Letter to James Kellog from Napoleon Williams RE Mountain for Summary Judgment

    NAACP LEGAL DEFENSE AND EDUCATIONAL FUND, INC. 

und 10 Columbus Circle, New York, N.Y. 10019 « (212) 586-8397 

May 7, 1983 

James Kellog, Esq. 
William P. Quigley, Esq. 
631 St. Charles Avenue 
New Orleans, Louisiana 70130 

Re: Major v. Treen (E.D. La.) Civil Action 
82-1192 
  

Dear James and Williams: 

I received this day a copy of your Motion for 
Summary Judgment in the above case with respect 
to the recent Congressional reapportionment in 
Louisiana. The overall population deviation of 
21.95% is not only too large under the federal 
standards for Congressional reapportionment, 
but would also be too large for reapportionment 

of a state legislature. I really am glad that we 
finally got the lawsuit off the ground. 

I think the memorandum of law is far too skimpy, 
especially for a judge who has only recently been 
appointed to the bench. The fact that the judge 
litigated one or more voting rights cases before 
joining the bench would not be, I think, determina- 
tive. 

There are some housekeeping details I must mention. 
First, when our names appear on any legal documents, 
they should be listed, in the order indicated, as 
follows: Jack Greenberg; James M. Nabrit, III; 
Napoleon B. Williams, Jr., Lani Guinier. We also find 
it helpful in identifying the attorneys who take re- 
sponsibility for submission of legal papers, to 
include our telephone number. If there is publicity 
concerning a matter in which we are involved, it is 
also preferable to mention the organization by its full 
name or, in the alternative, to mention Jack Greenberg's 
name since his name, unlike the other names, have a 
very strong association with the organization 

Contributions are deductible for U.S. income tax purposes 

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



Robert W. Cullen, Esq. -2- May 7, 1982 

I will try and submit to you next week a draft of a 

supplementary memorandum of law which you may wish to 

consider filing in support of your request for sum- 

mary judgment. The motion, by the way, was, I thought, 

a very clever move. 

As always, I wish you well. 

Sincerely, 
2/7) i] 

i a 

LA ii HRA 

;] / 

Napoleon B. williams, Jr. 

NBW/x 

Jack Greenberg, Esq. 

Lani Guinier, Esq.