Wright v. Bailey Reply Brief

    UNITED STATES DISTRICT COURT 

FOR THE MIDDLE DISTRICT OF ALABAMA 

NORTHERN DIVISION 

JOHN DILLARD, ET AL, 

PLAINTIFFS 

VS. CIVIL ACTION #85-T-1332-N 

CRENSHAW COUNTY, ALABAMA, 

ET AL, 

DEFENDANTS. V
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ANSWERS TO PLAINTIFFS' INTERROGATORIES 

AND MOTION TO PRODUCE 

BY W. H. LANG, JR. 

PROBATE JUDGE, PICKENS COUNTY 

  

  

  

  

Comes W. H. Lang, Jr., Probate Judge, Pickens County and for 

answer to Plaintiff's Interrogatories and Motion to Produce 

Documents says as follows: 

1. Reverend James Corder, Eliezer Washington. 

la. County Commissioner, District 2 and 3 respectively. 

lb. Rev. Corder, 1984; E. Washington, 1980. 

lc. Rev. Corder narrowly defeated. E. Washington strongly 

defeated, both in primaries. 

2. Deny. 

3a. Bonnie Connor, black male, still current, Hospital Board; 

Walter W. Jones, black male, ending 1984, Board of Registrars; 

Voncille Wright, female black, 1984, current, Board of Registrars. 

4a. Pickens County Hospital Board, Pickens County Water, Sewer 

and Fire Protection Authority, Pickens County Industrial 

Development Board, Pickens County Library Board. Procedure is 

review of all qualifications. The Commission District affected 

 



  

PAGE TWO 
  

recommends nomination with approval subject to Commission as a 

whole. DPS Board and one member to PCAC Board. 

4b. List attached. 

4c. N/A. 

4d. Water Board - runs and oversees operation of county-wide 

water system; Hospital Board - operates Pickens County Hospital 

in Carrollton; Library Board - operates library system in the 

county; Industrial Development Board - seeks new industry for 

Pickens County. Operate DPS - operate PCAC. 

5a. 1. Corder vs. Kirksey: (2) Charlie Harris, et al. v. Charles 

A. Graddick, et al. 

5b. (1) United States District Court for the Northern District of 

Alabama, (2) Civil Action No. 84-T-595-N. 

5c. (1) Case ended March, 1982. (2) Case ended July, 1985. 

5d. #1). Corder ivs. Kirksey, same allegations as 1in present 

action. (2) Required county to appoint more black elective 

officials. 

6. Black CETA employee claimed that he did not get to ride in 

the cab of a truck as did others. Date not available. Filed 

with CETA. 

7b. Yes. 

8. See attached Affirmative Action Plan in the office of Verbon 

T. Atkins, Clerk, Pickens County Commission. 

9. See attached copy of Affirmative Action Plan that was adopted 

April 22, 1980. Same as Question 8. 

 



  

PAGE THREE 
  

10. None. 

11. ‘In the* past "15. years Pickens County elections have had 

several poll watchers from the Justice Department. 

12a.Richard Walters, District One Commissioner, White; Jerry 

Fitch, District Four Commissioner, White: Garvin Bryant, District 

Two Commissioner, White; Jack Pate, District Three Commissioner, 

White; W. H. Lang, Jr... Probate Judge, White; Louie Coleman, 

Sheriff, White; James Floyd, Circuit Clerk, White. 

12b.Garvin Bryant, January. 1983-1986: Richard Walters, January 

1973-1986; Jack Pate, January 1985-1986; Jerry Fitch, January 

1983-1986; Louie Coleman, 1962-1986; James E. Floyd, January. 

1977-1986; W. H. Lang, Jr., January. 1983-1986. 

13a.See attached expense accounts for full answer tO this 

question . 

13ai.See attached expense accounts for Question 13a. 

13b. Do not recall any contribution from predominantly black 

individual or organization. 

13c. See attached expense account to Question 13a. 

13d. I used radio, newspaper, handouts and posters during my 

campaign. 

13e. See attached. 

13f. I attended church at pickensville Methodist and Reform 

Baptist. I was interviewed by ADC and NAACP. I attended 

Southern Pickens Deacons Meeting. I visited all neighborhoods in 

Pickens County door to door. 

13f1. At churches I attended services and was recognized as 

 



  

PAGE FOUR 
  

present; at ADC and NAACP I responded to questions presented to 

me. At deacons meeting I attended and spoke. 

13f2. At deacons meeting only Mr. Billy Ray Cook was present. At 

church meeting I was only candidate present. 

13g. To the best of my knowledge, I attended only rallies held in 

each community, those sponsored by clubs and each of those were 

attended by all races. Again, I visited door to door in all 

neighborhoods in the area. 

13gl.. At vcalljes all candidates draw cards to speak. Each 

candidate was allowed a time. 

13g2. All candidates were invited and in most cases they 

appeared. 

13h. Attached brochure covers each item of my speeches. 

131i. Most of the candidates including myself spoke for all 

citizens of Pickens County together. 

133% At three sessions I was present in which minorities 

constituted the large majority. My speech as at all other 

occasions was that all our citizens could work together for our 

future. 

13k. None. 

13kl. The only people I witnessed actively campaigning for my 

campaign was my family. I do feel several whites and blacks 

worked for me. 

13m. N/A. 

i3n. No. 

130. NONE. 

 



  

PAGE FIVE 
  

13p. Have not spent any on campaign. 

14. W. H. Lang, Jr., Reform, AL, my attorney W. O. Kirk, Jr., 

Carrollton, AL, Chief Clerk of Probate Court, Mrs. Glenda Ryan, 

Carrollton, AL; Clerk of Commissioners' Court, Verbon Atkins, 

Carrollton, AL; Ralph Smith, Superintendent of Board of 

Education, Carrollton, AL;all records in Probate Office, Board of 

Education, Pickens County Commission. 

15. No. 

15a. United States District Court for the Northern District of 

Alabama, the Eleventh Circuit and the Supreme Court of the United 

States have approved the present plan under which Pickens County 

elections are held. 

15. -: N/A. 

15bl1. N/A. 

152. . N/A. 

15b3. N/A. 

le. Deny. 

17a. In 1981 General Election for the Commissioner's Race 

involving Rev. James Corder and Commissioner Garvin Bryant. 

17b. Based on results of absentee voters of the Aliceville 

District votes were heavy for white candidate and voters are a 

majority black. 

18. Several years ago all schools were integrated. 

19. N/A. 

20. School system is under Federal Court Order from the 

Northern District of Alabama. 

 



  

PAGE SIX   

21. All EEO-4 annual reports are available for copying in the 

Probate Office of Pickens County or Pickens County Board of 

Education Office in Carrollton, AL. One copy of said reports are 

enclosed with this Answer to Larry T. Menefee. Others are 

available for inspection and copying. 

22. United Methodist Church, Rotary Club, Farm Bureau, Chamber 

of Commerce, Cattleman's Association: Historical Association, 

Alabama National Guard, Red Cross, and Boy Scouts. 

23. All documents relating to this question are available for 

copying in the Probate Office of Pickens County or Pickens County 

Board of Education Office in Carrollton, Al. One copy of said 

reports are enclosed with this Answer to Larry T. Menefee. 

Others are available for inspection and copying. 

24. All documents relating to this question are available for 

copying in the Probate Office of Pickens County or Pickens County 

Board of Education Office in Carrollton, Al. One copy of said 

reports are enclosed with this Answer to Larry T. Menefee. 

Others are available for inspection and copying. 

25. All documents relating to this question are available for 

copying in the Probate Office of Pickens County or Pickens County 

Board of Education Office in Carrollton, Al. One copy of said 

reports are enclosed with this Answer to Larry T. Menefee. 

Others are available for inspection and copying. 

26. See attached map. 

27. I have no knowledge of any formal proposal. 

 



  

PAGE SEVEN 
  

28. 1980 - approximately 34; 1982 - approximately 54. (These 

are estimates.) 

29. 1980 approximately 266; 1982 approximately 246. (These are 

estimates.) 

30a. None at present. Names and addresses will be provided if 

and when obtained. 

30b. N/A. 

    

30c. . N/A. 

wy, 
W. H. LANG, JR., PROB XRESOBCE 
  

STATE OF ALABAMA 

COUNTY OF PICKENS 

Before me, the undersigned authority in and for said County and 
said State, personally appeared W. H. LANG, JR., who after being 
first duly sworn, deposes and says that he is cognizant of the 
facts as set forth in the foregoing Answers to Interrogatories 
and Motions to Produce and he further states that the facts as 
stated therein are true and correct according to the best of his 
knowledge, information and belief. 

Given under my hand and seal this 3 / day of January, 1986. 

LP a 
NOTARY PUBLIC 
  

ATTORNEY FOR W. H. LANG, JR. 

DEFENDANT 

As Cor 
  

W. O. KIRK, JK. 
CURRY & ag 
P. O. BOX A-B 
CARROLLTON, AL 35447 
TELEPHONE: (205) 367-8125 

 



  

upon: 

PAGE EIGHT 
  

CERTIFICATE OF SERVICE 
  

Wanda J. Cochran 

Larry T. Menefee 
James U. Blacksher 

Blacksher, Menefee & Stein, 

405 Van Antwerp Building 
. OO. Box 1051 ; 

Mobile, AL 36633 

Terry Davis 
Seay and Davis 
732 Carter Hill Road 
P. O.:Box 6215 
Montgomery, AL 36104 

Julius L. Chambers 

Deborah Fins 

Legal Defense Fund 
99 Hudson Street 

léth Floor 

New York, New York 10013 

W. Edward Still 

Reeves and Still 

714 South 29th Street 
Birmingham, AL 35233 

Reo Kirkland, Jr. 

Attorney at Law 

P. O. Box 646 

Brewton, AL 36427 

P. 

I hereby certify that I have served the foregoing Answers 

A. 

by placing copies of the same in the United States Mail properly 
addressed and postage paid this 3 day of February, 1986. 

cH ay 

1986. 

  

W. O. KIRK, JR., ATTORNEY FOR 
PICKENS COUNTY DEFENDANTS 

 



  

PAGE NINE 
  

CERTIFICATE OF SERVICE 
  

I hereby certify that I have served the foregoing Answers on 

the other Defendants by 

record: 

Jack Floyd 
Floyd, Kenner & Cusimano 

816 Chestnut Street 
Gadsden, AL 35999 
(ETOWAH COUNTY ) 

D. L. Martin 

215 South Main Street 

Moulton, AL 35650 

and 

David R. Boyd 
Balch and Bingham 
P. O. Box 78 

Montgomery, AL 36101 
(LAWRENCE COUNTY) 

H. R. Burnum 

P. O. Box 1618 

Anniston, AL 36202 

(CALHOUN COUNTY) 

Alton L. Turner 

404 Glenwood Avenue 

P. O. Box. 207 

Luverne, AL 36049 

(CRENSHAW COUNTY) 

Warren Rowe 

P. O. Box 150 

Enterprise, AL 36331 
(COFFEE COUNTY) 

serving the following attorneys of 

Barry D. Vaughn 
Proctor and Vaughn 

121 North Norton Avenue 

Sylacauga, AL 35150 
(TALLADEGA COUNTY) 

James W. Webb 

Webb, Crumpton, McGregor, 
Schmaeling & Wilson 
166 Commerce Street 

Montgomery, AL 36101 

and 

Lee M. Otts 

Otts & Moore 

P.. O. Box 467 

Brewton, AL 36427 

(ESCAMBIA COUNTY) 

by placing copies of the same in the United States Mail properly 

addressed and postage paid this 3 day of Febrary., 1986. 

(20 oF 
  

KIRK, JR.5 ATTORNEY FOR 

PICKENS COUNTY DEFENDANTS 

 



Guedio... V20.899 

  

AFFIRMATIVE ACTION PLAN 

APRIL 22, 1980 

The Pickens County Commission Affirmative Action Plan and steps 
taken to implement this plan are listed below. 

a. Employment and Personnel Practices. The Pickens County 
Commission has adopted the policy of prohibiting discrimi- 
nation because of race, creed, color, national origin, sex, 
age, handicap, or political/religious affiliation in all 
aspects of its personnel policies, programs, practices and 
operations, and in all its working conditions and relation- 
ships with employees and applicants for employment; and to 
promote the full realization of equal opportunity in em- 
ployment through continuing programs of affirmative action 
in the region. 

  

b. Affirmative Action Program. The Pickens County Commission 
shall direct the implementation of this affirmative action 
program to promote equal opportunity in every aspect of em- 
ployment policy and practice including but not limited to: 
employment, upgrading, demotion or transfer, recruitment or 
recruitment advertising; lay-off or termination; rates of 
pay or other forms of compensation; and selection for train- 
ing, including apprenticeship. This implementation shall in- 
clude, but not limit, the following actions: 

  

a-a- A notice of The Pickens County Commission policy 
on non-discrimination in employment is posted in con- 
spicuous places, so as to come to the attention of all 
Pickens County employees and applicants for employment. 

a-b- Notification of employment opportunities, new 
positions, vacancies, promotion possibilities and train- 
ing opportunities shall be posted in conspicuous places, 
so as to come to the attention of all Pickens County 
employees and applicants for employment. 

c~c-~ Newspaper advertisements and other public announce- 
ments of employment opportunities placed by or on behalf 
of The Pickens County Commission shall state that the 
County Commission is an equal opportunity employer. 

c. Equal Opportunity Procedures 

a-1l. Equal Opportunity Counselor. / The Pickens County 
Commission shall designate / Equal Opportunity 

  

  

Counselor to provide advice to employees, or other per- 
sons, concerning their rights under the equal opportunity 
policy established in Section 1, and other pertinent 
laws and regulations; to conduct initial investigations 

 



  

  

as provided in this section; and to seek conciliation of 
such complaints with The Pickens County Commission. 

a-2. Equal Opportunity Hearing Officer. In appropriate 
cases, an Equal Opportunity Review Board shall be de- 
signated, a dis-interested person to conduct formal in- 
vestigations and hearings on complaints of discrimination 
brought in the manner provided in this section. 

Procedures for Conciliation, Investigation and Resolution of 
  

Complaints of Discrimination. 
  

a-l. Any person who believes that he has been discrimi- 
nated against by reason of race, creed, color, national 
origin, sex, age, handicap, or political/religion in 
connection with any personal action taken by or under the 
authority of The Pickens County Commission shall be ad- 
vised of his rights under this section, including his right 
to seek advice and conciliation through the Equal Opportunity 
Counselor. 

a-2. The aggrieved party shall, within 15 days of the 
action giving rise to his complaint, submit his complaint 
in writing to the Equal Opportunity Counselor. 

a-3. The Equal Opportunity Counselor shall conduct such 
* investigation as he/she deems appropriate in the circum- 
stances, and shall seek to conciliate the complaint with 
the appropriate person. 

a-4. If the Equal Opportunity Counselor is unable to ef- 
fect a satisfactory resolution of the matter through con- 
ciliation, he/she shall complete his/her initial invest- 
igation and forward his/her recommendations to the EOR 
Board. 

a-5. The EOR Board shall refer the report of the Counselor's 
initial investigation and his/her recommendations to legal 
counsel, who shall review the evidence in the file and the 

recommendations in light of the policy in Section 1, and 
pertinent laws and regulations, and submit his review and 
recommendations to the EOR Board. Such recommendations 
by legal counsel may include recommendations as to matters 
of fact, law, appropriate actions to be taken. 

a-6. The EOR Board shall review and initial report and 
recommendations of the EO Counselor (and legal counsel's 
review and recommendations thereon) and take one of the 
following actions: 

l. Render a decision in favor of the complaint and 
direct The Pickens County Commission to take necessary 
corrective action. 

fit J 

 



  

i a —————— Es — scrim Seaman ————— 

3. render a decision against the complainant and advise complainant of his right to a hearing. 
a-7. If the complainant requests a hearing, the EOR Board will refer the matter to a Hearing Officer, de- signated pursuant to Section a-3, for formal investij- 

a-8. The EO Hearing Officer shall conduct a hearing on complaint cases referred to him, to discover all perti- 

shall be given the opportunity to Cross-examine witnesses who appear and testify, Testimony will be under oath of affirmation. a Summary record of the Proceedings shall be made. 

"a-9. The Hearing Officer will weigh the evidence pre- sented before him/her, brepare findings of facts, con- clusions of law, and a recommended decision, including appropriate corrective action, if any is indicated. (The findings of facts, conclusions of law, recommended decision shall be forwarded to the legal counsel for re- view, recommendation, and subsequent submission to the EOR Board. ) 

a-10. The legal counsel shall review for legal suff- iciency the record of the Proceedings and the officer's findings of facts, conclusions of law, and recommended decision, and shall Prepare his advice and recommendation for the EOR Board for its final decision. 

a-1ll. The EOR Board shall review the record of the pro- ceedings, the hearing officer's findings of facts, cone clusions of law, and recommend decisions (and the legal counsel's advice and recommendation thereon), and make a final decision on the complaint. Such decision of the EOR Board shall be in writing, shall determine whether discrimination has occurred, shall contain findings of 

—_3 

 



  

fact and reasons for the decision, and shall direct 

such remedial action as it deems to be required to 

effectuate the policy in Sectionl. 

a-12. A copy of the decision shall be furnished to the 

complainant. 

Quantitative Equal Employment Opportunity Goals for the 

Agency. 

It is the goal of this agency to ultimately have a staff 

that represents a typical cross-section of the region's work 

force particularly as to racial minority, sex and age in both 

professional and sub-professional positions. 

  

fl 

 



   Brown Priating Ca.. Montyomeyy, Alsbama Crenlisn, Is a 

EXPENSE ACCOUNT OF CANDIDATE 

(To Be Flled Within 1§ Days After the Election) 

NAME WILLIAM H.- LANG Rr mmm = ene ge tae ig eben on He 

MAILING ADDRESS ©. Ps 0. BOX 288 «= wo oii... 2» 

a Lat RAR REEORY 4 ALABAMA. vo peo CR CEE 

Pursuant to Title 17, Sections 278, 279 and 400 of the Code of Alabama as amended, defining the Corrupt 
Practices Act, | herewith submit a full, correct, detailed and itemized statement of all expenses made directly 
or indirectly in sums over $5.00 and of all obligations, debts, or Habilities assumed or Incurred at the time of filing 
this statement, together with the names of all contributors of amounts in excess of $10.00, with the amounts given 
by each, and a list of all gifts, loans or coptributions made in connection with my campaign as a candidate in the 

  

  

  

  

Election held on Tuesday, ._ ______. SEPTEMBER .Z ___.__ __ 1882 _, for the office of 
PROBATE JUDGE 

a Ea (Caer meotOflice. 2-7 irr 
I FE 

a CONTRIBUTIONS Te i 

WILLIAM H. LANG SR, iE 450.00 
William H. lang dri 1! 3230.94 : 
ROBERT E. LANG [3% 200.00 : 
HELEN HILL 100.00 oy 
BETTY PATE 50.00 Rd 
RICHARD STOKES 100.00 
LAVERT STOKES 166.00 

TOTAL _.__ 430,94 

EXPENSES INCURRED | 
| 
| 

WRAG | 860.04 ’ 
DRAKE PRINTERS © 1834,34 
WEST ALABAMA PRINTERS | 65.00 
PICKENS COUNTY HERALD | 365.00 
PICKENS COUNTY ADVERTI. 138.90 
MISSISSIPPI WELDING 113.40, 
PETROL. 4184.26 

DEMOCRATIC PARTY 500.00 
SCHOOL BOOSTER CLUgS 50.00 

| 
| - 

| 

| 

Ps —~ a CAL 
| — ~~. 

Signature of Candidate oe ——— Rd or 
{ 
| 
| 

STATE OF ALABAMA, COUNTY OF ___ PICKENS... ... .. _._... 
[1] I 

. | y Lk : 
I, 50 lb lo 4 Mes : Clr diene 4 Notary Public in and for said county in said 

! 

  

| 

state, hereby certify that we mmmrne WILLIAM H 5 “LANG Ry t= woeaem sa semmt +3 commer om vatwms s+ onions mnnm: mn  swenemnes + WHHISE 1H 1S 
signed to the foregomg statement, who is known to me, he personally appeared before me on this day and being 
first duly sworn deposes and says that the statement hereinabove made is in all respects true, and that the same 
15 a full and detailed statement of all monies, securities or equivalents for money coming under the continl or cus 
tody of said committee and by it expended directly or indirectly. 

TNS 
Swarn to and subscribed: before me this Ao. day of Ag d LN {Sa lea 

1 IEEE Sh i \ : ¥. 

| . Clon a rs . Notary Public 
) 

[} 

Title 17§ 400. Expense account of candidate must he made and filed.- -Any candidate for any office elected by the votes of 
mote than one county, except candidates for the office of state senate, shall file with the secretary of state, and every candidate 

tor a county office and candidates for the state senate and house of representatives shall file with the judge of i of the 
county or counties in which said election is held, a sworn statement, setting out and itemizing the expenses of his canvass in such 
election within fifteen days after such election, and any candidate who fails to so file und swear to such statement within said 
funy, shall be guilty of a misdemeanor, aud, on canviction, must he fined not less than one hundred nor mare than one thousand 
dollgesit sta rT ir 3 

  

1 rl Co PO PTY wri ol Bp spans PE oh TRIG RORY SEA Sh J LAL ne Sa 3s 3 a a no 34 mi a Ei Kn Yo se Safe yeas Se & wt mt i 1 A mE 

 



   
Awa Fainting Ca. Muatyumery. Alshaiie 

EXPLNGE ACCOUNT OF CANDIDATL 
(Tq He Filed Within 1§ Days Altgy the Llaction) 

NAME 

  

Pursyunt to “Title 17, Sections 270, 270 und 400 of the Code of Alabama us aw 
Poactices Ack | herewith submit a full, correct, detulled and itemized statement « or indirectly In sums over sri and of all obligation, debts, or Hubilities assumed or neared at the thoe of (ilu this statement, together with the names of sll contributurg of Mnounts In excess of $10.00, with the simmons pave hy cach, and a lat of all Kilts, loang ar contributions made 1g ghmtiun with my campaign as a candidate 1a the 

Election held on Tuesday, 2. SET. 28 _—y CL SH | 82. for the office uf hath ol Ko 

sel rent ons ctemeshtenaiete. VRCIOALE. “XUDOE 
(Enter Name of Office) 

wnded, detinlng the Conran 
of all expenses made divear 

i 

oo Bh  — 

| CONTHIBUTIONY 3 
| fi 

Da. Lwuam &. Hw 80605 
Lotetiam KLANG TR BB4% i Ap 
Rogert E LAWS zoo | 
RedaR 0 Stokes 100% po 
LAUVERT STYowE S 1e g%. ti 
MALCOLN LANG \ OOS ti 

Bevty Poi * 0% Andry 

Elen Hue los x 
RACUHARD LOA 2.5% 3 igh oy 

R.E Frid IxERS RO0R CC  10TAL 20H = 

EXPENSES INCURKED 

Pe be, County edd 3 £2 

LORAG ISR 
LaRA ¢, 363% 
Xe ‘ Plus [Ae 
oRDO T Oc 

Gendo LE Tose 
203qQ bs 

wea ec, bQA2 .2¥ 
Pie, Cas lant 1S .00 

NT ie 4 372.90 
MISSLS3i pl welds 113. Ho 

LN PRWTIVG 11 D100 
o-MEQL g 263.40 

Fra) Hoe | 25. 00 ! | he hous 12S oz 101AL SSE. 29 
S60 o 

beme fond Signature of Candidate 2A : 2 AJ, = asin, 

STATE OF ALABAMA, COUNLY OF 

  

  

    
    

   
EY vom mmm nem i NOGCY Pubic in and for sod county we tan 43 . ¥ ~ - . s hg trmive 

state hereby ‘certify that i ed lin & Jar ! i 0) ’ ( 18 - Rie ow whi: bl-bp a, Mponed to the foregoing statement, who 1s known to me, he pevsinally”ippearcd before sae on this day and beng 
fab duly sworn deposes and spys that the statement hereinabove nde 1 in all vespects ae, and that the san Sy oat ea ful) and detained statement’ of all immmes, securities or equivalents lor money conning uder thee vonbicd or cue 
body ol sand comupnttes ayl hy it expended divectly or mdivectly 

i ' —— dr od SEE ; 3 / 
Sworn bo aed subscribed before pe th f day a ret 

? ‘ \ 
Vopr Sh an OATS Ln bear 2 f 2 

et i mn Tp fy pet em er —— owe te — 
Title 174 400. Lapense account of candidate niust he made and filed. 

tte than one county, except camddobales 

ar 2 

  

    Notuwiry able 

  

    

Any candolate for Buy ollie elected by the voles of 
fore thie lice of Sante neste, shit pale swath the secietnry of Slate und every enntudale for a county iothiee und candbitites for the state senate and hou: e olf representatives shill file with the judge of prohate of the 

Coulton Contes ae whieh 0a election 18 held, 0 sworn statement, seth! cut and iteanozing the expenses of Wis canvass In Such election within Jlltaen Jays altar such election, ind wny candidate who fails be so Ole aid swe nt to such Automent within auld Ling, phigh) hy gaily of, w iadenenpor, snd, on conviction, most be Ged net bess than one biandeod nor wine then one thotausal dotlain ™ 
8 haa bs tau Wid cof eed 

 



  

   
vr 

< ; 
Afown FPantiug Cu. Munlyomery, Alabama’ “Reema =. hy e& (& Envela Ly) 

EXPENSE ACCOUNT QF CANDIDA’ SL 
(Yo Me Filed Within 1§ Daye Alte the Election) 

NAME. .. .. HB NILANG JR | YY 7 Sr tp se py 4 W110 lee Ee IG oY a GS een 
anna ‘ ” gid ' 1 Bo 

MAING AES PQ Bop. al. ih 

Pursuant fo Title 17, Sections 270, 270 and 400 of the Code of Alabamu as mnended, detining the Cova 
Peactices Act | heyewlith submit a full, corvect, detailed and lemlzed statement of all expenses pide divedtly 
or indirectly in stuns over $6.00 and of all obligntions, debts, or Habillties assumed or Incaveed ut the time of filo 
this statement, together with the names of all contributors of pinouts In excess of $10.00, with the amounts poen 
hy each, pod a lat of all gifts, loany of epntelbutiong made In connection with my campulgn us a candidate mn the 

Election held on Tuesday, MOY 2 ver eiall §2; for the office of 

CLIERIRNIE tie ML 55] i TE SF Si 

re ——— 

(Enter Name of Office) by el 
: : : ! | bo im ; 

FI CONTRIBUTIONS | te Yee 
TU PARLCS 50) WE Hite Bf! 
ABT 2 ob, 2 
CARL CiMDPLeR. 25° 4 ii EA id 

RET fe pens ER 
Tehn RuIteye So ef Qe % nt : 

Bon ay Wis pe 700°® Hecenr Ket! 409 SET 

Licwnro ©allee 26%: ATE 94 Le ee ccuc BAvis! soro lu 
9 [ 

! 

Orneic MEDAWRL J00 22 
SAM PA7T- §o=° Keep rtoerc Sco ea f a, 29 

an 3 I'O'TAL - MEET Ae @ driers © SOE 5 
Srweare mio Jo °° EXPENSES 1GYNRLD 
Pea as 

WER C- f2t. 0 Mapa ~~ JF YD 

An ws Cour 0 Say + Sues 300.05 

para 219. 4 
house R 349.00 4 Kallay; $8.00 
IMAGES -+ 262,00 Qovocialic nt 00.00 
Coro ATHLelre 30,00 di 

Y ART l6 {00 

Pralce 2 3d0 
Dewars < Pee 

Geie Sp. CFSE 

- 

TOTAL y £29.9/     
Signature of Candidate . 

| 

STATE OF bse Sn 

J land : EF! wd wean as ses snide aimee i NOGEY ube Ss dnd fon sould corny an Las 

plate, heyeby certify that A . / h v * 
, he 

IW... FResce ro Te 

  

    
b scrion Whose dine a. 

sigoed Lo the foregomg statement, who as know to previonally appeared Lefore me on this day wid beng 

fival duly sworn depases and says that the statement hevcinabove made is in all respects tae, and tha the sao 
in a ful) pnd detailed statement of all wonies, securities oe equivalents for lnoney coming under the coticd me one. 
body of said committee and hy it expended divectly or indiveetly 

Hwhker ds I= A day of ~. 

| TY PW y Tl 

ee emer mene mee A300 Of Probate... A yt 
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wate than ope county, except camldidites for the allie of stile senate, shall lille «sts the gsvnetesy 

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clecpion within (teen doys afier such election. wid any camlidatlr who fails 1 wo file Seed 30008 lu th Malrwdt ed wotiun 2a! | 
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DEMOCRATIC RUN-OFF ELECTION 
SEPTEMBER 28, 1982 
  

FOR GOVERNOR—(Vote for One) 

CC ) GEORGE McMILLAN 

{ =) GEORGE C. WALLACE 

FOR ASSOCIATE JUSTICE OF THE 
SUPREME COURT, PLACE NO. 3 

—(Vote for One) . 
{_.) OSCAR W, ADAMS 
(1) JIMZEIGLER 
FOR STATE AUDITOR—(Vote for One) 

y JANCOORK. ~~ = ~~ 5 i 

  

  

() KAY IVEY 
FOR COMMISSIONER OF 
AGRICULTURE AND INDUSTRIES 
—(Vote for One) 

(_) ALBERT McDONALD 

( 3 BUBBA TROTMAN 

FOR JUDGE OF PROBATE 

—(Vote for One) REI 

L: ) BILLY R. (Bill) COOK hits & 

WILLIAM H. LANG, JR. 

FOR MEMBER PICKENS COUNTY 

COMMISSION, DISTRICT NO. 2 

—(Vote for One) pr 

( ) GARVIN BRYANT a 

"= JAMES H. CORDER 

FOR MEMBER PICKENS COUNTY 

COMMISSION, DISTRICT NO. 4 

—(Vote f for One) : pr EA 

{ 7) JERRY T. FITCH 

  

  

  

  

( ) BOBBY C. WINDLE 

this ballot 1 do pledge myself 10 abide by the 

  

  

“By casung 
result of Ship Primary Run-Off Election and to aid and support 

all the Nominees thereof in the ensuing General Election.’ 

  

FOR THE BRIGHT FUTURE 

PICKENS DESERVES! 
Pd. Pol. Adv. by William H. Lang, Jr. Reform, Alabama 

 



   JOIN THE 

“PROUD PICKENS’ PEOPLE” 

Wigianehy | Sample Ballot 

   

    

  

    

  
  

  

  
  

    

        

  
    

  
  

    
  

    
    

  
  

  

        

  
      

    

    
  
  

    

          

  

    
  

  
  

    

  

  

  
  

  
  

  

      

  

  

  

        
    

      
  
  
  
      

          
  

      
  

        

  

  

            

  

  

  

    

        

    

  

      

          

    

    

  
  

  

    

   

  
  

    

  
  

  

      

  

  

      

Ma 0 al) os 

FOR 

PROBA 
| 

HONESTY BATE J UDGE wa INDEPENDENT 

Names of ALABAMA ALABAMA 

Offices To 
DEMOCRATIC REPUBLICAN 

Be Voted For ® (> 

FOR GOVERNOR—(Vote for One) () GEORGE C WALLACE () EMORY FOLMAR 

FOR LIEUTENANT Ser for One) ym Baxeey ir 

TERE |) oven 
FOR ATTORNEY GENERAL (Vote for One) () CHARLES A. GRADDICK 

FOR STATE SENATOR, DISTRICT NO. 30—(Vote for One) () EDWARD (Big Ed) ROBERTSON 

FOR STAT REPRESENTATI, DISTRICT NO. 88 () PHIL POOLE 

FOR STATE REPRESENTATIVE DISTRICT NO. 89 () EARL MITCHELL () STEVE EMENS 

FOR CHIEF ISTIcE OF THE SUPREME COURT ( C.C.~Bo" TORBERT, IR 

a SUPREME COURT, () HUGH MADDOX () HARRY LYON 

ET SUPREME COURT, () SAM BEATTY 

FOR SS300TE MiSTEe OF Thi SUPREME COURT, | () OSCAR W. ADAMS () THOMAS J. “Tom" HAYDEN 

"FOR COURT OF CIVIL APPEALS JUDGE~(Vote for One) () ROBERT P. BRADLEY 

ER OUR OF le ens . () JOHN PAUL DeCARLO 
: 

a (RL 
me) aor on 

FOR SECRETARY OF STATE—(Vote for One) () DON SIEGELMAN 

 FORSTATE E TREASURER —(Vote or Gre) () ANNIE LAURIE GUNTER 

FOR SATE AUDITORY for Ors) 1) an cook 
FOR COMMISSIONER OF AGRICULTURE AND INDUSTRIES () ALBERT McDONALD 

dh SCAGECIMNITION FE. 1 Er) LYNN GREER 

FOR PUBLIC SERVICE COMMISSION, PLACE NO. 2 () JIM FOLSOM, JR 

a CIRCUIT COURT JUDGE, 24th JUDICIAL CIRCUIT () CLATUS K. JUNKIN 

FOR CIRCUIT CLERK, PICKENS COUNTY (Vote for One) | () JAMES E FLOYD 

"FOR JUDGE OF PROBATE (Vote for One) OQ WILLIAM H. LANG, JR. () DEBORAH CHANDLER ( ) JAMES H. (Doc) ASHCRAFT 

SE a () LOUIE C. COLEMAN 

yous rca comsn || () aun orn 
FOR MEMBER Fos a COMMISSION, () JERRY T. FITCH () WILLIE L. WRIGHT 

“im | 
LL diy EDUCATION MEMBER, () JAMES . (Buy) NOLAND | 

  

  
  

    

      
FOR THE BRIGHT FUTURE PICKENS DESERVES! 

Pd. Pol. Adv. by William H. Lang, Jr., Reform, Alabama 

 



Qunetosn la. 13h 

  

Pickens County Needs 

1. JOBS for its young people. 

2. A balanced budget through 
responsive, mature management. 

3. No increase of taxes on Pickens 

Countians. 

4. Strong, clear, concise leadership. 

5. Adirect plan of development that 
assures all our citizens a secure 
bright future. 

6. Experience in working with State and 
Federal Government. 

7. Honest Government for all. 

8. A fulltime, hard working Judge with a 
strong conviction to a County he 
loves. 

VOTE LANG 

 



  

  

WHY BILL LANG FOR 
YOUR PROBATE JUDGE 

| want the job. 

| consider it full time. 

| can deliver strong clear leadership 

ar
 

Oe
 

i 
pt 

ay
 

My experience in Montgomery will 

help Pickens County. 

5. |love Pickens County. 

6. | believe the best people in the 

world live in Pickens. 

7. My management and engineering 

background will provide the plan- 

ning and organization talents 
needed for the County to change 
directions. 

8. My farm up bringing gives me the 

horse-sense to apply my talents as 

Pickens County folks want. 

  1 ll i RR x Sb hh 13 o Aaa i ests Boil . i WEIRD or 

  

Brad, Annette, Bunky, Bill 

Subject to the Action of the 1982 Democratic Primaries 

WILLIAM H. LANG PICKENS COUNTY" 
Qualifications 

36 years old. 
. 

Married Annette Hill of Carrollton. 

Two children: William H. Lang Ill (Bunky) 

12; Bradford Hill Lang (Brad) 6. 

University of Alabama graduate in Indus- 

trial Management. 

Five years working with leaders of Mont- 
gomery County as executive with Boy 
Scouts of America. 

Worked directly with the State Legisla- 

ture and Governor's office as Director 

of Commission on Ingovernmental 

cooperation and national representa- 

tive to the Council of State Govern- 

‘ments. 

Five years Industrial Engineer and Direc- 
tor of planning, research and evalua- 

tion, Bryce State Hospital. 

Chairman of Board 1st United Methodist 

Church of Reform. 

Vice President of North Pickens 

American Red Cross. 

Past President of Rotary Club of Reform. 

Member Alabama Farm Bureau. 

Captain in the Corps of Engineers, U.S. 

Army, Alabama National Guard 

(16 years). JR. 

Farm owner, operator. 

Chamber of Commerce. CANDIDATE FOR YOUR 

Past member Society for Advancement 

i anscemen: PROBATE JUDGE 
Born and raised in Pickens County. 

Member of Boy Scouts of America, Join The 

sustained member (Eagle). Proud Pickens’ People 

  
WILLIAM H. 

     

® fine | Pd. Pol. Adv. by William H. Lang, Jr., Reform, AL 

 



 
 

 
 

 
 

 
 

 
 

    

    
 
 

  
 
 

 
 

  
  

  
  

  

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