Answers to Plaintiffs' Interrogatories and Motion to Produce by County Commissioner Jerry Fitch
Public Court Documents
February 10, 1986

11 pages
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Case Files, Dillard v. Crenshaw County Hardbacks. Answers to Plaintiffs' Interrogatories and Motion to Produce by County Commissioner Jerry Fitch, 1986. 43f1e03a-b9d8-ef11-a730-7c1e527e6da9. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/ef7185f5-4490-47ca-926b-eeedacbe5100/answers-to-plaintiffs-interrogatories-and-motion-to-produce-by-county-commissioner-jerry-fitch. Accessed July 07, 2025.
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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, N a a N t ” N t ” N a N t ” “m at “i t? “ u i ? ET AL, DEFENDANTS. ANSWERS TO PLAINTIFFS' INTERROGATORIES AND MOTION TO PRODUCE BY JERRY FITCH, PICKENS COUNTY COMMISSIONER Comes Jerry Fitch, Commissioner, Pickens County and for answer to Plaintiff's Interrogatories and Motion to Produce Documents says as follows: l. Reverend James Corder la. County Commissioner lb. Don't know. lc. He was defeated. 2. I do not know of any. 3a. N/A 4a. Pickens County Hospital Board, Pickens County Water, Sewer and Fire Protection Authority, Pickens County Industrial Development Board, Pickens County Library Board. Commissioners review all applications and look at all qualifications. See additional response in answers of Pickens County Probate Judge. 4b. See response in answers of Pickens County Probate Judge. 4c. See response in answers of Pickens County Probate Judge. 4d. See response in answers of Pickens County Probate Judge. PAGE TWO 5. See response in answers of Pickens County Probate Judge. 5a. Corder vs. Kirksey. See additional response in answer of Probate Judge. 5b. United States District Court for the Northern District of Alabama. 5c. See response in answers of Pickens County Probate Judge. 5d. See response in answers of Pickens County Probate Judge. 6. Do not know of any. 7a. I do not know of any. 7b. No. 8. N/A 9. See Affirmative Action Plan that was adopted by Commissioners on April 22, 1980. A copy of which is attached to Probate Judoets Response to this Question. 10. I am not aware of any. 11. See response in answers of Pickens County Probate Judge. l2a.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.See response in answers of Pickens County Probate Judge. l3a.See attached records of expense account. l3ai.See attached records of expenses account. 13b. None 13c. None PAGE THREE 13d. WRAG and WAQT Radio Stations, PICKENS COUNTY HERALD newspaper, PICKENS COUNTY ADVERTISER, newspaper. Also see attached list of expenses. 13e. See attached card and sample ballot. 13f. None. Made public campaign appearances with blacks and whites attending at the following places: Pickens County Courthouse Square, Carrollton; Political Rally at Aliceville City Park; Political Rally at Reform City Park. 13f1.. R/3 13f2. N/A 13g. None. 13gl. N/A 13g2. N/A 13h. Promised to work toward constructing a road to connect Beaver Town and Hinton Town Communities. 13i. I" do not recall. 133. I appealed for all the people's votes. 13k. None. 13kl. Six (6) whites and seven (7) blacks. 13m. J. S. and Lucille Gosa of Aliceville, AL, I. V. Prude, Carrollton, AL, Lemon Forte, Aliceville, AL, Son and Hattie Cockrell, Ethelsville, AL, Frankie L. Hinton, Ethelsville, AL. 13n. None. 130. None in my possession; endorsed only by the Democratic Committee and Party. PAGE FOUR 13p. None. 14. Jerry Fitch, Ethelsville, 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; all records in my custody or Chief Clerk's custody or Verbon Atkins' custody or Probate Judge's custody. 15. No. 15a. Corder vs. Kirksey litigation. See additional response in answers of Pickens County Probate Judge. 15b. See response in answers of Pickens County Probate Judge. 15bl. See response in answers of Pickens County Probate Judge. 15b2. See response in answers of Pickens County Probate Judge. 15b3. See response in answers of Pickens County Probate Judge. 16. I do not know. 17a. N/A. 17b. N/A. 18. Schools were segregated in the past. 19. N/A. 20. I do not know. 21. See response in answers of Pickens County Probate Judge. 22% None. 23. See response in answers of Pickens County Probate Judge. 24. See response in answers of Pickens County Probate Judge. 25. See response in answers of Pickens County Probate Judge. 26. See response in answers of Pickens County Probate Judge. PAGE FIVE 217. See response in answers of Pickens County Probate Judge. 28. See response in answers of Pickens County Probate Judge. 29. See response in answers of Pickens County Probate Judge. 30a. None at present but names and addresses will be provided if and when obtained. 30b. N/A. 30c. N/A. eves ZL ZA [/IERY FITCH STATE OF ALABAMA COUNTY OF PICKENS Before me, the undersigned authority in and for said County and said State, personally appeared Jerry Fitch, 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. 2: NOTARY PUBLIC ’ ATTORNEY FOR JERRY FITCH DEFENDANT ~ UAH W. O. KIRK, JR. CURRY & KIRK P. O. BOX A-B CARROLLTON, AL 35447 TELEPHONE: (205) 367-8125 PAGE SIX CERTIFICATE OF SERVICE I hereby certify that I have served the foregoing Answers upon: Wanda J. Cochran Larry T. Menefee James U. Blacksher Blacksher, Menefee & Stein, P. A. 405 Van Antwerp Building 0." 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 by placing copies of the same in the United States Mail properly addressed and postage paid this 2 day of February, 1986. FP, W. O. KIRK,”7JR., ATTORNEY FOR PICKENS COUNTY DEFENDANTS PAGE SEVEN 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 = day of February , 1986. / Ww. 5 pra ATTORNEY FOR PICKENS COUNTY DEFENDANTS Blown Palating Co. Montgomery, YP a G Whey 4) ( 3A : DATL EXVPENGE ACCOUNT OF CAND (To Be Filed Within 13 Days Alter the Llactlon) NAME... ~JerCu Loh. Std % waning anes BILL Poe Zad L Ef elseitle BK 3IS¥6 £.. Pursuant to Tule 17, Sections 270, 279 and 400 of the Code of Alabama us waended, delinlag the Conrupit Practices Act. 1 herewith submit a full, corvect, detatled and Itemlzed statement of al) expenses nade dueatly of indirectly in sums over $8.00 und of all ubligations, debts, or Habilities assumed or neared ut the thine of Gila this statement, together with the names of sll contributors of amounts In excess of $10.00, with the amounts pve n hy coch, and a List of all giles, Jonny ar contributions made la conncetion with my campaign us a candidate 1a the Election held on Tusaday, Sept. l ye ¥ept.2 § 10 § for the office of Pickens County Co am missioners. Piste «4 ERE RR (Enter Name of Office) _— | : foes ETA t [ CONTHIBUTIONY | iy : NV Vz | Raat = 19 Ye Filed whe_—f 2 anv ot % | | PR | Judge of Prepate BE LE EERE PRP ‘ - enim EE . Lk : ‘og | ' TOTAL A 0 Ne. : EXPENSES INCURRED | “Pickens County Pemeeratic Executive Comm, Hee [8.00 C+ P Prioking 5 fl Q49.8S Pickens Count Aewaid I0/.80 The Advertise /]S 00 WRPG - WAHT S/2.%0 Sarcone [Photos raphic prt 29.00 Hiway 4 Brecon TYS 00 ! ; rora. BI12/. 0S” ATI Sees i Hp STATE OF ALABAMA, COUNTY OF ... ©; clon. 1 ; Glenda Que , Bus S< iq. meen ee i Notary Pubic in and for sod conmnty a saad state he rely cen lilly that DECOY rx 9 =A ch FA whore taney, 13 k spud to the foregomg statement, who nown tone, hie personally appeared before me on this diy wd (RTI, (iat duly sworn deposes and Says that the statement hereinabove mde 1s mall respects ba, and that the san Ea full and detaded siatement of all somes, securities of equivalents for money couing under the sont ae Ge. : Swen to ad ltt) before ane the J, of... 1 O chbas Es : Vif 2- ; ae : Laney IHMo. da Sta (Ca if Notiey uli ——— ——————— ———————————— a Sa ———— a rr an ———— I mm rn a — — Title 17§ 400. Lxpense account of candidate must hie made and filed. Any candulate for way ollie elect Ly the vutep ud ete then one county, except candibates bor the office of state senate, shall Bile with the secretory of state und every shndadite Cor a county otfice und candidates for the state senate and how: ¢ of representatives shall file with the plge of probate of the county oF founbies i whieh said election 1s held, 0 sworn statement, setiing cul und itemnzing the expenses of his canvass in ah cles tion within tees deya alter such election. inl sny condidiate who Gals to 0 Gle sod swear to such atulement within auld tune, shall In; ginlty of a ndademennpr, oid, on conviction, mnt be ned not Jess than one bundiod nor meme than one thousuin dallury M } ow Printing Co. amr) EXPUNGE ACCOUNT OF CAND | 2 (To He Flled Within 1§ Days Alter the Llectton) ervnal Ebel no MAILING ADDRESS .. | [ 4,1 Rox 321 TR MAE . Ethelso: lle AL 3SYC/ Pursuant to Title 17," Sections 278, 279 and 400 of the Code of Alabama as amended, defining the Corraga Practices Act. | herewith submit a full, correct, detailed and itemized statement of al) expenses made directly or indirectly in sums over $3.00 and of all obligations, debts, or Haubilitics assumed or Incurred at the time of flog this statement, together with the names of all contributors of amounts In excess of $10.00, with the amounts paven by cach, and a list of all gifts, loans or contributions made lu connection with my campaign as a candidate 1 the Election held on Tuesday, .. Novem be C- od 18 IR for the office of Pickens County Coon MSS wl Disdeiel- L i, Tole (Enter Name of Office) ’, NAME ein CONTHIBUTIONS tie La ba | : . | ' ) © NONE ie TOTAL. ~O wu EXPENSES INCURRED 9 /- The Advertiser | J08.50 or “Pickens County Neva 1d 2720.80 the (IRAQ -WAQ TT 39.20 0, OP Printi ney £9. 2S 3 ueatherSod "Printing 283.50 Nong Hf Bresery 328, 60 Flled this 2 day of Jb . 10 0R roraL [3 09. 9s Signature of Candidate . Jey wil C STATE OF ALABAMA, COUNTY OF tel Pi A lenit 2h oy stale, hereby certify tht EET Ne. + ee erent memes we sree wee $0 NOLFY. Public in and for suid consiity. an 2a ~ : od. Tilo h.. isd in ia Ths saps Wn whose sane a, naw Wane, he personally sipued to the foregomg stateme appeared before ane on this day and bong fiat duly sworn deposes and says that The statement hereinabove made is in all respects ae, and that the sana is a full and detailed statement of all monies, securities or equivalents for money coming under the conto bo cae, tody of said committee and by it expended directly or indivectly % Siw h to waned subscribed before me this bi 4 day of Eh SE BURGE a wa 1 Nein AIEEE PE : x pe oS ae tn. Notary Publi —— ——————————— a ————. a = Title 17§ 400. Lxpense account of candidate must hie made and filed. - Any candidate for any Alice elected by the votes of tote then one county. hf To camdbicbistes foe the othe of state senate, shall file with the secretary of state, und eves y candulate for a county othice and candidates for the state senate and house of representatives shall file with the judge of probate of the ounty ar counties iv which sad election is held, a sworn’ statement, setting ant and itemizing the expenses of his canvass in such clectpun within fifteen daya after such election. iwi) nay candidate who falls to so Gle and swear to such statement within sahil type, shall fn guilty of. 4 pisdemepnor, sd, on conviction, must he ned not less then one hundved noe more then one thous ' 0 “ ! } ' 3 V | LZ ’ ' dollars 3 EEO i, fai ¥ vidi LM SE J bru vy Elect JERRY T. FITCH For County Commissioner CARROLLTON DISTRICT 4 Subject to the Act of the Democratic Party in 1982 §) I Want Your Vote and Support “ Pd. Pol. Adv. by Jerry 1. Fitch, Ethelsville, Al on Elect JERRY T. FITCH ~JERRY T. FITCH County Commissioner CARROLLTON DISTRICT 4 County Commissioner iro DISTRICT 4 v a PRA : Sublet to the Act of the Democratic Party in 1982 our Vote and Support Will Be Appreciated ® I Want Your Vote and Support Subject to the General Election on November 2, 1982 : teense srr nine Pd. Pol. Adv. by Jerry 1. Fitch, Ethelsville, AL ® caliE3 2 Pd. Pol. Adv. by Jerry T. Fitch, Ethelsville, AL FOR GOVERNOR—(Vote for One) ( ) GEORGE McMILLAN ( ) GEORGEC. WALLACE FOR ASSOCIATE JUSTICE OF THE SUPREME COURT, PLACE NO. 3 —(Vote for One) (_) OSCAR W. ADAMS (__) JIM ZEIGLER FOR STATE AUDITOR—(Vote for One) (__) JAN COOK (__) KAY IVEY FOR COMMISSIONER OF AGRICULTURE AND INDUSTRIES —(Vote for One) () ALBERT MCDONALD ( ) BUBBA TROTMAN FOR JUDGE OF PROBATE —(VoteforOne) (_) BILLY R. (Bill) COOK () WILLIAM H. LANG, JR. FOR MEMBER PICKENS COUNTY COMMISSION, DISTRICT NO. 2 —(Vote for One) () GARVINE BRYANT ( ) JAMESH. CORDER FOR MEMBER PICKENS COUNTY COMMISSION, DISTRICT NO. 4 —(Vote for One) O¢) JERRY T.FITCH () BOBBY C.WINDLE DISTRICT NO. 2—(Vote for One) Elect 2 JERRY T. FITCH \, Nii For * County Commissioner ye : i N D El CARROLLTON DISTRICT 4 fone A RS ANA Your Vote and Support Will Be Appreciated DEMOCRATIC REPUBLICAN Subject to the General Election on November 2, 1982 saab. Pd Pol Adv. by Jerry T. Fitch, Ethelsvilie, AL OO C) FOR GOVERNOR-(Vote for One) ( ) GEORGE C. WALLACE { ( ) EMORY FOLMAR FOR LIEUTENANT GOVERNOR (Vote for One) ( ) BILL BAXLEY FOR UNITED STATES REPRESENTATIVE, 4th CONGRESSIONAL DISTRICT—(Vote for One) () TOMBEVILL FOR ATTORNEY GENERAL — (Vote for One) () CHARLES A. GRADDICK FOR STATE SENATOR, DISTRICT NO. 30—(Vote for One) ( ) EDWARD (Big Ed) ROBERTSON FOR STATE REPRESENTATIVE, DISTRICT NO. 88 —(Vote for One) () PHILPOOLE FOR STATE REPRESENTATIVE, DISTRICT NO. 89 () EARL MITCHELL () STEVE EMENS (Vote for One) FOR CHIEF JUSTICE OF THE SUPREME COURT “pan — (Vote for One) ( ) C.C."“Bo" TORBERT, JR. FOR ASSOCIATE JUSTICE OF THE SUPREME COURT, PLACE NO. 1-(Vote for One) () HUGH MADDOX ( ) HARRY LYON FOR ASSOCIATE JUSTICE OF THE SUPREME COURT, PLACE NO. 2— (Vote for One) ( ) SAM BEATTY FOR ASSOCIATE JUSTICE OF THE SUPREME COURT, “Tam N PLACE NO. 3—(Vote for One) ( ) OSCAR W. ADAMS ( ) THOMAS J. “Tom" HAYDE FOR COURT OF CIVIL APPEALS JUDGE~—(Vote for One) ( ) ROBERT P. BRADLEY FOR COURT OF CRIMINAL APPEALS JUDGE, PLACE NO. 1-(Vote for One) (02 JOHN PAUL DeCARLD FOR COURT OF CRIMINAL APPEALS JUDGE, PLACE NO. 2—(Vote for One) ( ) BILL BOWEN FOR COURT OF CRIMINAL APPEALS JUDGE, PLACE NO. 3—(Vote for One) () BISHOP BARRON FOR SECRETARY OF STATE~—(Vote for One) ( ) DON SIEGELMAN FOR STATE TREASURER (Vote for One) () ANNIE LAURIE GUNTER FOR STATE AUDITOR (Vote for One) ( ) JAN COOK FOR COMMISSIONER OF AGRICULTURE AND INDUSTRIES —(Vote for One) ( ) ALBERT McDONALD FOR PUBLIC SERVICE COMMISSION, PLACE NO. 1 ( ) LYNN GREER —(Vote for One) FOR PUBLIC SERVICE COMMISSION, PLACE NO. 2 (Vote tor One) ( ) JIM FOLSOM, JR. FOR CIRCUIT COURT JUDGE, 24th JUDICIAL CIRCUIT — (Vote for One) ( ) CLATUS K. JUNKIN FOR CIRCUIT CLERK, PICKENS COUNTY —(Vote for One) ( ) JAMES E. FLOYD FOR JUDGE OF PROBATE (Vote for One) ( ) WILLIAM H. LANG, JR. ( ) DEBORAH CHANDLER ( ) JAMES FOR SHERIFF ~(Vote for One) ( ) LOUIE C. COLEMAN . FOR MEMBER, PICKENS COUNTY COMMISSION, () GARVIN BRYANT ( ) JOHNN FOR MEMBER, PICKENS COUNTY COMMISSION, DISTRICT NO. 4—(Vote for One) (78 JERRY T. FITCH () WILLIE L. WRIGHT FOR PICKENS COUNTY BOARD OF EDUCATION MEMBER, DISTRICT NO. 1-(Vote for One) ( ) MARK AUSTELL FOR PICKENS COUNTY BOARD OF EDUCATION MEMBER, DISTRICT NO. 4—(Vote for One) ( ) JAMES G. (Buddy) NOLAND