First Set of Interrogatories and Request for Production of Documents

    DA 
A JARBARA ET MAJOR, 

Plaint 1 £ fs 

a 
“ YAVID TREEN, ET 

Defendants 

- 

COURT 

nD 
\ LOUISIANA 

AL 

rm ST MAGI RATE 

' Ed 1 C 
el 

~ pm : 
SEX NL 

ST FOR 
ORF 
Or I RROGATORIT AND 

DUCTION OF DOCUMENTS 

i J! 

PR( 
  

781.30, 

accordance wit 

ERIN [TIONS AND 
T 
te 

the Federal 

Preen, through 

yllowing First 

>r Production of Documents to 

and that these requests 

 ) 
roduction Documents for 

requested 

of Bronfin, 

Whitney New Orleans, uilding, 

of Sou. 

 initions and instructions. 

  

shall mean the 

0 Ng "describe appear 

1. 

comp 

he) 

when 

Complaint" appears herein, 

3): filed id this matter on or about 

"identify" and "identity", terms 

they shall mean: 

in reference to an individual: 

address and employer, 

the description of the 

ationship, ch he bears or at any 

has borne this action;  



whe se n refer } LO a company or other 

business organization: its name, address and 

principal plac at Line of business; 

when used in reference to a document: 

date, if any, its physical location at 

the answeri 

preparer, the person under whose control it 

contents; 

communi - 

Occurred, 

person or persons participating therein, 

substance of the communication and the doc- 

uments relating or referr in any way thereto. 

when used in reference to any act, occurrence, 

occasion, meeting, transaction or conduct: 

date and persons participating, present or 

involved, the event or events constituting such 

he documents relating 

in any way 

rgon” 

shall mean any individual, vartnership, firm, ¢ oration, 

association, trust joint anture, c ! other business or 

legal entity. 

D. Whenever the arms "you 'vour" appear 

mean-the plaintifs every other individual who, 

he plaintiff, can be 

nish informaion to such plaintiff, including any 

lawyer or other person acting on the Plaintiff's behalf or as 

his representative in the investigaton, preparation or mai 

tenance of this action. 

E. Whenever an interrogatory calls upon you to 's 

all information" of a particular kind "and the sources 

thereof", your answer should set forth every  



persons and 

to the defendant 

shall mean both 

parate response 

of produci 

interrogatories 

ire thereby releved 

re aforesaic 

privilege with 

request for pro- 

the privilege 

you base the claim of 

claim Supports those 

privileged communi- 

Partly written, iden- 

ment « aining any part of such communicat ion; 
loc LOC 

partly al 1 fy the or: cummunication; ar 

~~ CSN +. - } - ¥ Person {other than the 

$ communication) to whom 

regard to paragraph liv the Complaint, 

1a reapportionment 

EO comply with 

rson-one vote standards including in your answer: 

uy 
“1 (a) the details  



Source who 

tion: and 

documents 

copying 

| we J - 

nerein. 

speci 

Your 

Louisiana reapporti plan was to 

Of black itizens and deny 

source who 

(c) produce any and : docu ts identified 

your answer to bparta (a) and (bp) of 

interrogatory for inspection and copying 

the time and place specified on page 1 

Paragraph 21 

1 1 + +h identify with specificity t 

Louisiana reapportionment an's sffect was gh L  



" 
voting 

ln your answer: 
lization 

information; 

identified 

(bY of this 

nd copying 

what you cla 

ion, includi: 

ource who 

your answer to subparts 

interrogatory for ins and copying a 

on page 1 hereof. 

Complaint, 

which You al lege 

7 Is it vour.contentioy 

Treen" was intended strengtt 

and the effective 

i: sO, state. and utilization of their rig! to vote 

identify with specificity each and every basis upon which you 

in your answer: intend +o establish such intent,  



source who 

supplied 

>roduce any and all documents identified in 
Y X 
bie 

YOUr answer to =i gs {3) {b) of this 

interrogatory 

district in Orleans 

and 

I person or source who 

mation; and 

documents identified in 

page 1 

Complain 

how Act. 1 and Act 20 

he voting strength of b 

Or source who 

Ce any and all documents identified 2 

answer to subparts (a) through 

wterrogatory for inspection and copying 1 

specified on page 

ate and 

whom you intend to call  



3 1 5 
noice a brief subject matter 

witness will testif 

State and identify with specificity all files in 

your possession which relate in Y this litigation. 

Purther identify all apers or files 

been dest) C 

which have 

State and with city all persons 

whom you have discussed litigation and the subject 

>f those discussions. 

gpecificity each and 

every experi wit whom you intend to call in this matter, 

including the following informaton: 

expert 

state the subject on which the expert 

and opinions 

the he ie summary of 

investigations or 

conducted on your behalf. 

State and identify with specificity all 

ho in the furnishing of information and/or 

preparation of these interrogatories and request for 

MARTIN 
ROBERT A. 

of 

BRONZIN, HELLER, 

& STEINBERG 

624 Whitney Building 
New Orleans, 

504/568-1888 
ATTORNEYS FOR DAVID C. 

Te. CC. PPILDMAN # 1d | 

KUTCHER IN 

FELDMAN 

lcuisiana 70130 

TREEN