Correspondence from Winner to Guinier, Derfner, and Suitts

Correspondence
July 28, 1986

Cite this item
Correspondence from Winner to Guinier, Derfner, and Suitts preview

Cite this item

  • Case Files, Bozeman & Wilder Working Files. Amendment to Petitioner's Motion for Summary Judgment, 1984. ffa7a171-ed92-ee11-be37-6045bdeb8873. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/d2c71427-9369-4f5a-9386-7330095a209a/amendment-to-petitioners-motion-for-summary-judgment. Accessed August 19, 2025.

    Copied!

    I

;

IN THE I'NITED STATES DISTRICT COURT
rEci'j-'

FOR THE MIDDLE DISTRICT OF ALABAMA

'$,b,iloJrl"i' ,lrr*o*

JULIA P. WILDER,

Petltioner,

against

EALON M. LAMBERT, JACK C. LUFKIN AND
JOHN T. PORTER IN THEIR OFFICIAL
CAPACITTES AS MEMBERS OF THE ALABAIW\
BOARD OF PARDONS AND PAROLES, AND
TED BUTLER, A PROBATION AND PAROLE
OFFICER, EMPLOYED BY THE ALABAMA
BOARD OF PARDONS AND PAROLES,

Civl1 Action No.
83-H-580-N

Respondents

A]VIENDMENT TO PETITIONER'S MOTION
FOR SUMMARY JUDGMENT

peliti-oner, by and through her attorneys, hereby amends

her Motion for Summary Judgment of January 18, L984, by with-
drawing the followlng claims for judgment as a matter of law:

1. that petiti-oner was subjected to ex post
facto Ilability and

2, that petltioner was convicted on strlct
liability grounds.

It appears that substantial and material facts are in
dlspute with respect to these two claims. Petitioner with-
draws these two claims for development at an evidentiary
hearing or such further proceeding as the Court. permits.

Since, however, petitioner wilI be entitled to habeas corpus

relief if she prevalls on any of the remaining claims in her



I

Motion for Summary Judgment, Do further proceedings may be

necessary. Therefore, in the interest of judicial economy

and of expediting this Court's ability to dispose, ds a

matter of 1aw, of the remaining grounds asserted by petitioner

in her pending Motion for Summary Judgment, petitioner files

this amendment.

Dated: February 2L, 1984

7

Of Counsel:

639 Martha Street
Montgom€Fy, Alabama 36108
(20s) zoz-zssz

JACK GREENBERG
LANI GUINIER

99 Hudson Street
16th Floor
New York, New York 10013

Attorneys for Petitioner

Anthony G. Amsterdam
New York Universlty
Schoo1 of Law, Room 327
20 Washington Square South
New York, New York 1OOI2
(ztz) sge-zose

Siegfried Knopf
Brown, Wood, Ivey, Mitchell
and Petty
555 Callfornia Street
San Francisco, California 94LO4

Respectfully submltted,

2



a

t

CERTIFICATE OF SERVICE

I certify that a copy of the foregoing Amendment To Peti-

tioner's l4otion For Summary Judgiment, has been served upon

Jean WiIliams Brown, Esg., Assistant Attorney General by mailing

same to her by first class United States mail, Postage prepaid

on this & day of February, 1984, addressed as follows:

JEAN WILLIAMS BROhIN , ESQ.
Assistant Attorney General
25O Administrative Bullding
l4ontgomery, Alabama 36I30

7

Copyright notice

© NAACP Legal Defense and Educational Fund, Inc.

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.

Return to top