Moon v. Meadows Motion for Leave to File Brief

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

Topic
- Political Participation
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 November 20, 2025.

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    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

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Moon v. Meadows Motion for Leave to File Brief

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