Plaintiffs' Motion for Preliminary Injunction; Plaintiffs' Statement of Facts; Affidavits (Redacted)

    .*il".*s. FERGUS.N. *ATT, *ALLAS, ADKTNS & FULLER , 
p

ATTORNEYS AT LAW

SUITE 73O EAST INDEPENDENCE PLAZA

951 SOUTH INDEPENDENCE BOULEVARD

CHARLOTTE, NORTH CAROLINA 28202
TELEPHONE t704) 375-4461

September 2, 1983

JULIUS LEVONNE CHAMBERS

JAMES E FERGUSON. II

MELVIN L WATT

JONATHAN WALLAS

KARL ADKINS

JAMES C FULLER. JR

YVONNE MIMS EVANS

JOHN \^/ GRESHAM

GILDA F GLAZER

LESLIE J WINNER

JOHN T NOCKLEBY'

.OF O,C, AAR ALSO

Ms. Lani Guinier
Legal Defense Fund
10 Columbus Circle
Suite 2030
New York, New York f0019

Dear Lani:

Hope you had a good vacation.

I have enclosed a copy of the most recent Or-$gf in Gingles.
I am a 1itt1e worried about getting everything done which
needs to be done. I have gotten the f irst f our vol-umes of
the transcript and they do not even compl-ete our testimony.
My biggest fear is that, 3s long as I stay in Charlotte in
my office, Ey time will keep getting eaten away and I will
never be able to work very hard on the brief. In order to
avoid the nibbling away of my time, I think it would be a
good idea for me to come to New York for a few days to work
on the brief with you. I have an age discrimination case on
the jury trial calendar sometime during the weeks of September
L2 and 19. What I would propose to do is to come to New
York sometime during the week of the 19th, when my trial is
over, and stay until sometime during the next week. Hope-
ful1y we could finish a rough draft during that time which
would give us time to get it finalLzed before it is due on
October 7. In order for this to work, two things need to
to be done. The first is that we need to have the
transcript indexed before I come. I can start working on
that. Do you or anyone else in your office have time to work
on that between now and the middle of September? The second
thing is that I think you need to be available during the
time that I am in New York in order for my time there to be
fruitful. Is that a convenient time for you?



Ms. Lani Guinier
September 2, 1983
Page 2

Since I saw you last, I tried a teacher Title VII and First
Amendment case in front of Judge Britt in Wilmington. He was
very friendly to me and gave me a good trial. In addition,
he ruled in our favor on the Title VII c1aim. It is most
comforting to me to know that at least he believes that there
sti1l is discrimination in North Carolina in 1983. Perhaps
there is hope yet.

Give me a call as soon as you geL a chance. I assume that you
will want your own copy of the transcript and I'm going to go
ahead and have a copy made for you.

One more big push and we will be there. I guess I can hang in.

Since e1y,

1ie J. trlinner

LJW: ddb
Enclosure



a

IN THE UNITED STATES DISTRICT COURT
FoR rHE EAsrERN"SlSl-l:$rSloNoRrH cARotrNA

NO. 81-803-CrV-5

9BqEB

FII- ]D
83 I

RALPH GINGLES, €t 61., )
)

Plaintiffs )
)vs.. )
)

RUFUS EDMISTEN, €t d1., )
)

E. DtsT. NO. cAR.

Defendants )

On August 3, 1983, the court informed the parties that they

would be required to file their respective briefs and findings

upon receipt of the trial transcript, and the court is now informed

that the parties will receive the transcript during the week of

September 5, 1983. Accordingly, the parties are directed:

l. To submit proposed findings of fact and conclusions of

Iaw, together with memoranda, on or before October 7, 1983, and

ro key each proposed finding to the corresponding page in the

record i

2. To appear for closing arguments in the case on October

L4,1983 at 10:00 a.m., in Courtroom No. I, Seventh Floor, Federal

Building, Raleigh, North Carolina.

t Certilv the foreqoin'1 tt1 !'.'e a true

and corrr:ct coPY of tho original,

J. Pif" t Pa1r7'1, Clgrrr

United States District Court
Eastern District of l)'lorth Carolina

AUo 30 rc

'r:t'ri5i;'iSi?r'r-T^

pb-

DUPREE, JR.
STATES DISTRICT JIJDGE

August 30, 1983.

Page I By-&rl$.=-d
Deputy Clerk



o

t

E;u,ffiqg.Es

OBn I q 'tv
r0IAEslU