Correspondence from Hebert (DOJ) to Guinier

Correspondence
December 14, 1982

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Correspondence from Hebert (DOJ) to Guinier preview

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  • Case Files, Major v. Treen Hardbacks. Correspondence from Hebert (DOJ) to Guinier, 1982. 6e837b6b-ca03-ef11-a1fd-6045bdec8a33. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/90c99105-b540-40cf-af30-00764cddbeb6/correspondence-from-hebert-doj-to-guinier. Accessed November 05, 2025.

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    U.S. _— ustice 

  

JGH: ce Washington, D.C. 20530 

Ms. Lani Guinier 
NAACP Legal Defense Fund 
806 15th Street, N.W. 
Suite 940 
Washington, D. C. 20005 

Re: Major v. Treen, C.A. No. 82-1192 (E.D. La.) 
(F. S. 82-0501)     

Dear Ms. Guinier: 

This confirms our agreement reached by telephone on 
December 13, 1982. 

In our conversation, you agreed not to enforce the 
subpoenas served on Assistant Attorney General Wm. Bradford 
Reynolds, and Gerald W. Jones, J. Gerald Hebert and Robert N. 
Kwan, attorneys in this Division; and that the depositions 
noticed to begin on December 16, 1982 would not be taken at 
this time. In turn, we agreed to provide you with all factual 
information contained in the Section 5 file concerning 
Louisiana congressional reapportionment. For the purposes 
of our agreement, the term factual information includes 
factual portions of all memoranda, telephone communications, 
notes to the file and logs of telephone calls. We further 
agreed that the United States would not furnish the legal 
analysis contained in any of the memoranda pertaining to 
the Section 5 submission of the Louisiana Congressional 
reapportionment plan, nor would information protected under 
the privilege of confidentiality (see 28 C.F.R. §51.27) be 
supplied. 

It is our understanding that after reviewing the 
information, which we will furnish you by December 17, 
1982, if possible, you will contact us if further questions 
remain. By entering into this agreement, it is our 
understanding that you are not waiving any right you may 
have to enforce the subpoenas or take the depositions at a 
later time, if, in your view, that becomes necessary.  



% 

Rather, you have agreed to postpone the depositions until 

after you have inspected the Section 5 submission and files 

to determine whether there is a need to go forward with the 

formal process. 

It is our hope that we can continue to work with 

you in an effort to supply you with all of the factual 

information in our possession relevant to the Louisiana 

Congressional reapportionment plan. 

Sincerely, 

A 4 ) SS ( - 

ft, Cl Sela 
J. GERALD HEBERT 

Attorney, Voting Section 

Civil Rights Division

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