Defendants' Response to Interrogatories, Martha Kirkland

    INTHE UNITED STATES DISTRICT. COURT FOR THE 
MIDDLE DISTRICT OF ALABAMA 

NORTHERN DIVISION 

JOHN DILLARD, ET ALL, 

Plaintiffs, 

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

CRENSHAW COUNTY, ALABAMA, 
ET AL, , 

Defendants. 

RESPONSE TO INTERROGATORIES BY DEFENDANT, MARTHA KIRKLAND 

Defendant, Martha Kirkland as Probate Judge of Escambia County, 

Alabama, responds to plaintiff's interrogatories as follows: 

1. A. William America. 

(a) School board place number four. 

(b) 1976. (Primary May 4th) 

(c) America lost. 

B, + A.J. Middleton. 

(a) County commmission District 4. 

(b) 1980. (Primary in September) 

(c) Middleton lost. 

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

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

Chairman, County Commission. 

3. Not applicable. 

 



  

4. 

belief 1 

Chairman, 

5. 

6. 

T. 

regulations 

belief I 

Wiggins, 

8. 

regulations 

belief 

Wiggins, 

9. 

regulations 

belief I 

Wiggins, 

10. 

regulations 

  

I 

I have no personal knowledge, however, on information and 

adopt the answer to this question submitted by Devon Wiggins, 

County Commission. 

Yes. 

(a) Harris v. Graddick, Civil Action Number 84-T-595. 

(b) ‘United States District” Court, Middle District’ of 

Alabama. 

(c)~ April 31st, 1984. 

(d) Class action for appointment of minority citizens as 

poll officials. 

Not to my knowledge. 

I have no personal knowledge of ordinances, rules or 

of the county commission, however, on information and 

adopt the answer to this question submitted by Devon 

Chairman of the County Commission. 

I have no personal knowledge of ordinances, rules or 

of the county commission, however, on information and 

adopt the answer to this question submitted by Devon 

Chairman of the County Commission. 

I have no personal knowledge of ordinances, rules or 

of the county commission, however, on information and 

adopt the answer to this question submitted by Devon 

Chairman of the County Commission. 

I have no personal knowledge of ordinances, rules or 

of the county commission, however, on information and



  

belief I adopt the answer to this question submitted by Devon 

Wiggins, Chairman of the County Commission. 

11. Not to my knowledge. 

12. A. ‘Chairman of the County Commission. 

(a) Devon Wiggins, caucasion. 

(b) January 17th, 1977 to present. 

B. District one County Commission. 

(a) William Cook, caucasion. 

(b) January 16th, 1967 to present. 

Cs District two County Commission. 

(a) James E. Evans, caucasion. 

(b) Janaury 15th, 1985 to present. 

D. District three County Commission. 

(a) Sammy McGowin, caucasion. 

(b) January 16th, 1979 to present. 

E. District four county commission. 

(a) Weldon Vickrey, American Indian. 

(b) January 15th, 1985 to present. 

F. Probate Judge. 

(a) Martha Kirkland, caucasion. 

(b) October 1969 to present. 

G. Circuit Clerk. 

(a) James Taylor, caucasion. 

(b) January 1971 to present. 

H. Sheriff. 

 



  

13. 

(a) 

(b) 

(a) 

(b) 

(ec) 

(d) 

(e) 

CE) 

(g) 

(h) 

(1) 

(J) 

(k) 

(1) 

(m) 

(n) 

(0) 

(p) 

Timothy Hawsey, caucasion. 

January 1983 to present. 

Note attachegqd report. 

None. 

See attached report, 

See attached report. 

Attached. 

ADC Forum Group meetings at Southern Normal ang Paris 
Motel 1970 ang 1982. I was introduced ang spoke, I 
do not remember who else was there, 
McCall's School ang Escambia High School. I paid for 
@ cake at McCall's school in 1970 and Spoke, I do 
not remember who else was there, 

At Southern Normal I was asked in 1970 about hiring 
Practices for blacks, I promised to give every 
Consideration for qualified black applicants, 
I do not remember, 

I made an appeal to all voters. 

No campaign staff, 

Not applicable, 

I doénot remember, 

I'do not remember, 

No endorsements that I can recall, 

All current reports ior campaign expenses are 
attached. Prior campaign expense reports are not 

 



  

retained, 

14, Undersigned is Judge of Probate, The campaign reports are recorded in the Probate Judge's office. 
15. I have No personal knowledge, however, on information and belief I adopt the answer to the question Submitted by Devon Wiggins, Chairman Of the County Commission, 

16. 1 wnow of no election characterized by racial polarization, 17. Various candidates have sought and received the ADC backing for many years. J know of no elections ip Escambia County that have been Characterizeg by racial bolarization, 
18. This depends upon your definition Of the "recent past", The School system to my knowledge in"the recent past has been racially integrated. 

20. 87 ‘do not know the answer to this question. 
21. I have No personal knowledge, however, On information and belief 1 adopt the answer submittegd by Devon Wiggins, Chairman of the County Commission, 

22+ I 'am.a member of the First Methodist Church, Escambia County Farm Bureau, Escambia County Cattlemen's Association, Escambia County Association for Retarded Citizens, Escambia County Mental Health Association, Escambia County Cancer Society, Southwest Alabama Kidney Auxilliary, Delta Kappa Gamma, ang the University of Montevallo Alumni Association, 

 



  

23. The county school system is an agency of this State and we do 

not maintain this information. 

24. The county school system is an agency of this State and we do 

not maintain this information. 

25. The county school system is an agency of this State and we do 

not maintain this information. 

26. On information and belief I adopt the answer submitted to 

this question by Devon Wiggins, Chairman of the County Commission. 

27. I have no personal knowledge of any studies, reports or 

proposals regarding changes in the county commission or school board 

since 1930. On information and belief I adopt the answer submitted to 

this question by Devon Wiggins, Chairman of the County Commission. 

28. Attached is a list of "all poll officials for tne primaries 

and elections conducted from 1980 through 1985. The race of each is 

marked thereon. 

29. Attached "is a list of all poll officials for the primaries 

and elections conducted from 1980 through 1985. The race of each is 

marked thereon. 

30. Not known at this time. 

~~ 
p / 

/ / / msgramin lig” a ; / 

/ rg A << Z Z 

Noes We: Tell 
  

MARTHA KIRKLAND 
Judge of Probate 

SWORN to and SUBSCRIBED before m his the LO day of 
1986. ’ 

£ Rene 

  

  

  

NOTARY PUBLIC 

 



  

  

JAMES W. WEBB 
Attorney for Martha Kirkland 

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, Martha Kirkland, have been mailed to 
Larry T. Menefee, Esquire, James U. Blacksher, Esquire and Wanda J. 
Cochran, Esquire, Blacksher, Menefee & Stein, 405 Van Antwerp 
Building, P.O. Box 1051, Mobile, Alabama 36633, Terry G. Davis, 
Esquire, Seay. & '‘Dayis, 732" Corter “Hill i Road, P.O. 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.O. 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 
36101, W.0." Kirk, dr., Esquire, Curry | & Kirk, Phoenix Avenue 
Carrollton, Alabama 35447, Barry D. Vaughn, Esquire, Proctor & Vaughn, 
127 N. Norton Avenue, Sylacauga, Alabama 35150, H.R. Burnham, Esquire, 
Burnham, Klinefelter, Halsey, Jones & Cater, 401 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 copies 
of the same in the United States Mail, postage prepats this the AO 
day of February, 1986. 

  

‘James W. WebD