Defendants' Second Motion in Limine

    IN THE UNITED STATES DISTRICT COURT FOR THE 

SOUTHERN DISTRICT OF ALABAMA 
SOUTHERN DIVISION 

WILEY L. BOLDEN, et al., Ww
 

Plaintiffs, § 

VS. § CIVIL ACTION NO: 75-297-P 

CITY OF MOBILE, et al., § 

Defendants. § 

DEFENDANTS' SECOND MOTION IN LIMINE 
  

Defendants respectfully move the court as follows: 

l. To withhold any further proceedings in the above-styled 

cause and to direct Plaintiffs to make a showing to the court of 

any evidence that they intend to offer for the purpose of proving that 

the Alabama State Legislature is currently maintaining the City 

of Mobile's at-large form of government for the purpose of diluting 

the vote of black citizens; 

2. That Plaintiffs be instructed not to produce broad, 

generalized evidence in he form of conclusory statements; 

3. To instruct Plaintiffs to state with specificity the 

documents, persons, and other forms of evidence by which they intend 

to prove that the Alabama State Legislature is currently maintaining 

the City of Mobile's at-large form of government for the purpose of 

diluting the vote of black citizens; 

4. That Plaintiffs be instructed that they may not rely on 

any evidence that has been excluded pursuant to Defendants' motion 

in limine previously filed in this court; 

5. That Plaintiffs be granted a reasonable time during which 

discovery as allowed by the Federal Rules of Civil Procedure may be 

conducted; and, 2 

6. Following discovery by Plaintiffs and reasohable notice to 

the respective parties, a hearing will be conducted by this court to 

determine whether the evidence presented by Plaintiffs, if. subsequently 

proved, would meet the evidentiary standard enunciated by the United 

(24) nesting 

  

- 

States Supreme Court. 

  

C. B. ARENDALL, JR. 
Attorney for Defendants 
City of Mobile, et al. 

 



  

WILLIAM C. TIDWELL, III 

Attorney for Defendants 

City of Mobile, et al. 

  

DEFENDANTS RESPECTFULLY REQUEST ORAL ARGUMENT. 

OF COUNSEL: 

HAND, ARENDALL, BEDSOLE, GREAVES & JOHNSTON = 

Post Office Box 123 

Mobile, Alabama 36601 

CERTIFICATE OF SERVICE 
  

I do hereby certify that I have on this | #T day of November, 
1980, served a true and correct copy of the foregoing pleading on 
counsel for all parties of record by placing same in the United States 
mail, properly addressed and first class postage prepaid. 

  

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