Moon v. Meadows Motion for Leave to File Brief

Document text

The following text has been generated automatically during the document scanning process. It may contain errors, omissions, or incorrect formatting. Please refer to the PDF document if this text is not usable.

Download

By downloading, publishing, or reusing the Materials outside of the Website, you hereby confirm and attest that you have read and agree to the LDF Archival Collection Terms of Use linked below. We draw your attention to the following:

For those Materials owned by LDF, your use of the Material outside the Site is solely for one or more of the following (the “Permitted Purposes”):

Non-commercial research and private study;
Teaching, scholarship and instruction (including distance learning);
Non-commercial print and non-commercial online use;
Criticism, comment or news reporting; or
For people with visual disabilities (See Section 121 of the Copyright Act).
For those Materials not owned by LDF you understand that:
- It is your responsibility to determine whether the way you plan to use the materials falls within the copyright exception of Fair Use.
- For any use outside of Fair Use, it is your responsibility to seek and obtain all required permissions from any existing rights holders.

LDF hereby grants you the right to use LDF owned Materials for the Permitted Purposes without seeking further permission from LDF.

If you publish or redistribute any Materials (including excerpts and quotes), you must include a credit line and/or proper citation to the source of the Material. However, you may not use the name of LDF in any manner which creates any false association between you and LDF or that incorrectly implies any sponsorship or endorsement of you by LDF.

NOTICE: Uses that do not comply with these Terms or that do not fall under Fair Use (or another exception) may make you liable for copyright infringement.

Read the full LDF Archival Collection Terms of Use Here.

I agree to the terms and conditions for use of this content.

If you would like to use this content in other ways, contact us at

Moon v. Meadows Motion for Leave to File Brief of More than Thirty Pages

Topic
- Political Participation
Notable Person
- Elaine R. Jones
Organization
- NAACP Legal and Educational Defense Fund, Inc.
Collection
- Brief Collection
Taxonomy
Identifier
- f96881a2-be9a-ee11-be36-6045bdeb8873

Cite this item

Brief Collection, LDF Court Filings. Moon v. Meadows Motion for Leave to File Brief, 1996. f96881a2-be9a-ee11-be36-6045bdeb8873. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/aabd9de2-eb22-4148-a129-ea01bd0fa489/moon-v-meadows-motion-for-leave-to-file-brief. Accessed April 29, 2025.

Copied!

    IN THE UNITED STATES DISTRICT COURT 
FOR THE EASTERN DISTRICT OF VIRGINIA

Richmond Division

DONALD MOON
and ROBERT SMITH,

Plaintiffs,
v . No. 3:95 CV 942

M. BRUCE MEADOWS,
Defendant,

and
CURTIS W. HARRIS; JAYNE W. BARNARD;
JEAN PATTERSON BOONE; RAYMOND H. BOONE; 
WILLIE J. DELL; HENRY C. GARRARD, SR.; 
WALTER T. KENNEY, SR.; MELVIN R. SIMPSON; 
and GERALD T. ZERKIN,

Defendant-Intervenors.

MOTION FOR LEAVE
TO FILE BRIEF OF MORE THAN THIRTY PAGES

In accordance with new Rule 10(E)(3) of the Local 
Rules of this Court, the defendant-intervenors in this case, 
Rev. Curtis Harris, et al.. respectfully request that they be 
allowed to file the accompanying brief in opposition to 
summary judgment even though it contains 35 pages of text 
instead of the required 30.

This request was informally granted by the Court in 
advance of filing. See Local Rule 10(E)(3).



Respectfully submitted

MARY WYCKOFF
American Civil Liberties Union
132 W. 43 Street
New York, New York 10036

M. LAUGHLIN MCDONALD 
NEIL BRADLEY 
MAHA S. ZAKI
American Civil Liberties 

Union Foundation, Inc.
44 Forsyth Street, N.W. Suite 202 
Atlanta, GA 30303

STEPHEN B. PERSHING 
Virginia Bar No. 31012 
American Civil Liberties 
Union of Virginia 
6 N. 6th St., Suite 400 
Richmond, VA 23219 
(804) 644-8080

J. GERALD HEBERT 
Virginia Bar No. 38432 
800 Parkway Terrace 
Alexandria, VA 22302

ELAINE R. JONES,
Director-Counsel
THEODORE M. SHAW
NORMAN J. CHACHKIN
NAACP Legal Defense
and Educational Fund, Inc.
99 Hudson Street, Suite 1600 
New York, New York 10013

PENDA HAIR
CASSANDRA Q. BUTTS
NAACP Legal Defense and
Educational Fund
1275 K St. NW Suite 301
Washington, DC 20005

PAMELA S. KARLAN 
580 Massie Road 
Charlottesville, VA 22903

Dated:
ATTORNEYS FOR DEFENDANT-INTERVENORS
6 ^

k k k

CERTIFICATE OF SERVICE
I certify that on this day of ^  *7________ ,

1996, I caused the foregoing motion to be hand-delivered to 
Stephen A. Katsurinas, Esg., Hirsch, Robinson, Sheiness & 
Glover, 700 East Main Street, Suite 1603, Richmond, VA 23219, 
counsel for plaintiffs, and to Frank Ferguson, Esg., and Mary 
E. Shea, Esq., Office of the Virginia Attorney General, 900 
East Main Street, Richmond, VA 23219, counsel for defendants; 
and to be mailed first class, postage prepaid, to Paul Loy 
Hurd, Esq., 1101 Royal Avenue, P.O. Box 2190, Monroe, LA 
71207, counsel for plaintiffs.



VIRGINIA AFFILIATE
STEPHEN B PERSHING 
Legal Director

DIRECT DIAL (804) 644-8080

May 6, 1996

Via first-class mail

Hon. T.S. Ellis, I I I ,  Judge 
United States District Court 

for the Eastern District of Virginia 
P.O. Box 21449 
Alexandria, VA 22320

Hon. H. Emory Widener, Jr., Judge 
United States Court of Appeals 

for the Fourth Circuit 
P.O. Box 868 
Abingdon, VA 24210

Re: Moon v. Meadows, No. 3:95 CV 942

Dear Judges Ellis and Widener:

Enclosed for each of you is a copy of the defendant-intervenors’ 
opposition to summary judgment, with a separate volume of 
attachments. The originals of these documents were filed today in the 
district court clerk’s office in Richmond, and service has been effected 
on all parties.

Thank you very much.

Respectfully,

Stephen a. Pershing

SBP/
cc: Stephen A. Katsurinis, Esq.

Paul Loy Hurd, Esq.
Mary E. Shea, Esq.

American Civil Liberties Union of Virginia 6 N. Sixth St., Suite 400, Richmond, VA 23219

Copyright notice

This collection and the tools to navigate it (the “Collection”) are available to the public for general educational and research purposes, as well as to preserve and contextualize the history of the content and materials it contains (the “Materials”). Like other archival collections, such as those found in libraries, LDF owns the physical source Materials that have been digitized for the Collection; however, LDF does not own the underlying copyright or other rights in all items and there are limits on how you can use the Materials. By accessing and using the Material, you acknowledge your agreement to the Terms. If you do not agree, please do not use the Materials.

Additional info

To the extent that LDF includes information about the Materials’ origins or ownership or provides summaries or transcripts of original source Materials, LDF does not warrant or guarantee the accuracy of such information, transcripts or summaries, and shall not be responsible for any inaccuracies.

Moon v. Meadows Motion for Leave to File Brief

Topic

Notable Person

Organization

Collection

Taxonomy

Identifier

Cite this item

Copyright notice

Additional info

You may also be interested in