Motley, Constance Baker; and Others, 1962-1975, undated - 60 of 76
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January 1, 1962 - January 1, 1975

Photo by Clifton Cabell
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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