Plaintiffs' Answers to the Defendants' Interrogatories and Request for Production; Ten Most Significant Cases Submitted by Lani Guinier, May 1977 - May 1985

    IN THE UNITED STATES DISTRICT COURT FOR THE 

FOR THE EASTERN DISTRICT OF LOUISIANA 

BARBARA MAJOR, et al., 

Plaintiffs, 

Civil Action No.82-1192 
Section C 

DAVID C. TREEN, etc., et al. 

Defendants. 

PLAINTIFFS ANSWERS TO THE DEFENDANTS'® 
INTERROGATORIES AND REQUEST FOR PRODUCTION 
  

Plaintiffs hereby answer the defendants’ interrogatories and 

requests for production as follows: 

1. To Mr.Kellogg, Mr.Quigley, Mr.Scheckman, Mr.Halpin, Ms. 

Guinier and Mr. Derfner: do you consider Mr.Frank Parker to have 

the same, less, or more expertise as you do in voting rights 

litigation, in civil rights litigation? Why? 

A. Mr.Kellogg, Mr.Quigley and Mr.Scheckman consider Mr. 

Parker to have more experience than they do in voting rights 

litigation, but have no opinion as to Mr.Parker's experience in 

civil rignts litigation. Mr.Halpin, Ms.Guinier and Mr.Derfner 

have no opinion as to whether Mr.Parker has the same, less or 

more expertise in voting rights litigation or civil rignts  



litigation. They are of the opinion that among such experienced 

attorneys there is no meaningful way to reach an informed opinion 

as to the question asked. 

2. and 3. (Pursuant to Court order of May 20, 1985, the ten 

most significant cases in the last eight years which Mr.Kellogg, 

Mr.Quigley, Mr.Scheckman and Ms.Guinier have participated in 

along with the description of their participation, identification 

of the case, court and type of proceeding. Ms. Guinier's list is 

attached. The other attorneys have supplied such a list directly 

to defense counsel. 

4. This is moot, pursuant to Court order. 

5. and 6. Denied, pursuant to Court order. 

7. Ms.McCaughan was paid a salary of $2,500 per summer. As 

an addition to the salary, Ms.McCaughan, a law student, received 

training and instruction from LDF staff attorneys and other 

employment benefits. As a salaried, para-professional employee, 

Ms.McCaughan did not keep a record of the total number of hours 

worked. 
Nr Hy 

Respectfully submitted this 3) day of Lerner   J \ 

BLACKSHER, MENEFEE & STEIN, P.A. 
405 Van Antwerp Bldg. 
P. 0. Box 105] 
Mobile, Alabama 36633 
(205) 433-2000  



WILLIAM P. QUIGLEY 
STEVEN SCHECKMAN 

R. JAMES KELLOGG 
QUIGLEY & SCHECKMAN 

631 St. Charles Avenue 
New Orleans, Louisiana 70130 
(504) 524-0016 

STANLEY HALPIN 
2206 W. St.Mary 
Lafayette, Louisiana 70506 
{318) 387-2207 

LANI GUINIER 
LEGAL DEFENSE FUND 

99 Hudson Street 
16th Floor 
New York, New York 10013 
(212) 219-1900 

ARMAND DERFNER 
5520 33rd Street, N.W. 
Washington, D.C. 20015 

{202) 244-3151 

Attorneys for Plaintiffs 

CERYIFICATE OF SERVICE 
  

pot. 
I hereby certify that on this ¥) day of May, 1985, 

a copy of the foregoing PLAINTIFFS' ANSWERS TO THE DEFENDANTS® 

INTERROGATORIES AND REQUEST FOR PRODUCTION was served upon the 

following counsel of record: 

Patricia N. Bowers, Esq. 
Assistant Attorney General 
State of Louisiana 
Department of Justice 
234 Loyola Bldg., 7th Floor 
New Orleans, Louisiana 70112-2096  



and was properly addressed and deposited in the United States 

Mail, postage prepaid. 

 



UNITED STATES DISTRICT COURT 

EASTERN DISTRICT OF LOUISIANA 

  

BARBARA MAJOR, et al., 

Plaintiffs, 

v. 
Civil Action No. 82-1192 

DAVID C. TREEN, etC., 

at al., Section C 

) 

) 
Defendants. 

  

TEN MOST SIGNIFICANT CASES*¥* 

Submitted by C. Lani Guinier, May 1977 - May 1985 
  

A. United States Supreme Court (chronological order) 
  

1. Pullman Standard v. Swint, 456 U.S. 273 (1981) (worked 
  

on brief for respondent in United States Supreme Court in 

employment discrimination case). 

2. Rogers v. Lodge, 458 U.S. 613 (1982) (co-authored Supreme 
  

Court brief for Congressional Black Caucus as amicus in voting 

case, interpreting constitutional standards for proving discrim- 

inatory intent). 

3. Valteau v. Edwards, No. 84-1293 (E.D. La. March 21, 1984) 

stay denied, No. A-770 (Mar. 28, 1984) (By the Court) (prepared 

Response to Stay Application in United States Supreme Court in 

successful challenge under Section 5 of Voting Rights Act to 

Louisiana's effort to cancel presidential primary on heels of Rev. 

  

* Not reflected in this list are any pending district court voting 

rights cases and cases I handled at the grand jury or pre-trial 
discovery stage while at the Department of Justice.  



* » 

Jackson'd decision to run. 

    4. NAACP v. Hampton County, U.S. (1985) (co-authored 

brief for appellant in Supreme Court in Section 5 voting rights 

case). 

5. Hunter v. Underwood, 0.3. (1985) (drafted brief   

in Supreme Court for LDF as amicus in case finding unconstitutional 

Alabama statute disenfranchising certain misdemeanants). 

6. Gingles v. Edmiston, 590 F. Supp. 334 (E.D. N.C.) (three 

judge court), probable jurisdiction noted No. 83-1968 (April 29, 

1985) (trial counsel and counsel of record in United States Supreme 

Court in Section 2 voting rights challenge to North Carolina leg- 

islative redistricting plan). 

B. Federal Courts of Appeal, Three Judge District Courts, District Courts 
  

7. Chavis v. State of North Carolina, 637 F.2d 213     

(4th Cir. 1980) (co-authored amicus brief for United States on 

behalf of successful habeas petitioners challenging constitutionalty 

of state conviction). 

8. Booker v. United States, 655 F.2d 562 (4th Cir. 1981) 
    

(trial counsel for, United States in successful prosecution of 

migrant farm camp manager for violations of criminal civil rights 

statutes). 

9, Flateau v. Anderson, 537 PF. Supp. 257 (S.D. N.Y, 1982) 

(three judge court) appeal dismissed, 458 U.S. 1123 (1982) (litiga- 

ting amicus in successful challenge to New York legislative 

redistricting plan).  



10. Bozeman v. Lambert, Civ, A 83-H-579-N (M.D. Ala. 

April 13, 1984) and Wilder v. Lambert, C.A. 83-H-580-N (M.D. Ala. 
  

April 13, 1984), aff'c F.28 (11th Cir., May 6, 1983) 

(represented in district court and 11th Circuit successful habeas 

petitioners' challenging constitutionality of state conviction 

for voting fraud).