Motion to Dismiss
Public Court Documents
January 22, 1986

7 pages
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Case Files, Dillard v. Crenshaw County Hardbacks. Answers to Plaintiffs' Interrogatories and Motion to Produce by County Commissioner Richard Walters, 1986. 184b79ac-b7d8-ef11-a730-7c1e5247dfc0. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/f71658ac-72b1-48f3-a387-a9273b782ff2/answers-to-plaintiffs-interrogatories-and-motion-to-produce-by-county-commissioner-richard-walters. Accessed April 06, 2025.
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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. T t ” N t ” Na st ? Na t? N t ? u t ? “u aa ” “ u s ANSWERS TO PLAINTIFFS' INTERROGATORIES AND MOTION TO PRODUCE BY RICHARD WALTERS, PICKENS COUNTY COMMISSIONER Comes Richard Walters, Commissioner, Pickens County and for answer to Plaintiff's Interrogatories and Motion to Produce Documents says as follows: l. Reverend James Corder la. County Commissioner lb. Don't know. lc. Defeated. 2. 1 don't know of any. 3a..N/2 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. 4c. See response in answers of Pickens County Probate Judge. 4d. See response in answers of Pickens County Probate Judge. 5a. Corder vs. Kirksey. See additional response in answer of PAGE TWO Probate Judge. 5b. United States District Court for the Northern District of Alabama. 5c. See response in answers of Pickens County Probate Judge. 5d. See response in answers of Pickens County Probate Judge. 6. Do not know of any. 7a. Not that I know of. Tb Not that I know of. 8. N/A 9. See Affirmative Action Plan that was adopted April 22, 1980, and attached to response of Probate Judge. 10. Not that I know of. 11. See response in answers of Pickens County Probate Judge. 12a.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. 12b.See response in answers of Pickens County Probate Judge. l3a.See attached expense accounts for full answer to this questions. l3ai.See attached records. 13b. None 13c. None 134. WRAG and WAQT Radio Stations, PICKENS COUNTY HERALD newspaper, PICKENS ADVISOR, newspaper, printed cards. Also see PAGE THREE attached expense statement. l13e. I no longer have any campaign literature as have discarded the same. 13f. None 13f1. N/A 13f2. N/A 13g. McShan Community Club, Palmetto Community Club, City of Ethelsville Political Rally. 13gl. Political Rally - made a speech. 13g2. Do not remember. 13h. Providing county-wide water system. 13i. None that I can remember. 133. Went to home and talked with people individually and left my card. 13k. None. 131. Several people both black and white volunteered to pass out cards for me. I do not know if they actually did and so do not consider that actively campaigning. 13m. Do not have name or address of anyone who actively campaigned. 13n. Do not recall any. 130. None. 13p. None. 14. Richard Walters, Reform, 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, PAGE FOUR Carrollton, AL; all records in my custody or Chief Clerk's custody or Verbon Atkins' custody or Probate Judge's custody. 15. No. 15a. Corder vs. Kirksey litigation. See response in answers of Pickens County Probate Judge for more complete answer. 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. Several years ago all schools were segregated. 19. N/A. 20. I do not know. 21. See response in answers of Pickens County Probate Judge. 22. Masons, Chamber of Commerce, Cattleman's Association. 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. None at present but will provide name and address as soon as expert is obtained. PAGE FIVE 30b. . N/A. 30c. N/A. Z RICHARD WALTERS Before me, the undersigned authority in and for said County and said State, personally appeared Richard Walters, 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 Produce and he further states that the facts as stated therein are true and correct according to the best of his knowledge, information and belief. STATE OF ALABAMA COUNTY OF PICKENS Given under my hand and seal this TY day of January. 1986. An Ze TT Z NOTARY “PUBLIC ATTORNEY FOR RICHARD WALTERS DEFENDANT AY W.”0. KIRK, JR. CURRY & KIRK P. O. BOX A-B CARROLLTON, AL 35447 TELEPHONE: (205) 367-8125 PAGE SIX CERTIFICATE OF SERVICE I hereby certify that I have served the foregoing Answers upon: Wanda J. Cochran Larry T. Menefee James U. Blacksher Blacksher, Menefee & Stein, P. A. 405 Van Antwerp Building «0. 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 by placing copies of the same in the United States Mail properly addressed and postage paid this o day of February, 1986. W. O. KIRK, JR., ATTORNEY FOR 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. 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. 0. Box 207 Luverne, AL 36049 (CRENSHAW COUNTY) Warren Rowe P. O. 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. 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. Hy PAT W. O. KIRK, JR.,“ ATTORNEY FOR PICKENS COUNTY DEFENDANTS Brown Printing Co.. Montgomery, a » PENSE ACCOUNT OF CANDIDATE Salat. | JB (To Be Filled Within 15 Days After the Primary Election) | NAME oa Blo £ MAILING ADDRESS Mou Jon Opa Do. Ruy 14S 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 Jiretly 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 excess 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 Primary Election held on Tuesday, N Ap 180_722, for the office of 0 . 0g mani d PRAT, (Enter Name of Office) ° CONTRIBUTIONS EXPENSES INCURRED Con afoprnas Coad A p> TOTAL 4S 0.00) 7 14. LL Zz / nrg Signature of Candidate STATE OF ALABAMA, COUNTY OF Xi 0, 1, MEAT on) {( : Unto a Notary Public in and for said county in said Hy state, hereby certify that \Picio. { : OY) oA whose name is signed to the foregoing statement, who is known.to me, he personally appeared before me on this day and being first duly sworn deposes and says that the statement hereinabove made is in all respects true, and that the same is a full and detailed statement of all monies, securities or equivalents for money coming under the control or cus- tody of said committee and by it expended directly or indirectly. i \ \ ‘ 5 ‘Sworn to and subscribed before me his iB day of MON Gy d= a 198 c=. Yad it] 4%. 2. PA TREE (§ . ‘ \ Tn TL Low Pot JQ : \- '— Notary Public Title 17§ 400. Expense account of candidate must be made and filed.—Any candidate for any office elected by the votes of more than one 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, soiling out and itemizing the expenses of his canvass in such election within fifteen days after such election, and any candidate who falls to so file and swear to such statement within sald time, shall be guilty of a misdemeanor, and, on conviction, must be fined not less than ong h indred nor more than one thousand dollars.” J eto . a > Filed 2, 1972 Brown Printing Co., Montgomery, Alabama JAM A Jedi A abe ; PER: PIRES ie o SSR— EXPENSE ACCOUNT OF CANDIDAS : : / (Tq Be Filed Within 15 Days After the Bnet Election) ) g Z, NA ME: a AFL ALE Lec (Ls ag MAILING a [45 & : BI iF j. SZ » : pl 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 excess of $10.00, with the amounts given by each, and a list of pll gifts, loans or contributions made in connection with my campaign as a candidate in the Eee Election held on Tuesday, Noy. 7 12.72. mk, for the office of Clipe y. = oo i (Enter Name of Office) —p—— CONTRIBUTIONS Nore TOTAL___ a. EXPENSES INCURRED lL 7) one JI0TAL.. £2 = of Signature of Candidate [¥ Wh 1 ie Ar Ply STATE OF ALABAMA, COUNTY OF 3 32 Re 1 li Q 2 a Notary Public in and for said county in said state, hereby certify that (tus i 7 whose name is signed to the foregoing statement, who is known to me, he personally appeared before me on this day and being first duly sworn deposes and says that the statement hereinabove made is in all respects true, and that the same is a full and detailed statement of all monies, securities or equivalents for money coming under the control or cus- tody of said committee and by it expended directly or indirectly. : — yp Sworn to and subscribed before me this_./&____day of lr onidy 198.2 Cte Ca. \heall Norery Publi Title 17§ 400. Expense account of candidate must be made and filed.—Any candidate for any office elected by the votes of more than one county, except candidates for the office of state senate, shall file with the secretary of state, and eve candidate for a county office and candidates for the state senate and house of representatives shall file with the judge of owe of the county or counties in which said election is held, a sworn statement, getting out and itemizing the expenses of his canvass in such election within tifteen days after such election, and any candidate who falls to so file and swear to such statement within sald Hime, shall be guilty of a misdemeanor, and, on conviction, must be fined not less than one hundred nor more than one thousand dollars.” . : Brown Printing Co., Montgomery, Alabama © — — a v X rl » Brodn Frinting Co.. Montgomery, al EXPENSE ACCOUNT OF CANDIDATE (To Be Filed Within 15 Days After the Primary Election) NAME Richard Walters MAILING ADDRESS_Reform, Alabama Pursuant to Title 17, Sections 278, 279 and 400 of the Code of Alabama as amended, defining the Corrupt Practices Act, | herewith submit a full, correct, detailed and itemized statement of all expenses made directly Primary Election held on Tuesday, May 7, 196_8 , for the office of —— County Commissioner-- District One x RTH CC nd (Enter Name of Office) CONTRIBUTIONS TOTAL: None « . . ° EXPENSES INCURRED Radao Advertisement $ 120.00 Qualifying Fee 50.00 Auto Expense 250.00 Cards 109.00 TOTAL $989.10 = : — S Signature of a STATE OF ALABAMA, COUNTY OF____Pickens I, Geraldine D, Duckworth a Notary Public in and for said county in said slate, hereby certify that Richard Walters ; whose name is signed to the foregoing statement, who is known to me, he personally appeared before me on this day and being first duly sworn deposes and says that the statement hereinabove made is in all respects true, and that the same is a full and detailed statement of all monies, securities or equivalents for money coming under the control or cus- tody of said committee and by it expended directly or indirectly. Sworn to and subscribed before me this__.21 day of May 196 8__. " Nocodin BB cline otary Public Title 17§ 400. Expense account of candidate must be made and filed.—Any candidate for any office elected by the votes of more than one county, eXxcepl 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 falls to so file and swear to such statement within said time, shall be. guilty of a misdemeanor, and, on conviction, must be fined not less LL eed nor more than one thousand Hay 7 Brown Being Co., Montgomery, Alabama Jor bs YY Coy, A. Lo LP dollars.” Piown Printing Co.. Maonlygomery. aise) » ge a 5g i rit BATA re Lr RSA ul EXPENSE ACCOUNT OF CANDIDATE af, ¥ / (To Be Filed Within 15 Days After the Primary Election) Seg 7 % 7 7 foi? / 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 db ecty 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 excess 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 NAME __ Richard Walters MAILING ADDRESS. PaOL. Box 15, Reform, Alabama 35L81 Primary Election held on Tuesday, - MAY Ly, 1976. < pe, for the office of Pickens County Commissionn, District 1, Reform, Alabama y at La (Enter Name of Office) CONTRIBUTIONS TOTAL. a. se EXPENSES INCURRED Qualifying fee 100.00 3/8/76 Merald Printing Company Ad announcemept $50.00 3/19/76 Pickens County Advertiser Political Announcement | $36.00 L/19/76 Political Rally At Mc Shan, Alabama $10.00 3/3/76 LAA Political Cards | $88.L0 L,/16 /76 LAA Political Cards | $88.10 L/22/76 Pickens County Advertiser Ad in paper $ 86.L0 Li/22/76 WRAG Radio Stat$nn $25.00 L/29/16 2AA Sample ballots ; | A $3k.29 TOTAL... $hifB.ho _. diy J wi 2275 Signature of Candidate ” STATE OF ALABAMA, COUNTY OF 7 eo Rta) — 1, (tiasia) NADL fa fan) a Notary Public in and for said county in said state, hereby certify that (8.00. hax Jd A ong EA) whose name is signed tothe foregoing statement, who is known to me, he personally appeared before me on this day and being first duly sworn deposes and says that the statement hereinabove made is in all respects true, and that the same is a full and detailed statement of all monies, securities or equivalents for money coming under the control or cus- tody of said committee and by it expended directly or indirectly. 7 Sworp to and subscribed before me this ] £2 TT otary Public Title 17§ 400. Expense account of candidate must be made and filed.—Any candidate for any office elected by the votes of more than one 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 caunty 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 and swear to such statement within said time, shall be guilty of a misdemeanor, and, on conviction, must be fined not less than one hundred nor more than one thousand dollars.” pelt >is » ® Fold Left Nir EXPENSE ACCOUNT OI CANDIDATE Kol, y (‘I'o Be Miled Within 15 Days After the Primary Election) of 7 7 sw. fre Aare Walters MAILING ADDRLSS 7 tore, AL. Pursuant to Title 17, Sections 22-10, et seq. 1975 Code of Alabama defining the Corrupt Practices Act, | 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 excess of $10.00, with the amounts given by each, and a list of all gifts, loans or contri- butions made in connection with my campaign as a candidate in the Primary Election held on Tuesday, September 5, 1978, for the office of (Enter Name of Office) a CONTRIBUTIONS None TOTAL EXPENSES INCURRED West AlabamaOffice S upply (cards) $ 137.01 West Alabama Office Supply (cards) 190. 03 County Democratic Chairman (qualifying fee) 200. 00 Gasoline expense 300. 00 Pickens County Herald (newspaper ads) 68. 00 Pickens County Advertiser (newspaper ads) 50. 00 WRAG (radio advertising) 94.50 TOTAL $1039. 54 = Signature of Candidate_ ar — VATE OIF ALABAMA, COUNTY OF PICKENS ,» a Notary Public in and for said county in ~ whose name is signed to the oregoing statement, who is known to me, he personally appeared before me on this day ind being first duly sworn deposes and says that the statement hereinabove made is in all ‘espects true, and that the same is a full and detailed statement of all monies, securities 4 equivalents for money coming under the control or gustady of said committee and by t expended directly or indirectly. ‘Sworn to and subscribed hetore me this 4 day ot ges baa + 198%. ald state, hereby certify that Notary Public J ———— v. « = Byowh Painting Cu. Munigomersy. rn. A EXPENSE ACCOUNT OF CANDIDATE (To Be Filed Within 1§ Pays After tho Election) NAME K, chav ds Walters al MAILING ADDKESS ‘PO Bex 48. ih... 00. on R eForm AL os SygL Pursuant to Title 17, Scctions 278, 279 and 400 of the Code of Alabama as amcndal, denming the Corrupt Practices Act, 1 herewith submit a full, correct, detailed and Memized statement of ull capenses wide directly or indirectly in sums over $5.00 and of all obligations, debts, or liabilities assumed or incurved at the time of filing this statement, together with the names of all contributols of amounts in excess of $10.00, with the wnounts given by cach, and a list of all gifts, louns or contributions made in connection with my campaign as a condidite m the Election held on Tuesday, Sep fe amber ch YU Brow 1 4 for the office of Rekens County Commission Dusted I (Enter Wame of Office) ———— + —— CONTRIBUTIONS Bank oF Ke For np Rso.oa IME EXPENSES 1§iCULMED We sf Al ¢FFlcs Swpply S233 .19 West AL ADVISOR NG. 64 Herald Frinting Cs, bib 150 W RA G Negy. 08 @ os R 3 [Justi Fina Fee 18.0 Pied tue) & day ot a) - 1 Judge of Probore Y( J" Signature of Candidate — 1w&Y § A wos... 4349.37 ZZ lf + —— . — — STATE fr counryor.. PeKens. oi. 1, wie ; ou a Dblinho don. 0 Notary Public in and (04 Saad county dn cand state, hereby ceruty inal will rau J = Utne). RE te ele ta enim FTI GETTY signed to the foregoing statement, who is knowin toe, he personally appeased before aie on ts diy aad bog first duly sworn deposcs and says that the statement hereinabove ide is in all respects Lae, and taut the sae is a tull and detailed stateinent of all monies, securities or equivalents foi roney corning under the contol oo cus: tody of said committee and by it expended directly or indirectly. 1] \ ARATE L Sworn to gud subscribed before me this lo EI ee a Gl Rl at inci a eas eho don Notary Public Title 17§ 400. Expense uccount of candidate must be mude and filed.--Any candidate for any office clected Ly the volves of yaore than one county, except candidates for the office of state senate, shall fle with the sceevetary of state, snd every candidate for u county office and candidates for the state senate and house of representatives shall Ole with the judge of probate of the county or counties in which sid election is held, a sworn statement, setting ont and itemizing the expenses of his canvass in such election within tiftoen days after such eloction, anid any candidate who fails to so file und swear to such statement witha seid tune, snall be guilty of a misdemeanor, Bid, on conviction, mist be Goed not less than oue hundred nor nore than one thousand dollars” Pry —— ———y 4 a we wa—w CR} Wie my ee roa a y—— . eae ams ies - ‘. pn . ao . -~ ma a es ew Yee Grown Ponging wie. Llantuginerv Flubawy Brown £rinting~Co.. Montgomery. = a EXPENLE ACCOUNT OF CANDIDATL (To Be Filed Withia 15 Days After the Election) 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 excess of $10.00, with tlic 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, Na API Ka VE MOLINA. (3 1 £4, for the office of Y Menbec Pic k < as tesa £0 A Place No "NL SN (Enter Naine of Office) CONTRIBUTIONS TY Loe ME 4 ARE POT Ble ae ee himmim EXPENSES INCUHRED “YL Love Joti ofa F Ate gan Glogtat..), 0 TOTAL... —-e Signature of win, kl fe ie cn ein wa AO _a Notary Public in and for suid county 1a said v Led Wolly RE RNTORE.. 1 AVRO BRT Whose name 1. ett a STATE OF ALABAMA, COU AR state, hereby certify that. em signed to the foregoing statement, who is known to me, he personally appeared before ne on this day and bel: first duly sworn deposes and says that the statement hereinabove made is in all respects true, und that the saa is a full and detailed statement of all monies, securities or equivalents for money coming under the control or cus- tody of said commitfee and by it expended directly or indirectly. Sworn to and subscribed before me this ( 2 day of la L2lecdn bc Title 17§ 400. Expense account of candidate must be made and filed.-- Any candidate for any office clected by the votes of more than one county, except candidates for the office of state senate, shall file with the secretary of state, und 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, und any candidate who fails to so file und swear to such staternent within sald tune, shall be guilty of a misdemeanor, and, on conviction, must be fined not less than one hundred nor more than one thousand dollars.” : PIAA Ld Cy Notary Public Brown Printing Cu. Meantyomory, Alshuma