Supplemental Response, To Gingles, Plaintiffs' First Set of Interrogatories and Request to Produce

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

RALEIGH DIVISION

RALPH GINGLES, et d1.,
Plaintiffs,

v.

RUFUS L. EDMISTEN, et 81.,
Defendants.

No.81-803-CIV-5

SUPPLEMENTAL RESPONSE, TO GINGLES, PLAINTIFFSI
FIRST SET OF INTERROGATORIES AND

REQUEST TO PRODUCE

NOW COME Defendants, by and through their undersigned

counsel, and supplement thej-r responses to the Gingles,

Plaintiffsr First Set of Interrogatories and Request to

Produce. Defendantst supplemental responses are attached

hereto. The undersigned has answered these Interrogatories

and Request to Produce in its capacity as counsel for the

respondent defendants.

This the

Deluty ALEorney2General for
al Affairs

ttorney Generalrs Office
Department of Justice
Post Office Box 629
Raleigh, North Carolina 27602

Phone (919) 733-3377



CERTIFr CATE-OP SERVICE

r hereby certify that r have this day served the fore-
an.i-_ supplemental Response, to Gingles, plaintiffs' First set ofYv4r'Y Interrogatories and Request to produce

by placing a copy of same in the united states post office,
postage prepaid, addressed to:

Ms. Leslie Winner
Chambers , Ferguson, Vlatt, Ilallas,

Adkins & Fuller, p.A.
951 South fndependence Boulevard
Charlotte, i,Iorth Carolina ZB2O2

IUr. Jack Greenberg
Itr. James M. lJabritt III
Ms. Lani Guinier
10 Columbus Circle
New York, New York 10019

Mr. Arthur J. Donaldson
Burke, Donaldson, I{oishouser & Kener}y
309 North l"lain Street
Salisbury, North Carolina 28144

l1r. Robert N. Ilunter, Jr.
Attorney at Lavr
Post Office Box 3245
Greensboro, North Carolina 27402

Mr. Hamilton C. Horton, Jr.
Horton, Hendrick, and Kummer
450 I.ICNB Plaza
Winston-Salem, Ilorth Carolina 2?t}l
Mr. Ilayne T. Elliot
Southeastern Legal poundation
1800 Century Boul-evard, Suite 950
Atlanta, Georgia 30345

rhis *" l7 day of ,1983.



:

t
IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF NORTH CAROLINA
RALEIGH DIVISION

RALPH GINGLES, et al.,
Plaintiffs,

v.

RUFUS L. EDMISTEN, €t al.,
Defendants.

No.81-803-CIV-5

SUPPLEMENTAL RESPONSE, TO GINGLES, PLAINTIFFSI
FIRST SET OF INTERROGATORIES AND

REQUEST TO PRODUCE

7. In addition to those reasons found in the deposition given

by John Sanders on February 23,-1983, defendants now advance

additional reasons and explanations for North Carolinars

Constitutional Prohibition and policy against dividing counti-es

in the creation of legislative districts. North Carolina has

an effective legislative system for the introduction, con-

sideration, and passage of tocal legislation. That system

is based around certain assumptions which operate effectively
only if counties are not divided in the creation of legislative
districts. Multi-member delegations are more effective in
representing the j-nterests of a county than are representatives

from si-ngle-member districts carved out of a county.

33. In addition to those experts already listed, defendants

intend to call as an expert witness at the trial of this
matter the following person:



-2-
Joe Ferrell
Knapp Building
Institute of Government
Chapel HiIl, N. C. 27514

Phone (919) 966-5381

Ferrell will testify concerning the history and importance

of county governments and of counties as the administrative
provider of state services. Ferrell will also testify
concerning loca1 legislation in the General Assembly, the

assumptions on which the mechanism for introduction,

consideration, and passage of 1ocal legislation is founded,

and the importance of using whole counties for representa-

tive districts for a county to be effectively represented,

especiatty for tocal legislatio'n.

rhis the t? day of JuIy, 1983.

RUFUS L. EDMISTEN
Attorne

Jam a1la

egal Affairs
Attorney Generalrs Office
Department of Justice
Post Office Box 629
Raleigh, North Carolina 27602

Phone (919) 733-3377



CERTTFTCATE OF SERVICE

r hereby certify that r have this day served the fore-
_^:__ Supplemental Response, to Gingles, Plaintiffs' First Set ofgor'ng tnllrrogatories -and Request to Produce

b1, placing a copy of sarne in the united states post office,
postage prepaid, addressed to:

Ms. Leslie Winner
Chambers , Ferguson, Vlatt, Ila11as,

Adkins & Fu1ler, P.A.
951 South Independence Boulevard
Charlotte, i'Iorth Carolina 28202

IrIr. Jack Greenberg
l1r. James 1"1. IJabritt III
Ms. Lani Gui-nier
10 Columbus Circle
New York, New York 10019

Mr. Arthur J. Donaldson
Burke, Donaldson, I{olshouser & Kenerly
309 North l"lain Street
Salisbury, North Carolina 28144

l1r. Robert N. Ilunter, Jr.
Attorney at Lavr
Post Office Box 3245
Greensboro, North Caro_lina 27402

Mr. Hamilton C. Horton, Jr.
Horton, Hendrick, and Kummer
450 NCNB Plaza
Winston-Sa1em, tlorth Carolina 27101

Mr. Ilayne T. Elliot
Southeastern Legal Foundation
1800 Century Boulevard, Suite 950
At1anta, Georgia 30345

rhis *e fi aav of ,1993.



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

RALEIGH DIVISION

ALAN V. PUGH, et a1.,
Plainti-f f s,

No. 81-1066-CIV-5

JAMES HUNT, JR., et al.,
Defendants.

SUPPLEI\,IENTAL RESPONSE, TO PUGH, PLAINTIFFS I

FIRST SET OF INTERROGATORIES AND
REOUEST FOR ADI{ISSION

22. Defendants do not intend to use the testimony of H. parks

Helms or senator Russert waIke.- i" any way. However, Repre-

sentative Hauser, vernon Malone, Howard clement, and Malachi

Greene may testify to the lack of a raciar appeals in their
experiences.

34. The defendants currently expect to carl as witnesses at
the trial of this matter those p.r=orr" listed in the pre-trial
order, with the addition of two persons to be added to the

Pre-trial order, Malachi Greene and Mark Lanier. Defendants

are sending information concerning these two witnesses for
addition to the Pre-trial Order to all counsel.

35. rn addition to those experts already listed, defendants

intend to call as an expert witness at the triat of this
matter the following person:

v.

B.



-2-
Joe Ferrell
Knapp Building
Institute of Government
Chapel Hi1l, N. C. 275L4

phone (919) 966-5381

Ferrell wilr testify concerning the history and importance

of county governments and of counties as the administrative
provider of state services. Ferrell wirl also testify
concerning Ioca1 legislation in the General Assembly, the

assumptions on which the mechanism for introduction,
consideration, and passage of local regislation is founded,

and the importance of using whole counti-es for representa-

tive districts for a county to be effectively represented,

especially for local legislation.
36. As to Ferre1l, see response to Interrogatory No.

35. Ferrell will testify on the basis of his years of
experience as the county expert with the Institute of
Government and hi-s research and publi-cations in the area

of North Carolina county government.

rhis the /? day of Juty, 1983.

RUFUS L.

De;/uty Attorney General for
Legal Affairs

Attorney Generalrs Of f j-ce
Department of Justice
Post Office Box 629
Raleigh, North Carolina 27602

Phone ( 919 ) '; 33-337 7

AttorneV

VI,
J"*d, wall!-c



CERTIPTCATE OF SERVICE

r hereby certify that r have this day served the fore-
nnina Supplemental Response, to Pugh, Plaintiffs' First Set ofYv4rrY rnterrogatories and Request for Admission
by placing a copy of sarne in the united states post office,
postage prepaid, addressed to:

Ms. Leslie Winner
Chambers , Ferguson , glatt, Ilallas ,Adkins & pul1er, p.A.
951 South Independence BoulevardCharlotte, i,Iorth CaroU.na Zg2O2

IrIr. Jack Greenberg
l1r. James M. IJabritt III
Ms. Lani Guinier
10 Columbus Circle
New York, New york 10019

1"1r. Arthur J. Donaldson
Burke, Donaldson, Ilolshouser & Kenerly
309 North Main Street
Salisbury, North Carolina 29t44

llr. Robert N. Ilunter, Jr.
Attorney at Lavr
Post Office Box 3245
Greensboro, North Carof.ina 27402

Mr. Hamilton C. Horton, Jr.
Horton, Hendrj.ck, and Kummer
450 IICNB Plaza
Winston-Salem, Ilorth Carolina 27t0t
Mr. Ilayne T. Elliot
Southeastern Legal Foundation
1800 Century Boulevard, Suite 950Atlanta, Georgia 30345

rhis the /7 day of , 1993.



~tat£ nf ~nrlq C!!nrnlimt 
~.epudm.etrl n£ 3hmtic.e 

P. o. Box 629 
RALEIGH, N . C. 27602 

Ms. Lani Guinier 
10 Columbus Circle 
New York, New York 10019 

. I 

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