Deposition of Leo A. Watermeier (Redacted)

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23 December 19582 

re: MAJOR VS. TREFEN 

NO. 82-1192 

WATERMEIER 

DEAR MR. WATERMEIER: 

Enclosed find the original transc cript 
deposition given in this matter 

you read and sign the deposition 
our office as soon as possible. 

If you should find eces sary, to make any 
Or corrections in t ; please do 
the transcript but changes or 
on the form which is ached and date and 
the bottom, 

Again, it 1s most important this be done promptly 

returned to me at our address above. If you have 
estions call us. 

Thanking you for your prompt attention, we remain 

Yours very truly, 

ED REPORTERS, INC. 

    

James Kellogg 
TY 1 

Martin L. C. Feldman 

SS hb in Se sd  



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A DDE A FST ad ld 
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LEPORTED BY: 

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Stipulation . 

Examination by Mr. Quigley 

Examination by Mr. 

Signature of the Witness 

Certificate 

  

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a 110 

it , stipulated and agreed by and 

among all parties that this deposition is 

being taken in accordance with the Federal 

Rules of Civil 

is further stipulated that, 

the exception of the filing 

transcript of the deposit: 

and signing of the original transcript 

deposition, all formalities are waived, 

it is further stipulated that, with 

the exception of all objections as to the form 

of questions and the responsiveness of answers 

all objections are reserved until the time 

transcript of the deposition used or sought 

to be used in evidence 

ol 
¥o 

LEO A, WATERMEIER, 

of 

Louisiana, having been first duly sworn, 

¢xémined and testified 

QUIGLEY 

Q Would you give your name, address, and       
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district that you represent for 

record, please, 

name is Leo Watermeier, 

95th House Distri 

¢h is part of the 3rd, 4th, and 

2th Wards in New Orleans, 

were you elected to this position? 

@¢lected in December of 1979. My 

term is from 1980 to 1984, 

And what committees do you serve om in 

the 

I s the Civil Law Committee, 

and Welfare Committee, 

Municipal and 

Won oun own Bf Be Se om 
VOMIT CE] 

employment. 

wr on 9s Le 3 3n sua a work, though? 

affirmatively.) 

estate and real 

development 

Q JRE what 18 ¢ oy - A £ enera 1 wnat is     
  

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  By EB VE MTG 
CCONOML ECE 

of 3 
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om go 
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{4% @ wo 
WEES Ye     

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I voted, you know, on one plan or the 

other, 1 wasn't involved in the 

decision making processes, no. 

You voted -- prior to your voting, did 

you have any activities involved 

in this? Were you contacted by 

people, lobbied by groups, given 

information, communicated with? 

I think -~ let me think of what was going 

on. I was aware of, you know, 

sort of of the floor -- the floor 

talk about the plans, you know. 

I was not privy to any private 

meetings at all, and I would not 

say that I wae in any way involved 

in the decisions that were being 

made that led to one plan or another] 

I personally was more involved with 

the State House Reapportionment, 

because I was concerned about making 

changes in that plan and was not 

very involved or very active in the 

congressional plan, 

Okay. Did you hear directly or indirectly 

from any of the congresspeople about   
  

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their positions on the congressional 

reapportionment? 

The only one that 1 ever talked to 

personally was Bob Livingston, who 

called me to ask for his support 

for the plan that sort of helped 

save his district, which was, from 

my understanding, from my remembrancg 

the final plan that we voted on, 

that we approved, 

1 believe I also got a call 

from him afterwards thanking me 

for sort of sticking with him. 

Okay. You say the plan to help save 

his district. Did he explain to 

you why he liked one plan more than 

another, do you recall? 

No, we didn't go into details. Again, 

it was sort of the floor talk and 

floor knowledge that there was a 

plan that saved his district, and 

we 2811 knew what we were talking 

about when that came up. So when 

he called, you know, it's -- a lot 

has happened, you know, It was   
  

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quite a while ago to remember some 

of the details, but basically I 

remember getting a call from here 

at my desk sometime before the 

bill came up that we had to vote on, 

and 1 was able at the beginning to 

say, you know, "I am planning on 

voting for, you know, the plan 

you want," I don't remember him 

soliciting, you know, 

or soliciting support 

plan, because we all knew 

what that plan did, and 1 was able 

to tell him I was going to support 

that plan, 

Okay. Another plan that was before the 

Legislature was for the creation of 

a Black majority district. Do you 

recall that plan? 

I don't remember the lines, no, I don't 

remenber the map of it, but 1I 

remember that being a factor. 

Do you remember which people were 

interested in that plan? 

To 

  

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contacted specifically by anyone. 

I mean, I knew that the Blacks 

=~» that the Black representatives 

were in support of that plan, you 

know, after I voted against it, 

You know, a couple of Black legis- 

lators made some remarks about that's 

going to be a factor in my own 

reelection, and that it wasn't such 

8 smart vote, because the new 

district that I am going to be 

representing has 4&4 majority of 

Black voter registration, You know, 

they made some comments about that, 

but nobody called me == you know, 

nobody specifically asked me to 

vote for that plan, from what I 

remember, 

you contacted at all by anyone 

from the Governor's Office or any 

of his floor leaders about the plans] 

Not directly from anybody from the 

Governor's Office, from what I 

remember. Now, I am trying to 

think of the floor leaders. You   
  

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know, there is so much contact 

back and forth, that I will be 

honest with you, I don't remember 

&@ couple of people from the =- you 

know, from the administration, that 

people said anything. I just don't 

remember, 

Okay. 

Just part of the whole general picture. 

Do you remember what the general goals 

were for congressional reapportion- 

ment during that session? 

You know, in my opinion in general, 

with all of the reapportionment, 

there was a strong emphasis on 

protecting incumbents. I mean, 

whether it was in a House district 

or whether it was in the congression- 

al. You know, that was never ever 

said, but that was the general 

understanding that, you know, we 

are -- you try to do things that 

will help the incumbents, that 

they would be in a distriet that 

would allow them to get reelected,   
  

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In none of the speeches was that 

ever said, you know, It was just 

part of the premise, the basic 

premise that we were using. 

In addition to incumbency, were there 

other goals of reapportionment that 

you recall? 

trying to think. There was another 

plan that was going to create a 

Jefferson district, if I remember, 

and there was, you know, talk about 

some people out in Jefferson, that 

they preferred this plan, because 

they wanted to see a district that 

would allow someone from Jeffexson 

Parish to get elected. Again, things 

get a little bit hazy, but it seems 

that was part of the proposal to 

create a Black district, that was 

going a basically Orleans dice 

Parish District which would have 

been a Black majority, and then a 

Jefferson Parish =~ that was kind 

of a coalition with the Jefferson 

ma jority, That was one of the other     
  

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factors that was given considera- 

tion, 

Okay. You were not in favor of that plan 

the Jefferson-Black majority dis- 

trict? 

Ne. 

Do you remember why? 

I didn't like splitting up the city on 

racial grounds, 1 didn't think it 

would be 8 good situation to have 

8&8 heavily Black district versus 

2 heavily white district. 

And what reasoning did you use for that? 

Personally 1 think Blacks, and I guess, 

lower income people, would end up 

getting a better ~~ having more of 

a8 voice if they had a significant 

voice in two districts, because 1 

know how politics works, and I know 

& representative would be trying to 

reconcile his district to the fact 

that we would have ~~ and partly 

part of the vote im Orleans, that 

the Orleans Parish vote could be 

split among two congressional 

  

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glve Crleans Fa 

greater representation in 

I think it's a different 

philosophy. I think it's a health~ 

than having one 

predominantly Black district repre~ 

sented and then have one sort of 

white, conservative district. 

that is marke 

congressional division of New Orleans 

prior to reapportionment with a 

to the right being 

" 

letter B is the way that Orleans 

8 divided as a result of 

18 the basis for cutting the 

city up in this fashion? 

- gr 1 y 1 
» f # y ou Know N   

  

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group 

lines, so I can't tell you what 

I think I 

in general, sort 

things that were 

on, but, you know, I wasn't 

part of the group that -- I could 

tell you what was the reason the 

people were drawing 

resides 

already told you. 

All right. Now, in congressional 

reapportionment, the various plans 

what you call 

vhatever it is 

on on the bills, were the bills 

described to you at all in terms 

~c»d nl vee 1s " ny 4 rial makeup of 

- 
wr « . ¢ JOR oF on vy 4 or @ sn p ay 1 

h Ou Nad Ow ® 2 LWeel i 1 4 a 4 ) «tL a A8 AL 

ODViIOUs ly the considera- 

L410 810C the JeiXey¥son Jarisn coa~ 

sideration, you know, because you 

had the Jefferson people basically 

2 wn FR a wr sh Yr n 4 - Fa % o ws 2a 2 4 " } - in favor of a plan that created a     
  

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district because they were 

going to get their own district 

you had that coalition, I would 

1 -« v 11 it, that shared thet interest. 

celling thet the 

wae supporting 

iR, FELDMAN: 

v 

herdy Black or white? 

. It was an 

interesting coalition of people, 

coalition thet you don't usually 

« on ov gn @ To 2 - 1 . together votes, 

describe the district, 

ecially in the Black majority 

ribbing a Black 

never heard 

1B in those 

  

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-“ 
but wouldn 

the floor. 

I am not talking about the floor. 

People are too smart to talk like 

Did you 

have a nigger mayor. 

don't need a nigger congressman’? 

opposition 

the Governor's 

Plan or Livingston's Plan? 

Was I aware of it? 

Yes, 

Sure, 

Who was leadin g that opposition in 

addition to Chehardy? 

I guess the Black legislative delega- 

) Ye 7 n9 ' vein ta 
the Black Caucus. 

those people speak to 

that, 

ould think, yes, but 

don't remember, I do remember 

it sticks in my mind more after 

vote. 1 seems to me     
  

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given the makeup of that 

strict. I seem to recall that, 

a va #9 v & ‘ ry 
and Livi: 8% 1 

basically sort of a friendship 

ir va Med 
KNOW 9 

2 

m y min d 

« 

healthy situation splitting the 

§ 4 os $d oq 4 2 ‘ 4 ® LA 4 » v 4 9 va do oA 2 cus Fd pnb w 7 . "uy 
Le A 8 y 41% Q tL. » R./ LN Q Loe Ww la Ve ,       

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my own rnouse disc: 

used to havi 

*sonall y 

kind of votes 

We have three 

neighborhood to heart, and they 

us. We 

based on that, I wanted to support 

that plan, 

know whether 

opposed to 

reasons? 

the legislac 

      
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with you directly 

thelr opposition to the Black 

me jority plan -- thet it was basged 

on racial reasons? 

sure the: 

voted 

not say, you know, Legislator X 

voted against this plan because 

2 Black district, 

I never talked to 

about, you know, the reasons for 

their voting, and any time you vote, 

here's all kinds of issues, all 

kinds of factors that are part of 

So, no, I couldn't say 

you know, "Legislator X voted 

against it for racial reasons, 

he 

cther than 

in peoples' opposi- 

tion to the Black majority district, 

I think one of the main factors was 

protecting incumbents I said that       
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already, I don't think -- 

what ~- you know, if it's the =-- 

the real effect was a consideration 

-=« 7 don't remember now how this 

St. Tammany 

1 don't remember 

though, how those people up there =-- 

how they stood in line in all of 

that, I don't remember, I don't 

remember if that was another factor, 

I guess people, as I told you =- 

say that the factor that 

me was my philosophy of try- 

spread out the city vote, 1 

thought it was a healthier situation. 

«now ~~ again, you said ~~ you 

say specifically 

Jo you know whether 

8 role at all in the Govern- 

or’'s actions in reapportionment, 

congressional reapportionment? 

Absolutely not, no. I really don't think     
  

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28d, 

You don't know? 

I must that when I talked to 

ce wads never an issue, aCe 

“= you know, my ling 

Governor was more interested in WF 

protecting Livingston, you kmow, 

MR, QUICLEY: 

think that's all 

I have. 

ERY A ATT AY 
NAY LON 

BY MR. FELDMAN: 

Q Let me just make a note, 

and along with 

Leo, my name 

is Marty Feldmar 

Bob Kutcher from my law firm, 

‘e defendi the Governor and 

questions to ask I believe, 

Just so the record will be clear, 

I believe we can agree that on the 
% 

fie J   
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House side, the llovuse Governmental 

Affairs Committee was the committee 

with overall jurisdiction for the 

redistricting issue, and the sub- 

committee on 

specific responsibility 

legislation, isn't that 

Yes. 

And you were not a member of 

of those committees? 

-~=- the factors that 

into one's vote, are you aware 

of any legislator who voted or who 

told you that they had voted that 

their goal was diluting the minority 

voting strength in any congressional 

district? 

You asked 

a factor, 

fhether you are aware 

whose goal was to dilute minority 

voting strength in any of the 

congressional aciLstLyices, 

  

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dy told 

from what I know of 

personality, their outlooks about 

racial or minority voting strength, 

factor in people’: 

support of one plan or another, 

That would be your opinion, is that 

"We got to vote for this 

7 don get a 

{ 

1A oH dh AR i don't 

8 

remember ing told that, 

In connection with the philosophy of 

spreading the votes among more than 

one district, as you characterized 

Is it your view that gd jority Black 

congressional district would have 

isolated the Rlack vote       
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favor, 

Can you recall in the time that you 

been in the Legislature t! 

there has 

flition which you have 

between the Black Caucus 

-'s infrequent. 

And it's correct, is it not, that this is 

a coalition 

iominated cor 

Sure. There was 

Nunez Plan. 

That's correct,   
  

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% 
Chehardy 

ferson 

LO% 

Congress. 

matter of fact, I believe 

Mx. Nunez thought about running 

for Congress one time, didn't 

Yee, I believe 

In addition to 

-=- and consequently 

coalition 

Ys @ wre 3 z » ut 4 Fu on 4 n | ry Ala Ve ME oLL ADC U 2 many Will C es J 

opposed to it, too, weren't they? 

generally the surburban people. 

#3 aware of any 

Governor eve! ade or that 

administration 

made during the months of 

the legislative process in connec- 

tion with congressional redistrict- 

ing? 

Is . A 
LLOVErneyr 

  

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bout reapportionment. 

ivy to any of their meet 

you know,. so I would say, 

>, but, you know, there 

noe reason to believe that 

been 1 } #4 

ems to me that that's sort of 

questions. Vas race a factor 

discussion? 

was a factor, you know. 

Whether that was the dominant 

* on oe O° py pe pr on fe _— y of re Th. lctor or not, I certainly could: 

minant factor 

. B wag your political judgment th 

Covernor wag concerned about     
  

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And that was the street ~~ the loor 

talk. The Chehardy and the Nunez 

would create a Black 

there is a plan that 

rgston's district, 

how things were 

talked abo 

1 believe you testified that Congressman 

cr mentioned racial 

that correct? 

matter of fact, the second ~- the 

registered vote in the Second 

ressional District wes increased 

Legislature 

that correct? 

a 
to what you are 

3aid 1 am sure race 

you know, part of the 

was that Livingston 

r1lacted ~-- reelected     
  

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a predominantly 

I keep saying that in protecting 

incumbent, this kind of catch 

y, nobody ever 

as the foundation of protecting Ww 

Livingston, or one founda- 

Cions was o0DLY 

intact as possible, but, also, not 

putting him in a district that was 

going 

or Black majority registration. 

Well, the district, as it was proposed 

with the majority of Black voter 

registration, would have been 

rv $ y > t 33 ode oo , » 7 1 Lindy Bogg listriet, would 

't remember, you 

I believe 

  

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Tren T ee f R—— 
WIINESS — CERILFICATE 

I, LEO WATERMEIER, do hereby 

state that I have read the above and 

foregoing dep 

above transcript and accompanying 

9 

f any, constitute a corrections, 

true and correct record of my testi- 

mony, which was given under oath and 

best of 

tine 

of the deposition, 

ai. IEG WATERMEIER     
  

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CERIIEICAILIE 

I, the undersigned reporter, do 

hereby certify that the above and foregoing 

is a true and correct transcription of the 

stenographic (Stenotype) notes of the proceed- 

ings herein, taken down by me and transeribed 

under my supervision, at the time and place 

hereinabove noted, in the above-entitled 

and -numbered cause, 

I further certify that the witness 

was duly sworn by me in my capacity as 

Certified Shorthand Reporter for the State of 

Louisiana; that I am not of counsel or related 

to any of the counsel or any of the parties, 

or in the employ of any of them; and that I 

have no interest in the outcome of this action 

rR 
i \ 

dinin” 

Se 

Xx my \ | / 

A 

7) A 3 3 3% A * 
BRAD GULLY 

Certified Shorthand Reporter 

      
  

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