Correspondence from Guinier to Seay

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February 26, L982

Solomon S. Seay, Esq.
352 Dexter Avenue
Montgomery, Al-abama 36LO4

Dear Mr. Seay;

I am writing in reference to the cases of State of
Alabama v. Maggie Bozeman and Jul-ia Wilcler. I frEG-Eeen
reviewing the transcripts of the trial with the assistance
of a law student from New York University Law School , MS.
Cheryl Howard. As the Alabama Court of Criminal Appeals
noted about this case, the testimony of the witnesses is
quite confused, and often contradictory depending on who
was examining them.

I have tried unsuccessfully to call you several times
to discuss questions which have arj-sen as we examine the
transcript. I have also spoken to Mr. J.L. Chestnut whose
recollection of the trials is somewhat faded. He was ex-
tremely cooperative, however, and has agreed to review his
files as soon as possible.

In the meantime, it would be very helpful i-f you could
cal-I me or wite me in response to the following questions:

What preliminary motions did you file? Did
you file a motion to sever the cases? Did
the judge state a reason that the cases should
be tried separately? Did you file a motion
for a change of venue and if not, why not?
Did you file a motion to quash the indictment
on the grounds that blacks were systematically
excluded from the jury venire?

When you questioned the jury on voir dire did
you ask any questions about pre-triaI publicity?
If not, why not? Did you note for the record
the race of the jurors against whom the
prosecutor used his peremptory challenges? Do
you have any notes from the voir dire?

Otrntriltuliotts are tl<:tluttible lor IJ.5. inconrr lor l)tlll,osrs

The I{MCP TEGAL DETENSE & EDUCATIONAL FUND is not part of the National Association for the Advancement of Colored People although it
was lounded by it and shares its commitment to equal rights. LDF has had for over 20 years a separate Board, program, staff, office and budget.

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Solomon S. Seay, Esq.
Page 2
February 26, l9B2

Did you become aware at any time of any
conflict between the defense of Julia
Wilder and that of Maggie Bozeman? Were
your clients ever asked by the judge
about having the same attorney represent
them?

Why was Julia Wilder tried first? Who
or what was nesponsible for the six month
delay in the trial of Maggie Bozeman?

Did you know that the prosecutor was
deposing wj-tnesses prior to trial? Were
you ever notified of such depositions?
Did you request copies prior to trial?

Can you provide us with a transcript of
the defendants' arrangement copies of
the briefs filed by the State of Alabama
on appeal, copies of the depositions of
the witnesses taken before trial in the
prosecutor's office, and copies of the
trial exhibits?

Please excuse the volume of questions. If it is too
burdensome or inconvenient to respond in writing or by
telephone, Cheryl and f would be happy to come to your
offices and meet with you as soon as possible. Please let
me hear from you.

We are very encouraged from our limited review that there
are several possible constitutional claims to be naised in a
habeas corpus or post-conviction proceeding. We look forward
to working with you on this matter.

Yours si-ncerely,

Lani Guinier

LG/ Jb

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