Answer to Plaintiffs' Third Discovery Request; Amended Answer to Request for Admissions; Amended Answer to Second Discovery Request; Coffee County Commission Voting Plan; Calhoun County Election Plan Schedule

    Kg L125 [3 & 
IN THE UNITED STATES DISTRICT COURT FOR THE et 

MIDDLE DISTRICT OF ALABAMA 

NORTHERN DTVISTON 

JOHN DILLARD, ET Al 

PLAINTIFFS, k 

VS. * CA NO. 85-T-1332-N 

CRENSHAW COUNTY, ALABAMA, ET AL x 

DEFENDANTS : 

Comes now the Defendants, Coffee County, Alabama, and for answer 

to the Plaintiffs! Third Discovery Request heretofore filled, would answer 

as follows: 

lL. [t 1s unknown at this time the names of expert witnesses that 

will he ged at trial, 

2. “N/A 

}. See attached 

4. See attached 

5 See attached 

ROWE, ROWE & SAWYER 

\ ATP, 

oe <r. / l/ Pa; f \ - ve 

BY » FUN. [ £ { { 1, {, \/ — { - \ {2 { A —— - -  —_ . 

Warren Rowe 3 

. Attorney for Defendants of Coffee Co 

P. O. Box 150 

Fnterprise, Alabama 3633] 

(205) 347-3401 

CERTIFICATE OF SERVICE 

[, Warren Rowe, of Counsel for Defendants from Coffee County, Alabama, 

hereby certify that T have mailed a copy of the foregoing Answer to Hon. James 

Blacksher YO QL ad yirepnld and ‘proper: vddreased to him at P. 0. Box 1051, 
iy A | | | 

Mobi | Alabamn thig the 18th da of Jung 1086. ) 

. 
71 Rs / 

 



  

IN THE UNTTED STATES DISTRICT COURT FOR THE 

MIDDLE DISTRICT OF ALABAMA 

ORT] EDIVISTION 

JOHN DILLARD, ET ALS Je 

PLAINTIFFS, * 

VS. % CTVII, ACTION NO, 85-T-1332-N 

CRENSHAW COUNTY, ALABAMA ET ALS % 

DEFENDANTS * 

AMENDMENT TO DEFENDANTS 

ANSWER TO PLAINTIFFS! REQUEST FOR ADMISSIONS 

Comes now all of the Defendants of Coffee County, Alabama, and 

would hereby amend their original Answer to Plaintiffs’ Request for Admissions 

heretofore filed in this matter to read as follows: 

mat the Defendants, Coffee County, deny each and every allegation 

contained in this Request for Admissions. 

f 
\ 

ROWE, ROWE & SAWYER ~ 

bay X ,», 
BY : ( {/ Z1enr~ 0 tet 

“Warren Rowd 
P. O. Box 150 

interprise, Alabama 3633] 

(205) 347-3401 

CERTIFICATE O] HIN TC 

Warren Rowe, of Counsc| r Dofendants from Coffee County, Alabama, 

hereby certify that I have malled a coj of the foregoing Answer to Hon. James 

bl ksher, postage prepaid and proper! vcd sed to him at P. 0. Box 1051, 

flo Alabama. this the 18th cla Of lin RAG 

) 
/ 

/ 7 : XY 
(AAA \ () 

Of Counjge 

 



INTTED STATES DISTRICT COURT FOR THE 

MIDDLE DISTRICT OF ALABAMA 

NORTHERN DIVISTON 

JOHN DILLARD, ET ALS 

PLAINTITTS, 

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

COUNTY SET... 

DEFENDANTS 

AMENDMENT TO DEFENDANTS 

ANSWER TO PLAINTTIFFS' SECOND DISCOVERY REQUEST 

Comes now all of the Defendants of Coffee County, Alabama, and would 

hereby amend their original Answer to Plaintiffs' Second Discovery Request 

heretofl ol {led in this matter to read as follows: 

That the Defendants, Coffee County, deny each and every allegation 

contained 11 thia Second Discovery Request 

ROW ROWT 

Alabama 3633] 

Sy FERVICT 

I, Warren Rowe, of Counsel for Defendants from Coffee County, Alabama, 

herehv certify that I have mailed a copy of the foregoing Answer to Hon. James 

Blacksher, postage prepaid and properly addressed to him at P. O. Box 1051, 

Mobile, Alabama, this the 18th day of June, 1986. 

( 4 Y { 

0 Counsel  



  

IN. THE DISTRICT COURT OF “TBE 

MIDDLE DISTRICT OF. Al 

JOHN DILLARD, ET ALS A 

PLAINTIFFS, k 

‘TO A 

CRENSHAW COUN ETC. ET ALS A 

DEFENDANTS 

Comes now Coffee County in the 

to this Honorable Court the pn] 

Commina]on {Ot the development ppt ri | 

Commission 

amended, and more particularly described 

Court of Mav 28 and reat 

to submit ourt: its 

Attached are the maps of the 

AMA MA 

of comply with Section 2 of h 

present 

UNITED STATES FOR THE 

NORTHERN DIVISION 

CIVIL ACTION NO, 85-T-1332-N 

above styled action and would submit 

an promulgated by the present Coffee County 

and Implementation by said 

of 10465 y a8 e Voting Rights Act 

in that Order by this Honorable 

raining sald Commission from 

configuration of the Coffee 

County Commission including the voting precinct lines, box lines and the 

boundaries of any residency districts for county commissioners, Also 

attached 1s the additional Commission member placement proposal and his 

respective district which the County has proposed to add to its present 

member configuration, 

  

ROWE, ROWE & SAWY 

LL 

ER ; ) 

\ X ) BY: dmg NOLL mat ———— EN ea ein - p——————— 

Warren Rowe 

P. 0. Box 150 

Enterprise, Alabama 3633] 

347-3401 (205) 

falling



  

CERTIFICATE OF SERVICE 

, Warren Rowe, of Coungel Defendants from Coffee County, 

Alabama, hereby certify that 1 have mailed a copy of the foregoing to Hon. 

James Blacksher, postage prepaid and properly addressed to him at P. 0. Box 

J051. Mobile, Alabama, thiz the 18th dav of June, 1986 

\ ) 
\ 

p \ g 

/ a) 
{ V2 . , C’ | Fel AA ( 1 \ £ UU 

w— Mo menses sl A avast pt——————— 

Of Counsel 

 



  

Va : F ae 1) 9 Ld / oq 2 / ” 

IN THE UNITED STATES DISTRICT COURT FOR THE 

MIDDLE DISTRICT OF ALABAMA 

NORTHERN DIVISION 

JOHN DILLARD, et als, * 

PLAINTIFFS, id 

VS: * CASE NO. 85-T-1332-N 

CRENSHAW COUNTY, ALABAMA, * 

et als, 
* 

DEFENDANTS. 

Pursuant to the Court's Order of May 28, 1986, Calhoun 

County offers the following time schedule for implementing an 

election plan which complies with the Voting Rights Act: 

1. By July 15, 1986, these Defendants will submit to the 

Department of Justice for pre-clearance, a plan with the following 

features: 

a. The county will be divided into districts 

with one commissioner elected from each 

district by the voters of that district. 

b. One district will have a majority black 

population. 

c. The population of each district will be 

equal, as far as practicable, in population. 

d. There will be a Chairman or County Executive 

elected by all the voters of the county. 

2. By September 13, 1986, the Department of Justice must 

object or acquiesce to the proposed plan. If no objection is made, 

the county will petition the Court for final approval. 1f objec- 

tion is made, the plan will be amended and resubmitted within 15 

days. 

BURNHAM, KLINEFELTER. HALSEY. JONES & CATER. P.C.. ATTORNEYS. BOX 1618. ANNISTON. ALABAMA 36202     
 



  

3. Once the boundaries of the districts are agreed upon, 

the county will begin jdentifying individual voters to their 

districts. 

4. To implement the plan, the person elected Chairman of 

the County Commission in the November General Election will serve 

as Chairman or County Executive. The persons elected as Associate 

Commissioners in the November Genral Election will serve as the 

Commissioners for the districts in which they reside; provided, 

however, that no encumbent will represent the new majority black 

district. Before January 1, 1987, elections would be held to 

elect commissioners for the majority black district and any other 

unrepresented district. 

BURNHAM, KLINEFELTER, HALSEY, 

JONES & CATER, P. C. 

By: 
7H. R. Burnham 
  

  

; Jop€s, Jr. 

| hereby certify that a copy hereof has been personally 

hanced or mailed, properly addressed, first class post- 

ege prepaid, to counse! for all parties to this proceeding 

on this [DB _ day of ) [ZN : 198 
  

Burnham, Klinefeit alsey, Jones & Cater, B.Gs    



HE Gen og 

 



    

IN THE UNITED STATES DISTRICT COURT FOR THE 

MIDDLE DISTRICT OF ALABAMA 

NORTHERN DIVISION 

JOHN DILLARD, et als, * 

PLAINTIFFS, * 

VS: * CASE NO. 85-T-1332-N 

CRENSHAW COUNTY, ALABAMA, * 

et als, 
* 

DEFENDANTS. 

pursuant to the Court's Order of May 28, 1986, Calhoun 

County offers the following time schedule for implementing an 

election plan which complies with the Voting Rights Act: 

1. By July 15, 1986, these Defendants will submit to the 

Department of Justice for pre-clearance, a plan with the following 

features: 

a. The county will be divided into districts 

with one commissioner elected from each 

district by the voters of that district. 

b. One district will have a majority black 

population. 

c. The population of each district will be 

equal, as far as practicable, in population. 

d. There will be a Chairman or County Executive 

elected by all the voters of the county. 

2. By September 13, 1986, the Department of Justice must 

object or acquiesce to the proposed plan. If no objection is made, 

the county will petition the Court for final approval. If objec- 

tion is made, the plan will be amended and resubmitted within 15 

days. 

BURNHAM. KLINEFELTER. HALSEY. JONES & CATER. P.C.. ATTORNEYS. BOX 1618. ANNISTON. ALABAMA 36202 

  
 



    

3. Once the boundaries of the districts are agreed upon, 

the county will begin identifying individual voters to their 

districts. 

4. To implement the plan, the person elected Chairman of 

the County Commission in the November General Election will serve 

as Chairman or County Executive. The persons elected as Associate 

Commissioners in the November Genral Election will serve as the 

Commissioners for the districts in which they reside; provided, 

however, that no encumbent will represent the new majority black 

district. Before January 1, 1987, elections would be held to 

elect commissioners for the majority black district and any other 

unrepresented district. 

BURNHAM, KLINEFELTER, HALSEY, 

JONES ‘& ‘CATER, P. C. 

H. R. Burnham 

By   

erbe : Jop€s, Jr. 

| hereby certify that 2 copy hereof has been personally 

handed or mailed, properly addressed, first class post- 

ege prepaid, to counse! for all parties to this proceeding 

on this /B_day of ) [2% J ’ 19€r 

aisey, Jones & Cater, B.Gs 

  

    Burnham, Klinef 

  
 



  

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