Correspondence from Pamela Karlan to Kathleen Bell, Esq. Re Whitfield v. Clinton; Draft Answers to Interrogatories

Correspondence
October 20, 1987

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Correspondence from Pamela Karlan to Kathleen Bell, Esq. Re Whitfield v. Clinton; Draft Answers to Interrogatories preview

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Matter
- Lani Guinier Correspondence
Case
- Lani Guinier Correspondence
U.S. state
- General
Collection
- Legal Department General
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- 8112d457-eb92-ee11-be37-6045bdeb8873

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Legal Department General, Lani Guinier Correspondence. Correspondence from Pamela Karlan to Kathleen Bell, Esq. Re Whitfield v. Clinton; Draft Answers to Interrogatories, 1987. 8112d457-eb92-ee11-be37-6045bdeb8873. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/7d6af624-19f3-47e8-9bf0-09eb268f769d/correspondence-from-pamela-karlan-to-kathleen-bell-esq-re-whitfield-v-clinton-draft-answers-to-interrogatories. Accessed December 04, 2025.

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LesarED**H. NAACP LEGAL DEFENSE AND EDUCATIONAL FUND, INC.
99 Hudson Street, New York, N.Y. 10013 o (212) 21$1900

October 20, L987

Kathleen BeII, Esq.
Wllson, BeIl & NeaI
130 Colunbia Street
Helena, Arkansas 72342

Re: Whitfield v. Cllnton

Dear Kathleen:

I am enclosing draft answers to interrogatories 28, 42, and
43. The latter two were also answered in Plaintiffs' [First]
Supplemental Responses to Defendants' Expert Witness
Interrogatories, which were filed, I believe, sometime in June.
In fact, most of the interrogatories--Nos. 1-18 , 2L-24, 26-27 ,
41-47--were ansrrered completely at that tiure. I have compared
your proposed answers in the Third Supplemental Responses with
the ansrrers rre gave in the first supplemental set and they seem
virtually identical.

I shall caII you early next week about sending these off.
I'm sorry you lron't be able to come to San Antonio, but good luck
with your busy week.

S. Karlan

enclosure

Contributions an dzdtntiblt tor U.S. inaotne tnr pwVoaca.

The NMCP Lcgal &lense & Educational Fund, lnc. (LoD is not parl ol the l{ational Association lor the Advancemenl of Colored People (ilMCP) although
LDF wasfountled by the llMCPand shares its commitment to equal ri0hts. L0F has had lor ovtrl) years a separate Board. program, statl, otlice and budOet.

RESPONSE TO fNIERROGATORY NO. 28: Dr. Gates used standard

techniques of eocial science research, Lncluding exanination of
the IawE themselves, examination of available legislative
records, examination of secondary sources such as books and

nehlspaper articles, and intenriews of individuals involved in the
process surrounding the passage of the most recent run-off
statutes.
RESPONSE TO INTERROGATORY NO. 42: Dr. Gates is to be paid $rSoo

for research time and $1O0 per hour for time spent at trial.
RESPONSE TO INTERROGATORY NO. 43: No.

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Correspondence from Pamela Karlan to Kathleen Bell, Esq. Re Whitfield v. Clinton; Draft Answers to Interrogatories

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