Correspondence from Karlan to Quigley; Affidavit of Pamela S. Karlan; Certificate of Good Standing of Karlan

    • 

egal 
NAACP LEGAL DEFENSE AND EDUCATIONAL FUND, INC. 

efense und 99 HutitOri Street, New York, N.Y. 10013 • (212) 219-1900 

April 6, 1987 

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

Re: Chisom v. Edwards  

Dear Bill: 

I am sending you a certificate of good standing from the 
S.D.N.Y. and an affidavit so that you can prepare a motion for me 
to appear pro hac vice to argue the motion to dismiss in Chisom. 

I called the Judge's chambers this morning and the secretary 
said we're on for 10:00 a.m. on the 15th. I'm planning to come 
down the evening before. Could we meet early the morning of the 
15th to go over things? If it would be more convenient for you, 
I could fly down earlier on the 14th. 

As you may have heard by now, we won (with respect to 8 
districts) the Mississippi judicial elections case, Martin and  
Kirksey v. Allain. The judge's 47-page opinion, a copy of which 
I'm also sending you, contains only a brief discussion of the 
applicability of § 2 to judicial elections. See pp. 35-36. It 
might be worth serving the opinion on the court and the 
defendants. Let me know if you want me to do that, and I can get 
it photocopied and sent out from here. 

Please give me a call when you're free. I'll be in the 
office every day this week except Friday, when I'll be in D.C. I 
aook forward to seeing you next week. 

cerely, 

W AA.-
Pamela S. Karlan 

Contributions are deductible for U.S. income tax purposes 

The NAACP Legal Defense & Educational Fund, Inc. (LDF) is not part of the National Association for the Advancement of Colored People (NAACP) although 
LDF was founded by the NAACP and shares its commitment to equal rights. LDF has had for over 25 years a separate Board, program, staff, office and budget. 



UNITED STATES DISTRICT COURT 
EASTERN DISTRICT OF LOUI'SIANA 

RONALD CHISOM, MARIE BOOKMAN, 
WALTER WILLARD, MARC MORIAL, 
LOUISIANA VOTER REGISTRATION/ 
EDUCATION CRUSADE, and HENRY A. 
DILLON, III, 

Civil Action 
Plaintiffs, Number: 86-4075 

Section "A" 
V . 

EDWIN EDWARDS, in his capacity as : 
Governor of the State of Louisiana,: 
JAMES H. BROWN, in his capacity as : 
Secretary of State of the State 
of Louisiana, and JERRY M. FOWLER, 
in his capacity as Commissioner of : 
Elections of the State of 
Louisiana, 

Defendants. 

Class Action 

AFFIDAVIT 

I, Pamela S. Karlan, being duly sworn, do hereby state: 

1. I make this affidavit in support of a motion to appear 

and participate in the above-captioned litigation, pursuant to 

Rule 21.5, Loc. R. E.D. La. 

2. I am admitted to practice in the State of New York, 

where I am in good standing, as well as in the United States 

District Court for the Southern District of New York and the 

United States Court of Appeals for the Eleventh Circuit, where I 

am also in good standing. 

3. I hereby certify that no disciplinary proceedings or 

criminal charges have been instituted against me. 

Subscribed to before me this 
EK_ day of April, 1987. 

N 

1,/cuL c) irc;ADAA-

Public 

. REED 
te of New York 

No. 60-4640840 
Qualified In Westch.ezler 

Commission Expires 

unty 



AO 136 
(Rev. 6/82) 

CERTIFICATE OF GOOD STANDING 

UNITED STATES OF AMERICA 

SOUTHERN DISTRICT OF NEW YORK 

RAYMOND F. BURGHARDT 

DO HEREBY CERTIFY That PAMELA S, KARLAN 

duly admitted to practice in said Court on FEBRUARY 24th 

and is in good standing as a member of the bar of said Court. 

Dated at 

APRIL 6 th 
on 

NEW YORK 

, 19 87 

SS. 

, Clerk of the United States 

was 

, 19 87 

RAYMOND F BURGHARDT • CLERK , 

Clerk 

Deputy lerk