Attorney Notes Pages 1575-1576

    IN THE 
UNITED STATES COURT OF APPEALS 

FOR THE FIFTH CIRCUIT 

RONALD CHISOM, et al., 

Plaintiffs-Appellants, 

V. 

BUDDY ROEMER, et al., 

Defendants-Appellees. 

AFFIDAVIT OF DR. ROBERT S. MILLER  

STATE OF LOUISIANA ) 

PARISH OF ORLEANS ) 
SS: 

Dr. ROBERT S. MILLER, being duly sworn, deposes and says: 

1. I make this affidavit in opposition to Appellants motion for summary 
judgement. 

2. I am currently President of Market Research and Issues Management, 

Inc., located in Baton Rouge, Louisiana. A copy of my resume' and relevant 

professional experience is attached to this affidavit as Appendix A. 

3. I have extensive experience in the analysis of voter behavior with 

particular reference ta voter fall-off, turn-out participation, and voter 

demographics In Louisiana. Specifically, I have conducted statewide legislative 

district analyses for the Louisiana Association of Business and Industry, and 

have participated professionally in more than 70 elections in Louisiana. I have 

provided voter analysis, targeting, and opinion research for 11 judicial elections 

and have worked for Sylvia Cooks, a black candidate in the 18th Judicial 

District, in her most recent judicial election, and Fay Williams, a black 

candidate in the 8th Louisiana Congressional District. I have worked for eight 

black candidates in municipal and legislative offices. I have served on the staff 

of the Department of Experimental Statistics, Louisiana, State University, and I 



am the political polling and elections consultant to Channel 2, WBRZ television 

station in Baton Rouge, Louisiana. 

4. I was retained by the Louisiana District Judges Association to assist 

in their analysis of reports prepared by the experts for the State of Louisiana 

and the plaintiffs in Clark v. Edwards. The State of Louisiana in this case has 

asked me to present my opinions with regard to those reports analyzing the 

presence of racial dilution in judicial elections conducted within Orleans Parish. 

5. The fact that there is voter polarization does not mean that there is 

racial vote dilution. In the elections in the First Judicial District involving 

Lynch and Stewart, in the 19th Judicial District involving Pitcher, and in 

Orleans Parish involving Morial, Ortigue, and Magee, although there was 

polarized voting, the black candidate chosen by black voters was elected. 

While bivariate ecological regression is one method to establish polarization in 

voting, both sign-in and participation rates must be considered to establish 
racial vote dilution. 

5.1 Sign-in data as available in Louisiana, is an indication that a voter 

has actually presented himself at a polling place on election day. In Louisiana, 

this information is recorded for each voter by the dates he has presented 

himself to vote, as well as his race, precinct where registered, party 

affiliation, and date of birth. By knowing the dates of the election, the type 

of office contested (executive, legislative, or judicial), as well as the race of 

the voter who signed-in, the best evidence is generated to determine voter 
participation patterns. 

5.2 Participation is the choice of the voter to •cast a vote in one or more 

elections on a single ballot. On a multi-election ballot the number of voters 

casting ballots for each position to be chosen may vary. The variance in the 

actual number of black and white voters casting ballots in the same election 

forms the basis with sign-in data and bivariate regression to establish the 
presence of racial vote dilution. 

6. Bivariate Ecological Regression as used by Engstrom is a procedure to 

estimate polarization in previous voter behavior. The best data to study 

specific voter behavior is exit interviews of voters as they leave the polling 

place. The next best procedure is to use sign-in data as the basis for analysis 

of voter behavior. A study or experiment should not be designed to suit any 

particular method. A researcher must be guided by theoretical, practical, and 

observational demands. Whatever data are generated, should be analyzed by 



the optimal method of analysis that the researcher can find. A method of 

analysis should never dictate the measurement, design, and collection of data; 

this applies to the use of the bivariate procedure by those wishing to document 

vote dilution. The availability of election day voter participation data by race, 

(sign-in data), indicates that the bivariate procedures used by Engstrom are 

not the optimal research procedures to analyze Louisiana elections. Sign-in 

data is available from State Registrar of Voters. The data used by Engstrom 

to analyze Orleans elections ignores sign-in data. 

Engstrom's analysis seeks to test covariational relationships. Typical 

propositions stating covariational relations are: "The higher the A, the higher 

the B"; "The higher the C, the lower the D"; and "The lower the E, the lower 

the F." The first proposition states a positive covariational relation, the 

second a negative covariational relation, and the third proposition, a reverse of 

the first, is also a positive relation. Propositions about covariational relations 

are concerned with co-occurrence of two or more activities. They provide no 

information about which activity is cause and which is effect. For example, the 

covariational proposition, "prestige varies directly with power", suggests that a 

person who has a lot of prestige, however defined, is likely to have a lot of 

power over others. The proposition does not tell us whether he gains prestige 

because he is powerful or becomes powerful as a result of his prestige. The 

problem is that Engstrom's methods are designed not to explain actual voter 

behavior. Rather, his methods are designed to reach a conclusion that if the 

results of elections are polarized, then racial vote dilution is to be implied. 

This methodology, which is based on but two factors (votes per candidate and 

the race of registered voters, not the race of those who actually voted), 

factors that are not the best available data, does not enable one to reach valid 
conclusions about vote dilution. 

It is my view that the dilution issue has not been proven by 

Engstrom's analysis. Specifically, Engstrom must show not only the extent to 

which the electoral preferences of the minority group members differ from those 

of the rest of the electorate; he must also show the extent to which the level of 

participation .in the electoral process is lower amongst minority group members 

than others, leading to minority voters having less opportunity than other 

members of the electorate (i.e. white voters) to elect candidates of their choice. 

Engstrom's analysis is based on estimates of behavior of potential 

voters, where potential voters represent the pool of registered voters in each 



precinct who may or may not vote in any election on election day. Under 

Engstrom's logic, potential voters could as easily be minority individuals of 

voting age, whether they are registered or not. 

Engstrom's estimates of both votes cast for the black or white 

candidate and "participation" rates are biased by imputing black voter efficacy. 

Engstrom assumes that 100$ of black voters desire to vote for every position on 

a ballot. This establishes the benchmark for black voter behavior at 100$ of 

registered voters. This is a key bias in one's analysis as both estimates of 

"participation" and voter percentages are based on a model of total voter 

participation. The preferred procedure is to measure actual participation and 

percentages based on the numbers of black and white voters signing in, 

computing the various roll-off and turn-out percentages, then comparing these 

percentages to the total voting population, or the potential voting population. 

7. The dilution question in judicial elections can not be resolved if 

drop-off characteristics (whether voters had voted for one item on the ballot 

but had failed to vote for a judicial post lower down on the ballot) are not 

considered. Engstrom does not use drop-off data in his analysis. If a voter 

signs in on election day, he has an opportunity to vote. If the voter does not 

cast a ballot for a particular post, then that is the voter's choice; the voter 

still had an opportunity to vote. The results of roll-off can be dramatic. As 

Fay Williams' pollster during the congressional election, I recall that in the 

run-off election between her and Clyde Holloway, a white candidate, almost 

6,000 fewer voters voted for the congressional position than voted on the same 

ballot for either U. S. Senate candidates John Breaux or Henson Moore in the 

Scotlandville area, a 90% black area of East Baton Rouge Parish. As Ms. 

Williams lost her election by fewer than 6,000 votes, had those voters cast a 
ballot, Ms. Williams might have won. 

8. In Engstrom's double-regression procedure, non-participation rates 

are based on the pool of potential voters rather than actual voters. The result 

is that the potential exists to misinterpret voter preferences. For example, the 

results of the Sylvia Cooks election (an election in which I designed voter 

targeting objectives), show that when Ms. Cook ran a second time, she received 

fewer votes (both black and white) than during her first campaign. At the 

run-off following her second campaign, she received still fewer votes than 

during the primary. However, the percentages of those black's who did cast 

cast ballots for Ms. Cook were consistent. This shows that Engstrom's analysis 



is biased. If one looks at actual voter behavior, one cannot account for 
election results using Engstrom's procedure. 

9. I have reviewed material by Dr. Ronald E. Weber concerning the 

Louisiana Secretary of State 1987 primary election. Dr. Weber used a 

precinct-based data base in doing his. statewide analysis. He performed 

regressions based on the total number of registered voters, not the actual votes 

cast. Dr. Weber analyzed each precinct in each judicial district and reported 

his results by judicial districts. I prepared the following figure as a graphic 

presentation by judicial district of the weighted regression analysis performed 

by Dr. Weber. As shown in the chart, there is no clear pattern among the 

estimated voter cast by black voters. From my expert review of Dr. Weber's 

report, I can conclude that there is no clear pattern among the estimated votes 

cast by black voters even using Dr. Engstrom's analysis methods. Sometimes 

the estimated black vote for all white candidates exceeds the estimated black 

vote for a candidate. Sometimes the estimated black vote for one or more 

specific white candidate exceeded the estimated black vote for both black 

candidates. At no time did the estimated black vote for one black candidate 

uniformly exceed the estimated black vote for any white candidate. I also 

participated in a district court primary election in the 19th judicial district 

between McDonald, Pierson, and Clark, a black candidate. In that election, 

Ms. Clark received substantially less than 50% of the black vote. The majority 

of black voters preferred Pierson, a white candidate. This shows the fallacy of 

the assumption that when given a choice, black voters always prefer a black 

candidate over a white candidate. Therefore, the use of only black/white 
election contests is flawed. 

11. Given that Louisiana has had open primaries since 1976, at which the 

party affiliation is irrelevant for voting, that single shot voting is allowed; and 

that I am not aware of any impedimenta to voting sine 1976 in the First 

Supreme Court Judicial District, I believe that all judicial elections since 1976 

should be included in any analysis seeking to to establish that minority voters 

can not elect candidates of their choice. The analysis prepared by Dr. 

Engstrom in my view is incorrectly limited to elections with black and white 

candidates. Dr. Weber examined 191 judicial district court elections (126 

majority win, 34 plurality win, 31 run-off win). As shown by the following 

charts, which I prepared using Dr. Weber's data, it appears clear whether one 



looks at the results statewide by district, or statewide by year that black 

voters have elected candidates of their choice more often than not. 

Sworn to and Subscribed 
Before me this 541' d 
of Augu 

Act- 1-17,41310. 



Contested Majority win Elections for Louisiana District Judge 
Categorized by Preferences of Minority Black Voters 

by Year of Election (1976-1988) 

70— 

so-

T 50— 
A 

X 

40-
- 

30-

20— 
. 

10— 

o 

.5 of Elections 
Where Winner is 
Preferred by 
Minority Bloc 

X of Elections 
Where Winner is 
Not Preferred by 
Minority Bloc 

2 3 4 6 7 8 9 10 11 
DISTRICT 

12 13 
II 

17 18 19 20 21 22 23 24 252827 282930 31 32 33 
DISTRICT 

34 35 35 37 38 39 40TOTAL 

Tab 1.2b 



100 

90 

so 

E • 70 

C • 60 

T • 50 
A 
6 E 40 

X 30 

20 

10 

0 

Contested Runoff Melons for Louisiana District Judge 
Categorized by Preferences of Minority ElWA( Voters 

by Year of Election (1970-1968) 
X of Elections 
Where Winner is 
Preferred by 
Minority Bloc 

X of Elections 
Where Winner is 
Not Preferred by 
Minority Bloc 

1 2 3 4 5 6 7 8 9 10 11 

DISTRICT 
12 13 14 15 16 

• 

17 18 19 20 21 22 23 24 25 26 27 29 29 .30 31 32 33 34 
DISTRICT 

35 36 37 38 39 40TOTAL 

Tab lee 



100T 

90-

90— 
. 

P 
E iu— 

C 60— 
E 

T • 50— 
A 
8 
E 

• 30-
- 

20-

10 — 

o 

Contested Plurality win Elections for Louisiana District Judge 
Categorized by Preferences of Minority Black Voters 

by Year of Election (1976-1988) 
X of Elections 
Where Winner is 
Preferred by 
Minority Bloc 

X of Elections 
Where Winner is 
Not Preferred by 
Minority Bloc 

2 3 4 5 6 7 8 9 10 11 12 13 
DISTRICT 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 

DISTRICT 
34 35 36 37 39 39 40 TOTAL 

Table* 



100— 
. 

90— 
. 

60-r 

60-

40-r 

20— 
. 

10— 
. 

0 

Summary Of Judicial District By X Of Black Votes 
Weighted Regression Analyses - Secretary Of State 
Lombard. Rivers, and All Other White Candidates 

Lombard Rivers White Candidate 
Total 

,IJ 
V A 

2 3 4 5 6 7 8 9 10 11 12 13 14 
JUDICIAL DISTRICT 

19 20 21 22 23 24 25 26 

• 

di  
27 al 29 30 31 32 33 34 53 36 37 38 39 40 Or. 

Civil 
JUDICIAL DISTRICT 

abV 



Robert S. Miller 
 

   
(504) 344-6023 

PROFESSIONAL PROFILE 

EDUCATION: 

Ph.D, Marketing, Louisiana State University, 1979 
MS, Experimental Statistics, Louisiana State University, 1975 
MSW, Social Welfare, Louisiana State University, 1972 
BS, Psychology, Louisiana State University, 1970 

WORK HISTORY:  

1977 - 1988 President, Miller Associates, Inc., Market Research and 
Issues Management Consultants 

1975 - 1977 Director (Part-time), Governor's Pardon Parole and Rehabilitation 
Commission, State of Louisiana 

1975 - 1977 Vice President, International Systems Limited 

PRINCIPAL RESPONSIBILITIES AND CONSULTING ASSIGNMENTS:  

Governmental/Community Relations - Opinion research, public 
relations programming, legislative, and press relations, crisis 
management, issues forecasting services provided to the 
Louisiana Chemical Association, Louisiana Association of Business 
and Industry, Chemical Manufacturers Association, and 18 
chemical manufacturers in ten states. 

Health Care - Regional and national health care studies for AMI, 
Health-America, National Medical Enterprises, and employer 
groups looking toward cost containment and service packaging. 
In addition, participated in 37 health related studies in 12 states 
regarding product line management, service offering, and 
pricing. 

Market Research Services - Includes economic impact, feasibility 
and attitudinal studies for a diverse group of clients. Included 
in this group are services for the financial industry, consumer 
product goods, and the media. Study's dealt with product 
adoption', consumer trade-offs, and distribution. A substantial 
amount of activities have been directed toward chemical product 
marketing. 

Political Polling - Participated in more than 100 elections, 
including substantial services for the Louisiana Association of 
Business and Industry. Currently completed surveys for 
current members of the Legislature, as well as services for a 
variety of print and broadcast enterprises in Louisiana. 



CIVIC AND PROFESSIONAL ACTIVITIES:  

A. Currently serving on: 
Board of Trustees, Louisiana Arts and Science Center 
Board of. Directors, Louisiana Jewish Federation 
Board of Directors, Greater Baton Rouge Chamber'. of Commerce 
Board of Directors, L/PAC (Louisiana State University System 
Political Action Committee) 
Board of Directors, LASPAC, AIPAC 
Founder, Champac 

Facility Political Training Institute - Greater Baton Rouge Chamber of 
Commerce 

B. Memberships include: 
The American Marketing Association 
The Market Research Association 
Opinion Research Association 
The American Association of Political Consultants 
National Network of State Polls 

C. Volunteer work for the following organizations: 
Baton Rouge Symphony 
Hospice Foundation 
Battered Childrens Foundation 
YMCA 
East Baton Rouge Parish School Board 
Capital Area United Way 
TAC/AAU Youth Track 
Episcopal High School 
Catholic High School 
Champac 
Greater Baton Rouge Chamber of Commerce 
Sewerage Planning Committee 



CORPORATE CLIENTS  

The following represents a partial listing of corporate clients segmented by 

industry: 

Medical Institutions  

American Medical Enterprises, Beverly Hills, California 

Ault Chiropractic Clinics, Baton Rouge, Louisiana 

General Health Systems, Baton Rouge, Louisiana 

Baton Rouge Chemical Dependency Unit, Baton Rouge, Louisiana 

Central Georgia Eye Care Center, Macon, Georgia 

Central Indiana Eye Institute, Kokimo, Indiana 

Cleveland Clinic, Cleveland, Ohio 

Drs. John Cooksey &.Priscilla Perry, Monroe, Louisiana 

East Jefferson General Hospital, Jefferson, Louisiana 

EmergiCenter, Pensacola/Fort Walton, Florida 

Eye Care and Surgery Center, Baton Rouge, Louisiana 

Eye, Ear, Nose and Throat Hospital, New Orleans, Louisiana 

F. Edward Hebert Hospital, New Orleans, Louisiana 

Forrest General Hospital 

Havins Eye Clinic, Las Vegas, Nevada 

HealthAmerica, Baton Rouge, Louisiana 

Humana Sunrise Hospital, Las Vegas, Nevada 

Jo Ellen Smith Medical Center, New Orleans, Louisiana 

Lane Memorial Hospital, Zachary, Louisiana 

Louisiana State Medical Society, New Orleans, Louisiana 

Louisiana Nursing Home Association, Baton Rouge, Louisiana 

Mary Bird Perkins Radiation Center, Baton Rouge, Louisiana 

Meadowcrest Hospital, New Orleans, Louisiana 

Medivac 

Mercy Hospital, New Orleans, Louisiana 

Northshore Medical, Slidell, Louisiana 

Ochsner Medical Center, New Orleans, Louisiana 

Ochsner Clinics, Baton Rouge and New Orleans, Louisiana 

011ie Steele Burden Retirement Center, Baton Rouge, Louisiana 

Our Lady of the Lake Regional Medical Center, Baton Rouge, Louisiana 

Palms of Pasadena Hospital, St. Petersburg, Florida 

• ' • *:. • : 



S 
Singing River Hospital - Pascagoula, Mississippi 

Touro Infirmary, New Orleans, Louisiana 

Tulane University Hospital, New Orleans, Louisiana 

UCLA Medical Center, Los Angeles, California 

Woman's Hospital, Baton Rouge, Louisiana 

Financial Institutions  

Bank of New Roads, Louisiana 

Britton and Koontz- Bank, Natchez, Mississippi 

City National Bank of Baton Rouge 

First Allied Bank of Baton Rouge 

First Bank of St. Tammany, Louisiana 

First Financial of Ascension, Lutcher, Louisiana 

First National Bank of Commerce, New Orleans, Louisiana 

First National Bank of Denham Springs, Denham Springs, 

First National Bank of Jefferson, New Orleans, Louisiana 

First National Bank of Port Allen/St. Tammany, Port Allen 

First National Bank of Shreveport, Shreveport, Louisiana 

First Savings of Louisiana, LaPlace, Louisiana 

Guaranty Bank of Alexandria, Alexandria, Louisiana 

Guaranty Bank of Lafayette, Lafayette, Louisiana 

Guaranty Bank of Hammond, Hammond, Louisiana 

Jeff Davis Bank and Trust, Jennings, Louisiana 

Livingston Bank and Trust, Denham Springs, Louisiana 

Louisiana Bancshares, Incorporated, Baton Rouge, Louisiana 

Louisiana National Bank, Baton Rouge, Louisiana 

Merchants National Bank of Mobile, Alabama 

National Bank of Commerce, Jefferson, Louisiana 

NEAR Network - LINC Switch, Baton Rouge, Louisiana 

Ouachita National Bank, Monroe, Louisiana 

Patterson State Bank 

People's Bank and Trust of Iberia Parish, Louisiana 

Security Homestead, New Orleans, Louisiana 

Southern Savings, New Orleans, Louisiana 

Louisiana 

, Louisiana 

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Political Research/Polling  

Richard Baker, Congressional Campaign 

• Larry Bankston, Baton Rouge Councilman & Senate 

Butch Baum, Governor 

Howard Beck, State Senate Campaign 

Pat Bergeron, School Board 

Leon Borne - House District 55 

Senator Bill Bradley, New Jersey Environmental Issues 

Armand Brinkhaus - Senate District 24 

Jim Brown, Governor 

James David Cain, Congressional campaign 

Leonard Charbert - Senate District 20 

Sylvia Cooks, Judge - 15th Judicial District 

Archie Crosby - House District 18 

Mike Cross, State Senator 

Tony D'Angelo, Mayor 

Joe Delpit, Representative 

Salvador Diesi - House District 40 

Hunt Downer - House District 52 

Jack Doland - Senate District 26 

John Ensiminger - House District 14 

Representative James Florio - New Jersey Environmental Issues 

Bobby Freman, Lieutenant Governor/Congress 

Davin Ginn - Senate District 35 

Jessee Guidry - House District 54 

Paul Hardy, Lieutenant Governor 

William Hays, City Commissioner, Mobile, Alabama 

Murray Hebert - House District 53 

Ted Hicks, EBR Assessor's Race 

Jiff Hingle, Sheriff, Plaquemines Parish 

Senator Fritz Hollings - South Carolina 

Lynda Imes, Baton Rouge Council Race 

Grady Kelly, Sheriff, Rapides Parish 

Donald Ray Kennard, House Representative 

Carson Killen, Congressional race 

Leonard Knapp, District •Attorney, Lake Charles 

' 



Raymond Laborde, House Representative 

Raymond LaLonde - House District 39 

Leon Langley, Council Race, New Orleans 

Buddy Leach - House District 30 

Sam LeBlanc, Mayor's Race, New Orleans, Louisiana 

Conway LeBleu - House District 36 

Richard Lee, Judge, Alexandria, Louisiana 

Danny Lemoine - House District 38 

Sheriff Elmer Litchfield, East Baton Rouge Parish 

Gillis Long, U.S. House of Representatives 

Margaret Lowenthal - House District 35 

Bruce Lynn, House Representative 

Jimmy Martin - House District 37 

Jim McCrery, Congressional Campaign 

Bill McLeod - Senate District 27 

Representativgs Henson Moore - United States Senate Race 

George Mustakas,.Congressional Campaign 

Richard Neeson, Representative 

Cliff Newman - Senate District 26 

Jewel Newman, Representative/City Council 

B. R. O'Neal - House District 

Senator Robert Packwood - Oregon environmental issues 

Mary Olive Pierson - District Judge 

Pat Screen, Mayor-President, East Baton Rouge Parish 

Weldon Russell - House District 72 

John Saunders - Senate District 28 

John Smith - House District 30 

Stewart Thomas, District Court Judge, Jefferson Davis Parish 

Frances Thompson - House District 19 

Sandra Thompson Clerk of Court Race, East Baton Rouge Parish 

John Travis - House District 62 

Richard Turnley, State Senator 

Faye Williams, Congressional Campaign 

Ed Watson, Mayor's Race in Lake Charles, Louisiana 

Peggy Wilson, Council Seat, New Orleans, Louisiana 

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Corporate Market Research  

Acadiana, Inc., Lafayette, Louisiana 

Affiliated Foods, Lafayette, Louisiana 

Back Store 

Jim Bailey, Baton Rouge, Louisiana 

Balfour, Baton Rouge, Louisiana 

Baton Rouge Broadcasting (WJBO/WFMF), Baton Rouge, Louisiana 

Baton Rouge Business Report, Baton Rouge, Louisiana 

Baton Rouge Magazine, Baton Rouge, Louisiana 

Boardwalk Title Company, Baton Rouge, Louisiana 

Bon Marche Mall, Baton Rouge, Louisiana 

Brown, Koff, & Fried, 

Butch Baum, Inc., Baton Rouge, Louisiana 

Cablecast, Baton Rouge, Louisiana 

Camp-Carmouche, Washington D.C./Baton Rouge, Louisiana 

Cellular-One, Baton Rouge, Louisiana 

Community Coffee Place, Inc., Baton Rouge, Louisiana 

Computer Communications 

Decision Center 

Delta Companies 

Delta Health Network 

Delta Queen, New Orleans, Louisiana 

Guaranty Broadcast Corporation, Baton Rouge, Louisiana 

J. U. Blanchard & Co. 

Louisiana Dairy Board, Baton Rouge, Louisiana 

Louisiana State Newspapers, Lafayette, Louisiana 

Mid-Continent Oil & Gas 

New Orleans Hilton 

Santa Maria Development Corporation, Baton Rouge Louisiana 

sit 

7.: .1...r:TM ITVMIT.' •:•". L'•"7..! '',"" "::tr-r"!..• • A'sf 74;gw, f7;`A.1- :* 7:eV s. •71r1'( 



Speedy Oil Change, Baton Rouge, Louisiana 

Struman & Associates, 

Jimmy Swaggart Ministries, Baton Rouge, Louisiana 

National Food Stores, Lafayette, Baton Rouge, Louisiana 

Tiger Rag Magazine, Baton Rouge, Louisiana 

TJM Corporation, New Orleans, Louisiana 

Tulane University, New Orleans, Louisiana 

Warner Communications, New York, New York 

Westminster Corporation, New Orleans, Louisiana 

Weylock & Associates 

Whites Auto Parts 

William B. Reily Company (Luzianne Coffee/Blue Plate Mayonnaise) 
Witter Enterprises 

Wolf's Sunbeam Bakery, Baton Rouge, Louisiana 

WRBT TV - Channel 33, Baton Rouge, Louisiana 

Public Agencies, Non-Profit and Trade Associations  

Baton Rouge Alliance for Good Government 

Baton Rouge Chamber of Commerce 

Champac 

Chemical Manufacturers Association, Washington, D.C. 

Council for A Better Louisiana 

East Baton Rouge Parish School Board, Baton Rouge, Louisiana 

Education for a Better Louisiana, Baton Rouge, Louisiana 

Educational Testing Service, Princeton, New Jersey 

Faucheux - Farwell Associates 

James H. Gill, Jr., Baton Rouge, Louisiana 

Gulf South Research Institute (including Livingston derailment issue) 

Louisiana Association of Business and Industry 

Louisiana Association for Retarded Citizens 

Louisiana Chemical Association 

Louisiana Department of Commerce and Industry 

Louisiana Department of Education 

Louisiana Learning Center 

Louisiana Nursing Homes 

Louisiana Office of Tourism 

i".:.:?•"et •••- •-• iv; • ',II-C.-Y.1'.• - •• • . 

• • • 



, • 
Louisiana Public Facilities Authority 

Louisiana Retail Association 

Louisiana School Boards Association 

Louisiana State Medical Society 

New Orleans Chamber of Commerce 

New Orleans Gaming Commission 

Office of Mental Retardation, State of Louisiana 

Public Affairs Research Council, Baton Rouge, Louisiana 

Volunteers of America 

Corporate Governmental Affairs - Chemical Companies  

Air Products, Inc. 

Armtech (Armstrong) 

BASF 

Borden Chemical 

CIBA-GEIGY Corporation 

Copolymer 

Dow Chemicals, USA 

Dupont 

Exxon Chemicals, USA 

Melamine Chemicals, Inc. 

Monsanto 

Shell Oil Company 

Vulcan Chemical 

Waste Management, Inc. 

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