Correspondence from Quigley to Pugh; Request for Production of Documents; Request to Admit

Public Court Documents
October 25, 1988

Correspondence from Quigley to Pugh; Request for Production of Documents; Request to Admit preview

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  • Case Files, Chisom Hardbacks. Correspondence from Quigley to Pugh; Request for Production of Documents; Request to Admit, 1988. 035a0274-f311-ef11-9f8a-6045bddbf119. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/1f763d96-6ad1-4c97-8aba-14ada3b9a29c/correspondence-from-quigley-to-pugh-request-for-production-of-documents-request-to-admit. Accessed April 06, 2025.

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    WILLIAM PATRICK QUIGLEY 
ATTORNEY AT LAW 

FULTON PLACE - SUITE 119 

901 CONVENTION CENTER BOULEVARD 

NEW ORLEANS, LOUISIANA 70130 

IN ASSOCIATION WITH: 
CATER 64. WILLIS 
A PROFESSIONAL LAW CORPORATION 
R. GLENN CATER 
JENNIFER N. WILLIS 
(504) 524-9447 October 25, 1988 

Mr. Robert Pugh 
Special Assistant Attorney General 
330 Marshall St., Suite 1200 
Shreveport, LA 71101 

RE: Chisom v. Roemer  
USDC# 86-5075 "A" 

Dear Bob: 

TELEPHONE: (504) 524-0016 

Enclosed please find a single request for production of 
documents and a request to admit two statements regarding sign-in 
data in Louisiana elections. 

If you have any questions, please feel free to contact me. 
Thank you for providing us with the requested material last 

week. 

Sincerely, 

William P. Quigley 

WPQ/jbc 

Enclosures 

cc: All counsel of record 



UNITED STATES DISTRICT COURT 

EASTERN DISTRICT OF LOUISIANA 

RONALD CHISOM, et al., 
Plaintiffs 

Versus 

BUDDY ROEMER, et al., 
Defendants 

To: 

CIVIL ACTION 

NUMBER 86-5075 

SECTION "A" 

REQUEST FOR PRODUCTION OF DOCUMENTS  

All defendants 
through counsel for State of Louisiana 
Robert Pugh 
Special Assistant Attorney General 
330 Marshall St., Suite 1200 
Shreveport, LA 71101 

PLEASE produce, at undersigned counsel's office, within 15 

days within the reception of this document the following: 

REQUEST NO. 1  

All sign-in data by precinct for Orleans Parish for the 

October 1, 1988 elections. 

Respectfully submitted, 

William P. Quigley 
Bar Number 7769 
Counsel for Plaintiffs 
901 Convention Center Blvd. 
Fulton Place, Suite 119 
New Orleans, LA 70130 
(504) 524-0016 



UNITED STATES DISTRICT COURT 

EASTERN DISTRICT OF LOUISIANA 

RONALD CHISOM, et al., 
Plaintiffs 

Versus 

BUDDY ROEMER, et al., 
Defendants 

To: 

CIVIL ACTION 

NUMBER 86-5075 

SECTION "A" 

REQUEST TO ADMIT  

All defendants 
through counsel for State of Louisiana 
Robert Pugh 
Special Assistant Attorney General 
330 Marshall St., Suite 1200 
Shreveport, LA 71101 

PLEASE admit the truth of the following statements within 15 

days in accordance with the Federal Rules of Civil Procedure, 

Rule 36: 

1. Sign-in data for individual voters who voted in past 

Louisiana elections but who are no longer registered to vote are 

not now available. 

2. Sign-in data by precinct is available for only Louisiana 

elections which have been held in 1988. 

Respectfully submitted, 

William P. Quigley 
Bar Number 7769 
Counsel for Plaintiffs 
901 Convention Center Blvd. 
Fulton Place, Suite 119 
New Orleans, LA 70130 
(504) 524-0016

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