Memorandum from Winner to Suitts, Chambers, Williams, Klein, and Guinier; from Quigley to Williams; from Henderson to Quigley; from Henderson to Kwan

    }IEMORANDUIT{

TO: Steve Suitts, Julius Chambers, Napoleon Williams,
Richard Klein add Lani Guinier
Leslie winner ,(NFROM:

RE: North Carolina Reapportionment
DATE: March 3, L982

Attached is a draft supplement to the Complaint. If you

call me with comments by Monday, I will try to have a second

draft for f inalizing by our meetinqi'on March g, 1982.



MLLTAM P. QUIGLEY
STEVEN SCHECKMAN

IN ASSOCI.ATION VTH:
R. JAMES KELLOCC

MARK S. GOLDSTEIN

March 4, L982

Napoleon B. Williams
Legal Defense Fund
Suite 2030
10 Columbus Circle
New York, New York 10019

Dear Mr. Williams:

On February L9, Robert Kwan of the Justice Department called
and said that it was very important that we have maps of the
Henderson PIan to him within the next two to three d.ays so
that he could present them to the appropriate officials at the
Justice Department. These maps were necessary in order to show
that the Henderson Plan was not defective in some way and there-
fore should not be compared to the state reapportionment p1an.

At his request I contacted Gordon Henderson and asked him to
prepare maps for the Justice Department's review. I ca11ed him
on a Friday and told him that this had to be in the mail on
I{onday. He cooperated immediately and forwarded these maps to
the Justice Department.

It a1so, had to make a trip to Baton Rouge to get a statewide
map which I mapped out showing the districts as they appeared
on a map similar to the one the Justice Department had. Alt of
these maps were Federal Expressed to the Justice Department to
enable them to make the appropriate comparisons of reapportion-
ment p1ans. I am enclosing a bill from Gordon Henderson for the
time expended in this matter. It was over and above the time
spent which has already been bil1ed. I think its important to
point out that this was done at the request of the Justice Depart-
ment so there was rea1ly no choice in the matter whether this
work should be done.

LAIiY OFFICES OF

QUIGLEY & SCHECKMAN
6]I ST. CHARLES AVENUE

NEW ORLEANS, LOUISIANA 70130

TELEPHONE: tM.524{0t6

questions about this bill, please feel free to
I will explain anything.

If you have any
t me and

ely,

Iliam P. Quigley

Enclosure

cc: Gordon Henderson

wPQ/ lag



-t

TO: I{1111an Qulgley
c/o Schrckrn & Qtrlglcy
531 St. Chrrlor Ancntn
t&w Orlotnr Lanletrtr 70130

FR0M: Gordqr G. llmdcreon
220 South 19th
Rlchnrond IN 47374

RE: Pr.eparlng tnp. for Jurttse

DATE: Febnrary 26 , L9E2

STATETTIENT

TI}8:

Preprrlng nps rcqrrrtcd by lobcrt Knn
of Justlce llepertrtrt

1 day pluc 5 hcrrr $ 350.00 $
250.00 600.00

TI(PEIISES:

hrrolator Sky Courter ehlpn:nt to Robert
Kllen. (TeLephone con\rcraatton betrreen
Kruen and Herdcrscr cqrftrnr rhlpcnt was
recelvcd. ) Bccclpt cnclolcd. 29.00

Total $ 629.00



TO: Honorable Rohert Kwan

FROM: Gordon G. Henderscn for Wtlllam fot81ey
220 South 19th
Rtchmond IN 47374

DATE: FebruarT 22, L982

RE: Louls{ana submlsslcn under Sectlon 5

At the request of Mr. IlJllllann QuJ3leYr 3r aEtorney ln the law flrm
of eulgley and Schec'<nan, of New drleans, I am sendinc! y!'ouenclosed

herewl th:

1. A large htqhrmy rnap of Lotr{olana'

2. A map shorlnq parrsh hotrnclar{es (traced hy nre from Ehe

hlghrmy map $ust mentforea) on wtrtch aPpears (a) lndlcaEed
by yeliol.r iri., the botrndartes of dtstrlcts f or the Louls{ana
House of Representattves as def{ned ln Ehe Hendersori Hottse

;i;;-subrnrrted earller, and (U) tnd{ca!:d bI qedenun:unbers

the number of each such dlsErlct accirafn"{ Eo the salne

Henderson llouse Plan'

3. llaps of those parlshes {n r^trtch Ehere are noptrlattons larqe
eno,rgh to support several le'i{slatf ve d{str{cts narnely

orleans, Jefferson, ouachr Ea r caddo, calcas{etr, I-sfayette
arrd East Baton RcuSe'

4. Seven sheets of Papers eachr 85 wlll he ohvlotrs, llst{ng
' the "f."*ic" 

(t-ltshes, "td" and/or preclncts) aef {nlnq
a dlstrict under the Henderscn House p1an. These are belng
Senc becatrse when I went Eo draw Ehe encl0sed rnans, r
dlscovered thaE rTy own perscrral coDy of the Henderson i{ouse

plan dtd not {n every case ccrtEaln Ehe last dlsEr{ct ruade

and I do not lrranE to- tatce the chance tkrat the cony of the-

Henderson Horrse plan wtr{ch r senE Eo Mr. Quiqley and r'ukrlch

was forwardecl to you does not stmtlarly contarn noE the
last dlstrlcEs drawn'

If you shotrld lrave any questlons ahctrt any aspect of uttat {s
eirClosed <yr about the wor'- done by nre earller tn Ehls srea'
please do noE hesi.EaEe to call trron tte for ftrther exfrlanatlcrt
or asslstance. I w111 be more than happy to cooperaEe'

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