Notice to Take Deposition

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EASTERN RCT COURT 

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IN THE UNITED STATES piri S387? 

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FOR THE EASTERN DISTRICT OF (LQUISIANA 

BARBARA MAJOR, et al., CIVIL ACTION NO. 82-1192 
: SECTION Fc) 

Plaintiffs, 

THREE JUDGE COURT CASE 
  

- against - 

CLASS ACTION   
DAVID C. TREEN, =2tc.; et al. 

Defendants. 

NOTICE TO TAKE DEPOSITION 
  

Martin L.C. Feldman 
Bronfin, Heller, Feldman & 

Steinberg 
624 Whitney Bldg. 
New Orleans, La. 70130 

PLEASE TAKE NOTICE that plaintiffs in this matter will take 

the following depositions upon oral examination: ROBERT N. KWAN, 

Attorney, U.S. Department of Justice, Civil Rights Division Voting 

Section, on the 16th day of December, 1982 at 9:30 a.m.; GERALD 

W. JONES, Voting Section Chief, Civil Rights Division, at 1:30 p.m. 

on the 16th day of December, 1982 or as soon as Mr. Kwan's 

deposition is completed; WM. BRADFORD REYNOLDS, Assistant Attorney 

General, Civil Rights Division, U.S. Department of Justice at 

9:30 a.m. on the 21st day of December, 1982 and GERALD HEBERT, 

Attorney, Voting Section, Civil Rights Division, Department of 

Justice at 1:00 p.m. on the 22nd day of December, 1982, at 806 

15th Street, N.W., Suite 940, Washington, D.C. 20005, or at some 

other mutually convenient place in the District of Columbia. 

The deponents are requested to bring with you all documents 

of any kind which you have in your possession which relate to 

review under Section 5 of the Voting Rights Act, 42 U.S.C. §1973 

of the submission by the State of Louisiana of its congressional    



  

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redistricting plan. This request includes but is not limited to 

correspondence, memoranda or other writings of deponents in con- 

nection with this submission. In addition, please bring any and 

all memoranda of telephone conversations, interview notes, notes 

to the file, memoranda and telephone logs of and travel vouchers 

for meetings with representatives of the State of Louisiana on the 

subject of this submission or during the year preceding the letter 

of preclearance as well as any memoranda, telephone logs, travel 

vouchers and notes to file pertaining to any meetings on any 

subject with the defendant Governor Treen or with any other persons 

with knowledge relating to the congressional redistricting plan, 

and any memoranda summarizing the facts of the submission, and 

documenting any inferences to be drawn from the facts. 

Plaintiff seeks deponents' testimony to determine the facts 
and inferences 
that underlie or form the basis for the June 18, 1982 decision of 

the Assistant Attorney General not to object to the submission. 

Plaintiff also is attempting to determine with whom deponents met 

or discussed the facts of the submission and the circumstances of 

those meetings and to adduce all evidence that may assist us in 

proving that the redistricting plan is discriminatory in purpose 

and/or result. This summary of the testimony is provided pursuant 

to 28. .C.P.R 16.22. 

These depositions will be taken for discovery purposes before 

a person authorized to administer oaths, and will continue from 

day to day until completed. You are invited to attend and cross- 

examine. 

Dated: December 7 ; 1982 

Respectfully submitted, 

R. JAMES KELLOGG 

WILLIAM P. QUIGLEY 

STEPHEN SCHECKMAN 

STANLEY HALPIN 

631 St. Charles Avenue 
New Orleans, Louisiana 70130     
   



  

  
      

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JACK GREENBERG 

JAMES M. NABRIT 

LOWELL JOHNSTON 

LANI GUINIER 

10. Columbus Circle 
Suite 2030 

New York, New York 10019 

) 

Lk A F tm rney for Plaimtjffs 
  

  

CERTIFICATE OF SERVICE 

I certify that I have served the foregoing document on all 

other parties and the United States Attorneys for the District of 

Columbia and the Eastern District of Louisiana by placing a copy 

thereof enclosed in a postage prepaid properly addressed wrapper 

in a post office or official depository under the exclusive care 

and custody of the United States Postal Service, addressed to: 

Martin L.C. Feldman 

Bronfin, Heller, Feldman & Steinberg 
624 Whitney Building 
New Orleans, La. 70130 

John Volz 
United States Attorney 
500 Camp Street 
New Orleans, La. 70130 

Stanley S. Harris 
United States Attorney 
District of Columbia 
U.S. Courthouse, Room 3600-E 

3rd and Constitution Ave., N.W. 
Washington, D.C. 20001 

day of December, 1982 

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Atyoyrsy for Plaingitfs