Defendants' Response to Interrogatories, James D. Taylor

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IN THE UNITED STATES DISTRICT COURT FOR THE 
MIDDLE DISTRICT OF ALABAMA 

NORTHERN DIVISION 

JOHN 'DILLARD, ETSAL., 

Plaintiffs, 

v5, CIVIL ACTION NO. 85-T-1332-N 

CRENSHAW COUNTY, ALABAMA, 
ETAL. 

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Defendants. 

RESPONSE TO INTERROGATORIES BY DEFENDANT, JAMES D. TAYLOR   

Defendant, James D. Taylor as Circuit Clerk of Escambia County, 

Alabama, responds to plaintiff's interrogartories as follows: 

7. I have no personal knowledge, however, on information and 

belief I adopt the answer to this question submitted by Martha 

Kirkland, Probate Judge of Escambia County. 

2. I have no personal knowledge, however, on information and 

belief I adopt the answer to this question submitted by Devon Wiggins, 

Chairman of the County Commission. 

3. I have no personal knowledge, however, on information and 

belief I adopt the answer to this question submitted by Devon Wiggins, 

Chairman of the County Commission. 

4. I have no personal knowledge, however, on information and 

belief I adopt the answer to this question submitted by Devon Wiggins, 

Chairman of the County Commission. 

5. I adopt the response submitted by Martha Kirkland, Judge of 

 



  

Probate. 

6. Not to my knowlege. 

7. On information and belief 1 adopt the response submitted by 

Devon Wiggins, Chairman of the County Commission. 

8. On information and belief I adopt the response submitted by 

Devon Wiggins, Chairman of the County Commission. 

9. On information and belief I adopt the response submitted by 

Devon Wiggins, Chairman of the County Commission. 

10. On information and belief I adopt the response submitted by 

Devon Wiggins, Chairman of the County Commission. 

11. Not to my knowledge 

12. I adopt the response submitted by Martha Kirkland, Judge of 

Probate. 

13. A. See records and reports attached to the response by 

Martha Kirkland, Judge of Probate. 

B. None, 

C. Holly Gilmore $50.00, Joe Everette $25.00. 

D. See record of contribution attached to response by Judge 

of Probate. 

E. Note campaign literature attached. 

F. 1 attended the ADC meeting at the Southern Normal School. 

(1) I attended and sought votes. 

(2) All other candidates were there. 

G. None. 

H. 1 made no speech regarding any particular issue directed 

 



  

at black citizens but at all citizens. 

I. . None, 

J. 1 made an appeal to all citizens. 

K. " None, 

L. None, 

M. Not known. 

N. Not known. 

O+.i None, 

P. See reports of campaign expenditures attached to response 

by Judge Kirkland. 

14, I was assisted by my attorney and by the records of the Judge 

of. Probate, 

15. 1 have no personal knowledge, however, on information and 

belief I adopt the answer to the question submitted by Devon Wiggins, 

Chairman ot the County Commission. 

16. I know of no election characterized by racial polarization. 

17. Various candidates have sought and received the ADC backing 

for many years. I know of no elections that have been characterized 

by racial polarization. 

18. This depends upon your definition of the "recent past". The 

school system to my knowlege in the recent past has been racially 

integrated. 

19. I do not maintain documents and have no personal knowledge of 

the names of witnesses regarding this fact. 

20. 1 do not know the answer to this question. 

 



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21. I have no personal knowledge, however, on information and 

belief I adopt the response submitted by Devon Wiggins, Chairman of 

the County Commission. 

22. I am a member of the Alco Methodist Church and the American 

Legion. 

23.%:0n information and belief 1  adoptis the response 10 this 

question submitted by Devon Wiggins, Chairman of the ‘County 

Commission. 

24. On information and .belief I adopt the response to this 

question submitted by Devon Wiggins, Chairman ‘of “the County 

Commission. 

25. On information and belief "1 adopt the response to this 

question submitted by Devon Wiggins, Chairman of the County 

Commission. 

26. On information and belief I adopt the response to this 

question submitted by Devon Wiggins, Chairman of the County 

Commission. 

27... On information. and: belief I .adopt #the’ response to this 

question submitted by Devon Wiggins, Chairman of the County 

Commission. 

28. I adopt the response of Martha Kirkland, Judge of Probate. 

29. I adopt the response of Martha Kirkland, Judge of Probate. 

30... Not known at this time. 

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JAMES D. TAYLOR - Circpit 
/Fscambia County / 

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SWORN to and SUBSCRIBED before me this the <O 4ay of Fabaceae 

NOTARY PUBLIC 
\ 

1986. 

  

Im AO INIASY 

Jhmes W. Webb 
Attorney for Escambia County 

  

OF COUNSEL: 

WEBB, CRUMPTON, McGREGOR, SCHMAELING & WILSON 
166 Commerce Street 
P.O. Box 238 
Montgomery, Alabama 36101 
(205) 834-3176 

OTTS & MOORE 
P.O. Box 467 
Brewton, Alabama 36427 
(205) 867-7724 

CERTIFICATE OF SERVICE 

I hereby certify that copies of the foregoing response 
to interrogatories by defendant, James D. Taylor, have been mailed to 
Larry T.' Menefee, ©FEsquire, James U. Blacksher, Esquire and Wanda J. 
Cochran, Esquire, Blacksher, Menefee & Stein, 405 Van Antwerp 
Buildingy P.O. Box 1051," Mobile, ' Alabama 36633, Terry G. Davis, 
Esquire, 2Seay  & Davis," 732 Carter Hill Road, <P.0. "Box 6125, 
Montgomery, Alabama 36106, Deborah Fins, Esquire and Julius L. 
Chambers, Esquire, NAACP Legal Defense Fund, 99 Hudson Street, 16th 
Floor, New York, New York, 10013, Jack Floyd, Esquire, Floyd, Kenner & 
Cusimano, 816 Chestnut Street, Gadsden, Alabama 35999, Alton Turner, 
Esquire, Turner & Jones, P,0, Box 207, Luverne, Alabama 36049, D.L. 
Martin, Esquire, 215 S. Main Street, Moulton, Alabama 35650, David R. 
Boyd, Esquire, . Balch & Bingham, P.O. Box 78, Montgomery, Alabama 

36301,  ¥W.0. Kirky Jr., Esquire, Curry  & Kirk, ‘Phoenix Avenue 
Carrollton, Alabama 35447, Barry D. Vaughn, Esquire, Proctor & Vaughn, 
121 N. Norton Avenue, Sylacauga, Alabama 35150, H.R. Burnham, Esquire, 
Burnhaw, - Klinefelter, Halsey, Jones '& Cater, U4071 SouthTrust Bank 
Building, P.O. Box 1618, Anniston, Alabama 36202, Warren Rowe, 

 



  

Esquire, Rowe, Rowe & Sawyer, P.O. Box 150, Enterprise, Alabama 36331, 
Edward Still, Esquire, 714 South 29th Street, Birmingham, Alabama 
35233-2810, Reo Kirkland, Jr., Esquire, P.O. Box 646, Brewton, Alabama 
36427, and all defendants not represented by counsel by placing coples 
of the same in the United States Mail, postage prepaid this the _ <5 
day of February, 1986. 

— { YW lied / { / (A VAL 
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James W. Webb