Deposition of Governor David C. Treen (Transcript)

    AociaTep REPORTERS, ing 

CERTIFIED SHORTHAND REPORTERS 

644 CAMP STREET TELEPHONE 
(504) 529-3388 

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4 JANUAPY 1983 

re: MAJOR VS. TRFEEN 
NO. 82-1192 

GOVERNOR DAVID C. TPEEN 
CAPITOL BUILDING 
STATE OF LOUISIANA 
BATON ROUGE, LOUISIANA 70804 

Dear Governor Treen: 

Enclosed find the original transcript of your 
deposition given in this matter. It is important 
you read and sign the deposition and return it to 
our office as soon as possible. 

If you should find it necessary to make any changes 
or corrections in the transcript, please do not mark 
the transcript but indicate such changes or corrections 
on the form which is attached and date and sign it at 
the bottom. 

Again, it is most important this be done promptly and 
returned to me at our address above. If you have any 
questions call us. 

Thanking you for your prompt attention, we remain 

Yours very truly, 

Bi REPS IN INC 

vs Yc { Alot 
Rrad Guest 

  

C.C. 

R. JAMES XELILOCGC 
MARTIN L. C. FELDMAN  



UNITED STATES DISTRICT COURT 

EASTERN DISTRICT OF LOUISIANA 

BARBARA MAJOR, ETC., 
ET AL 

VERSUS 

DAVID C. TREEN, ETC., 
ET AL 

Deposition of GOVERNOR DAVID C. TREEN, 

given in the above-entitled cau pursuant 

to notice and the within stipulation, in 

the Capitol Building, State of Louisiana, 

The Governor's Office, Baton Rouge, Louisiana, 

before Brad Guest, Certifi Shorthand 

Reporter, on Monday, the 20th day of 

December, 1982. 

APPEARANCES : 

QUIGLEY & SCHECKMAN 

(BY: R. JAMES KELLOGG 
and 

WILLIAM PATRICK QUICG 
631 St. Charles Avenue 
New Orleans, Louisiana 

For the Plaintiff 

  

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APPEARANCES (Continued): 

HELLER, FELDMAN 

C. FELDMAN 

ROBERT A, KUTCHER) 
624 Whitney Building 
New Orleans, Louisiana 

For the Defendant 

KENNETH C. DeJEAN 
Post Office Box 44005 
Baton Rouge, Louisiana 70804 

Chief Counsel, 
Office of the Attorney Ceneral, 
State of Louisiana 

REPORTED BY: 

horthand Reporter 

  

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Stipulation . » . eile 9, 0 

Examination by Mr. Kellogg 

Signature of the Witness 

Certificate. . . «+ sv. 0 

Treen No. 1 

  

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and signing 

deposition, 

it 

the exceptio: 

of question: 

all objectic 

transcript f the deposition 

to be used in evidence ai 

BY MR, KELI 

Q Governor 

pleas 

  

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David C. Treen, Governor of Louisiana, 

Could you st: fly your background 

area. 

AS you know, 

focusing 

ional rea 

some 

processes that you went 

and, unless I state othe 

I am asking 

4 
i- 4 ™ ah ee ee a bad ps . 9 

J Ga LVOUT MMR LC DO LOLA § 

«© - 3 o 

LOCUE 

you       

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One 

at it on a day-by-day bas 

cén be very conplicgcated, 

iament s y ry 
: NEY 

but we are going to 

arlily about jus 

to be 

P [4] i Ti 

red 

when it 

  

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acted on by one of the two branches, 

and how it was changed as it went 

through, and it might have been -- 

frankly, I couldn't tell you now 

whether it had been or whether it 

was intact all the way through or 

not, you understand, as I talk about 

some minor variations. So with that 

caveat to you. that we are talking 

about the Nunez Plan, it might have 

been changed in some particulars as 

it went through, but I know generally 

what it was. 

All I am talking abou 

in general, not as it 

particular day. 

try to catch you on 

details of that plan. Obviously, 

if you have any questions or my 

questions are not =-- 

you say ~- you are 

the existing ~~ you are 

to that -~ an old plan? 

The one that was passed pursuant to 

court order and finally approved,     
  

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  wg nt 
3 Y BD) 

N 

i 1 ¥ [ 4 I think, about 1974, the one 

that the members of Congress were 

undey oO the Special 8 ession 

wv Se y pe Tad 
Q x tne Leg 16 Lal 

1 
ES ure. Up until then, 

still under unti 

month, Next 

existing law, 

of back-~ 

1 LI a 'y 
ICUS 

accurate representa- 

i ru 
LQ 

wo 

stion., Vhy don't 

legislation 

voted for or against, 

one perceive 

“ 

legislation, 

  

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would 

the 

use 

rious 

flon~   
  

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there. be 

Py ; < m > 3 P| « $3 
suspended unt i I 

constitutiona 

thing, as 8 lav 

accept. 

votes against 

been a vote ag 

of passage, because 

that passage, but tha 

been the reason. In 

that, states were bel 

I also am aware t 

voting rights 

I believe 1 was at 

Governors' Conference, you 

quoted as being against com 

the Federal Covernment for 

ing the voting right 

orrect, and. I did 

rather ex 

  

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® @ 
  

  

¢aid was omitted, but I stated at 

that time that I was convinced the 

State of Louisiana would be fair 

that -- that we would not rass that 

~~ were descriminatory, and for 

us to have to continue to have 

those lawe cleared hy the Court, 

I mean, by the Justice Department 

before they became effective, I felt 

was wrong, and that {s the reason I 

voted against the resolution, and 

that ie the only reason T voted 

against the resolution, 

I understood it was reported, and there 

was a8 lot of dispute as to whether 

it was accurate or not. 

Let's focus 2a few minutes on 

the powers of the Governor of the 

State of Louisfana., It's my under- 

standing that the Covernor of 

Louisiana {is perceived by most 

political scholars to have c¢ompara-~ 

tively more power than in many of 

the other states, 

Is that your appreciation? 

  

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MR. FELDMAN: 

Are you asking him what his 

understanding is of what scholars 

think about the powers of the 

Governor's Office in Louisiana? 

MR. KELLOGG: 

I am asking him his opinion of 

the Office of Governor in Louisiana 

as compared to other states, 

BY MR. KELLOGG: 

Q To the extent that you know. 

Well, actually, I haven't thought -- 

well, to my knowledge, I really 

couldn't give you an assessment 

that, I think that in terms of 

rank order the fifty states are 

== 1 really couldn't obviously 

=~ there are powers here greater 

than some governors have, 1 think 

some governors don't have veto 

power. I believe that to be the 

case, but I am not a student of the 

comparative powers of the governors 

of the states, 1 am really not. 

I just don't know. I have heard it, 

  

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that Louisiana's Governor 

answering the question, 

don't know. I have heard it 

said, but 1 just on't know, 

you have any appreciation -- how do 

you perceive the power of the 

Governor in reapportionment matters, 

first; and, secondly, specifically 

as to reapportionment matters, 

MR, FELDMAN: 

Jim, I don't want to continually 

Baz 1. ¢t form of your 

questions is so vague that {t's 

difficult for the Governor to frame 

& precise answer. That question 

could encompass everything from 

vhether the Governor has any power 

at all to simply focusing on the 

power of veto or to whether he can 

draw plans. Could you refine it a 

bit, because I do have an objection 

28 to the form of the question. 

MR. KELLOGG: 

those.   
  

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.1 break tt down one 

I am not asking specifically 

Inlon from the 

constitution. 

That's liable to be what you will get, 

but go shead. 

It's my perception that the -- and 1t 

certainly appears from what I know 

occurred during the session, that 

in view == that the Governor has 

an appropriate role in reapportion- 

ment matters, and specifically 

congressional 

matters, I believe in the Just 

Department you set it forth as 

you were the only state-wide el 

official and, nerefore, {it was 

appropriate for you to be concerned 

with those kinds of matters, 

Just asking for an expansion 

that, some deseription of that 

your own words, 

the Governor, of course, has the 

pover in louisiana to recommend     
  

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legislation to the Legislature, and 

he has veto power over, I think, 

just about everything except that 

which 1s specifically excluded by 

our State Constitution, and that's 

not one of the areas that's excluded] 

T will make the assertion that the 

veto power 13 a selective power, 

and {it 4s ~~ the Governor has that 

power, and I guees that's about all 

I can say on it, 1 did propose 

rlans, bills, proposed a compromise 

along the way, and talked about the 

use of the veto power in that 

process, 

for purposes of clarification, I am 

not trying to raise these as argu- 

mentative points, This may very 

well be seen by eyes other than ours, 

by the Distriet Courts, and 41f {it 

does, it will be a part of the 

record, I simply was trying to get 

a description of what your apprecia- 

tion of the nroper role of the 

Governor 1s in those kinds of mat-   
  

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M R . 

THE W 

) 1 different from 

FI.DN 
ei Ad AS 

\ 4A 1 
A ahd 4 

th That wasn't e question you 

asked him, ough. You can answey 

that question. 

* 
. ITNESS 

se 1 
4 

& 
€ It's a role that I think at 

hag to decide how 

he to in the propose 

way of legislation. Obviously 

the constitution doesn't mandate 

Governor to on everything 

that he believe should 

be done, and 

chosen to speak out on the 

that they feel they want to, 

vhatever reason, so I do -- I 

Bo 
oe propose legislation 

with 

often, 

veto some frequency, primarily 

" in money bills, though really I 

think the record will show that 

. 
cv EEped to y appropriaf 

~ 
the oi power 

those appropria- 

  

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BY MR, 

Q Were 

tiong bills, w 

the President. 

governors hawve 

of my veto 

not trigger ha 

all. 

ELLOCGG: 

2] you playing a 

congressional 

opposed to rea 

two Houses of 

and the Public 

and, 

role, 

us your percep 

mo I play: Vell, 

In the Public 

race, there df 

controversy 2i 

" 
oh 

we played 1 

no 

Senate yvea 

hich 

1f you wer 

could yo: 

object ic 

is different from 

I think many 

- < - < that power, o 

8 but I am 

That's 

are there, 

Pry about veto, 

different role in 

reapportionment 

pportionment of 

legislature rd 

Service Commission, 

££ pe 
(SBS = 

different 

  
  

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tionment than I did in the legis- 

lative, ‘and for a couple of reasons 

that may be o! terest, One, the 

legislative reapportionment, legis- 

lators themselves, of course, were 

involved, and it was their own 

reapportionment, The Senate and 

House, I think, had pretty well 

an understanding that of each branch 

agreed on how their branch be 

reapportioned, and the other wouldn't 

get involved, TI only looked at it 

the sense of whether it appeared 

me to be fair, and it did, and, 

» to provide access for anybody 

who wanted to come and talk to me 

as to whether they thought it was 

unfair or not. I think I let that 

be known, Anybody who thought {it 

was unfair, my door was open to talk 

about it. 1 took more of a role 

in the ‘ reapportionment, 

because ‘elt that state-wide 

leadership was needed, becouse you 

can't arrange one district without   
  

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affecting another district, Second, 

because I had been a member of 

Congress and naturally had a strong 

interest in congressional reappor- 

tionment. 

Let's focus for a few moments 

beginning of reapportionment this 

time around. At what point in time 

did you become aware of the need 

to reapportion? I will just call 

your attention to a letter, which 

I can pull out {f you need it. That 

was a letter dated August 15th, 

1981, from Allen Martin suggesting 

that a system dealing with reappor- 

tionment be set up, A couple of 

questions sbout that, One is, could 

identify for the record who he 

what your reaction to that was, 

this the first beginnings of 

the congressional reapportionment 

process in your mind. 

me, Governor. You 

  

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can answer the question, 

are going to refer to documents, 

please show the Governor 

documents. 

KELLOGG: 

That's what I 

MR, FELDMAN: 

I would prefex 

BY MR, KELLOGG: 

Q Would you like to see that letter? 

Let me -- Allen Martin then was 

Administrative Assistant to 

Congressman Bob Livingston. Yes, 

it might be of some help to me to 

see that, 

1 will tell you what, rather than taking 

the time to pull it out right now ~- 

Marty, 1 think it would be a good pra: 

tice, but let me Just say -- 

answer to it, ther 

further eluclidatic 

+0 ¢» y to respond           
    

  

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have to have respportionment prior 

to the 1982 election, congressional 

elections. So it has been something 

I heave been 2ware of for a long 

time. 

Now, it's difficult for me to 

quantify the levels of my awareness, 

but it was a continual awareness 

that we would have congressional 

reapportionment, and obviously, 

28 you get closer to the date when 

you have got to take action, it 

becomes more pressing that whatever 

you are going to do you start doing. 

There was a8 period of doubt as to 

whether the census would be filed 

In time for us to be required under 

our constitution to reapportion. 

I don't know {f you are familiar 

with that, but {f the census was 

filed with the President, then we 

had to enact within the following 

session, I believe, 1s the law, 

but, anyway, that's a matter of law, 

but so -- and then there was sone 

  

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discussion about including it {in 

the regular session of 1981, and 

then as it developed, it was not 

handled until we got a special 

session, I couldn't draw a graph 

for you right now, my amount of time 

but interest has always been there, 

BY MR, KELLOGG: 

I believe on December lst, 1980, at 

least according to answers to 

interrogatories that have been 

provided to us, you met with the 

congressional delegation? 

Vhat date? 

December 1st, 1980, 

It said that one of the 

primary purposes of that meeting 

was to decide on whether reapportiony 

ment of the congressional district 

should be handled in the regular 

session or the special session. 

Was that meeting in Washington or here? 

1 don't have any idea, That was my 

next question. 

Do you have any present nemory   
  

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of that meeting as a discreet event? 

I have that ~~ I think that I may have 

met with the congressional delega- 

tion in Washington ~~ that one in 

tors and 

House members, a I think towards 

the end of the meeting and after 

the senators had left, there was 

some discussion, and I think that 

the content of that was that they 

ay would like, course, to have a 

resolution as early as possible 

80 they would know their districts, 

To the best of your memory =-- 

I don't think there was any discussion 

at that time, I can't be certain, 

but I don't think -- I feel fairly 

sure that there was no discussion 

of the configuration of the districts 

at that time. 

Now, I could make no commitment 

about whether it would be taken up 

in the regular session or not. I 

think I told them I had no problem 

1£f it could be, I would always like     
  

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to avoid special sessions {f 

possible. I feel sure that I told 

them that I would have no problem 

with it being taken up in a regular 

session. 

Was the matter taken up in regular 

session, and we might need to =-~- 

1 don't remember whether the bill was 

introduced or not. 

But as far as you know, there was no 

appreciable movement on that topile? 

No. 

At what point in time was the decision 

of the special session made, to the 

best of your knowledge? 

To have one? 

Yes, sir, 

1 guess a definitive decision wasn't 

made until I called one, actually 

called it, which would be a matter 

of record, but I think there was a 

general perception as we drew towards 

the end of the regular session that 

we would have to have a special 

session on reapportionment.       
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Prior to the beginning of this special 

session, at any point prior to that, 

what contacts, if any, did you have 

with members of the Louisiana 

Congressional Delegation relative to 

reapportionment? 

How were those initiated? Was 

there a correspondence back and 

forth? Was there any specific 

meetings? 

I think we provided you anything that 

was in writing. I believe we have, 

and, also, I think in request to 

the Justice Department -- Counsel i 
’ 

I will ask your advice in response 

to the Justice Department, the 

decision that was made under the 

voting rights act. I think we 

submitted everything that wae in 

writing. 

MR, FELDMAN: 

Yes, sir. 

MR, DeJEAN: 

You provided that, I know. 

THE WITNESS:     
  

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Well, you have the submission. 

BY MR, KELLOGG: 

Q We have coples of letters. 

A Well, that would cover the written 

communications, Verbal contacts 

would be extremely difficult for 

me to reconstruct for you. I would 

categorize them as minimal, very 

minimal, casual, This is prior to 

the session, you are talking about? 

Yes, sir, prior to the special session, 

Could you outline just briefly the 

mechanics for calling a special 

session under Louisiana law, 

Well, the Article III, Section 2 is 

that whenever the Governor wishes 

to have a special session, he issues 

a call, and it must be issued five 

days prior to the session, and he 

sets forth in that call the items 

that will be considered, and the 

general principle is that only 

things that he sets forth in the 

call may be considered during that 

session. I think mechanically that's   
  

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with the Secretary of State 

days prior to the beginning 

session, I think that's all 

there is to the mechanics of it. 

Prior to the time that you issued the 

call for the special session, were 

you aware of any particular plan 

that was being backed by the 

congressional delegation? 

Prior to issuance of the call? 

I guess the call was probably issued 

ten days or so before the seasion, 

I think the record -- 

ere had been congressional 

plans being advanced, and I think 

the group actually got together and 

agreed on that plan, 

To what extent 

Which was sent to me and 

ture. 

That was my question. 

vou made awa 

It was 

that 

  

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prior 

the call, 

to the extent 

™ ££ ay 
my XL £ 

v 
r iran. x y 

there a reason 

your plan over 

I would have to 

communi 

I think it was. t J 

~= representing my 

congressional distr 

arranged, and that 

think, several some 

elements fro the c¢ m 

plan. Particu 

affected the 

Could 

October cation 

o the legislators 

views of how the 

fects should be 

varied in; 1 

eig what n 

ongrees i 

  

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® 

three proposals and the differences 

between them. 

I would be glad to, but this gives it to 

you in writing. 

Are vou referring 

what was submitted to you. 

Dave Treen's three 

is part of the subn 

Justice Department. 

a date on that document? 

This one doesn't happen 

but I think it was 

can be provided to you. 

I don't doubt that we have it. 

This was sent to every legislator. 

This was provided to the press 

and everybody else, so we would be 

glad to have you -- and it has 

maps, : Each of the three proposals 

as described has a color 

just == 1 will describe 

the record, It has the 

ward, precincts, precincts 

in each, and then describes 

racial makeup under the 

  

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als for each of the eight districts 

from the present districts, and, 

then, under each of the three 

proposals 

These were the Treen A, B, and C Plans? 

Those are the plans that we were 

talking about earlier’ 

We will make a copy of that, 

be given a copy with the colors 

it, because 1 now we have got 

3, but we can't distinguish 

one section from the other, 

if we can get some more of 

I think we can round 

it up for you. 

Thank you. It would be very helpful. 

By whom in your office were these 

plans actually drawn? We are talk~- 

g about the Treem A, B, and C 

Plans now, By drawn, I mean con- 

fected, Who came about with the 

alternativ Who in your office 

involved with this process’ 

more than any- 

1¥e that ~= 

  

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wards te 

us 

draw 

the 

lanning 

  

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in this 

divided 

out. 

But you were 

Yes. 

MR. FELDMAN: 

The document the 

was referring to was not 

in the document request, 

it was undated and we had limited 

the time frame within which the 

responses would be given -- why 

don't we mark this as an exhibit to 

the deposition, and then you e¢an 

have ‘it. 

WITNESS : 

Well, this was submit 

the Justice Department. 

FELDMAN: 

Well, they may have 

the submission to the Justice 

Department, but I don't want     
  

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FELDMAN : 
L 8 4 y ”y 

10U Wer:s 

" Reynolds 

KELLOGG: 

We will mark 

as 

KELLOGG: 

Well, preferabl 

colors on it, then 

FELDMAN: dd LJ RE 

Treen 1 1s, 

sense, the 

That was 

letter to the 

sent 

them together, 

it 

Treen 1. 

in a 

congressional 

covered 

legislators. 

for didentifica~ 

y with 

background 

reapportion= 

in the ¢over- 

sheets, h 

I want to try     
    

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the way, I meén, legislators came 

ir here with their ideas. 

BY MR, KELLOGG: 

Q You are speaking of about before the 

special session or during the 

epecial segsion? 

Jock Scott, notably, you know, 

was one, 1 guess, {in here more than 

enybody else, spresding out maps 

and ideas and plans, and, I mean, 

this was a ~~ he was here 2 good 

bit. 

Did you speak with any of the Black 

legislators, and we are still 

speaking of before the special 

session? 

I don't recall. I also do not recall 

ever declining to see anybody 

that wanted to see me about reappor- 

tionment, I don't recall any 

request to vieit with me that I 

did not provide or grant or provide. 

But as far as you recall, you didn't 

seek out, particularly, the input 

of the Black legislators prior to 

  

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this time? 

I didn't seek out the input of any 

Black legielators, I think they 

came in. T provided access, 

MR. FELDMAN: 

I want to object to the -- 

"HE WITNESS: 

I didn't seek out Mr. Scott, 

but he wae knocking at the door a 

good bit, 

BY MR. KELLOGG: 

Q In drafting these three plang, what 

general principles were you operat- 

ing under to the extent that you 

can state those? 

Exactness of districts, general sense 

of fairness, equity, and I suppose 

to some extent the natural or 

natural boundaries, you know, like 

the Mississippi River, or to a 

certain extent, economic. I 

remember in the Third District one 

of the things TI said was that he 

bring 2 lot of the sugar producing 

area together through thie configura-       
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tion, and you will find that's my 

consideration set forth there. 

May I suggest a couple.of others and 

see if these factors played any 

part, Was there any consideration 

given to recognized political 

boundaries, and, {f so, what sorts 

of boundaries? 

There would be a desire to avoid 

splitting parishes, to a certain 

extent, smaller parishes, 

Is there any consideration given to 

the non-exclusion ~- 

MR. FELDMAN: 

Just a second, 

(There was a brief recess at 

this point.) 

BY MR. KELLOGG: 

Q Let me finish my question, 

stopped in the middle. 

1 was asking, did you give any 

consideration to the non-exelusion 

of recognized voting minorities? 

The racial mekeup of the districts 

obviously was considered in putting 

  

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together districts in this sense: 

That the numbers had to be deter~ 

mined as they would fall in each 

district, and I guess =-- I don't 

recall specifically, but I am sure 

that I recognized that this would 

be a factor of interest to the 

legislators as they considered the 

legislative plans, and, of course, 

there i138 no way mathematically to 

avoid reducing the number of Blacks 

in one district {f you increase 

it in another. So when you say 

was coneideration given to non- 

exclusion =~ did you say -- 

Yes, sir. 

I guess I am grasping for what you may 

be driving at, so maybe you better 

== but in this submission, you will 

see that I indicated what the makeup 

would be, let's just go ahead and 

get into it right now, upon these 

plans, In that under -- under the 

several plans that I had, I think - 

let me refresh myself here. The       
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First, Second, and Third -- the 

First and Second Districts were 

identical in that ~~ and if this 

re focusing on -- 

l District ~- 18 that 

are focusing in on? The 

1ree proposals that Dave Treen 

advanced all Increased the Black 

voting In the Sacond District from 

40.7 percent ~~ excuse me. Now, 

T<think this {s populetion. 43.5 

recent, all three plans, and it 

cut down the Black vote in the 

First District. Now, I can tell 

you the cutting down of the Black 

vote in the First District was not 

intentional, but a necessary result 

1£f you are going to increase the 

Black vote in a eontiguous district. 

I understand. Focusing on some other 

to what extent did the 

of incumbents play a 

drawing of your plans? 

Not too much, except that later on, when 

ft occurred to me that there were 

    
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some forces that were targeted in 

on Bob Livingston's -- the district 

he represented ~=- that didn't sit 

well with me. 

You are speaking after the special ses~ 

sion? 

Well, after the ~~ well, I don't know. 

Whenever the Nunez Plan emerged. 

Let me focus the question so the record 

is clear, 

Prior to the time of the 

session, as you were draw- 

g up your three plans, to what 

extent did protection of incumbents 

-=- was protection of incumbents a 

factor? 

That's difficult for me to quantify. 

Did it play any consideration in your 

drawing of the three plans? 

Well, I think that =-- I think (t's 

fair to say that =-- well, first of 

all, what protects an incumbent? 

You know, that's a question, because 

there wae a difference of opinion   as to whether my proposals would 

  
  

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  To 

help or hurt G41l1lis Long, for 

& example, One of them I thought 

would help him a great deal 

he thought {it would hurt 

it depends on where you 

I think in all of my proposals, 

1f I am not mistaken, I think that 

the incumbent congressman would not 

have to move if he wanted to run 

in that district, which he doesn't 

have to do, of course, but the 

political realities are that you -- 

1s that congressmen have a 

support in the Legislature 

districts, So I think to be honest 

you have to say that that 18 the 

consideration in anybody's drawing 

of a plan, but that was not =~- 

certainly was not an overwhelming 

P # 1] consideration. I guess that the 

only way I in say that, 

what extent in the drawing 

plans -- still focusing on that 

area -- was getting a safe seat for 

Congresemen Livingston & considera~ 

  

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tion? 

MR. FELDMAN: 

You mean now, 

Governor was 

proposals, prio 

session? 

BY MR, KELLOGG: 

Q His own three ple 

session. 

say not significant. In fact, 

I. didn't really focus in on Bob 

Livingston. I think he {sg ve 

strong, ‘1 think he wae ceapebl 

in almost any configured 

I think he very well could hav 

won in the Nunez proposed dist 

but that was not -= {t might 

better if you understand how 

came about, how Dave Treen's 

posals came gbout. You take 

existing 

Necessary 

ing point in my 

¢0 into     
  

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al district. 

he modifications and 

. You take 

balance &nd estimate 

anything that would be unconstitu- 

tional, that would be unfair, and 

so you put it together that way, 

and the eminently logical way that 

the -- the second and third were 

the districts that 

balance a great deal, 

In fact, I think the F 

was right on the money in 

population. So, no, I - 

make a case, 1 suppose, 

Republican or for Livin + 

can say {is 

thinking >] 

speculation at the 

  

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plans 

hawe 

if he, at suc! 

Covernor of this 

éxtént did that play a role in your 

confection of these plans? 

None, My district wou be state-wide, 

and I was unable to alter that. 

Pid you have any ~-- 

At least no way occurred to me to alter 

that. 

I understand. Did you have any communica- 

tions with the U, 8. Department of 

Justice prior to the convening of 

the special session relative to 

congressional reapportionment, and, 

1f so, what communications were 

those? 

I think there was some indicated in the 

submission, 

MR, FELDMAN: 

given every submission 

Governor, to the 

ou dDetween   
  

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and September 

were the dates 

agreed as being 

limiting dates to the freme of 

reference of his request, 

THE WITNESS: 

From what date? 

MR. FELDMAN: 

.» 1981, to September 

1 communications with 1, 

the Justice Department from your 

office that were in the file. 

MR. KELLOGG: 

All written communications. 

MR. FELDMAN: 

All written communications. 

THE WITNESS: 

I don't think certainly any 

occurred prior to that time, and 

your question was at any time 

prior to this session? 

BY MR, KELLOGG: 

Q At any time prior to the session. It's 

my understanding that, you know, 

G, Bradford Reynolds, the Assistant 

  
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Ch, 

Coul 

i go 

No. 

Vas t 

Prior 

  
August of 1981, 

Se 

Attorn 

i 

ey General Rights 

s that correct? 

b 4 es. 

brie d you fly describe for us the 

nature of that relationship? 

t hi “ to know fn connection wit n 

the litigation involving higher 

education in Louisiana and worke 

the of settlement 

he settlement of that litips 

prior to or subsequent to 

special ses 

to. That matter was t a set 

to the sessior 

saion was In 

any verbal communica-   
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nean orel ecommunicat: 

understand the questioc 

have ‘been, I think, on a casus 

asis, I have a recollection of 

asking for ~~ and I don't know 

whether I1'did this ‘to him or some- 

for a copy of one elege -- asked 

the rules and regulations or policy 

that they may have had, and I don't 

know when that came, to tell you the 

truth, I think it probably came 

before the session, and I think we 

have -- there may have been some 

communications, 

BY MR, KELLOGG: 

Q Of the written communications, you are 

speaking of the submission te the 

Justice Department after Act 20 was 

passed? 

session? 

  

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®_ 

Prior 

None 

  

to the session, 

stand out, I would have to =~ 

stand out, I would have to 

and see, and I doubt 

keep records of phone 

much, but Reynolds 

versations all during 

and 1t 1a -- 1t¢ 

we discussed on those occasions 

something to do with respportion- 

ment. No outstanding event stands 

in my mind about it. We were also 

-- when 1 said we settled that case, 

1 want to add to that we sett 

the main part of the case in 

of 1981. We continued for -- 

MR, FELDMAN: 

Seven months, 

THE WITNESS: 

And during this time frame, 

conversations about 

the Caddo-Bossier aspect of that 

dispute, and that was ing along 

at the same time as reapportionment. 

We very well may have had 

  

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BY MR. 

Q Is it your usual practice when you have 

I usually do not. 

Does anyone in your administration make 

No 

Se there would be no phone logs of who 

KELLOGG: 

mentation of telephone conversations] 

conversations with him at that 

time, but nothing =- nothing of any 

outstanding ~~ nothing eventful, 

I would say, 

telephone conversations with a persor 

to keep notes of those conversations 

or to dictate memos of the conversa- 

tions or to make any written docu-~ 

documentation for you of such 

conversations? 

No one else listens to them, 

you ~-- with whom you spoke on 

particular occasions or the general 

subject matter of those conversa- 

tions 2s a general practice? 

These blue cards are phone calls 

that I haven't returned, and the 

8 record is kept of that until I 

return them, but once the card is     

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disposed, there is ~~ now, some- 

times I do dictate memoranda {if 1 

consider it something that I want 

to record, or something ~~ 1f it's 

important to, I will do so, but 

routinely it 4s not done. 

about meetings, face-to-face meet~- 

ings with particular persons on 

particular issues? Do you keep 

memos of that, or do any of your 

aides keep memoranda of that? 

It depends, It routinely 1s not done, 

but I have a sheet here of my 

appointments for today, and that 

record 1s kept. 

I see, Is there any dictation afterwards 

as to what transpired at the meet-~ 

ing or what was discuesed? 

Sometimes. Sometimes I do, 

@n aide, who may be in here 

do so. 

Under what circumstances would that 

dictation occur? 

Usually when I make 2 commitment, I will 

dictate 8 memorandum, 

  

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Let's 

Or 4f I want somebody to follow up on | 4 

All three were introduced, and I would 

focus ~~- 

something, I will dictate a memoran- 

dum, If 1 had 2a meeting and I have 

been asked to do such 

I wi 

's focus now on the special 

legislative session which was in 

November of 1981, I don't want to 

go through all of the details of 

what transpired at that time, I 

Just want to have an understanding 

from you of what happened in general. 

Again, I point out that we are not 

talking -- when we say Treen A, B, 

or C ~~ 1 am not concerned about the 

particular refinements which are 

part of the legislative record, 

Could you tell us briefly when 

Treen A, B, ‘and C were introduced 

end which House of the Legislature, 

to the extent that you know, and 

what happened to each of then.   
  

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have to go to 

you on what 

is no need to speculate Tl re 

shows, I thin 

duced on the 

You didn't have anyone 

in the Legislat 

as your spoke 

plans? 

Whoever the author: 

wouldn't say the 

became authors that were not 

men for the plan. Actually, 

don't think we -- I don't thin! 

there was any real organized 

on these plans. I put them 

consideration primarily. 

went on, there was the -- the racord 

will reflect, and I honestly can't 

reconstruct the -- the Jouxnal, of 

course, 1s the 

that, but the ~ 

proposal B 

different people, or one 

in the Senate     
  

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try proposal B, I think Jock Scott, 

and 1 get B and C mixed up, but 

the record will show that, but my 

favorte proposal was A, and our 

efforts were concentrated on A. 

(There was a2 brief recess at this 

point.) 

BY MR, KELLOGG: 

Q Just to remind you, we are focusing on 

the legislative -- the special 

session. At what point did you 

become aware as to what we heave 

referred to as the Nunez Plan? 

Was it prior to tt session, during 

the session? At what point? 

It would have been close. I don't think 

that --.1 may have had a general 

awareness of it prior to the cession, 

but not with any specificity until 

after, 1 guess, it came up in the 

Senate out of the committee, Prob- 

ably at that time. 

8 your first awareness of 

details of {t? 

ve Ss yes,   
    

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am really trying to give you an 

honest answer, I think that was 

probably about the time. It -- 

there was so many ideas, plans kick- 

ing around here, rumors about what 

committees were going to do, and 

what they would do, and I don't -- 

I don't usually pay a lot of atten- 

tion until some definitive action 

is taken, 

there any particular constituency 

of which you were aware for the 

Nunez Plan? 

FELDMAN: 

I didn't hear the question. 

KELLOGG: 

Was there any particular 

constituency that you were aware of 

of the Nunez Plan. 

FELDMAN: 

1 am going to object to the 

form of the question. I don't 

suppose there were any, 

IE. WITNESS: 

I would assume’ that you meant       
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conetitvency for 1t? 

otherwise, 

the plan of which you were aware? 

Well, aes time went on, it was apparent 

that Lawrence Chehardy was interested 

in the Nunez Plan, 

That's the Assessor of Jeffer: 

0f Jefferson Parish, and 

MR. DeJEAN: 

referring to the Assessor, 

~ 

The younger Chehardy, 

during the legislative 

- b | 8 process, that's all that I cen 

recall outside of 

although I heard that 

Covernor was involved 

BY MR, KELLOGG: 

Q You are speaking of 

Fdwin Fdvwarda? 

Edwards,     
  
  

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Were you aware of the Black legislators 

on this particular plan during the 

legislative session’ 

I don't recall them ever coming to me, 

but I think the vote ~~ as the vote 

occurred, it was apparent where 

they stood. 

You realize, of course, that the 

created -- I don't think it’ 

unfair to characterize it =-- 

would have passed, it would have 

created what I think you referred 

to as a Jefferson Parish-dominated 

but, also, had, as an effect, that 

it would create 2 primarily Black 

majority district centered on 

Orleans Parish, 12 that correct 

Yes. 

You were aware of that practically 

the beginning of your knowledge of 

the Nunez Plan? 

Well -- from the beginning of 

From your knowledge -- ne rephrase 

the question, because at what 

point were you aware that the Nunez 

  

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lan would do both of those fact 

Sometime during the session is all I 

tell you. 

All right, At what point did 

a position on the Nunez Plan? 

I would have to say fr 

I -- without specifying the time, 

but I think what you want to know 

is what caused me, from the time 

that I became fully aware of 

1 was unfavorably disposed towards 

it, and the votes ~- and the 

were a8 lot of different votes, 

that would reflect, I think, the 

Administration's position as those 

plans c&me up. 

the plan, 

Excuse me. You were opposed to the 

Yes, right. Not because it created a 

Black majority district, because 

said repeatedly d 

legislators that 

  

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You h 

Yes. 

Prior 

Yes, 

How w 

1 gue 

Throu 

Yes. 

Was t 

Houses you would 

ad a position on 

is that correct? 

£0 that t 

as that position made known 

legislators, if it was mac 

to the legislators? 

ss {t had been made known when { 

was voted on in the House. 

gh your floor leaders or through 

particular individuals? 

I would say through floor leaders, 

It wags certainly not a sec: 

I mean, I didn't address 

Legislature, I didn't comn 

with all of them in 

form, and I don't know 
$ 

a press statement 

of the one which 

on. 

here any personal 

  

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Buti it 

Excuse me. 

Go ahead 

Yo eo Was there any persont 

to the threat of 

or by any member 

Any lobbying would 

Dave Treen's Plan, 

fox have been done 

a plan came up that 

- 
of which would have 

out 

fought for 

So it would not be 

lobbied against the 

J to the time o 

Plan 

Tr 
T nl fa o ’ I 

went through 

relatively easy, 

without any ‘ 

any lobbying effort 

the floor leaders 

unders 

that. 

stop our plan or stop 

fair ¢ 

came 

a nd 

3 7% va 
Con 

Lobbying would 

Any time 

the effect 

been to knock 

our plan, we 

o say that you 

Nunez Plan prior 

the threat 

up against 

think {t 

the Senate 

don't think 

recall of 

or efforts of 

that time, 

general, and 

  

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corxect me If I am wrong, please, 

that the Nunez Plan passed through 

the Senate and a very similar ver- 

sion passed through the House, and 

it was at that point that you made 

known to the legislators that if {t 

was passed in a final form by both 

Houses, you would veto that plan, 

Well, without vouching for the factual 

statement, part of your question, 

as it was passing in both -- but 

the record will clearly reflect 

when I went to the press and said 

that I would veto that plan if {it 

came through. 

it your position -- 

There was some action taken, Jim. There 

was some action taken in the House, 

which I am not sure whether it was 

on proposal B or proposal A, 

again, the record will reflect 

and so the record should speak 

exactly what happened, but 

I. think proposal B lost out, 

L) 

C:lost out 1% the 

    
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r 60 
  — 

Nunez Plan, procedural or something, 

but it lost out in ft. I don't 

think the proposal A came before 

the House. I think {it was proposal 

B, I think, advanced by Scott, I 

believe, at that time. 

Let me focus on =- 

So that the Nunez Plan had a head 

steam, {if this 1s what you are 

getting at, 

Is there any difference in your mind, 

&ny major differences -- is it your 

position that the Nunez Plan did 

not pass both Houses of the lLegis- 

lature in substantially the same 

form? This 4s a point of clarifica- 

tion, 

MR, FELDMAN: 

Governor, you are not obliged 

to speculate. I just want to remind 

you of that, If you recolleet the 

facts that are responsive to a ques- 

tion, you should answer. If you 

don't, you should say you don't. 

THE WITNESS:     
  

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you got a record that 

then I would have, 

to rely upon 

be g¢orrected by 

would show, but 

not aware that fina 

taken in the House, 

tive action taken {i 

the Nuneg Plan, 

that, 

BY MR, KELLOGG: 

Q Is it fair to say that yc 

that the. Nunez Plan 

both Houses of the 

out interven 

some intervent 

3 Well, I really don 

gubernatoris 

were concerned 

11 pass 

that poin 

  

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just as effective es 

other words, 

Nunez Plan for that 

Legislature, 

Would you agree or disagree 

with that assessment? 

Well, what relevance does that have, 

that the news people speculated 

on that? 

I wasn't focusing on the news people. 

MR, FELDMAN: 

Your question. asked him to 

agree or disagree with the newspapers. 

I think the Governor is absolutel 

correct. Why don't you just ask 

the Governor what his view {s of 

the so-called threat of veto without 

testifying as to what newspapers 

have said. 

BY MR. KELLOGG: 

Q That's what I was just about to do. 

Governor, what 1s your 

How do you perceive the 

the veto? 

I don't know. I think it could have.     
  

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I am speaking -- 

Well, okay, but 

you that I really 

ever you brandish 

run the risk that it will 

attitudes against the Governor 

I can't tell you 

whether it had 

of not passing it or not. 

think it would 

judgment, without that 

what you are getting at 

think it would have passed 

The purpose of your statement =- 

I1f I am not mistaken, the proposal 

had been approved by the I 

Again, the record will 

I don't know if you recall 

I think the proposal A 

MR. PELDMAN: 

Over the weekend, 

  

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sgain, the record will show it, 

go I don't think it would have 

passed without that statement, I 

think what really motivated me in 

making the stetement, obviously 1 

didn't want the Nunez Plen to pass, 

There ie& no question about thet, 

and, again, not for the reasons 

that are suggested in this litiga-~- 

tion, but I didn't want it to pass, 

1 wanted them to know, you know, 

thet they might have to come back 

for another session. 

(There was a brief recess at this 

point.) 

BY MR, KELLOGG: 

Q We are talking about opposition to the 

Nunez Plan, 

Yes, 

Could you state for us why you were 

opposed to the Nunez Plan, 

Well, I think, several ressons, but let 

me say that one of the reasone was 

not because of the racial makeup of 

it. The First and Second Congres-       
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sional Districts historically have 

had a big piece of the City of New 

Orleans, Certainly a case can be 

made for New Orleans to continue to 

have a strong voice with two con- 

gressmen. The wholesale change -- 

the First Congressional Distyict, 

on the order of, what] 75 percent 

new district? Something like that? 

It was a contrivance in my opinion 

to -- to go to an extreme with the 

geographical configuration to 

provide a district that would 

dominated by Jefferson Parish. I 

am from Jefferson Parish. That's 

ny home parish, Jefferson Parish 

had a very strong voice in the 

Third District. I was elected from 

Jefferson Parish in the Third Dis- 

trict. It was not necessa: 

my opinion, for Jefferson to have 

a strong voice, a dominant voice. 

I felt 4t was patently unfair to 

St. Bernard and to have to say, 

"We have a district that will be       
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dominated 

I thought 

designed to do what 

the proponents were mo 

admitting that it would do, 

be to give Jefferson Parish 

dominating role in that congression- 

al district, and while no congress- 

man, as 1 have said before, nor 

legislator, owns a congressional 

district, no one has an inherent 

right to be protected under reappor- 

tionment. I argued that unsuccess~ 

against the forces of Hale 

in. this Legislature many 

ago. On the other ha 

think anyone has 

have a district single 

kind of massive surge: 

envisioned under this 

You saw this as ¢ 

ake out larg: 

Livingston's   
  
  

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Congressional Dis 

You used the term 

describe what you 

Are you 

in general, 

Parish would dominate it, or was 

it more political in the general 

sense of the term? Were party 

politics involved with the attempt? 

I don't know that there was so much 

party politics, since in the sense 

of Republican versus Democrat, 

although I feel sure that may have 

been’ to some degree, but I think 

it was local pol 8 in the sense 

of Jefferson 

I think it wae demonstrated by the 

strong that was given by the 

dud Vo 1 oo 2A py um or] Lesh Delegation, and 

re was a good bit of lobbying 

it on the basis of what this       

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You *e 

Mi 

think that a of the 

plan. IT don a plan 

- t o establish majority 

district. 1 ¢ provided 2] = 

convenient lance, 1f you will, 

but I think the plan was to find a 

way for Jefferson Parish to dominate 

2 district, and I think even in one 

of the plans Jefferson Parish would 

have a plece of three eo ongre ssmen fi 

One would be very negligible. 

entioned earlier that you saw the 

Nunez Plan, attempt 

to Congressman Livingston's 

& 
his been think 

75 percent something on 

Those fiesurees are 

avallable, 1¢'s entirely 

MNnnecessary In "ey view in ¢ Sal i / = W entirely 

  

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unnecessary to ~ and at varlance 

with what I said was my operative 

principle which was to start with 

what your district was and to make 

the modifications necessary 

made to give you the balance 

the same time observing all 

things that I stated should 

observed if you did that. S 

Did you do any analysis or anyone 

any analysis as to electability of 

Congressman Livingston under your 

plans as opposed to the Nunez Plan? 

No. 

None of that analysis was done at your 

direction or to your knowledge? 

Not that I can recall. I wouldn't see 

any reason to do that, 

Fast Jefferson better than 

analyst, 

used the term contrivance 

minutes ago. Were you 

that you felt this 

trivance to make a 

was {it a contrivance 

  

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MR. FELDMA) 

nswered that it was a 

to provide a geograph- 

Jefferson dominated district. 

your question -- 

THE WITNESS: 

I think the genesis was the 

district that would be dominated by 

Jefferson Parish, 1 think that 

wags the genesis of it. Now, when 

those pursuing it thought that it 

would fit in neatly with some other 

considerations and would provide 

some additional alliance, I don't 

know, but it obviously got addition- 

41 alliance because of what {it did 

to the Second District. Whether 

that was planned in the beginning, 

I do not know. The contrivance 

I referred to was when I said 

contrivance, and 1 was referring 

to the plan to build a dominated 

Jefferson Parish District. 

BY MR. KELLOGG: 

  

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So it was not your 

time of this s 

that was a c¢ on 

$x Black majority 

«@ a fair stateme 

I don't think that' 

kn 

whether there 

engaged in the 

had that idea 

know, to tell 

Your perception of 

MR, FELDMAN: 

That's th 

have asked the 

don't think yo 

any more, Gove 

“ 
+ BY MR. KELLOGG 

Q was there Governor, 

in your oppost 

Plan, the ripp 

plan might hav 

lon't recall. 

perception at the 

pecial session that 

trivance to make a 

district? Is that 

nt? 

where it [= 
~ started, 

ow, I don't know 

wag any of those 

planning of it that 

in mind, I do not 

y you the 

it was not 

e fourth time you 

question, and 1 

u have to answer it 

ror, 

any consideration 

tion to the Nunez 

le effect that the 

e on other districts? 

vou were primarily 

happening 

  

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in the Orleans Parish, Orleans 

and Jefferson Parish areas and 

surrouding parishes? 

and to the extent that it had a 

ripple effect on the other districts 

that would be at variance with what 

I thought was the best plan, that 

I might have been concerned about 

the ripple effects, 

But the focus of your opposition was 

not that it may have split a 

particular parish between the 

Third and Fourth Districts, and 

the Fourth and Fifth Districts, 

is that a fair assessment? 

I can't -- I don't recall what {it 

exactly did in these districts at 

this point, It had something to do 

with East Baton Rouge Parish, At 

one time 1 think that plan may have 

been to split Fast Baton Rouge 

was some local 

newspaper 

to that, 

it was 

  

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centered on that, what it did to 

the First Congressional District. 

I see. Was there any other opposition 

to the Nunez Plan? 

Also, let me just say this: I felt 

that -- I stated it at the time -- 

that New Orleans had had two 

strong representatives that had 

had Eddie Hebert and Hale Boggs 

representing New Orleans, It's a 

large, metropolitan community, 1 

thought there was something to be 

sald for New Orleans having a 

strong voice in two congressional 

districts, two congressmen, and 

under that plan, I think they would 

be minus Orleans Parish in the 

First District. 

You are speaking of the geographic 

Orleans Parish, not the Orleans 

metropolitan area? 

Well, no. The City itself, I thought 

the geographic area would be well 

served, but the City would have two 

voices, 

  

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Was there any other opposition? 

thought there was some value to the 

And, again, you are not speaking 

opolitan area? 

ing of the City of New 

articular 

>or have a position as 

’) me , +t 4 ¢ 
were RNR LLE 

re any substa 

Orleans Parish 

of whict were 

tors wh 

think you would have 

£ opposed, Mrs, Boggs       
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was publicly. 

Were there any 

of whom you were 

Bernard Parish? 

9 Tammany Parish? 

I don't recall. 

Placquemines Parish? 

I don't recall, 

Congressman Livingstor 

Oh, s opposed he was to 

You had conversations 

ngston 

Yes, 

Would you describe 

extent of your intera 

Congressman 

topic. 

MR, FELDMAN: 

Nunez 

BY MR, KELLOGG: 

concerning 

Livingston 

Faso tors 
fiCials 

Orleans 

n 

the Nun or 

ction 

on 

Plan? 

  

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About the Nunez Plan. 

1 guess I can give only a 

characterization, becaus don't 

remember specifies; but hi feeling 

was that it was not necessary, that 

he had worked hard to represent 

St, Tammany Parish, got to know 

their needs, had established good 

relationships in St. Tammany, and 

why should he, you know, have to 

face a district that would have 

75 percent new constituents. Those 

were his concerns, even th 

lot of those constituents wc 

one might presume they might 

philosophically oriented his way, 

thought he had done 

representing the City of New 

Orleans, and I think wanted to 

continue to represent 

thought he had done a 

represen 

would 

would have had a serious, 

reduc~- 

  

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® 
  

tion in his Black representation, 

and he felt that he was representing 

them well, had established good 

relationships with them. Those were 

some of his considerations, some 

of the things he talked to me about, 

1s it fair to say that some of those 

became some of your considerations, 

also, in your opposition? 

Well, I had a number of the same feel- 

ings. I don't know that, you know, 

most of these things were fairly 

obvious. I had served in Congress 

with Bob Livingston myself, saw how 

he operated. frankly thought he 

had done a great job, and in terms 

of things for the local community, 

the combination of Bob Livingston 

and Lindy Bogge wat 

the Appropriations Committee, one 

a Republican and one a Democrat. 

So had a lot of the same feelings 

that Bob ivingston had, So 1 

wouldn't say that talking to me 

about them certainly didn't cause       
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me to become aware of them, because 

1 was already aware of them and 

didn't really influence me towards 

my position. 

To the best of your knowledge, were any 

of the other members of the 

congressional delegation opposed to 

the Nunez Plan? 

Well, Counsel, 1 was told these things 

by Mrs. Boggs in conference. 

MR. FELDMAN: 

Let's 1 

THE WITNESS: 

Were any other men 

delegation opposed, 

MR. FELDMAN: 

Other than Congressman Liv 

the question, 

1 said I ama 11it     
  

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state factually whether members 

of Congress were opposed to the 

Nunez Plan, {if they said something 

to you about why they were opposed 

to the Nunez Plan that you consider 

to be privilege information, and 

I think you should state so. 

THE WITNESS: 

Well, in all fairness, I 

can't recall now whether it wes 

direct or through somebody else 

on Mrs, Boggs' position. On the 

other menbers of the delegation, 

1 think they preferred their plan. 

Several of them didn't like mine. 

Tauzin didn't 1ike mine. I think 

John Breaux didn't think he had 

any problem with mine, but in order 

| £ to beat mine, 1f ft took the Nunez 

0 beat mine, then they wou 

support that, So I would 

say that at least at sa 

Tauzin and Breaux favored the 

Nunez Plan, although I think it 

was a strategy involved more than 

  

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BY MR, 

10 That 

Yes, 

You 

ir 
EFL 

% 

= wn wr PP n & - 2 ion. Rw pe F yp 
anything else. I don't think 

. we Jf 4 na wn TO . - - ™ ~ th two northernmost congressme: 

themselves. 

1.OCQC » 
LR LS BN ® 

would be Mr, Waggoner and 

Mr, Huckaby 

They were prett v 211 out of 

process I don't recall, whole 

don't think re too much was 

difference in their districts or 

my plan or th 

Boge: 

4 

standing 

opposition 

now, this 

speculs 

better not 

eve you said there was 

communicated you, either from 

thro intermediary, 

that there opposition to 

the plan, 

- well, to characterize it as 

know, in the realm of 

    
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why such a8 massive change -- you 

know, certainly she, from her 

stéandpoint, had well represented 

the Blacks in her district, from 

her point of view, and well 

represented the City of New Orleans, 

and it was unnecessary to have such 

a drastic change, So I guess all 

I can tell you is I think it fair 

to say that, of course, she may 

have had some public statements on 

this, as well as -- but 1 got the 

impreseion, and, again, this may 

a combination of things that I 

heard from other people, that she 

would prefer not to have that kind 

of a change in her district, which 

I can well understand. She was 

being elected overwhelmingly in the 

district she was in, Why change it? 

Towards the £f the legislative 

Yoru 1a 

1ion, &@ compromise plan came 

I believe you introduced what 

dubbed as Plan X, and -- 

re about to run out of letters. 

  

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1 believe so. There ultimately was a 

compromise reached which became 

Act 20 of the Legislature. 

Yes, 

Could you tell us what you knew about 

that plan, about that compromise 

process at that point in time. 

MR, FELDMAN: 

About the compromise after 

Flan X? 

MR, KELLOGG: B 

Q The compromise that became Act 20, 

A Well, let's see, I don't remember 

exactly the legislative process, 

what the status of the legislation 

wag at that time, but we proposed =~- 

I proposed X publicly. At that 

time, I think, several of the 

congressmen were here. 1 know they 

were here towards the end. I think 

they had all arrived by that time. 

The matter was taken up, I don't 

know who all the players were. They 

met some place down in the basement 

of the Capitol and considered this     
  

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plan, 

Excuse me for a moment. Were you aware 

of that meeting as 1t was taking 

place? 

Did you have any input or were 

any of your aides involved in that? 

No, none of my aides were involved in 

that meeting at all, There was a 

newspaper report at ome time that 

said we were, which was e: 

and I don't know when all 

It didn't real 

much, although I 

plan... Where they were meet: 

who they were meeting with 

(There was a brief recess at this 

point.) 

BY MR, KELLOGG: 

Q We gz about compromise 

became Act 20, 

mean about when 

participat 

compromi e 

Yes, 

I believe 

  

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% 

have asked very open- 

Wane Co De 

your memory. 

I don't remember 

it... but it's 

day 1 had a press conference, 

describe the compromise, what I 

called Plan X, and then after that, 

many people were involved in this 

process, Nunez, O'Keefe. I guess 

it was primarily the Administration 

and the Senate and the congressmen 

and Lawrence Chehardy was deeply 

involved. 

referred - 

I understand they were having meetings 

and, you know, they had computers 

and data banks and so forth, and 

nessing with differ- 

thea: B Tha they came 

late in the 

<3 » #3 3 3 a 
 ADed This   

    
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Excuse me, We are speaking of 

plan that became Act 

have any present knowledge 

plan that was? 

Essentially that there may have been 

one or two modifications subsequent 

to that, 

They came to see you? 

Yes, 

And what happened? 

A bunch of ~- 

And what happened at that meeting? 

I listened and told them -~ trie 

give them an answer or a re: 

to their proposal as soon as 

possible, and I think we gave them 

a response the next day, which 1 =-- 

essentially was, I think, to accept 

We may have had a modification 

or presented {it to them, 1 am sure. 

There has been described in the New 

Orleens Times Picayune 2 meeting 

which took place in the sub-basement, 

I believe, on the Senate side.       
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. 

I was told. 1 was not there. 

Did you have any participants at that 

meeting? 

No. 

You were not 

was decided 

Well, there were meetings down there all 

the time, Now, I think Senator 

Nunez called me one time, told me 

they had come up with something, 

told me he hoped 1 would accept it. 

I think, from time to time, he or 

somebody else would say that they 

were working on something, "We are 

getting close," that sort 

and you would see them in connection 

with other things that they wer 

coming up with, but I said I would 

be glad to listen. V itude was 

I was ~~. I wanted 

advanced plans 

promise X, which I 

press conference, 

listen to everyb 

ideas, 1 will       
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working - ~ there were differences 

amongst them, also, down there, 

ag 1} 

conflicts 

understoo d. I had heard that 

began to develop between 

Chehardy and some 

and so 

1 heard 

down there, 

that. We 

former 

of 

former 

heard. 

a lot of people 

their finger in 

that 1 really was 

18 “@ 

it came 

their product 

didn't like 

ifdn't 

that 

the 

in the 

the 

forth. 

that 

Governor? 

Edwin Edwards, 

Governor. 

Can't 

interested 

t like 

matter. ni fact, 1 

extent 

lack 

So 

the 

and he was involved in 

had nobody in there, 

You are speaking 

again? 

That's what 1 

vouch for but 

apparently had 

the thing, and all 

concerned =-- I 

in was the product 

back here, and when 

came back here ’ ‘x 

it as well as 

it well as X, for 

think, to 

that are interested 

of configuration in 

Second Congressional District, 

  

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8 

it wag under 

am not sure, 

became the 

1 & ultimately. 

\ 
Po you remember 

Congressman 

% plan by teleph 

MR. FELDMAN: 

Concerning 

207 became Act 

BY MR, KELLOGG: 

1 n 
The Q n compromise pla 

minor modificat 

was one 

de Jn 

this 

Speak 

greatey under 

conversat 

my Plan X 

theirs slightly, 

case, but 

ition I oY not, 

that 
: 2 

basically 

anda accepted {it 

fr { with 

rnine 
~ AL 4 ng conce this 

"ne i a bf eon ! 
OX rsoni 

ions, 

the principal I ! 

member who 

spoke, 

PVT IR | 
Cd LL 

  

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Tavzin w not here that particular 

night, but there w¢ : I think 

either Gilli: 01 representa~ 

tive was here to descr it. 

Do you remember making 

that you felt like 

funny on 

Could very 

don't know 

"funny." 

then, we have seen some 

ones in states 

congressional 

legislative. 

you concerned 

was mapped 

to get 

approval 

there. 

the plan? 

"" my recollec- 

it made changes beyond       

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Uptown area, which was put ia the 

First Diatriet. 1 think, if you 

will look at the map of Plan X as 

opposed to the ultimate plan, I 

think which I called Y, I am not 

sure, but that the configuration 

was neater, It put some precincts 

of Jefferson Parish into the First 

Congressional District, 

the principal difference, I think. 

What they came back with was to take 

that Uptown area, Fourteenth Ward 

area primarily, and put it into 

the First Congressional District, 

and not take portions of East 

Jefferson, and Tauzin was not here, 

which I regretted, because, actually, 

1 think my plan would have been 

more satisfactory to Tauzin than 

the compromise plan that came in. 

you concerned - 

wanted to be rid 

son, This did that. 

accepted it after 

it overnight,     

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you concerned that this might 

dilute minority voting strength? 

do you mean by dilute? 

you concerned that it had any 

effect on minority voting strength? 

Il had no concern that it had an unfair 

Were 

Well, 

or discriminatory or unconstitution- 

al effect. 

you concerned that the districts 

drawn were compact? 

I didn't -- 1 didn't have real 

constitutional concerns about that, 

because, as I say, our experience 

has been that it has been that the 

Courts have approved that, and, 

indeed, I don't think that they 

have ever ruled out anything except 

on a racially discriminatory basis, 

but from my own point of view, as a 

matter of policy and having people 

understand where their districts 

are, 1 thought that ~-- I thought 

that the Plan X would be clearer 

and easier for people to understand 

and, also, was great a 

  

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historical 

you 

anced wats 

nately 

) Ul nd - 

roundaries 

I don't know 

there.       
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f . 

wards are political boundaries. 

Neighborhoods, just to change in 

that Uptown neighborhood, that 

maybe wasn't necessary, but the 

fact that it was the Fourteenth 

Ward or the Third Ward or the 

Nineteenth Ward or the Second Ward 

doesn't give me a lot of concern, 

as 1 recall. 

you or any of your aides have any 

contact with Congressman Livingston 

while you were considering this 

plan? You said that you were giv- 

ing him the answer that next day, 

Did you? 

he was here, and he was in the 

I think, for the several 

prior to the final vote. So 

steady communication with 

and 

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Let's 

Livingston had no 

with the fina 

concurre 

hing e 

would have DYE 
® 

congressional 

Rh] v ” d Plan preferre 

you would have 

he concurred. 

Fo | focus now on the period 

1ich 

you, 

nodding head affirma 

(es, Excuse me 

ultimately submitted t 

£ of Justice partment | 

ry be J 

about 

PY 

f oY 

oblem 

timately 

N : 1@racter- 

after 

it was 

tively.) 

o the U. S. 

approval? 

fore 

your 

the 

  

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could you describe for us your 

contacts with the Justice Depart-~ 

ment in gener2l and the Assistant 

Attorney General Reynolds, specific- 

ally after the legislation was 

passed, | 

Well, we sent -- we sent the written 

submission. I sent additional 

material to him from time to time, 

I think there were two or three 

written communications. I did talk 

to him on the telephone, telling 

him additional information wag 

coming. I saw him in Washing 

when I went with the legisi 

regarding legislative reapportion- 

ment and talked very briefly about 

it at the end of that meeting, tell- 
ing him I wanted to send additional 

information to him, and so there 

were, you know, three, four perhaps, 
verbal conversations in addition 

to the written communications to him, 
You had characterized or said there were 

8 number of pending pieces of     
  

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Were any of 

KELLOGG: 

Excuse 

‘he question. 

FELDMAN: 

1 think the 

MR, 

fe 
. to know when such 

tion took place, 

characterized anything 

referring to vou 

” 

interrogatories 

MR, KELLOGG: 

I am sorry 

your response 

stood you to say 

y & 
81% legislative session, 

period from summer up 

legislative session, 

a characteri 

because 

isunderstood 

Y [9]  ] 1 

ough t 

hasn't ae 

today, Are 

under ~ 

till the 

had a   
  

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number of contacts with the Assis-~ 

tant Attorney General, 

MR, FELDMAN: 

About the college case, 

MR, KELLOGG: 

Concerning various pieces of 

legislation -- T don't think we 

vent into detalls of it concerning 

what they were. 

MR. FELDMAN: 

He only mentioned the college 

case, 

THE WITNESS: 

only mentioned 

of our institutions. 

think you might be confused, 

Jim, One of the 

interrogatories indicated 

the time the 

matters with Mr, 

tion to this one, of which one was 

the college case, and one which 

  

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a7 23 vas ol x 
involved the 

Right, and perhaps one or two 

others, 'I forget what the specifics 

are, but today the Governor has 

mentioned only the college 

and that was in the context of 

i having met Brad Reynolds. 

BY MR, KELLOGG: 

Q All right. I had a question along those 

lines. In order to characterize 

the conversations that you had with 

him, on what topics and during this 

time period, the conclusion 

special session through the 

period of the approval of 

by the preclearance of Act 

the Department of Justice 

Let me ask       
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FELDMAN: 

Objections are reserved, 

KELLOGG: 

It's part of the stipulation pw 

that we have, 

All right. The consent 

agree in the university case, 

agreed to it in August, 

to be presented 

discussions 

-- although, any 

conversations al 

court, that sort 

iside part of the 

controversy for a& lighter resclu- 

and I don't know 

resolved, but ti 

involved in 

280lution of 

sier portion of it, 

N 

wiaen that     
    

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was 

an issue 

Then 

me 

Justice 

a at 

finally resolved, but that was 

at some time, I think. 

there was think he called 

one 

Departs ent would 

intervene 

believe 

ck Ja Ja 

think 

another 

0, 

 ¢ . do with 

institutions, 

that's the 

sS0nN. 

conversations about and 

one in which they had 

decided 

he 

discussed it, 

tio n 

In the context of 

tions, 

any of the 

a letter about 

& 

another 

\d 

any of these conversa- 

do you remember discussing 

substance of congress- 

reapportionment with 

FELDMAN: 

  

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BY MR. KELLOGG 

Q Yes. I'm 

really think 

have been re 

am going to send you some informaj 

tion on elections," or something or 

like that. I am not even sure 1 

said that, but | would 

in that context, 

provide you with 

£idua," or, 

provide you 

tion?" 1 sa: 

one 

time would 

addit: 

nded the time, 

1 n Be < - go 

the nagure   
  

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N 
  

of the conversations, and anything 

that I would have seid to him that 

lrany reletion to the 

e would heve been covered 

the actual written communications 

to him, 

You have no present memory of any tele- 

phone or verbal communications 

with him wherein you tried to 

convince him to preclear the plan? 
Well, he was well aware that what I was 

sending to him would be evidence 

to convince him that it was worthy 

of clearance. Sure. I don't think 

there is any doubt about that 

My question is, we have been given 

copies of the written communications, 

We have been given practically 

nothing concerning any verbal 

communications that you had with 

him, and I am asking about I 

of those, 

Nothing that -- I didn't beg or plead 

or anything there. I said that we 

got evidence that     

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  @   

staff com- 

municate with you that they were 

having certain problems with the 

plan and needed more information 

particular areas? 

to the best 

you mentioned one face-to-face 

meeting that you had, 

My aides would include the 

General. 

am leaving, 

iny communica- 

BY MR. KELLOGG 

  

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I don't know of any communications with 

ir, Feldman. 

that you mentioned a meeting 

in the interrcgator- 

ies. There were two staff members, 

Mr. Hainkel, Mr, Bruno, lr, Feldman, 

f Jay Stone -- that meeting was in 

~ 
Washington, D.C. Do you remember 

be the 

were th eg rLoxs 

r. 1 believe it was listed, 

and 1 can be correeted if I am 

wrong, 2 Mr, Reynolds, two of his 

staff members, Mr. Hainkel, 

Bruno, 

the meeting 1 referred to 

lluded to 2 while ago. It wa 

with the legislative 

  

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much time on 

Omitted from that 

was Mr. Pointer 

current reg rion 

Mr. Pointer 

or not? 

think 

did you say 

didn't understand 

don't remember. 

FELDMAN: 

No. 

THE WITNESS: 

You were 

MR. FELDMAN: 

1 did 

not Charbonnet was 

MR. KELLOGG: 

Do vou remember 

that were 

- I don't recall 

Act names 

legislative. 

; Me gma! = 
ticipants 

involved 

who was 

  

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MR, FELDMAN: 

I think, the exception 

of Pointer, vou have all the names. 

BY MR. KELLOGG: 

Q That's just 

You are talking about Louisiana ~~ 

MR. FELDMAN: 

I apologize for Mr. Pointer, 

BY MR. KELLOGG: 

Q As far 

Department of Justice were 

my assumption is that it was 

Mr. Robert Qualm (phonetic) w 

was one of them, 

I think he was, 

And probably Mr. Jerry Hebert, They 

say Hebert. We say Hebert. He 

was a participant. 

1 don't remember. 

MR. KELLOGG: 

Do you remember the second 

staff member of the Department of 

Justice, Mr, Jones, Mr. Gerald 

Jones, perhaps? 

MR. FELDMAN: 

  

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I don't remember, It was in 

the office of one of the long-time 

lawyers in the Civil Rights 

‘Division, but I can't remember his 

name, Very tall fellow. Been at 

the Civil Rights Division for some 

twenty-eight years. 

MR. DeJEAN: 

Carl Gable? 

MR. FELDMAN: 

I don't remember hie name. 

THE WITNESS: 

I don't remember, 

BY MR, KELLOGG: 

Q You don't have any present recollection 

as to who else that might have been? 

I would have no quarrel. I have no 

problem with supplying the informa- 

tion, you know, if I ean reconstruct 

it through Hainkel or Pointer. 

Mr. Jay Stone is listed Could you 

describe to me who Mr Jay Stone is, 

please. 

currently a Washington Representa- 

ive for the State of Louisiana on 

  

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® 
  

  

& contragt basis, Whether he was 

at that time, 1 am not sure. 

In the nature of a lobbyist or represent- 

ing your interest there? 

Yes, He 48 now, He was formerly 

administrative assistant to 

Congressman Moore, and I don't 

know whether he was in trensition 

at that time or not. 

Could you describe for us ~~ you men- 

tioned that most of the meeting 

concerned with the legislative 

reapportionment, Could you descri 

for us, to the best of your know 

ledge, what you remember about 

discussions concerning congressic 

reapportionment at that meeting. 

The only thing that occurred with respe 

to congressional was that 

to submit some more material 

1 told Brad Reynolds that 

that that material would be 

"fully evaluated. He said 

and that really was the extent of 

Marty, you were there, Feel 

  

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supply anything else. I don't 

think we got into any =-- I don't 

think there were any exhibits 

or ‘documents or papers nor anything 

like that, if that's what you may 

have reference to. We had addition- 

al time at that time, as 1 recall, 

on the congressional. We were up 

against the legislative time-wise, 

In fact, it was the holidays, Ve 

were up to the Federal holidays. 

1 believe it was Memorial Day, May 31st? 

It was a Federal holiday. I know the 

air conditioning was turned off, 

and the building was hot. 

Governor, I have asked you about contact 

with Mr. Reynolds and members 

his staff in Washington. Did 

have any contacts with him in 

Baton Rouge or anywhere in Louisiana 

this time period, meaning the 

pgislative session prior to pre- 

clearance? 

MR, FELDMAN: 

About reapportionment? 

  

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BY MR. KELLOGG: 

Q Any contact, first, 

A From what period? 

session through 

In Baton Rouge? 

KELLOGG: 

Baton Rouge or the State of Louisiana, 

I don't think so. From November of 1981 

0 now? No. I think that's the 

only time I have seen Brad Reynolds 

anywhere, I believe. 

The only time you have seen 

in Washington? 

vas over was in 

Washington, I believe that's the 

only time I have seen him. 

The way you answered the question, I 

understand you have seen Mr. Reynolds 

in Louisiana prior to that time, {is 

that correct? 

, he was here in connection with the 

desegregation case, 

discussion at that time   
  
  

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concerni 

don 

I gue 

That 

No 

MR. F 

THE W 

Washington on the 

BY MR, 

Q 

REL 

The m 

Louis 

[44 oa Nd : 88 / con rd od 
1 essional reappor- - ng 

? tionment 

't believe at that time. 

ficial meeting with the 

some time 

I 

sg that 

1981, 

was during 

September, think. 

- was 

It would be Septenber? 

ELDMAN: 

Either late summer or early 

fall. 

ITNESS: 

Y think 4t 8 we toward the end 

of the negotiating process, and I 

saw him in Washington prior to that 

first time 1 ever met him wag in 

university case, 

» 
. LOGG 

eeting we were talking about in 

ana, that 

2a meeting with one or 

more Federal Judges relating to that?   
  

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FELDMAN: 

Well, the Governor would 

have no way of knowing. It was 

during the negotiating sessione, 

WITNESS: 

Well, I didn't meet with any 

judges, 

FELDMAN: 

It was shortly after 

Mr. Reynolds was appointed. 

~ excuse me? 

FELDMAN: 

Shortly after Mr. Reynolds 

was appointed Head of the Civil 

Rights Division, and prior to that 

time there was no head. There was 

an acting head, but he wasn't really 

acting, and he came down here in 

connection with negotiations between 

the parties. That didn't involve 

the Governor at all. 

THE WITNESS: 

that, you mean?       
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[8 1 911 reapportionn 

time. 

L411 

seen him here once or 

think 

minutes 

shifting our 

1 you have 

Act 

with the 

    
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documents that 1 have seen, that 

you are speegking of that Blacks 

are better off with substantial 

input to two congressmen rather than 

having a majority in one district. 

Is that a fair assessment? 

Counsel, I think that's getting into 

our case, and if you want me to 

answer, I will, but -- 

MR. FELDMAN: 

You ¢an answer. 

THE WITNESS: 

I have stated repeatedly my 

views on the thing, publicly, and 

that the proposition is that you are 

better off having two congressmen 

than one, obviously you are better 

off with two votes than one. That 

answers one part of your question, 

You want to give me the rest of {t. 

BY MR. KELLOGG: 

Q Is the genesis of that argument with 

you, or is it with members of the 

legislative Black Caucus, or any 

other group to which you have 

  

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spoken? 

MR. FELDMAN: 

I don't understand the form 

of the question at all, I think 

it's objectionable for several 

reasons, but, most importantly, 

you asked the Governor what the 

basis for his views was, and now 

you are asking him the basis of the 

views of the Black Caucus, 

MR. KELLOGG: 

No. Let me restate the ques~- 

tion. 1 apologize if that's the 

way it came across, The genesis 

for your position that Blacks are 

better off with input into two 

districts rather than one, did that 

come from you, or was that suggested 

by members of the legislative Black 

Caucus, or any other political 

organization, or do you have any 

remembrance: of where that came from? 

MR, FELDMAN: 

Are you asking him the source 

of his belief? 

  

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BY MR, KELLOGG: 

Q The source of his belief. 

A I think that what I have said publicly 

was that argument can be made that 

Blacks having a strong voice in 

two districts could be as valuable 

or more valuable than having a 

stronger voice in one and a8 weaker 

voice in another, So the argument 

can be made, I don't know if I 

ever advanced it that definitively, 

that it's better in all cases or 

would be better, but I said that 

I think == I think I was stating 

that in the context of rejecting 

the notion that Blacks are better 

off by taking large numbers from 

one district and putting them in 

another. 

The Governor answered your 

I want to make sure this 

understood for the record. 

  
  

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BY MR, KEL 

think it depends upon lots of 

variables, but I think that -- and 

the argument has been made by 

others as the fact, I think 

Rupert Richardson stated that 

one time or somebody involved in 

the N.,A.,A.C.P, here, but that came, 

I think, during this debate or 

subsequent to that debate, but I 

guess the genesis for Dave Treen 

1s seeing 1t operate in 

LOGG 

Q Let's focus =-- 

MR, FELDMAN: 

Excuse me for a second, 

The Governor answered your question 

as it was limited to Blacks, but 

I think the characterization was 

yours and not his, The -- I believe 

when he answered the question 

earlier, he said that he thought 

it was good for Orleans Parish to 

have input into two 

and he didn't limit his answer or 

his argument to Blacks or whites. 

  

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of that 

Richard: 

am not sure it was her. 

submission to the 

did 

not have any conversat: s with 

Mrs. Richardson on that concerning 

her position on that, did you? 

the best of your knowledge, did 

your aides? 

don't believe. 

are pick 

reports? 

TET TMA N 
FELDMAN 

your case 

that's where 

1 think I 

did not meke the 

    
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$= } 
“AK 

you are apparent 

NN 
M MR. KRELLOGG 

No 

ing that any -- 

larly the view 

"OUT 

Does 

h 1 I could cite I guess 

imilar 

This 

were using for 

~ £3 vn 
C «a I > 

giving 

*  : 
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of any particular 

1 LE 

lew, 

is the same rationale that 

the 

[RvR 

om un f » dn “ 
conte xXe 0 

ly saying. 

that that 1s particu 

Justice Douglas 

Nid View and 

you 

- - Jew e that 

you 8 0ue SOV 

. 
A at, but really 

[3 
A,   

  
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are kind of gett we 

but I 

think 

that, have to 

don't 

Yn re a 
ER pire 

31 2 

@ strong voice with 

times that might be 

y qe 4 
PD 4 

glves what 

ing all of this 

district is 

I 

going ¢ 

wh think that ole 

80~-Cal 

willl sustain 

MR. FELDM bt Bt 47 NK AN: 

Ls BK 

0 

away irom 

1 

«Ng 

say, no, 

wa h 4 8S , | 

non 
ALAS YOUd Cé&n 

two votes, some- 

better than 

v 

be structured, 

creation of 

irizatrin 

  

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hoaocd nnd wv 
JEEZ ILNN1ING 

11losophize 1 was explaining 

[1 of this gives me 

that repre : others sho 

represent people without racial 

way I conduct my as Governor 

of this State. tually no 

ag ICL R , 

the record will show. So ~~ but to 

the extent that people in Congress 

nda? 

1501 

  

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BY MR, 

Q 

KEL 

You h 

v7 OC, eo 
L Vale, 

i your behalf 3 the aw e 

» 5 

that RO LE 

elected in 23 one or both of - 48 

the districts, the first and the ’ 

, over the next 

1IO0k8 CO lle LO vote 

block pattern would that be 

assuming, based on the kind 

assumptions 
at 

¥ 

presumably you would be 

in this case, to the extent 

is then 3 true, 

cted, and wr 

the individual 

  
  

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3 

dnd more people are voting 

- ye 1 a #3 0 y + “ on racial lines any more. 

assumption i hen you make 

assume you 

Second Congressional District 

ELE | ( ¢ vl oy : £m ELOWLNIE LENnaency Lox 

to be willing to vote for 

candidates. 

the present CiLsirict | 

very easily a Black could be elected 

to congress when Mrs, Boggs chooses 

AOR 

populat lon pt ojec- 

will be increase in the   
  

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~ 
“We 

Let's focus for 

the 

History and experience dats 

The source was not 

think I made 

      
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have been working on this? 

Well, they had 2 -- Wallace Walker who 

would be ~~ I worked through, 

Wage the gentleman whose name you were 

earlicr 

He sent one of his assistants, 

whose name I don't recall Walker 

{involved 

staff a good bit 

together, 

fice a part of the Division 

Administration, part of the 

Governor's 

Governor's 

argument that 

of interests 

First 

and do you also argue that 

is a community of interests 

“ P ~ f © ramroesants Sy uy SN Ng TRC OT 
. } t § H LEA A   
  

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I have never really understood that, 

Wh 1s meant 

not making 

a legal propos 

don't have a grasp of it or a 

| 

      

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“= 1s there -- is there a community 

of interests between a particular 

geographic seguent and another, 

might be able to tell you that. 
po pt 2 

1 Ww think ls some between the 

inth Ward and St, Bernard Parish, 

for example, The people seem to 

think alike and so forth, Whether 

that's good or had for congressional 

eT argument you 

lon't know that you 

can argue you ¢éan debate that 

one up and down the mountain, 

de $a N  ! . 
WILQ X CV 

ther they ought to 

same ~~ it might be it's 

for a congressman, 

ore questions, 

{alr statement to say 

on congressional 

you were and 

lature were constrained 

that you could not dilute minority 

voting strength, that you had no 

ybligation to maximize Black 

  

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this issue at 

can't, It's 144 

congressional dis 

State of Louisians 

answer your question 

we gw 4 on go 3 un bv gi P| trying to understand 

  

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I would 

    
    PRR ion 

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3 ue @n 3 £ va & 
quescions, 

THE 

  
      

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) ap wy wy ITT} qq! " ’ "7 Ln 

PLA WW FEE I *¥ 2 ATEN NE MYT 

SLCHEHTE 

. : 
foregoix » 

  

        

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orter, do 

egoing 

rrect transeription of the 

stenographic (Stenotype) notes of the proceed- 

ings herein, taken down by me and transcrided 

nder my supervision, 2t the time and place 

rinabove noted ln the above-entitled 

urtheyr ce 

or related 

any of the counsel or any of the parties, 

in the employ of 2ny of them; and that I 

Neve No rere s LI ££ QOULCCOM CL ThRig a ction, 

  
wp —_—" OA wd a 
an P vr ge 

BRAD GUEST, 
Certified & ge     
  

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