Motion to Withdraw Motion for Leave to File Amici Curiae Brief and for Leave to File a Brief of Appellee-Intervenors

Public Court Documents
May 6, 1998

Motion to Withdraw Motion for Leave to File Amici Curiae Brief and for Leave to File a Brief of Appellee-Intervenors preview

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  • Case Files, Perschall v. Louisiana Hardbacks. Motion to Withdraw Motion for Leave to File Amici Curiae Brief and for Leave to File a Brief of Appellee-Intervenors, 1998. 450aa71f-f211-ef11-9f8a-6045bddc4804. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/185b7305-85e4-42ad-8890-b5e0131d2666/motion-to-withdraw-motion-for-leave-to-file-amici-curiae-brief-and-for-leave-to-file-a-brief-of-appellee-intervenors. Accessed April 06, 2025.

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    '-3 

• oil MAY 2 2 19570 

No. 98-30004 

IN THE 
UNITED STATES COURT OF APPEALS 

FOR THE FIFTH CIRCUIT 

CLEMENT F. PERSCHALL, JR., 

Plaintiff-Appellant, 

V. 

STATE OF LOUISIANA, 

Defendant-Appellee 

and 

RONALD CHISOM, ET AL. 

Appellee-Intervenors 

On Appeal from the 
United States District Court 

for the Eastern District of Louisiana 

E MA 

coORT OF A 

*c°. RECEIVED * 
41) 

Y 0 6 1998 I 

Iv- woRLEANS,  I-1" 

MOTION TO WITHDRAW MOTION FOR LEAVE TO FILE AMICI 
CURIAE BRIEF 

AND FOR LEAVE TO FILE A BRIEF OF APPELLEE-INTERVENORS 

Ronald Chisom, Walter Willard, Henry Dillon, III, and the Louisiana Voter 

Registration/Education Crusade ("Appellee-Intervenors") respectfully request that its 

outstanding motion for leave to file an amici curiae brief be withdrawn and that leave be 

granted in order to file a brief as Appellee-Intervenors. 

On March 4th, Appellee-Intervenors filed a motion to intervene in this action. Motion 

To Intervene As Appellees, filed March 4, 1998. Before this Court had an opportunity to rule 



on this motion, the Appellee-Intervenors also filed a motion for leave to participate in this 

action as amici curiae, in order to ensure compliance with the briefing schedule for the instant 

action. Motion For Leave To File A Brief Amici Curiae, dated April 17, 1998. On April 24, this 

Court granted Appellee-Intervenors motion to intervene in the present action as appellees. 

Order, April 24, 1998. This order renders moot the outstanding motion by the same parties to 

participate in this case as amici curiae and thus, Appellee-Intervenors seek to withdraw this 

motion. However, in order for Appellee-Intervenors to have an opportunity to respond to the 

brief filed by Appellant Perschall in this matter, Appellee-Intervenors also now move for leave 

to file the accompanying Brief of Appellant-Intervenors.' 

Respectfully submitted, 

William P. Quigley 
Loyola University School of Law 
7214 St. Charles Avenue 
New Orleans, LA 70118 
(504) 861-5590 

Elaine R. Jones 
Director-Counsel 
Norman J. Chachkin 
Charles Stephen Ralston 
Victor A. Bolden 
Jacqueline A. Berrien 
NAACP Legal Defense & Educational Fund, Inc. 
99 Hudson Street 
Suite 1600 
New York, New York 10013 
(212) 219-1900 , 

Ronald L. Wilson 

lAppellee-intervenors have sought the consent of both the Appellant and the Appellee and 
neither have, expressed opposition to this motion. 

2 



837 Gravier Street 
New Orleans, LA 70113 
(504) 586-1241 

Counsel for Appellee-Intervenors 



CERTIFICATE OF SERVICE 

I hereby certify that copies of the foregoing MOTION TO WITHDRAW MOTION FOR 

LEAVE TO FILE AMICI CURIAE BRIEF AND FOR LEAVE TO FILE BRIEF OF APPELLEE-

INTERVENORS, have been served by depositing same in the United States mail, first class postage 

prepaid, on this May 5, 1998, addressed to the following: 

Clement F. Perschall, Jr., Esq. 
One Galleria Boulevard 
Galleria One, Suite 1107 
Metarie, Louisiana 70001 
Telephone: (504) 836-5975 

Richard P. Ieyoub 
Attorney General, State of Louisiana 
State Capitol 
P.O. Box 94005 
Baton Rouge, Louisiana 70804-9005 

Robert McDuff, Esq. 
767 N. Congress Street 
Jackson, Mississippi 39202 
Telephone: (601) 969-0802 

Peter Butler (Bar# 3731)-T.A. 
Peter J. Butler, Jr. (Bar# 18522) 
Richard G. Passler (Bar# 21006) 
LL&E Tower, Suite 2400 
909 Poydras Street 
New Orleans, Louisiana 70112 
Telephone: (504) 584-5454 

Tyron D. Picard (Bar# 20473) 
Mark Stipe (Bar# 19803) 
Petroleum Tower, Suite 330 
3639 Ambassador Caffrey Parkway 
Lafayette, Louisiana 70503 
Telephone: (318) 983-0090 

VICTOR A. BOLDEN 



No. 98-30004 

IN THE 
UNITED STATES COURT OF APPEALS 

FOR THE FIFTH CIRCUIT 

CLEMENT F. PERSCHALL, JR., 

Plaintiff-Appellant, 

V. 

STATE OF LOUISIANA, 

Defendant-Appellee 

and 

RONALD CHISOM, ET AL. 

Appellee-Intervenors 

On Appeal from the 
United States District Court 

for the Eastern District of Louisiana 

MOTION TO WITHDRAW MOTION FOR LEAVE TO FILE AMICI 
CURIAE BRIEF 

AND FOR LEAVE TO FILE A BRIEF OF APPELLEE-INTERVENORS 

Ronald Chisom, Walter Willard, Henry Dillon, III, and the Louisiana Voter 

Registration/Education Crusade ("Appellee-Intervenors") respectfully request that its 

outstanding motion for leave to file an amici curiae brief be withdrawn and that leave be 

granted in order to file a brief as Appellee-Intervenors. 

On March 4th, Appellee-Intervenors filed a motion to intervene in this action. Motion 

To Intervene As Appellees, filed March 4, 1998. Before this Court had an opportunity to rule 



on this motion, the Appellee-Intervenors also filed a motion for leave to participate in this 

action as amici curiae, in order to ensure compliance with the briefing schedule for the instant 

action. Motion For Leave To File A Brief Amici Curiae, dated April 17, 1998. On April 24, this 

Court granted Appellee-Intervenors motion to intervene in the present action as appellees. 

Order, April 24, 1998. This order renders moot the outstanding motion by the same parties to 

participate in this case as amici curiae and thus, Appellee-Intervenors seek to withdraw this 

motion. However, in order for Appellee-Intervenors to have an opportunity to respond to the 

brief filed by Appellant Perschall in this matter, Appellee-Intervenors also now move for leave 

to file the accompanying Brief of Appellant-Intervenors.' 

Respectfully submitted, 

William P. Quigley 
Loyola University School of Law 
7214 St. Charles Avenue 
New Orleans, LA 70118 
(504) 861-5590 

Elaine R. Jones 
Director-Counsel 
Norman J. Chachkin 
Charles Stephen Ralston 
Victor A. Bolden 
Jacqueline A. Berrien 
NAACP Legal Defense & Educational Fund, Inc. 
99 Hudson Street 
Suite 1600 
New York, New York 10013 
(212) 219-1900 

Ronald L. Wilson 

'Appellee-intervenors have sought the consent of both the Appellant and the Appellee and 
neither have expressed opposition to this motion. 

2 



837 Gravier Street 
New Orleans, LA 70113 
(504) 586-1241 

Counsel for Appellee-Intervenors 



CERTIFICATE OF SERVICE 

I hereby certify that copies of the foregoing MOTION TO WITHDRAW MOTION FOR 

LEAVE TO FILE AMICI CURIAE BRIEF AND FOR LEAVE TO FILE BRIEF OF APPELLEE-

INTERVENORS, have been served by depositing same in the United States mail, first class postage 

prepaid, on this May 5, 1998, addressed to the following: 

Clement F. Perschall, Jr., Esq. 
One Galleria Boulevard 
Galleria One, Suite 1107 
Metarie, Louisiana 70001 
Telephone: (504) 836-5975 

Richard P. Ieyoub 
Attorney General, State of Louisiana 
State Capitol 
P.O. Box 94005 
Baton Rouge, Louisiana 70804-9005 

Robert McDuff, Esq. 
767 N. Congress Street 
Jackson, Mississippi 39202 
Telephone: (601) 969-0802 

Peter Butler (Bar# 3731)-T.A. 
Peter J. Butler, Jr. (Bar# 18522) 
Richard G. Passler (Bar# 21006) 
LL&E Tower, Suite 2400 
909 Poydras Street 
New Orleans, Louisiana 70112 
Telephone: (504) 584-5454 

Tyron D. Picard (Bar# 20473) 
Mark Stipe (Bar# 19803) 
Petroleum Tower, Suite 330 
3639 Ambassador Caffrey Parkway 
Lafayette, Louisiana 70503 
Telephone: (318) 983-0090 

‘UR*ri 
VICTOR A. BOLDEN 



• 
No. 98-30004 

IN THE 
UNITED STATES COURT OF APPEALS 

FOR THE FIFTH CIRCUIT 

CLEMENT F. PERSCHALL, JR., 

Plaintiff-Appellant, 

V. 

STATE OF LOUISIANA, 

Defendant-Appellee 

and 

RONALD CHISOM, ET AL. 

Appellee-Intervenors 

On Appeal from the 
United States District Court 

for the Eastern District of Louisiana 

MOTION TO WITHDRAW MOTION FOR LEAVE TO FILE AMICI 
CURIAE BRIEF 

AND FOR LEAVE TO FILE A BRIEF OF APPELLEE-INTERVENORS 

Ronald Chisom, Walter Willard, Henry Dillon, III, and the Louisiana Voter 

Registration/Education Crusade ("Appellee-Intervenors") respectfully request that its 

outstanding motion for leave to file an amici curiae brief be withdrawn and that leave be 

granted in order to file a brief as Appellee-Intervenors. 

On March 4th, Appellee-Intervenors filed a motion to intervene in this action. Motion 

To Intervene As Appellees, filed March 4, 1998. Before this Court had an opportunity to rule 



on this motion, the Appellee-Intervenors also filed a motion for leave to participate in this 

action as amici curiae, in order to ensure compliance with the briefing schedule for the instant 

action. Motion For Leave To File A Brief Amici Curiae, dated April 17, 1998. On April 24, this 

Court granted Appellee-Intervenors motion to intervene in the present action as appellees. 

Order, April 24, 1998. This order renders moot the outstanding motion by the same parties to 

participate in this case as amici curiae and thus, Appellee-Intervenors seek to withdraw this 

motion. However, in order for Appellee-Intervenors to have an opportunity to respond to the 

brief filed by Appellant Perschall in this matter, Appellee-Intervenors also now move for leave 

to file the accompanying Brief of Appellant-Intervenors.' 

Respectfully submitted, 

William P. Quigley 
Loyola University School of Law 
7214 St. Charles Avenue 
New Orleans, LA 70118 
(504) 861-5590 

Elaine R. Jones 
Director-Counsel 
Norman J. Chachkin 
Charles Stephen Ralston 
Victor A. Bolden 
Jacqueline A. Berrien 
NAACP Legal Defense & Educational Fund, Inc. 
99 Hudson Street 
Suite 1600 
New York, New York 10013 
(212) 219-1900 

Ronald L. Wilson 

'Appellee-intervenors have sought the consent of both the Appellant and the Appellee and 
neither have expressed opposition to this motion. 

2 



837 Gravier Street 
New Orleans, LA 70113 
(504) 586-1241 

Counsel for Appellee-Intervenors 



S 
CERTIFICATE OF SERVICE 

I hereby certify that copies of the foregoing MOTION TO WITHDRAW MOTION FOR 

LEAVE TO FILE AMICI CURIAE BRIEF AND FOR LEAVE TO FILE BRIEF OF APPELLEE-

INTERVENORS, have been served by depositing same in the United States mail, first class postage 

prepaid, on this May 5, 1998, addressed to the following: 

Clement F. Perschall, Jr., Esq. 
One Galleria Boulevard 
Galleria One, Suite 1107 
Metarie, Louisiana 70001 
Telephone: (504) 836-5975 

Richard P. Ieyoub 
Attorney General, State of Louisiana 
State Capitol 
P.O. Box 94005 
Baton Rouge, Louisiana 70804-9005 

Robert McDuff, Esq. 
767 N. Congress Street 
Jackson, Mississippi 39202 
Telephone: (601) 969-0802 

Peter Butler (Bar# 3731)-T.A. 
Peter J. Butler, Jr. (Bar# 18522) 
Richard G. Passler (Bar# 21006) 
LL&E Tower, Suite 2400 
909 Poydras Street 
New Orleans, Louisiana 70112 
Telephone: (504) 584-5454 

Tyron D. Picard (Bar# 20473) 
Mark Stipe (Bar# 19803) 
Petroleum Tower, Suite 330 
3639 Ambassador Caffrey Parkway 
Lafayette, Louisiana 70503 
Telephone: (318) 983-0090 

VICTOR A. BOLDEN 



No. 98-30004 

IN THE 
UNITED STATES COURT OF APPEALS 

FOR THE FIFTH CIRCUIT 

CLEMENT F. PERSCHALL, JR., 

Plaintiff-Appellant, 

V. 

STATE OF LOUISIANA, 

Defendant-Appellee 

and 

RONALD CHISOM, ET AL. 

Appellee-Intervenors 

On Appeal from the 
United States District Court 

for the Eastern District of Louisiana 

MOTION TO WITHDRAW MOTION FOR LEAVE TO FILE AMICI 
CURIAE BRIEF 

AND FOR LEAVE TO FILE A BRIEF OF APPELLEE-INTERVENORS 

Ronald Chisom, Walter Willard, Henry Dillon, III, and the Louisiana Voter 

Registration/Education Crusade ("Appellee-Intervenors") respectfully request that its 

outstanding motion for leave to file an amici curiae brief be withdrawn and that leave be 

granted in order to file a brief as Appellee-Intervenors. 

On March 4th, Appellee-Intervenors filed a motion to intervene in this action. Motion 

To Intervene As Appellees, filed March 4, 1998. Before this Court had an opportunity to rule 



Nik 

on this motion, the Appellee-Intervenors also filed a motion for leave to participate in this 

action as amici curiae, in order to ensure compliance with the briefing schedule for the instant 

action. Motion For Leave To File A Brief Amici Curiae, dated April 17, 1998. On April 24, this 

Court granted Appellee-Intervenors motion to intervene in the present action as appellees. 

Order, April 24, 1998. This order renders moot the outstanding motion by the same parties to 

participate in this case as amici curiae and thus, Appellee-Intervenors seek to withdraw this 

motion. However, in order for Appellee-Intervenors to have an opportunity to respond to the 

brief filed by Appellant Perschall in this matter, Appellee-Intervenors also now move for leave 

to file the accompanying Brief of Appellant-Intervenors.1 

Respectfully submitted, 

William P. Quigley 
Loyola University School of Law 
7214 St. Charles Avenue 
New Orleans, LA 70118 
(504) 861-5590 

Elaine R. Jones 
Director-Counsel 
Norman J. Chachkin 
Charles Stephen Ralston 
Victor A. Bolden 
Jacqueline A. Berrien 
NAACP Legal Defense & Educational Fund, Inc. 
99 Hudson Street 
Suite 1600 
New York, New York 10013 
(212) 219-1900 

Ronald L. Wilson 

'Appellee-intervenors have sought the consent of both the Appellant and the Appellee and 
neither have expressed opposition to this motion. 

2 



837 Gravier Street 
New Orleans, LA 70113 
(504) 586-1241 

Counsel for Appellee-Intervenors 



S 
CERTIFICATE OF SERVICE 

I hereby certify that copies of the foregoing MOTION TO WITHDRAW MOTION FOR 

LEAVE TO FILE AMICI CURIAE BRIEF AND FOR LEAVE TO FILE BRIEF OF APPELLEE- • 

INTERVENORS, have been served by depositing same in the United States mail, first class postage 

prepaid, on this May 5, 1998, addressed to the following: 

Clement F. Perschall, Jr., Esq. 
One Galleria Boulevard 
Galleria One, Suite 1107 
Metarie, Louisiana 70001 
Telephone: (504) 836-5975 

Richard P. Ieyoub 
Attorney General, State of Louisiana 
State Capitol 
P.O. Box 94005 
Baton Rouge, Louisiana 70804-9005 

Robert McDuff, Esq. 
767 N. Congress Street 
Jackson, Mississippi 39202 
Telephone: (601) 969-0802 

Peter Butler (Bar# 3731)-T.A. 
Peter J. Butler, Jr. (Bar# 18522) 
Richard G. Passler (Bar# 21006) 
LL&E Tower, Suite 2400 
909 Poydras Street 
New Orleans, Louisiana 70112 
Telephone: (504) 584-5454 

Tyron D. Picard (Bar# 20473) 
Mark Stipe (Bar# 19803) 
Petroleum Tower, Suite 330 
3639 Ambassador Caffrey Parkway 
Lafayette, Louisiana 70503 
Telephone: (318) 983-0090 

VICTOR A. BOLDEN 



RIF MAY 2 2 19 

No. 98-30004 

IN THE 
UNITED STATES COURT OF APPEALS 

FOR THE FIFTH CIRCUIT 

CLEMENT F. PERSCHALL, JR., 

Plaintiff-Appellant, 

V. 

STATE OF LOUISIANA, 

Defendant-Appellee 

and 

RONALD CHISOM, ET AL. 

Appellee-Intervenors - 

On Appeal from the 
United States District Court 

for the Eastern District of Louisiana 

U. S. COURT OF APPEALS 

FILED 

MAY 6 '1998 

CHARLES R. FULBRUGE III 

CLERK 

MOTION TO WITHDRAW MOTION FOR LEAVE TO FILE AMICI 
CURIAE BRIEF • 

AND FOR LEAVE TO FILE A BRIEF OF APPELLEE-INTERVENORS 

Ronald Chisom, Walter Willard, Henry Dillon, III, and the Louisiana Voter 

Registration/Education Crusade ("Appellee-Intervenors") respectfully request that its 

outstanding motion for leave to file an amici curiae brief be withdrawn and that leave be 

granted in order to file a brief as Appellee-Intervenors. 

On March 4th, Appellee-Intervenors filed a motion to intervene in this action. Motion 

To Intervene As Appellees, filed March 4, 1998. Before this Court had an opportunity to rule 



on this motion, the Appellee-Intervenors also filed a motion for leave to participate in this 

action as amici curiae, in order to ensure compliance with the briefing schedule for the instant 

action. Motion For Leave To File A Brief Amici Curiae, dated April 17, 1998. On April 24, this 

Court granted Appellee-Intervenors motion to intervene in the present action as appellees. 

Order, April 24, 1998. This order renders moot the outstanding motion by the same parties to 

participate in this case as amici curiae and thus, Appellee-Intervenors seek to withdraw this 

motion. However, in order for Appellee-Intervenors to have an opportunity to respond to the 

brief filed by Appellant Perschall in this matter, Appellee-Intervenors also now move for leave 

to file the accompanying Brief of Appellant-Intervenors.' 

Respectfully submitted, 

No&s\  
William P. Quigley 
Loyola University School of Law 
7214 St. Charles Avenue 
New Orleans, LA 70118 
(504) 861-5590 

Elaine R. Jones 
Director-Counsel 
Norman J. Chachkin 
Charles Stephen Ralston 
Victor A. Bolden 
Jacqueline A. Berrien 
NAACP Legal Defense & Educational Fund, Inc. 
99 Hudson Street 
Suite 1600 
New York, New York 10013 
(212) 219-1900 

Ronald L. Wilson 

'Appellee-intervenors have sought the consent of both the Appellant and the Appellee and 
neither have expressed opposition to this motion. 

2 



S 
837 Gravier Street 
New Orleans, LA 70113 
(504) 586-1241 

Counsel for Appellee-Intervenors 

3 



CERTIFICATE OF SERVICE 

I hereby certify that copies of the foregoing MOTION TO WITHDRAW MOTION FOR 

LEAVE TO FILE AMICI CURIAE BRIEF AND FOR LEAVE TO FILE BRIEF OF APPELLEE-

INTERVENORS, have been served by depositing same in the United States mail, first class postage 

prepaid, on this May 5, 1998, addressed to the following: 

Clement F. Perschall, Jr., Esq. 
One Galleria Boulevard 
Galleria One, Suite 1107 
Metarie, Louisiana 70001 
Telephone: (504) 836-5975 

Richard P. Ieyoub 
Attorney General, State of Louisiana 
State Capitol 
P.O. Box 94005 
Baton Rouge, Louisiana 70804-9005 

Robert McDuff, Esq. 
767 N. Congress Street 
Jackson, Mississippi 39202 
Telephone: (601) 969-0802 

Peter Butler (Bar# 3731)-T.A. 
Peter J. Butler, Jr. (Bar# 18522) 
Richard G. Passler (Bar# 21006) 
LL&E Tower, Suite 2400 
909 Poydras Street 
New Orleans, Louisiana 70112 
Telephone: (504) 584-5454 

Tyron D. Picard (Bar# 20473) 
Mark Stipe (Bar# 19803) 
Petroleum Tower, Suite 330 
3639 Ambassador Caffrey Parkway 
Lafayette, Louisiana 70503 
Telephone: (318) 983-0090 

VICTOR A. BOLDEN

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