Pre-Trial Memorandum of Plaintiffs Ralph Gingles, et. al.

Working File
July 21, 1983

Pre-Trial Memorandum of Plaintiffs Ralph Gingles, et. al. preview

Contains handwritten note from Jerry Salarna[?] to Grace.

Cite this item

  • Case Files, Thornburg v. Gingles Hardbacks, Briefs, and Trial Transcript. Attorney Notes; Correspondence from Winner to Guinier; Notice of Deposition, 1982. aa9af65e-d792-ee11-be37-6045bddb811f. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/9f74ac48-aa71-42ec-87f8-7f578e17cf62/attorney-notes-correspondence-from-winner-to-guinier-notice-of-deposition. Accessed May 22, 2025.

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CHAMBERS, FERGUSON, WATT, WALI-AS, ADKINS & FULLER,
ATTORNEYS AT LAW

SUITE 73O EAST INDEPENDENCE PLAZA

95I SOUTH INDEPENDENCE BOULEVARO

CHARLOTTE, NORTH CAROLINA 2O2O2
TELEPHONE (704) 375-S461

May L1, L982

JULIU6 LEVONNE CHAMBERII

JAMEB E. FERGUSON. II

MELVIN L. WATT

JONATHAN WALLAB

KARL ADKINS

JAMBg C. FULLER. JR.

WONNE MIMS EVANA

JOHN W. ORBsHAM

RONALD L. GIBSON

OILDA F. GLAZER

LEBLIE J. WINNER

JOHN T. NOCKLEBY'

. OP D. C. IAR ONLY

Dear Lani:

I suggest that you come down
that we should uot try to do
go round

Ms. Lani Guinier
Legal Defenee Fund
10 Columbus CireLe
New York, New York L0019

Re:

LJI{: ddb
Enclosure

Gi.nEIeg v. Edmisten

sometlme on Monday. I deelded
more than this during the first

SincereLy,

rfub
rc{t{" s. wlnner



I

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF NORTH CAROLINA

RALEIGH DIVISION
No.81-803-Civ-5

RALPH GINGLES, €t 41., )
)

Plaintiffs, )

O J- tt-EZ

NOTICE OF DEPOSITION

Robert N. Hunter, Jr.
Arthur J. Donaldson
Attorneys for Plaintiffs
in Pugh v. Hunt, 81-1066-Civ-5

v.

RUFUS EDMISTEN, €t &L., )
)

Defendants. )

TO: James Wallace, Jr.
Jerris Leonard
Attorneys for Defendants

)
)
)

PLEASE TAKE NOTICE that the plaintiffs in the above captioned

action will take the depositions upon oral examination as follows:

1. Gerry Cohen, 9:30 a.m., Tuesday, May 25, L982;

2- I^Iilliam K. Hale, 2:00 p.m., Tuesday, May 25, L982,

or as soon thereafter as Mr. Cohen's deposition is
completed;

3. Daniel Long, 9:30 a.m., Wednesday, May 26, L982; and

4. Terrence Sullivan, 2200 p.m., Wednesd"y, May 26,

L982, or as soon as Mr. Long's deposition is completed.

The deponents are requested to bring with you all documents

of any kind which you have in your possession which relate to

the adoption of either Chapters 4 or 5 of the Extra Session

Laws of L982 or the modifications thereof enacted in the Second

Extra Session of L982. This request includes but is not limited
to correspondence, memoranda or other w'ritings proposing, or

objecting to, supporting, or requesting help in developing any

plan for the apportionment of the North Carolina General Assembly,

or any criteria therefore, and any maps or statistics which relate
to the apportionments.



,ila

The

General

officer,

Such

pleted.

depositions will be conducted at the North Carolina

Assembly, Raleigh, North Carolina before an authorized

pursuant to the Federal Rules of Civil Procedure.

depositions shall continue from day to day until com-

You are invited to attend and cross-examine.

This lt day of M"y, L982.

Chambers, Ferguson, Watt, Wallas,
Adkins & Fuller, P.A.

Suite 730 East Independence Plaza
951 South Independence Boulevard
Charlotte, North Carolina 28202
704 / 375-846L

Attorney for Plaintiffs

CERTIFICATE OF SERVICE

1 certify that I have served the foregoing document on

all other parties by placing a copy thereof enclosed in a postage

prepaid properly addressed wrapper in a post office or official

depository under the exclusive care and custody of the United

States Postal Service, addressed to:

Mr. James Wallace, Jr.
Deputy Attorney General for

Legal Affairs
N.C. Department of Justice
Post Office Box 529
Raleigh, North Carolina 27602

Mr. Jerris Leonard
900 17th Street, NW
Suite L020
Washington, DC 20006

This l/ _ d"V of May, L982.

Mr. Robert N. Hunter, Jr.
Attorney at Law
Post Office Box 3245
201 West Market Street
Greensboro, North Carolina 27402

Mr. Arthur J. Donaldson
Burk, Donaldson, Holshouser

& Kerely
309 North Main Street
Salisbury, North Carolina 28L44

-2-

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