Certificate of Service stating all parties have been served the Brief
Public Court Documents
April 15, 1991

6 pages
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Case Files, Thornburg v. Gingles Hardbacks, Briefs, and Trial Transcript. Affidavit of Counsel for Plaintiffs Alan v. Pugh, et al (81-1066-CIV-5) For Leave to File Supplemental Complaint Setting Forth Grounds (Rule 15(d) F.R.C.P.), 1982. d4744c4c-d792-ee11-be37-6045bddb811f. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/997e153e-a083-4227-9663-57c372d7cf3d/affidavit-of-counsel-for-plaintiffs-alan-v-pugh-et-al-81-1066-civ-5-for-leave-to-file-supplemental-complaint-setting-forth-grounds-rule-15-d-frcp. Accessed August 27, 2025.
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\ a Bura Donttosolr, Eor,snousn & Krrnr.v ATTORIIEYS AND COUNSELLORS AT LAW 09 NORTH MAIN STREET SALISBURY. l{. C. 28lt+ O !', $> IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF NORTH CAROLINA RALEIGH DIVISION Rule 15(d) F.R.C.P. Arthur J. Donaldson, being first duly sworn, says: That he is one of the counsel for Plaintiffs, Alan V. Pugh, et aI, in the above entitled consolidated action, which action was originally commenced in the Superior Court of Iredell County, lJorth Carolina on ttre 25L11 day of l{ovember, 1981, removed to the United States District Court for the Eastern Division of North Carolina on the t5th day of December, 1981 and consolidated with the case of Ra1ph Gingles, et al (BI-803-CIV-5) on the 18th day of February, LggZ; that said action seeks a declaration that the apportionment and redistricting of the North Carolina Senate and l{orth Carolina House of Representatives is unconstitutional and further seeks a court devised plan for both houses based on single member districts and substantial equality of population among the districts; That since the filing of the original complaint in this cause on November 25, 1981, the United States Department of Justice, under Section 5 of the Voting Rights Act (42 U'S'C' f973) disapproved the t\trorth Carolina Senate and North Carolina House of Representatives redistricting plans and thereafter the State of North carolina declined to appeal such disapproval. RALPH GINGLES, €t aI., Plai-ntif f s, vs. RUFUS EDMISTEN, €t 41., Defendants ALAN V. PUGH, €t AI., Plaintiffs vs. JAIIES B. HUNT, JR., etc., €t &1" Defendants No.81-803-CrV-5 No. 81-1066-cIV-5 AFFIDAVIT OF COUNSEL EOR PLAINTIFFS FOR COMPLAINT I \ That thereafter on February 9, L982, the l{orth Carolina General Assembly met in compliance with the Proclamation of the Governor of the State of North Carolina under Article III, Section 5(7) of the Constitution of tlorth Carolina for the convening of a Second Extra Session of the 1981 General Assembly of North carolina and attempted to enact new North carolina Senate and North Carolina House of Representatives redistricting plans, which plans have been forwarded by lhe State of North Carolina to the United States Department of Justice for pre-clearance under Section 5 of the Voting Rights Act (42 u.s.c. L973) ; That the Defendants have filed an answer to Plaintiffs' original complaint but it has become necessary for Plaintiffs to file and serve a supplemental complaint in this action fot the reasons that the North Carolina General Assembiy has, since the fiting of the original complaint, enacted new redistricing plans, all as detailed above. Arthur/J. Donaldson , Attorney or Plainti Sworn and subscribed to before this ,. ? 4 day of March , t982. otary Pub DAPHNE M. WEEMS NOTARY PUBLIC ROWAN CO., NCI{y Commission Expires: 4z y'-rt CERTIFICATE OT SERVICE This is to certify that the undersigned attorney has this date served this pleading or paper in the above entitled action upon each of the parties *to this cause by the method checked below: Depositing a copy hereof postage prepaid post office or official depository under exclusive care and custody of the United States Posta1 Service properly addressed the attorney(s) for said party(ies). Handing a copy hereof to the attorney for said party (ies) . ina the to B. tt C. Leaving a copy hereof with a employee at the office(s) of for said party(ies). partner or the attorney(s) *Mr. James C. Wallace, Jt. Deputy Attorney General for Legal Affairs North Carolina Department of Justice Post Office Box 629 Raleigh, North Carolina 27602 IvIr. Jerris Leonard 900 17th Street, Nw Suite 1020 Washington, D.C. 20006 J. Levonne Chambers James E. Ferguson, II Les1ie J. Winner Chambers, Ferguson, Watts, Wa11as, Adkins & Fuller, P.A. Suite 730 East Independence Plaza 951 South Independence Boulevard Charlotte, North Carolina 28202 Jack Greenberg Napoleon Williams Lani Guinier Suite 2030 10 Columbus Circle New York, New York 10019 rhis 4 day of 4, , Lgg 2 . 309 North Main Street Salisbury, North Carolina 28L44 Telephone: 704-637-1500 Arthur J. Dona BURKE & DONALDSON