Plaintiffs' First Interrogatories

    e 

UNITED STATES DISTRICT COURT 

EASTERN DISTRICT OF LOUISIANA 

BARBARA MAJOR, et al., CIVIL ACTION NO. 82-1162 

Plaintiffs SECTION I (C) 

-against- THREE JUDGE COURT CASE 
  

DAVID C. TREEN, etc., et al. CLASS ACTION 

PLAINTIFFS' FIRST 

INTERROGATORIES 

David C. Treen, through counsel of record, Martin L.C. Feldman. 

Martin L.C. Feldman 

Bronfin, Heller, Feldman & 

Steinberg 

624 Whitney Building 

New Orleans, LA 70130 

NOW INTO COURT, through undersigned counsel come the plaintiffs in 

this matter who prop d the following inte of: ies lefendant be ans- 1s pound the foilowing interrogatories to defendant to be ans 

wered within the delays allowed by law: 

I. 

The June 10, 1981 letter from the Louisiana Congressional Delegation 

to the Louisiana Senate regarding congressional reapportionment (Document No. 

97 submitted to the Justice Department) says that the Congressional Delegation 

had prior discussions with Dave Treen regarding reapportionment. Please state 

the date, parties to the conversation, and substance of prior conversations 

with the Congressional Delegation that Governor Treen had regarding Congression- 

al Reapportionment. 

1. 

Several Documents which were submitted to the Justice Department do 

not indicate who wrote them, nor who requested them. Therefore, for Documents 

Numbers 2) 5 » 9, and 10, which were submitted to the Justice De~- € 

partment, please advise the following: 

Who requested each Document? 

Who wrote each Document?  



C. Who had access to each document. 

111. 

Document No. 69, which was submitted to the Justice Department, a 

August 15, 1980 letter from Mr. J. Allen Martin to Governor David C. Treen 

suggests that a system be setup by the Governor's Office to devise a reappor- 

tionment plan. Please advise what system was setup in response to this letter, 

who funded it, and who was responsible for overseeing its activities. 

Iv. 

Document No. 22, which was submitted to the Justice Department is a 

House Committee Amendment. Please state what date Document No. 22 was acted 

upon and at whose request. Also, please state whether or not it passed. 

Vv. 

Please indicate how many communications the Governor's Office had 

with the Department of Justice regarding Congressional Reapportionment. For 

communication, please state: 

A. Whether it was oral or in writing; 

The date; 

The parties who communicated; 

The substance of the communication. 

V1. 

Please outline in summary form, how the finally passed bill reapport- 

ioning the Congressional Districts for the State of Louisiana came into being. oO 

Please indicate each step of the Legislative process, including amendments, 

and in which House of the Legislature each action took place. 

Respectfully submitted, 

R. JAMES KELLOGG 

WILLIAM P. QUIGLEY 

STEVEN SCHECKMAN 

STANLEY HALPIN 

631 St. Charles Avenue 

New Orleans, Louisiana 

504/524-0016 

70130 

Jack Greenberg 

James M. Nabrit, III  



Napoleon B. Williams 

Lani Guinier 

10 Columbus Circle 

Suite 2030 

New York, New York 

Certificate Service 

| certify that a copy of the foregoing pleading 

has been seived upon counsel for 

to this proceading, 

v 

axtponmandemmen I | 

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