Letter to Kenneth DeJean from James Kellogg RE Request for Production of Documents

Correspondence
July 26, 1982

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Letter to Kenneth DeJean from James Kellogg RE Request for Production of Documents preview

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  • Case Files, Major v. Treen Hardbacks. Letter to Kenneth DeJean from James Kellogg RE Request for Production of Documents, 1982. 9ffec887-5b02-ef11-a1fd-6045bddc4804. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/427df6c7-1b28-4ca7-b9a4-24fe77a34942/letter-to-kenneth-dejean-from-james-kellogg-re-request-for-production-of-documents. Accessed November 05, 2025.

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    LAW OFFICES OF 

QUIGLEY & SCHECKMAN 
631 ST. CHARLES AVENUE 

NEW ORLEANS, LOUISIANA 70130 

TELEPHONE: 504-524-0016 

WILLIAM P. QUIGLEY IN ASSOCIATION WITH: 
STEVEN SCHECKMAN R. JAMES KELLOGG 

MARK S. GOLDSTEIN 
. RONALD J. PURSELL 

July 26, 1982 

Kenneth C. DeJean 

Chief Counsel 

Department of Justice 

P. 0. Box 44005 

Baton Rouge, LA 70804 

Re: Major v. Treen, (Congressional) 
  

Dear Ken: 

On June .ll, 1982, I served on you and David Poynter a Request for Production 
of Documents. The Request covered essentially the same documents which were 
submitted by the Governor to the United States Department of Justice. Although 
under Rule 34 of the Federal Rules of Civil Procedure, you had thirty (30) days 

within which to reply, you still have not done so. I have spoken with you, 

your secretary, and members of David's staff concerning the importance of a 
timely response to this request, but the documents still have not been delivered. 

On our latest conversation on July 20, I stated to you that I would gladly 

have someone come to Baton Rouge to pick up the documents, and you promised 

you would get back to me and let me know when they would be assembled. You 
still have not done so. 

Accordingly, due to your failure to respond to ligitimate discovery requests, 

I feel T must notify you of a conference planned for purposes for amicably 

resolving this issue under Rule 3.11 of the Local Rules of the Eastern Dis- 

trict of Louisiana. I have scheduled that conference in my office for Wed- 

nesday, July 28, at 10:00 a.m. I am also sending a copy of this letter to 

Dave and to Marty Feldman so that they are also put on notice. If this 

time is inconvenient, please get with me immediately, so that one can be 

scheduled before Friday, July 30. 

It should be obvious that, unless each of the documents requested are made 
available to us before 12:00 noon on Friday, July 30, we will proceed with 

appropriate Motion to Compel. I sincerely regret that this action is necessary,  



Major v. Treen 

Page 2 

but I am sure that you realize how important your timely response to ligitimate 

discovery requests is. 

Thank you for your prompt attention to this matter. 

Sincerely, 

R. James Kellogg 

/mc 

cc: Martin Feldman 

David Poynter 

Lani Guinier 

Stanley Halpin 

Steven Scheckman 

William P. Quigley

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