Oklahoma City Public Schools Board of Education v. Dowell Brief in Opposition to Certiorari

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January 1, 1986

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Legal Department General, Lani Guinier Correspondence. Correspondence from Lani Guinier to Judge Emmett Cox Re: United States v. Albert Turner, United States v. Hogue, 1985. 3d0462d3-e792-ee11-be37-6045bdeb8873. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/89dab331-42bb-4efe-85c5-b2388a806344/correspondence-from-lani-guinier-to-judge-emmett-cox-re-united-states-v-albert-turner-united-states-v-hogue. Accessed August 19, 2025.

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    ApriI 19, 1985

Hon. Bmmett Cox
District Judge
United States District Court
Southern District of Alabama
Federal Building
113 St. Joseph Street
IlobiIe, AL 36652

Re: United States of America v. Albert Turner et al
-000I4; United States of America v.

Spencer Hogue, Jr., Ct. No. 85-00025

Dear Judge Cox:

On April 8, 1985, counsel for Spencer Hogue, Jr., defen-
dant in the above-noted matters, submitted a number of pretrial
motions in United States v. Hogue, Cr. No. 85-00025. On April
17, 1985, c mber of pretrial motions in
United States v. Turner, €t &1., 85-00014. With reference to

se be advised of the following:

1. Mr. Hogue hereby adopts the following motions
filed in United States v. Turner, Cr. No. 85-00014, as
motions i , Cr. No. 85-00025:

Motion to Suppress Evidence, etc.

Motion to Vacate or I'lodify Portion of Order
dated February 8, 1985, to Permit Defendant
to Participate in the Preparation of His
Defense

2. In support of 1"1r. Hoguers Motion in Cr. No. 85-00025
to Dismiss the Indictment, for Discovery and for an Eviden-
tiary Hearing, Mr. Hogue adopts pp. 6-76 of his Motion to Dis-
miss the Indictment as the Product of an Invidiously Selective
and Vindictive Prosecution, etc., the Exhibits (both sealed
and unsealed) to said Motion, and his Motion for Leave to File
Exhibits Under SeaI in Cr. No. 00014.

he
his

NINETY NINE HUDSON STREET (212) 219-1 900 NEW YORK, N.Y. 10013



Hon. Bnmett Cox
April 19, 1985
Page 2

3. In support of !1r. Hogue's Motion in Cr. No. 85-00025,
to Transfer Tria1 to the Northern Division, Elt Selma, Dlr.
Hogue adopts pp. 1-11 and Exhibit A to his it{otion in Cr. No.
85-00014 to Transfer the Trial to the Northern Division, at
SeIma.

4. Ivlr. Hogue adopts in Cr. No. 85-00025, the Motion of
Evelyn Turner in 85-00014 for Transfer Within Districts.

5. Mr. Hogue adopts in Cr. No. 85-00025 the l{otion for
Bill of Particulars filed by Albert Turner in Cr. No. 85-
00025.

Sincerg.\y, /)/){) il
l- - N*t,+-' rQllnazr-tt ryz
C. Lani Guinier
Attorney for Spencer Hogue, Jr.

CLG: deh

cc: Hon. Patrick H. Sims, Magistrate
Hon. John V. OrBrien, Clerk
Hon. E. T. Rolison

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Oklahoma City Public Schools Board of Education v. Dowell Brief in Opposition to Certiorari

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