List of Interrogatories

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UNITED STATES DISTRICT COURT 

EASTERN DISTRICT OF LOUISIANA 

BARBARA MAJOR, ET AL CIVIL, ACTION 

versus NO. 82-1192 

DAVID C. TREEN, ET AL SECTION C 

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INTERROGATORIES 
  

Mr. Kellogg 
Mr. Quigley 
Mr. Scheckman 
Mr. Halpin 
Miss Guinier 
Mr. Derfner 
Mr. Menefee 

PLEASE TAKE NOTICE that defendants request, pursuant 

to Rule 33 of the Federal Rules of Civil Procedure, that the 

attorneys seeking fees in this matter, answer under oath on or 

before April 24, 1985 the following written interrogatories. 

Responses to one interrogatory or part of an interrogatory may 

be incorporated by reference in response to other interrogatories 

if, and only if, the clarity and completeness of the response 

will not be compromised. 

As used in this discovery request, masculine pronouns 

are intended to refer to both men and women. 

In answering these interrogatories, you are required 

to furnish all information available to you, including information 

in the possession of your attorney or any person acting in your  



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or his behalf, and not merely such information as is known of 

your own personal knowledge. If you cannot answer any particular 

interrogatory or interrogatories in full after exercising due 

diligence to secure the information sought, so state and answer 

to the extent possible, specifying your inability to answer the 

remainder. 

You are reminded of your duties, under the provisions 

of Rule 26 (e) of the Federal Rules of Civil Procedure, to season- 

ably supplement your responses. 

l. To Mr. Kellogg, Mr. Scheckman, Mr. Quigley, Mr. 

Menefee: List your actual hourly rate or rates (if a particu- 

lar client gets different rates for different types of work) 

each non-contingent client for the last three years. If you 

feel that some clients' names or the business you have done for 

them is confidential, you may use codes in your answer as long 

as the Court is provided with an in camera list of codes and 

client names or types of work. 

2. To Mr. Kellogg, Mr. Quigley, Mr. Scheckman, Mr. 

Halpin, Mr. Derfner, Mr. Menefee: Were you guaranteed fees by 

LDF whether you won this case or not? Were you promised future 

business by LDF? 

3. To Mr. Rellogg, Mr. Quigley, Mr. Scheckman, Mr. 

Halpin, Mr. Derfner, Mr. Menefee, Miss Guinier: Identify each 

person whom you expect to call as a witness at the attorneys’ 

fees hearing in this action by responding to the following:  



(a) Identify such person by name, address, occupation, 

and employer, and state the education and/or training that he 

has received upon which plaintiffs intend to rely in establishing 

the credibility of his testimony and his expertise if he is to 

be used as an expert; 

(b) State the subject matter upon which he is expected 

to testify; 

(c) State the substance of the facts and opinions to 

which he is expected to testify; 

(d) Give a summary of the grounds for each such fact 

and opinion listed above; 

(e) Provide a current copy of his curriculum vitae 

if he has one including a copy of any scholarly papers, including 

but not limited to dissertations, all published articles, books, 

and manuscript of any description whatsoever. 

(f£) Identify fully any papers, treatise or any published 

work upon which he intends to rely in support of his opinion 

and/or testimony. 

4. To Mr. Menefee: How many §1988 fee requests have 

you handled prior to Major v. Treen? List those fee requests 
  

by name; court; case number; reported citation, if any; amount 

of fee requested; whether the fee requested was for yourself 

or others or both; the amount of the request and the amount awarded 

or settled upon; whether the fee requested was for yourself and/or  



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the other parties; the hourly rate requested and the hourly rate 

awarded or settled upon as to yourself and/or the other parties. 

Respectfully submitted, 

WILLIAM J. GUSTE, JR. 
ATTORNEY GENERAL 

KENDALL L. VICK 

ASSISTANT ATTORNEY GENERAL 

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or 

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PATRICIA NALLEY BOWERS OD 
ASSISTANT ATTORNEY GENERAL 4 
LOUISIANA DEPARTMENT OF JUSTICE 
234 LOYOLA AVENUE, 7TH FLOOR 
NEW ORLEANS, LOUISIANA 70112 
PHONE: (504) 568-5575 

CERTIFICATE OF SERVICE 

| certify that a copy of the foregoing pleading has been 

served upon counsel for all parties by mailing the same 

to each, properly addressed and postage prepaid 

  

  

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