Defendants' Response to United States' Second Set of Interrogatories; Defendants' Response to United States' Second Set of Request for Admissions

Public Court Documents
January 21, 1989

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Defendants' Response to United States' Second Set of Interrogatories; Defendants' Response to United States' Second Set of Request for Admissions preview

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LDF Attorneys
Organization
- NAACP Legal and Educational Defense Fund, Inc.
Matter
- Chishom v. Edwards (Chisom v. Roemer) (Perschall v. State of Louisiana)
Case
- Chisom v. Roemer
U.S. state
- Louisiana
Collection
- Case Files
Taxonomy
Identifier
- 488209d9-f211-ef11-9f8a-6045bddbf119

Cite this item

Case Files, Chisom Hardbacks. Defendants' Response to United States' Second Set of Interrogatories; Defendants' Response to United States' Second Set of Request for Admissions, 1989. 488209d9-f211-ef11-9f8a-6045bddbf119. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/5e9afc21-6d31-4921-8863-67ca4e3ee8a7/defendants-response-to-united-states-second-set-of-interrogatories-defendants-response-to-united-states-second-set-of-request-for-admissions. Accessed July 16, 2025.

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IN THE UNITED STATES DISTRICT COURT 

FOR THE EASTERN DISTRICT OF LOUISIANA 

RONALD CHISOM, et al., 

Plaintiffs 

UNITED STATES OF AMERICA, 

Plaintiff-intervenor 

versus 

CHARLES E. ROEMER, et al., 

Defendants. 

: Civil Action No. 
86-4075 

: Section A 

DEFENDANTS' RESPONSE TO UNITED STATES'  
SECOND SET OF INTERROGATORIES. 

Now into Court, through undersigned counsel, 

come CHARLES E. "BUDDY" ROEMER, in his capacity as 

Governor of the State of Louisiana; FOX McKEITHEN, in 

his capacity as Secretary of State of Louisiana; and 

JERRY M. FOWLER, in his capacity as Commissioner of 

Elections of the State of Louisiana, who, for their 

answer to the United States' Second Set of 

Interrogatories show: 



Interrogatory Number 1: 

If the defendants deny, in whole or in party, 
any item in the United States Second Set of Request for 
Admissions, for each such request, 

(a) Set out the number of the request 
(b) State the specific ground for the denial. 

Response to Interrogatory Number 1: 

No response is necessary to this 
interrogatory as Defendants have admitted each item in 
the United States' Second Set of Request for 
Admissions. 

Dated: January 21st, 1989. 

WILLIAM J. GUSTE, JR. 
ATTORNEY GENERAL 

Louisiana Department of 
234 Loyola Avenue, 7th 
New Orleans, Louisiana 

(504) 568-5575 

M. TRUMAN WOODWARD, JR. 
909 Poydras Street, Suite 2300 
New Orleans, LA 70130 
(504) 569-7100 
Bar I.D. No. 13676 

BLAKE G. ARATA 
201 St. Charles Avenue 
New Orleans, LA 70130 
(504) 582-1111 
Bar I.D. No. 2500 

By: 

Justice 
Floor 
70112 

A. R. CHRISTOVICH 
1900 American Bank Bldg. 
New Orleans, LA 70130 
(504) 561-5700 
Bar I.D. No. 4114 

MOISE W. DENNERY 
601 Poydras Street 
New Orleans, LA 70130 
(504) 586-1241 
Bar I.D. No. 4873 

ERT G. PUGH 
Lead Counsel 

330 Marshall Street, Suite 1200 
Shreveport, LA 71101 

(318) 227-2270 
Bar I.D. No. 10897 

SPECIAL ASSISTANT ATTORNEYS GENERAL 



IN THE UNITED STATES DISTRICT COURT 

FOR THE EASTERN DISTRICT OF LOUISIANA 

RONALD CHISOM, et al., 

Plaintiffs 

UNITED STATES Or AMERICA, 

Plaintiff-intervenor 

versus 

CHARLES E. ROEMER, et al., 

Defendants. 

Civil Action No. 
86-4075 

Section A 

--
DEFENDANTS' RESPONSE TO UNITED STATES'  
SECOND SET OF REQUEST FOR ADMISSIONS  

Now into Court, through undersigned counsel, 

come CHARLES E. "BUDDY" ROEMER, in his capacity as 

Governor of the State of Louisiana; FOX McKEITHEN, in 

his capacity as Secretary of State of Louisiana; and 

JERRY M. FOWLER, in his capacity as Commissioner of 

Elections of the State of Louisiana, who, for their 

answer to the United States' Second Set of Request for 

Admissions show: 



Request for Admission lb: 

The 1902 Report of the Secretary of State of 

Louisiana indicates that there were a total of 126,849 

black persons registered to vote in Louisiana in 1896. 

Response to Request for Admission lb: 

Defendants admit that the 1902 Report of the 

Secretary of State of Louisiana indicates that there 

were a total of 126,849 black persons registered to 

vote in Louisiana in 1896. 

Request for Admission 2b: 

The 1902 Report of the Secretary of State of 

Louisiana indicates that there were a total of 5,320 

black persons registered to vote in Louisiana on March 

17, 1900. 

Response to Request for Admission 2b: 

Defendants admit that the 1902 Report of the 

Secretary of State of Louisiana indicates that there 

were a total of 5,320 black persons registered to vote 

in Louisiana on March 17, 1900. 



Request for Admission 3b: 

Melvin Zeno, a black resident of Jefferson 

Parish, was a candidate for district court judge in 

Distric 24 in the election held on October 1, 1988. 

Response •to Request for Admission 3b: 

Defendants admit that Melvin Zeno, a black 

resident of Jefferson Parish, was a candidate for 

district court judge in Distric 24 in the election held 

on October 1, 1988. 

Request for Admission 4b: 

Attachment A is a map that accurately depicts 

the voting precincts for Orleans Parish in effect on 

March 8, 1988. 

Response to Request for Admission 4b: 

Defendants admit that Attachment A is a map 

that accurately depicts the voting precincts for 

Orleans Parish in effect on March 8, 1988. 

Request for Admission 5b: 

On February 13, 1988, black persons 

constituted a majority of those persons registered to 

vote in 226 voting precincts in Orleans Parish. 

Attachment B is an accurate list of those precincts. 



Response to Request for Admission 5b: 

Defendants admit that On February 13, 1988, 

black persons constituted a majority of those persons 

registered to vote in 226 voting precincts in Orleans 

Parish. Further answering, defendants admit that 

Attachment B is an accurate list of those precincts. 

WILLIAM J. GUSTE, JR. 
ATTORNEY GENERAL 

Louisiana Department of 
234 Loyola Avenue, 7th 
New Orleans, Louisiana 

(504) 568-5575 

M. TRUMAN WOODWARD, JR. 
909 Poydras Street, Suite 2300 
New Orleans, LA 70130 
(504) 569-7100 
Bar I.D. No. 13676 

BLAKE G. ARATA 
201 St. Charles Avenue 
New Orleans, LA 70130 
(504) 582-1111 
Bar I.D. No. 2500 

By: 

Justice 
Floor 
70112 

A. R. CHRISTOVICH 
1900 American Bank Bldg. 
New Orleans, LA 70130 
(504) 561-5700 
Bar I.D. No. 4114 

MOISE W. DENNERY 
601 Poydras Street 
New Orleans, LA 70130 
(504) 586-1241 
Bar I.D. No. 4873 

G. PUGH 
Lead Counsel 

330 Marshall Street, Suite 1200 
Shreveport, LA 71101 

(318) 227-2270 
Bar I.D. No. 10897 

SPECIAL ASSISTANT ATTORNEYS GENERAL 



CERTIFICATE  

I HEREBY CERTIFY that a copy of the above and 

foregoing Response to United States' Second Set of 

Interrogatories and Request for Admissions has been 

served on all counsel of record by depositing the same 

in the United States Mail, postage prepaid, properly 

addressed. 

All parties required to be served have been 

served. 

Shreveport, Caddo Parish, Louisiana, this the 

21st day of January, 1989. 

ert G. Pugh, 
Lead Counsel

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Defendants' Response to United States' Second Set of Interrogatories; Defendants' Response to United States' Second Set of Request for Admissions

LDF Attorneys

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