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Case Files, Chisom Hardbacks. Plaintiffs' First Request for Admission, 1988. 75d9aa2b-f211-ef11-9f8a-6045bddc4804. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/69258374-f7b4-41e8-9626-49aed0b93acd/plaintiffs-first-request-for-admission. Accessed August 19, 2025.
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IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF LOUISIANA RONALD CHISOM, et al., Plaintiffs-Appellants, Civil Action v. No. 86-5075 Section A EDWIN EDWARDS, et al., Defendants-Appellees. PLAINTIFFS' FIRST REQUEST FOR ADMISSION Plaintiffs, by their attorneys, request that defendants pursuant to Rule 36, Fed. R. Civ. P., and within 15 days after service of this request admit the truth of the following facts for purposes of this action and subject to all pertinent objections to admissability which may be interposed at trial. Pursuant to Rule 36, all written answers shall be addressed to the matter. Any answer shall be deemed inadequate which merely states with regard to any facts set forth herein that they are matters of public record and speak for themselves or which states that any facts set forth have previously been litigated. If any objection is made to any of the facts or documents set forth herein, the specific reasons for each such objection shall be stated fully in writing. Each answer to each of the facts and documents set forth shall specifically admit the matter, deny the matter, or set forth in detail why the answering party cannot truthfully admit or deny the matter. If defendants qualify their answer or deny only a part of •the matter of which an admission is requested, defendant shall specify which part of the request is true and qualify or deny the remainder. If defendants plead lack of information or knowledge as a reason for their failure to admit or deny, they must state in detail that they have made reasonable inquiry and state specifically what inquiries have been made to ascertain the requested information or the genuineness of-each document. If any facts stated herein are deemed by the defendants to be incorrect in whole or in part, defendants are requested to supply the correct facts to which each such request refers. These requests shall be deemed continuing and defendants shall be under a continuing duty to supplement the responses as required by Rule 26(e), Fed. It: Civ. P. 1. Justices for the Louisiana state Supreme Court are elected from six Supreme Court Districts. 2. Five of the districts elect one justice each. 3. One district--the First Supreme Court District--elects two justices. 4. Pursuant to La. Rev. Stat. § 13:101, the First Supreme Court consists of the parishes of Orleans, St. Bernard, Plaquemines, and Jefferson. 5. The two judicial seats assigned to the First Supreme Court District are not filled in the same election year. 6. One of the seats assigned to the First Supreme Court District is scheduled to be filled by election in the fall of 1988. S 7. One of the seats assigned to the First Supreme Court District is scheduled to be filled by election in the fall of 1990. 8. The First Supreme Court District is the only multimember Supreme Court District. 9. The First Supreme Court District is the largest Supreme Court District in population. 10. Elections for the Louisiana Supreme Court are covered by Louisiana's majority-vote requirement. 11. In the twentieth century, no black person has sought election to the Louisiana Supreme Court from the First Supreme Court District. 12. According to the 1980 Census, the combined total populations of Jefferson, Orleans, Plaquemines, and St. Bernard Parishes was 1,102,253. Of this total, 379,101 persons (34.4 percent) were black. 13. Louisiana has a history of official discrimination touching upon the right to vote and otherwise participate in the political process. 14. Louisiana is covered by section 5 of the Voting Rights Act of 1965, 42 U.S.C. § 1973c, because it used a literacy test and has had a history of depressed political participation. 15. In 1923, Louisiana authorized the use of a white-only primary. The use of white primaries continued until it was struck down by the U.S. Supreme Court in 1944. 16. Louisiana established a majority-vote requirement for election to party committees in 1959 to diminish the political power of black voters. 17. Voting in elections involving black candidates for political office the First Supreme Court District Parish is racially polarized in that such elections reflect a correlation between the race of voters and the selection of certain candidates. 18. Voting in judicial elections involving black candidates in Orleans Parish is racially polarized in that such elections reflect a correlation between the race of voters and the selection of certain candidates. 19. The demographic character of the New Orleans metropolitan area means that a district that includes both the city and suburban parishes submerges the city's predominantly black electorate within a larger group of white voters. 20. The black community forms only one-third of the electorate in a four-parish race in the First Supreme Court District. 21. White voters within the First Supreme Court District generally do not support black candidates in elections involving both black and white candidates. 22. Louisiana enforced a policy of racial segregation in public education, transportation, and accommodations until these practices were outlawed by the Supreme Court and Congress. 23. Louisiana operated a dual university system until 1981. 24. According to the 1980 Census, in Orleans Parish, 70.8 percent of white persons age 25 and over were high school graduates. 25. According to the 1980 Census, in Orleans Parish, 46.9 percent of black persons age 25 and over were high school graduates. 26. According to the 1980 Census, in Orleans Parish, 11.16 percent of white residents age 25 and over had completed fewer than eight years of school. 27. According to the 1980 Census, in Orleans Parish, 21.78 percent of black residents age 25 and over had completed fewer than eight years of school. 28. According to the 1980 Census, per capita income for white residents of Orleans Parish was $9,781. 29. According to the 1980 Census, per capita income for black residents of Orleans Parish was $3,985. 30. According to the 1980 Census, the median household income for white households in Orleans Parish was $15,605. 31. According to the 1980 Census, the mean household income for white households in Orleans Parish was $21,975. 32. According to the 1980 Census, the median household income for black households in Orleans Parish was $8,847. 33. According to the 1980 Census, the mean household income for black households in Orleans Parish was $12,159. 34. According to the 1980 Census, the median family income for white families in Orleans Parish was $21,544. 35. According to the 1980 Census, the mean family income for white families in Orleans Parish was $28,496. 36. According to the 1980 Census, the median family income for black families in Orleans Parish was $10,516. S 37. According to the 1980 Census, the mean family income for black families in Orleans Parish was $13,727. 38. According to the 1980 Census, 7.4 percent of white families in Orleans Parish had incomes in 1979 below the poverty level. 39. According to the 1980 Census, 11.5 percent of white persons in Orleans Parish had incomes in 1979 below the poverty level. 40. According to the 1980 Census, 8.0 percent of white persons in Orleans Parish had incomes in 1979 that were below 75 percent of the poverty level. 41. According to the 1980 Census, 33.4 percent of black families in Orleans Parish had incomes in 1979 below the poverty level. 42. According to the 1980 Census, 37.3 percent of black persons in Orleans Parish had incomes in 1979 below the poverty level. 43. According to the 1980 Census, 29.1 percent of black persons in Orleans Parish had incomes in 1979 that were below 75 percent of the poverty level. 44. According to the 1980 Census, 6.76 percent of white- occupied housing units in Orleans Parish had no telephone. 45. According to the 1980 Census, 20.78 percent of white- occupied housing units in Orleans Parish had no vehicle available. 46. According to the 1980 Census, 14.22 percent of black- occupied housing units in Orleans Parish had no telephone. 47. According to the 1980 Census, 42.39 percent of black- occupied housing units in Orleans Parish had no vehicle available. pectfully submitted, WILLIAM P. QUIGLEY 631 St. Charles Avenue New Orleans, LA 70130 (504) 524-0016 ROY RODNEY 643 Camp Street New Orleans, LA 70130 (504) 586-1200• JULIUS L. CHAMBERS CHARLES STEPHEN RALSTON C. LANI GUINIER PAMELA S. KARLAN 99 Hudson Street, 16th Floor New York, New York 10013 (212) 219-1900 RON WILSON Richards Building, Suite 310 837 Gravier Street New Orleans, LA 70112 (504) 525-4361 Counsel for Plaintiffs- Appellants ci • CERTIFICATE OF SERVICE I hereby certify that on this ay of October 1988, I served a copy of the foregoing Plaintiffs' First Request for Admissions by sending a copy, by overnight delivery service, to the following persons: William J. Guste, Jr. Attorney General Louisiana Department of Justice 234 Loyola Avenue, 7th Floor New Orleans, LA 70112 M. Truman Woodward, Jr. 909 Poydras Street, Suite 2300 New Orleans, LA 70130 Blake G. Arata 201 St. Charles Avenue New Orleans, LA 70130 George Strickler, Jr. 639 Loyola Street Suite 1075 New Orleans, LA 70113 A. R. Christovich 1900 American Bank Bldg. New Orleans, LA 70130 Moise W. Dennery 601 Poydras Street New Orleans, LA 70130 Robert G. Puch 330 Marshall Street, Suite 1200 Shreveport, LA 71101 I further certify that a copy of the foregoing document was served by first-class mail, postage prepaid, on counsel for • plaintiff-intervenor, addressed as follows: Robert S. Berman Attorney, Voting Section Civil Rights Division Department of Justice P. 0. Box 66128 Washington, D.C. 0035-6128 rney for Plaintiffs