Correspondence from Pamela Karlan to Tim Humphries, Esq. Re Whitfield v. Clinton

Correspondence
January 25, 1988

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Correspondence from Pamela Karlan to Tim Humphries, Esq. Re Whitfield v. Clinton preview

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Collection
- Legal Department General
Creator
- Lani Guinier and others
Taxonomy
Identifier
- a96cdf30-ec92-ee11-be37-6045bdeb8873

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Legal Department General, Lani Guinier Correspondence. Correspondence from Pamela Karlan to Tim Humphries, Esq. Re Whitfield v. Clinton, 1988. a96cdf30-ec92-ee11-be37-6045bdeb8873. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/3b9e8d08-bf65-4a43-9525-55a64f969f3f/correspondence-from-pamela-karlan-to-tim-humphries-esq-re-whitfield-v-clinton. Accessed May 12, 2025.

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January 25, 1988

Tim Humphries, Esg.
Office of the Attorney GeneraJ.
State of Arkansas
2ol East Markham Street
Heritage West Building
Little Rock, Arkansas 72201

Re: I,lhitf ield v. Clinton

Dear Mr. Humphries:

f have spoken to Dr. Engstrom, and he js prepared to be
deposed on the morning of Saturday, February 6,1988, in New
Orfeans, Loujsjana. Dr. Engstrom's office wiIL be cl.osed that
day. Therefore, 1zou should arrange to take the deposjtion at
another Location (perhaps a room at your hotel). Dr. Engstrom
will bring the materials you mentioned in your Letter of January
15, 1988. I remind you of our Third Supplementa.l. Responses to
Defendants'Expert 9{itness Interrogatories 36 and 37 regardinE
data prepared spec:aj.1y by the Bureau of the Census and purchased
by plaintiffs.

When Dr. Engstrom's deposition had originally been scheduLed
for February L, 1988, lou had agreed to inform plaintiffs of your
decjsion whether to retain a:: expert within one week of deposj.ng
Dr. Engstrom (and therefore prior to February 10, 1988, when the
pretrjaL jnformation sheet is due), and to make your expert
available for deposition a reasonable time thereafter. By
agreeing to reschedu-le at your request, wB are not waiving any
claims that we have to be informed by February 10, l.988, of alL
the witnesses you intend to caLl. AccordingJy, w€ are producing
Dr. Engstrom for deposition after the discovery per:.od under the
unCerstanding:

( 1 ) that you will inform us no Late:' than
February 10, 1988, whether you have decideo
to retain an expert who will. testify at
trial, and, if you have, the identity of any
such experts;

(2) that you will timely supplement your
responses to plaintiffs' Interrogatories 31

NINETY NINE HUDSON STREET, 16th FLOOR o (2121219'1900 . NEW YORK, N.Y. 10013

Tim Humphries, Esg.
January 25, 1988
Page 2

(3)

and 32 (regarding expert witnesses);

that you will inform us as soon as your
expert has completed his or her analysis;

(4) that you will make your expert available fordeposition at plaintiffs, convenience and at
least one week prior to the trial in this
case.

rf you have any probl.ems with this, fet us know by Februaryl, 1988. otherwise, please mail a signed copy of this letter t;us in time to arrive prior to Dr. Engstrom's deposition.
As for Dr. Gates, plaintiffs witl produce her for adeposition at a time that is mutuarly convenient for her, you,

and us.

r expect to hear from you concerning the logistics of Dr.
Engrstrom' s deposition

cc: All counseL

Agreed:

Si4pqreIy,

,"Jd*,l,Sl,l+L
Attorney for Plaintiffs

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Correspondence from Pamela Karlan to Tim Humphries, Esq. Re Whitfield v. Clinton

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