Letter from Lani Guinier to William Quigley RE Valteau v. Edwards

    LesalE&renseH.

September 4, 1984

William P. Quigley, Esq.
631 St. Charles Avenue
New Orleans, LA 70130

Re: Valteau v. Edwards

Dear Bill:

I write
my time

to elaborate on my hourly rate of $160.00 for
in Valteau v. Edwards.

NAACP LEGAL DEFENSE AND EDUCATIONAL FUND, INC.

99 Hudson Street, New York, N.Y. 10013o(212) 219.1900

I spent the bulk of my time in this case preparing
for filing in the United States Supreme Court, the
appellee's Opposition to the Stay Application. Of
the 2l- hours I spent on this case, I spent 18 contin-
uous hours, from 10:00 A.M. , until 4:00 A.l{., drafting
the papers, supervising the legal research of two 1aw
students, one of whom was in D.C., and reviewing
arguments and strategies over the telephone with you
(from New Orleans) and Armand (from South Carolina).
As you know, I assumed the yeoman's share of the
responsibility for drafting and ultimately filing the
papers in the Supreme Court since Armand Derfner was
out of town at a court hearing in South Carolina.

we filed a 24 page Memorandum in Opposition, with 4
exhibits, dt 8252 A.III., the following day. The Court
ruled in our favor that afternoon. No attorney in New
Orleans could have achieved such expeditious filing on
such short notice. The attorney with whom we worked
in Washington, D.C., while profoundly knowledgeable in
this area, tsds travelling within the reguisite 24 hour
time-frame, and was not available to draft a lengthy
and substantive response. Even within the New York area,
few members of the bar would be able to undertake, on a
contingent fee basis, the preparation of a response to
a Stay Application in a voting rights case within 24 hours.

Contribr1iorrs ort' deductiblt./trr I'.S. inutntr lat pxrpoNcs

The NAACp LEGAL DEFENSE & EDUCATIONAL FUND rs not part of the National Assoctation lor the Advancement of colore.d People although it

waltoundeOUyitandsharesitscommitmentloequalrights LDFhashadlorover25yearsaseparateBoard,program,statf,olliceandbudget



William P. Quig1ey, Esg. -2- September 4, 1984

I believe that $160.00 per hour is reasonable for a
specialist in voting rights'litigation practicing in
New York, who is willing to put aside other cases and
commitments to work through the night to file appellee's
opposition.

I trust this will assist you in explaining in greater
detail the role r played in this litigation. I enclose
a copy of my affidavit in l{ajor v. Treen which discusses
my qualifications and in paragraph 2 the role LDF has
played in the voting rights area. Please 1et me know if
you need more information.

Sincerely,

Lani Guinier

LG/ r
Enclosure