Correspondence from Chambers to Lorson

    ,.. !'

IN THE SUPREME COURT OF THE UNITED STATES

OCTOBER TERM, 1985

No.83-I968

LACY H. THORNBURG, ET AL., APPELLAN+S,

v.

RALPH GINGLES, ET AL., APPELLEES.

On Appeal From the United States District Court
For the Eastern District of North Carolina

UOAION FOR LEAVE TO FILE OYERSIZED
PORTION OF JOINT APPENDIX

Appellants and Appellees jointly move for leave to file an

oversized portion of the Joint Appendix. In support of this

motion, the parties say:

I. Thornburq v. Ginqles is an action pursuant to Section 2

of the Voting Rights Act of 1965e ds amended, 42 U.S.C. SI973

challenging the districting of the North Caroiina Gerlerai

Assembly.

2. At the trial of the matter, plaintiffs presented

courtroom sized maps (approximately 30" x 42") of each

legislative district in guestion and of the apportionment of the

House of Representatives and Senate as a who1e. These maps, and

8-L/2" x ll" reductions of them, hrere received into evidence as

plaintiffs' Exhibits 2-I0.

3. The parties believe that having these maps available

would be helpful, if not essential, to this Court's

understanding of the matters before it.

4. These maps cannot be reduced to 6-L/8" x 9-L/4", as is

reguired by RuIe 33(d), and remain legible. Furthermore,

because each map has an acetate overlay, they cannot be folded.



9

5. The Clerk of the United States District Court for the

Eastern District of North Carolina did not forward any exhibits

as part of the record in this case. Appellees offer to submit

the courtroom sized originals to the Court, in accordance with

RuIe 32, should the Court so reguest.

The parties therefore reguest leave to file a separately

bound volume of the Joint Appendix which contains these maps and

the legend for eachrplaintiffs' Exhibits 2-10, which is 8'l/2" x

I1" in dimension

rhis trl" f 7A- day of september, 198s.

LEONARD & MCGUAN, P.C.
900 17th Street, N.W., Suite 1020
Washington, D.C.20006
(202) 872-109s

Attorneys for Appellants

Suite 730 East Independence Plaza
951 East Independence Boulevard
Charlotte, North Carolina 28202
( 704 ) 37s-8451

Attorney for Appellees

Respectfully submitted.

HLEEN HEENAN McGUAN

FERGUSON, STEIN, WATT, WALLAS &

ADKINS, P.A.



CERTIFICATE OF SERVICE

I hereby certify that on this 18th day of septemberr l9S5

I sent via First Class U.S. Government Mail, a copy of the

foregoing I',lotion f or Leave to File Overs ized Portion of Joint

Appendix to the following:

Julius Chambers
Eric Schnapper
C. Lani Guinier
NAACP Lega1 Defense and Educational Fund Inc.
16th Floor, 99 Hudson Street
New York, New York 10013

LesIie J. Winner
Ferguson, Watt, Wallasr & AdkinsT P.A.
951 S. IndePendence Blvd.
Charlotte, North Carolina 28202

C. Allen Foster
Kenneth J. Gumbiner
Foster, Conner, Robson & Gumbiner, P.A.
104 North EIm Street
Greensboro, Ilorth Carol ina 27 401