Correspondence from Feldman to Judges Politz, Cassibry, and Collins

Public Court Documents
April 21, 1983

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LDF Attorney
- Lani Guinier
Matter
- Major v. Treen
Case
- Major v. Treen
U.S. state
- Louisiana
Collection
- Case Files
Creator
Publisher
Taxonomy
Identifier
- f739f5a5-c903-ef11-a1fd-6045bdec8a33

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Case Files, Major v. Treen Hardbacks. Correspondence from Feldman to Judges Politz, Cassibry, and Collins, 1983. f739f5a5-c903-ef11-a1fd-6045bdec8a33. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/dc04b29e-e160-4e5c-adfc-c338fa7ac003/correspondence-from-feldman-to-judges-politz-cassibry-and-collins. Accessed November 05, 2025.

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    BRONFIN, HELLER, FELDMAN, STEINBERG & BERINS 

ATTORNEYS AND COUNSELORS AT LAW 

WHITNEY BUILDING 

NEW ORLEANS, LOUISIANA 70130 

FRED BRONFIN 

EDWARD M. HELLER ISAAC S. HELLER (1893-1967) 

MARTIN L.C. FELDMAN ROBERT WEINSTON (1908-1962) 
SYLVAN J. STEINBERG 

3 
TELEPHONE BERNARD H. BERINS 

ROBERT A. KUTCHER Apri 1:21 ? 1983 S04/568- 1888 

JAN M. HAYDEN 

KAREN B. SHER 

Honorable Henry A. Politz 
United States Circuit Judge 
Room 2B04 
500 Fannin Street 

Shreveport, Louisiana 71101 

Honorable Fred J 

es Di 

t 

Cassibry 
trict Judge United State Ss 

500 Camp Stree 
New Orleans, Louisiana 70130 

Honorable Robe PF. Collins 
United States District Judge 
500 Camp Stree 

New Orleans, Louisiana 70130 

Major, et al v. Treen, et al 
Civil Action $82-1192, 
Division C 

Your Honors: 

Please permit this brief response to Mr. Kellogg's 
written objection dated April 20, 1983 to our submission of the 
Reynolds internal memorandum dated June 18, 1982 as Exhibit 49K. 

We respectfully submit that the Reynolds internal 
memorandum should be a part of Exhibit 49 because the Kwan 
memorandum, which is a part of Exhibit 49, is quite inflam- 
matory; it constitutes the most obvious kind of hearsay and we 
were not given an opportunity to cross-examine Mr. Kwan, who is 
a staff subordinate in the Civil Rights Division. The fact 
that the document was submitted under the Act of Congress in no 
way lessens the invidiousness of the document as a trustworthy 
piece of evidence. Nevertheless, the Court admitted the docu- 
ment into evidence over defense objections. Therefore, in view  



BRONFIN, HELLER, FELDMAN, STEINBERG & BERINS 

Honorable Henry A. Politz 
Honorable Fred J. Cassibry 
Honorable Robert F. Collins 
April 21, 1933 
Page Two 

of Mr. Kellogg's statement that he deliberately omitted intro- 
duction of the ynolds memorandum, we believe that Justice 
would be better served if Your Honors had a more complete pic- 
ture of what occurred during the pre-clearance process. In 
view of the fact that the Court admitted Exhibit 49, even 
though it contains the same kind of impediments as the Reynolds 
memorandum might contain, we respectfully submit that the 
Reynolds memorandum should go to the weight of the evidence and 
that Mr. Kellogg's objection regarding admissability is 
unfounded. We were never given a copy of the Reynolds memoran- 
dum until the gay I Ss Are d a copy with the Court, and we were 

unaware of Mr. request for the memorandum under the 
Freedom of EE Act. That is why the document was sub- 
mitted when it was. 

S 

Re 

Respectfully submitted, 

Wy tif ( 4 Misi 
Martin L. 

Attorney for Honorable David C. 
Treen, Governor of Louisiana and 

Honorable "Jim" Brown, Secretary 
Of State-0f Louisiana 

eldman 

MLCF:d)cC 

cc: Honorable David C. Treen 

R. James Kellogg, Bsquire

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Correspondence from Feldman to Judges Politz, Cassibry, and Collins

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