Answers to Plaintiffs' Interrogatories and Motion to Produce by County Clerk James Floyd

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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. 

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ANSWERS TO PLAINTIFFS' INTERROGATORIES 

AND MOTION TO PRODUCE 

BY JAMES FLOYD, PICKENS COUNTY CIRCUIT CLERK 

  

  

  

Comes James Floyd, Circuit Clerk, Pickens County and for 

answer to Plaintiff's Interrogatories and Motion to Produce 

Documents says as follows: 

1. Do not know. 

la. N/A 

lb. N/A 

lc. N/A 

2. None. 

3. N/A 

3a. N/A 

4. Do not know. 

4a. Do not know as all of this is done by the County Commission. 

4b. N/A 

4c. N/A 

4d. N/A 

5. Do not know. Only case that I am aware of is the Corder vs. 

Kirksey case. 

 



  

PAGE TWO 
  

5a. N/A 

5b. N/A 

5¢. N/A 

5d. N/A 

6. N/Aa to this Defendant. 

7a. N/A to this Defendant. 

7b. N/A to this Defendant. 

8. N/A to this Defendant. 

9. N/A to this Defendant. 

10. N/A to this Defendant. 

11. Not that I know of. N/A to this Defendant. 

12a.James E. Floyd, White, Circuit Clerk; 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. 

12b. January 16, 1977, to presesnt for myself. Do not know as to 

the others. 

13a.See attached copy of expense record. 

13ai.See attached copy of expense record. 

13b. No Contribution. 

13c. See attached copy of record. 

13d. Newspapers in Pickens County. Radio Stations WRAG and WAQT. 

13e. Do not have access to any as they were destroyed. 

13f. Town of Pickensville and various neighborhoods in 

Aliceville. 

 



  

PAGE THREE 
  

13f1. Passsed out campaign literature. 

13f2. NONE 

13g. McShan Community Club, Zion Community House, City of 

Palmetto and City of Gordo. 

13gl. Political Rally - made talks. 

13g2. Do not remember. 

13h. None that I can remember. 

13i. None that I can remember. 

13j. None. 

13k. None. 

13kl. No organizations; wife, daughter and son passed out cards 

for me. 

13m. None that I can remember. 

13n. None. 

130. None. 

13p. : N/A. 

14. James E. Floyd, Gordo,AL, my attorney W. O. Kirk, Jr., 

Carrollton, AL, Documents filed in the Probate Office of Pickens 

County. 

15, Not applicable to this Defendant. 

15a. N/A to this Defendant. 

15b. N/A to this Defendant. 

15bl. N/A to this Defendant. 

15b2. N/A to this Defendant. 

15b3. N/A to this Defendant. 

l6. No knowledge of this. 

 



  

17. 

17a. 

17b. 

18. 

19. 

20. 

2). 

22. 

Club. 

23. 

24. 

25. 

26. 

27. 

28. 

29. 

30a. 

N/A. 

N/A. 

N/A. 

Yes. 

N/A. 

No knowledge of 

PAGE FOUR   

this. 

See response in answers of Pickens County 

Alabama Clerks 

See response 

See response 

See response 

See response 

See response 

See response 

See response 

in 

in 

None at present 

obtained. 

30b. 

30c. 

N/A. 

N/A. 

Association, 

answers 

answers 

answers 

answers 

answers 

answers 

answers 

of 

of 

of 

of 

of 

of 

of 

Pickens 

Pickens 

Pickens 

Pickens 

Pickens 

Pickens 

Pickens 

Presbyterian 

County 

County 

County 

County 

County 

County 

County 

but will provide name and 

JAMES E. 

Probate 

Church 

Probate 

Probate 

Probate 

Probate 

Probate 

Probate 

Probate 

address 

OoYD 

Judge. 

and Lions 

Judge. 

Judge. 

Judge. 

Judge. 

Judge. 

Judge. 

Judge. 

if one is 

 



  

PAGE FIVE 
  

STATE OF ALABAMA 

COUNTY OF PICKENS 

Before me, the undersigned authority in and for said County and 
said State, personally appeared JAMES E. FLOYD, 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. 

J. 
Given under my hand and seal this 3/ day of Foley. 1986. 

Bs 2A 
NOTARY 
  

ATTORNEY FOR JAMES E. FLOYD 

DEFENDANT 

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

 



  

upon: 

PAGE SIX 
  

CERTIFICATE OF SERVICE 
  

Wanda J. Cochran 

Larry T. Menefee 
James U. Blacksher 

Blacksher, Menefee & Stein, 

405 Van Antwerp Building 
. O. 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 

leth 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 

I hereby certify that I have served the foregoing Answers 

A. 

P. O. Box 646 

Brewton, AL 36427 

by placing copies of the same in the United States Mail properly 
addressed and postage paid this 21 day of February, 1986. 

a 
  

W. O. KIRK, JK., 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 

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 

P. O. Box 78 Lee M. Otts 

Montgomery, AL 36101 Otts & Moore 
(LAWRENCE COUNTY) P. O. Box 467 

Brewton, AL 36427 

H. R. Burnum (ESCAMBIA COUNTY) 

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) 

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

r 

W. O. KIRK, 47 ATTORNEY FOR 
  

PICKENS COUNTY DEFENDANTS 

 



® 
i Se a 

EXPENSE ACCOUNT OF CANDIDATE 

  

(To be filed within 15 days after the Primary Election) With Secretary of Slate 

(To be filed within 30 days after the General Election) See asterisk below 

  
NAME OF CANDIDATE (or Committee) James E, Floyd 

MAILING ADDRESS Route L, Box 2L2, Gordo, Alabama  35L66 
(District, if) 

NAME OF OFFICE Circuit Clerk 
(Applicable) 24th Judicial Circuit   
  

  

Pursuant to Title 17, §§ 278, 279, and 400, 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 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, with the amounts given by each and a 

list of all gifts, loans, contributions, or services made in connection with my campaign as a candidate in the Pri- 

mary or General election held on _May Li and May 23 Democratic Primariegenc S800 no —=5 and General Election on 

(Date) November 2, 197 

vw CONTRIBUTIONS 

Mr. & Mrs. E. 8, Simpson $25.00 

EXPENSES INCURRED 

March 1, 1976 The Democratic Party 
$375.00 

March 2, 1976 Pickens County Advertiser 
36.00 

March 2, 1976 Pickens County Herald 
£0.00 

April 5, 1976 West i.p0ema Office Supplier 
21L.36 

April 25, 1976 Crimm's Signe 
10,00 

April 28, 1976 Gulf 011 Corporation 
80,00 

April 2R, 1976 Standard 041 Corporation 
40,60 

April 28, 1976 Pickens County Herald 
75.62 

April 28, 1976 Radio Station WRAG 
150,00 

May 5, 1976 Radio Station WRAG 
22.96 (see attached 

May 1, 1976 Gordo Band Boosters 
; 40,00 sheet) 

  
  Signature of Candidate 

TREASURER'S AFFIDAVIT (If applicable) 

I, 
. hereby certify and confirm that I am Treasurer 

of the above identified committee and that this financial statement 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 custody 

of the committee and by them expended directly or indirectly. 

  

  

  

  

Treasurer 

Sworn to and subscribed before me this — day of 
ORR | | NR 

Notary Public 

CANDIDATE'S AFFIDAVIT 

Jame S . EF [ e yd 
hereby certify and confirm that I am the candi- 

  

date on whose behalf the above identified committee has — and that, to the best of my knowledge and belief, 

this statement is in all respects true and I have not, in person, made any expenditures or received any coatribu- 

    

TL 3 

Sworn to and subscribed before me this 24% day of 

Notary Public 72d 
A : 

Statements should be tiled in the office of the Secretary of State, it the candidate {s a candidate for a national or state 

office, for representative in the United States ‘Congress, or for judge or district attorney in any udicial circuit, or if the proposi- 

tion or measure supported or opposed a submitted to the voters of the stato, They should be led in 

willie of the county of cotinties In which the election in held If Lhe entdidoto Inn enndidata for n A office, Hints Honale, of 

tute blouse of ep onentinsiven, or If the proposition or meneire Mbyiey or opined in submitted 
to the voters of u partioulnr 

  

  

county or counties, ' (Code of Alabama, Title 17, 68 470, 270, and 400 Z ; 

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FINAL : 
Itemized Expenditurea 
Page two We 

| James E. Floyd gi": Thage, ; ; 

May 1R, 1976 Pickens County Advertiser : 172.26 

May 18, 1976 Pickens County Herald 33.25 

May 18, 1976 Gulf 011 Corporation ; 81.00 est. 

May 18, 1976 Standard Oil Company "3 40.00 est. 

May 29, 1976 Pickens County Advertiser, 127.9 

May 29, 1976 Pickens County Herald, 66.50 

May 29, 1976 ~~ Radio Station WRAG, Cerrollton, Al. 15.00 

- -— 

 



= 

-~ : i =20 - ® Awe 3a. ) 

  

(To be filed within 30 days after the General Election) See asterisk below 

NAME OF CANDIDATE (or Committee) ___J ames E, Floyd 

<2 EXPENSE ACCOUNT OF CANDIDATE 7 = 
(To be filed within 15 days after the Primary Election) With Secretary of State 

  

  

MAILING ADDRESS _ Route L, Box 242, Gordo, Alabama  35L66 

(District, if) 2)41 Judicial Circuit 
  

  

NAME OF OFFICE Circuit Clerk (Applicable) 
Pursuant to Title 17, §§ 278, 279, and 400, 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 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, with the amounts given by each, and a 
list of all gifts, loans, contributions, or services made in connection with my campaign as a candidate in the Pri- 
mary or General election held on May L and May 25 Demogratic Primaries 

  

(Date) 

CONTRIBUTIONS 

Mr. & Mrs. E. 8. Simpson $25.00 

gil EXPENSES INCURRED 

March 1, 1976 The Democratic Party $375.00 
March 2, 1976 Pickens County Advertiser 36.00 
March 2, 1976 Pickens, County Herald 50,00 
April 5, 1976 West Alabama Office Supplier 214.36 
April 24, 1976 Crimm's Signs 40,00 
April 28, 1976 Gulf Oil Corporation 80,00 
April 28, 1976 Standard 011 Corporation 140,60 
April 28, 1976 Pickens County Herald 75.62 
April 28, 1976 Radio Station WRAG 150.00 
May 5, 1976 Radio Station WRAG 22,95 (see attached 
May 1, 1976 Gordo Band Boosters 40,00 sheet) 

Signature of Candidate 
  

TREASURER'S AFFIDAVIT (If applicable) 

], , hereby certify and confirm that I am Treasurer 
of the above identified committee and that this financial statement 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 custody 
of the committee and by them expended directly or indirectly. 

  

  

  

  

  

Treasurer 

Sworn to and subscribed before me this day of , 19 

Notary Public 

CANDIDATE'S AFFIDAVIT 

  
- : , hereby certify and confirm that I am the candi- 

date on whose behalf the above identified committee has acted and that, to the best of my knowledge and belief, 
this statement is in all respects true and I have not, in person, made any expenditures or received any contribu- 
tions which are not set forth and covered by said statement. 

  
Signature of Candidate 

Sworn to and subscribed before me this 19 day of His, l/ 

Notary Public 

       

*Statements should be filed in the office of the Secretary of State, if the candidate is a candidate for a national or state office, for representative in the United States Congress, or.for judge or district attorney in any judicial circuit, or if the proposi- 
tion or measure supported or opposed ls submitted to' the voters of the state. "They should he filed in the office of the probate udge of the county or counties in which the election In held 1 the enndidute Is a condldato for a Shy offl¢e, Stato Henate, or 
State House of Hoprosentugivos, or If the proposition or measura dibored or opposed In submitted to the voters of a particular county or counties. (Code of Alabama, Title 17, §8 378, 279, and 400) . = b Cons 

Brown Printing Co., Montgomery, Alabama 

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Itemi zed Expenditures 

Page two 

James E, Floyd 

May 1F, 1976 Pickens County Advertiser 172,26 

May 18, 1976 Pickens County Herald 33.25 
May 18, 1976 Gnlf O11 Corporation 87,00 est. 

May 18, 1976 Standard 01 Compeny LO,00 est,