Motion to Compel Defendants to Answer Interrogatories and Produce Documents

    CRAWFORD, BLACKSHER & KENNEDY 

ATTORNEYS AT LAW 

1407 DAVIS AVENUE 

MOBILE, ALABAMA 36603 

VERNON Z. CRAWFORD TELEPHONE 432-1591 

JAMES U. BLACKSHER AREA CODE (205) 

CAIN J. KENNEDY 

MICHAEL A. FIGURES 

W. CLINTON BROWN, JR. 

January 19, 1976 

Mr. William J. O'Connor, Clerk 
United States District Court 
213 Federal Building 
Mobile, Alabama 36603 

Re: Bolden, et al. v. City of Mobile, et al. 
Civil Action No. 715-297-P 
  

Dear Mr. O'Connor: 

Please file the enclosed motion to compel defendants to answer 
interrogatories and produce documents. 

Also please add Larry Menefee to the list of counsel for 
plaintiffs Wiley L. Bolden, et al. Because Larry is associated 
with our law firm, it will not be necessary to send additional 
copies of documents to him. 

Best regards. 

Sincerely, 

CRAWFORD & BLACKSHER 
- 

/ AAA 

U. Blacksher 

JUB: bm 

Enclosure 

cc: Charles Arendall, Esquire 
S. R. Sheppard, Esquire  



  

IN THE UNITED STATES DISTRICT COURT FOR THE 

SOUTHERN DISTRICT OF ALABAMA 

SOUTHERN DIVISION 

WILEY L. BOLDEN, et al., 

Plaintiffs, CIVIL ACTION 

VS. 

NO. 75-297-P 
CITY OF MOBILE, et al., 

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Defendants. 

MOTION TO COMPEL DEFENDANTS TO 
- ANSWER INTERROGATORIES AND PRODUCE DOCUMENTS 
  

Plaintiffs respectfully show unto the Court as 

follows: 

1. On or about December 8, 1975 plaintiffs 

filed "Plaintiffs' Third Discovery Notice" propounding 

questions pursuant to Rule 33 and asking for production 

of documents pursuant to Rule 34. On or about January 

7, 1976, defendants filed an "Answer £0. Plaintiffs’ Third 

Discovery Notice." The answers contained therein were so 

vague and broad as to be evasive, incomplete and unresponsive. 

2. The aforementioned discovery notice solicits 

information and responses of the defendants and does not 

seek production of documents or other tangible things within 

the meaning of Rule 26(b) (3) as relied upon by the defendants. 

The information requested is specific and the responses of 

the defendants is wholly insufficient. To allow defendants’ 

response would permit government to hide behind a bureaucratic 

maze of its own creation and set different standards for 

responses by individuals vis-a-vis governmental entities. 

3. Plaintiffs submit that if such documents and 

tangible things do exist, and plaintiffs have reason to 

 



  

believe they do exist, they should be produced in that they 

are of the utmost relevancy and that plaintiffs could not 

obtain the information without insurmountable difficulty 

and undue hardship. Plaintiffs said discovery notice does 

not seek mental impressions, conclusions, opinions, or 

legal theories but rather seeks data and factual information, 

largely of a clerical nature, subject to little, if any, 

interpretation. 

WHEREFORE, Plaintiffs, pursuant to Rule 37, move the 

Court to enter an order compelling the defendants to fully 

answer the questions propounded and to produce all of the 

requested documents as set forth in the above described 

discovery notice. 

Via 
Respectfully submitted this day of January, 1976. 

CRAWFORD & BLACKSHER 
1407 DAVIS AVENUE 
MOBILE, ALABAMA 36603 

  

{ ad Wid 
Pt aca 

GREGORY B. STEIN 

LARRY MENEFEE 

EDWARD STILL 
SUITE 601 - TITLE BUILDING 
2030 THIRD AVENUE, NORTH 
BIRMINGHAM, ALABAMA 35203 

JACK GREENBERG 
CHARLES WILLIAMS 
SUITE 2030 
10 COLUMBUS CIRCLE 
NEW YORK, N. Y. 10019 

Attorneys for Plaintiffs 

 



  

CERTIFICATE OF SERVICE 
  

I do hereby certify that on this the [94a of 

January 1976, I served a copy of the foregoing MOTION TO 

COMPEL DEFENDANTS TO ANSWER INTERROGATORIES AND PRODUCE 

DOCUMENTS upon counsel of record, Charles Arendall, Esquire, 

David Bagwell, Esquire, Post Office Box 123, Mobile, AL 

36601 and S. R. Sheppard, Esquire, City of Mobile, Legal 

Department, Mobile, AL 36602, by depositing same in United 

States Mail, postage prepaid. 

  

TORNEY FOR [PLATATIFFS