the following grounds: 

l. The said requests are not in compliance with Rule 36 of 

the Federal Rules of Civil Procedure and is not within the scope 

of Rule 26(b) of the Federal Rules of Civil Procedure. 

2. The said requests ask for admissions of law unrelated to 

the facts of this case and said requests are improper. 

3. Said requests involve matters of mixed law and fact and 

are improper. (Minnesota Mining and Manufacturing Co. vs. Norton 
  

Company. 36 F.R.D.1) 

4. The said requests are unduly burdensome and the said 

requests are so voluminous and are so framed that the said 

answering party cannot reasonably address the said questions. 

Be The said Defendants are not required to prove 

Plaintiffs' case by the answering of these burdensome requests 

for admissions and the information concerning the requests are 

 



  

not readily obtainable and are not within the special knowledge 

of the said Defendants. 

QUESTION 12. Admitted. 

Question 79. Admitted. 

Question 80. Admitted. 

Question 81. Denied as candidates of political office seek votes 

from both races. 

Question 99. Denied. 

Question 100. Denied. 

Question 101. Denied, as candidates seek votes from all segments 

of the voter population including black as well as white. 

PIC NS\COUNTY. DEFENDANTS 

BY: 
W. H. LANG, JR. CJS 
PROBATE JUDGE 

  

ATTORNEY FOR PICKENS COUNTY 

DEFENDANTS 

20 JAS 
  

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

 



  

CERTIFICATE OF SERVICE 
  

I hereby certify that I have served the foregoing 
Request for Admission upon: 

Wanda J. Cochran 

Larry T. Menefee 
James U. Blacksher 

Blacksher, Menefee & 

Answer to 

Stein, P. A. 

405 Van Antwerp Building 
Box 1051 

AL 36633 

Ps O. 

Mobile, 

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 

16th Floor 
New York, New York 

W. Edward Still 

Reeves and Still 

10013 

714 South 29th Street 

Birmingham, AL 

Reo Kirkland, Jr. 

Attorney at Law 

P. O. Box 646 

Brewton, AL 36427 

by placing copies of the same in 

35233 

e United States Mail properly 

  

addressed and postage paid this day of February, 1986. 

Ur riV A 
W. O. KIRK,” JR., ATTORNEY FOR 

PICKENS COUNTY DEFENDANTS 

 



  

CERTIFICATE OF SERVICE 
  

I hereby certify that I have served the foregoing Answer to 
Request for Admission on the other Defendants by serving the 
following attorneys of 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. O. Box 78 

Montgomery, AL 36101 
(LAWRENCE COUNTY) 

H. R. Burnum 

P. O. 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. O. Box 150 
Enterprise, AL 36331 
(COFFEE COUNTY) 

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. O. Box 467 

Brewton, AL 36427 

(ESCAMBIA COUNTY) 

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

  

We ” iz Jp ATTORNEY FOR 

PICKENS COUNTY DEFENDANTS