Motley, Constance Baker; and Others, 1962-1975, undated - 60 of 76

Photograph
January 1, 1962 - January 1, 1975

Motley, Constance Baker; and Others, 1962-1975, undated - 60 of 76 preview

Photo by Clifton Cabell

Front of photograph

Cite this item

  • Legal Department General, Lani Guinier Correspondence. Correspondence from Lani Guinier to Dr. Thomas Hilliard Re United States v. Turner 1, 1985. 2146e7a8-e792-ee11-be37-6045bdeb8873. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/ddac10dd-f6b3-47eb-a0cf-63f685ef82fc/correspondence-from-lani-guinier-to-dr-thomas-hilliard-re-united-states-v-turner-1. Accessed August 19, 2025.

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    Lesa,UDrenseH.
April 30r 1985

Dr. Thomas Hilliard
3528 Sacramento Street
San Francisco, California 941I8

R.E: United States v. Turner et aI.
Dear Dr. Hilliard:
I enjoyed meeting you.

r tarked with Margaret carey about the financial arrange-
ments which the center for constitutional Rights and the
Legal Defense Fund can make regarding your testimony and
expert assistance. As r understand my conversation withyou at the airport, you are prepared to do the following
to assist the defendants spencer Hogue and Evelyn Turner:

t. Review motions, pleadings, transcripts
filed in the casei

2. review attorney summaries, profiles and otherinternal memoranda;

3. interview selected witnesses to evaluate mental
status and administer memory examination;

. 4. prepare a report and/or affidavit based on your
interviews and on a review of literature in the field;

5. pre-tria1 consultation;

6. testimony re: (a) how witnesses respond to
authority figures, how witnesses respond when expectations
are uncertain, how witnesses require structured question-
ing to assist memory, how witnesses communicate voruntary
deference to and support position of perry county civic
League community leaders, (b) competence to testify of
specific witnsses.

Contributions are deductible lor U.S. income tar purposes

The NAACP LEGAL DEFENSE & EDUCATIoNAL FUND is not part of the National Association lor the Advancemenl ol Colored People although il
was founded by it and shares ils commitmenl to equal rights. LDF has had lor over 25 years a separate Board, pIogram, stall, ollice and budget.

NAACP LEGAL DEFENSE AND EDUCATIONAL FUND. INC.

99 Hudson Street, New york, N.y. 10013o(212) 21$.1900

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