Notice of Depositions

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,1q' i\

RAIPH GINGLES, et a1.,

Plaintiffs,
v.

RUFUS L. EDMISTEN, etc., et a1.,

IN THE UNITED STATES DISTRICT COIIRT
FOR TIIE EASTERN DISTRICT OF NORTH CAROLINA

RALEIG}I DIVISION

Civil No.' 81-803-CIV-5

(a

NOTICE OF DEPOSITIONS

Defendants.

TO COI]NSEL FOR TIIE ABO\TE-NA},IED DEFENDANTS:

Jemes C. Wa1lace, Jr.
Deputy Attorney General

for LegaL Affairs
Attorney General' s Office
North Carolina Department of Justice
Post Office Box 629
Raleigh, North Carolina 27602

PLEASE TAKE NorrcE that, 3r the office of rhe Artorney General

of North Carolina, North Carolina Supreme Court Building,
Raleigh, North Carolina, orr Monday, November 9, 1981, at 9:30 a.m.

before an authorLzed officer and pursuant to the Federal Rules

of Civil Procedure, the plaintiffs in the above captiongd action
will take the depositions upon oral examination of Willian Hale

and Terence Sullivan.

By agreement with the attorney for defendants, the deponents

wiLl attend without fo:mal subpoena and will bring to said deposi-

tions and produce for exemination and copying all documents

attached to this Notice as Exhibit A.

Such depositions shall continue from day to day until
completed. You are invited Eo attend and cross-ex:-ine.

This 29xh day of October, 1981.

I . E Yvlta

LESLIE J.

Sui.te 730 EasE Independence Plaza
951 South Independence Boulevard
Charlotte, North Carolina 28202
7 04 / 37s- 8451

Attorneys for Plainriffs



E)C{IBIT A TO NOTICE OF DEPOSITIONS

The following requests apply to all docurnents to which

you have access which contain information about redistricting
during the 1981 regular and special sessions of the General

As sembly:

1. The minutes of the House, Senate, or joint
redistricting conrmittees and subcoumiltees
for redistricting the General Assembly or
Congressional Districts.

2. Tapes of the cornmittee or subcournittee
meetings and any transcriptions of those
taPes.

3. All maps, or plans for redistricting con-
sidered by the conmittees or subcor'-ittees
and the name of the person submitting the
map or plan plus all supporting docr:n,ents
and any staff analysis of the plan.

4. A11 memos from the legislative staff or
other state employees to legislators
concerning legislative or congressional
redistricting including instructions,
guideLines, background information, etc.

5. A1l docrments whicb contain an analysis
of or data concerning the racial composi-
tion of counties or proposed legislative
or congressional districts which were
prepared by legislative staff or other
state government employees for use by
Legislators.

6, A11 correspondence from North Carolina
Congressmen or members of their staff to
the legislative staff, the Speaker of the
House, the Lieutenant Governor, or the
sornmiltss chairman or subcommittee chairman
and the responses to ttris correspondence.

7. Al-1 standards and guidelines adopted by any-of the redistricting coumittees br sub-
corrnittees.

8. Any, written statements or requests made by
members of the public and submitted to a
redistricting cormittee or subcornsrittee.

9. Correspondence to the legislative staff or
to the Speaker of the l{ouse, the Lieutenant- Governor, or the ccrmittee chairman from
anyone offering technical or computer
assistance to Ehe legislature for redistricting
and the responses to those offers.



10. The record of the vote on the floor of the
House and of the Senate on each redistricting
bill which was proposed or adopted and on
each anendment to each of the bi1ls whether
or not the amendment was adopted

11. A11 requests for info::uration or for assistance
concerning legislative or congressional re-
districting from an! member oE the legislature
to a member of the legislative staff and the
staff's response to tEe requests.

L2. All memos from the Speaker of the House or the
Lieutenant Governor to members of the redis-
tricting coumittees or subcornmittees concerning
congressional or state legislative redistricting.

13. Memos from the redistricting committee or sub-
committee chairman to coumittee members excluding
routine notices of comnittee meetings.



CERIIFICATE OF SERVICE

The undersigned hereby certifies that he has this day

served copies of the foregoing NorrcE oF DEposrrroNs upon

cor:nsel for the defendants and the ne''ted deponents by depositing
copies of snme in the United States mail, postage prepaid,
addressed to:

James C. WalLace, Jr.
Deputy Attorney General

for Legal Affairs
North Carolina Department

of Justice
PosE Offiee Box 629
Raleigh, North Carol-ina 27602

William Hale
Office of Legislative Services
North Carolina General Assembly
Jones Street
Raleigh, North Carolina

Terence Sullivan
Office of Legislative Services
North Carolina General Assembly
Jones Street
Raleigh, North Carolina

This 29tll. day of October, 1981.

ttorney