Correspondence from Guinier to Hebert (DOJ)

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December 16, 1982 

J. Gerald Hebert, Esquire 
Voting Section 
U.S. Department of Justice 
10th §& Constitution, N.W. 
Washington, D.C. 20530 

Re: ‘Major .v. Treen, C.A. NO. 82-1192 

{(RE.D. La.) {(F.5. 32-0501) 

Dear Mr. Hebert: 

I am in receipt of your letter of December 14, 1982. I 
have a few comments that I believe were a part of our agreement 
but are not reflected in your letter. 

It is my understanding, for example, that you will furnish 
us all memoranda that contain factual information, including 
inferences to be drawn from the facts, concerning the Louisiana 
congressional reapportionment. Although you may feel it neces- 
sary to withhold at this time certain portions of these memoranda, 
you understood that we may subsequently attempt to enforce our 
subpoenas to obtain copies of the withheld information. The same 
is true for information that you withhold to protect the identity 
of the source of the information. Because your letter leaves open 
the possibility of our working together to obtain all relevant 
information, I will wait to see what is made available to me by 
December 17, 1982 or within the following 10 days. 

I do want to take this opportunity, however, to specify the 
type of information we are seeking in particular. As I mentioned 
during our telephone conversation of December 13, plaintiffs in 
Major v. Treen seek, inter alia: 
  

1. Records from June 18, 1981 to the present of all tele- 
phone communications, meetings and correspondence, and 
travel and expense vouchers for such meetings with the 
Governor of Louisiana, his aides or members of the 
State Legislature or Congressional delegation pertain- 
ing to the subject of the congressional reapportionment 
or for any subject if the discussion involved the 
Governor. 

We are interested in determining what communication took 
place between any of the proposed deponents and the 
defendants, the circumstances of that communication 
(e.g. the dates, times, places and participants) and, 

if any travel or meetings took place, who paid for 

  
806 15TH STREET, N.W., SUITE 940 (202) 638-3278 WASHINGTON, D.C. 20006  



4 ° 
J. Gerald Hebert, Esquire 
December 16, 1982 

Page Two 

the travel or the meetings. We are interested in 
any notes or records pertaining to such meetings 
or conversations, even if such meetings or conver - 
sations are not reflected in telephone logs or 
the Section 5 file. 

I understand that you are processing the requested informa- 
tion expeditiously. I certainly appreciate your cooperation. 

Sincerely, 

An EAS 

Lani Guinier