Correspondence from Menefee to Bowers

    BLACKSHER, MENEFEE & STEIN, P.A. 

ATTORNEYS AT LAW 

405 VAN ANTWERP BUILDING 

P. O. BOX 1051 

MOBILE, ALABAMA 36633 

JAMES U. BLACKSHER November 13, 1984 TELEPHONE 
LARRY T. MENEFEE (205) 433-2000 

GREGORY B. STEIN 

Patricia Bowers, Esq. 
Assistant Attorney General 
234 Loyola Avenue 
New Orleans, Louisiana 70112 

Re: Major v. Treen 
  

Dear Patricia: 

Please find enclosed the notice of deposition which I discussed 
with you on the telephone. First, I wish to confirm that I am 
very agreeable to your producing the bills and statements 
reflecting the fees paid to and the services rendered by private 
counsel in this action. They in all likelihood will satisfy my 
inquiry under paragraph 1 of the notice of deposition. I would 
like a statement from you concerning the extent to which 
Mr.Feldman and any other private attorneys who appeared in this 
action have done work for the state of Louisiana or its officials 
during the past several years. My inquiry is whether this was 
one piece of specialized litigation which Mr.Feldman and others 
handled for the state of Louisiana or did he regularly perform 
this and other work for the state and its officials, and if so, 
give me some reasonable idea of the extent of that 
representation, such as the amount of fees billed during 1982, 
and perhaps the total number of cases he handled. 

As to the second item of inquiry in the deposition, I understand 
you may decide to file a motion to quash or other similar 
motion. Please let me know and I will be glad to handle that 
either in person or by telephone conference with the Court before 
the deposition, or you can wait until the deposition, hear the 
specific formulation of the questions and state your objection, 
and we can th present it to the Court. 

wid Nov-29T+ 
I want to also confirm the deposition of Lani Guinier for 11:00 
a.m. E.S.T., at the Washington, D.C. offices of the NAACP Legal 
Defense Fund, which are located at 806 15th Street, N.W., Suite 
94uv, Washington, D.C. I assume you will make the necessary  



Patricia Bowers, Esq. 
November 13, 1984 

arrangements for a court reporter, etc. As I stated over the 
phone, we are proceeding with this deposition without expecting a 
prepayment of costs and fees from the state, under the 
expectation that it will be a deposition of moderate length, 
e.g., two to four hours. If the deposition runs much longer, you 
understand that we may bill the state for payment of the fees and 
associated expenses. 

I have spoken with Stan Halpin and you may depose him on the 
morning of Monday, November 26, 1984, in New Orleans. Please let 
us know immediately if you wish to do so. 

If you wish to take Armand Derfner's deposition, he is located in 
Washington, D.C., and if you will promptly notify me, I expect he 
can be available under the same conditions as Lani Guinier. 

Also enclosed is the redrafted stipulation of fact. I believe it 
correctly reflects our agreement. However, if you find any 
problems, please let me know. I am disappointed that we cannot 
agree to any of the hours or any of the expenses. If your 
position on this issue changes, please let me know. If this 
draft is acceptable, please sign, file it and send me a copy of 
the signed document. 

Best regards. 

Sincerely, 

BLACKSHER, MENEFEE & STEIN, P.A. 

Larry T/. Menefee 

EnCls. 

LTM:pfm 

CC: William P. Quigley, Esq. 
Steven Scheckman, Esq. 
R. James Kellogg, Esq. 
Stanley Halpin, Esq. 
Lani Guinier, Esq. 

Armand Derfner, Esq.