Interrogatories and Request for Production

    UNITED STATES DISTRICT COURT 

EASTERN DISTRICT OF LOUISIANA 

BARBARA MAJOR, ET AL CIVIL ACTION 

versus NO. 82-1192 

DAVID C. TREEN, ET AL SECTION C 

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INTERROGATORIES AND 
REQUEST FOR PRODUCTION 
  

  

Mr. Kellogg 
Mr. Quigley 
Mr. Scheckman 
Mr. Halpin 
Miss Guinier 
Mr. Derfner 
Mr. Menefee 

PLEASE TAKE NOTICE that defendants request, pursuant 

to Rules 33 and 34 of the Pederal Rules of Civil Procedure, that 

the attorneys seeking fees in this matter, answer under oath 

the following written interrogatories and produce the following 

items at the office of Assistant Attorney General Patricia Nalley 

Bowers, 7th Floor, 234 Loyola Avenue, New Orleans, Louisiana 

70112 on or before Monday, May 13, 1985. Responses to one inter- 

rogatory or part of an interrogatory may be incorporated by refer- 

ence in response to other interrogatories if, and only if, the 

clarity and completeness of the response will not be compromised. 

As used in this discovery request, masculine pronouns 

are intended to refer to both men and women. 

In answering these interrogatories, you are required 

to furnish all information available to you, including information  



in the possession of your attorney or any person acting in your 

or his behalf, and not merely such information as is known of 

your own personal knowledge. If you cannot answer any particular 

interrogatory or interrogatories in full after exercising due 

diligence to secure the information sought, so state and answer 

to the extent possible, specifying your inability to answer the 

remainder. 

You are reminded of your duties, under the provisions 

of Rule 26(e) of the Federal Rules of Civil Procedure, to season- 

ably supplement your responses. 

l. To Mr. Kellogg, Mr. Quigley, Mr. Scheckman, Mr. 

Halpin, Miss 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? 

2. To Mr. Kellogg, Mr. Quigley, Mr. Scheckman, Mr. 

Halpin and Miss Guinier: List the civil rights cases in which 

you were lead counsel and the case was completed before the Com- 

plaint was filed in Major v. Treen. Do the same for voting rights 
  

cases. Compile your lists as follows: 

name of case 

court and court number of case 

a notation as to whether the case was voting rights 
or civil rights in general 

the citation to any reported opinions in the case 

how the case was resolved, i.e. settlement, prelim- 
inary motions, injunctions, trial and opinion.  



3. To Mr. Kellogg, Mr. Quigley, Mr. Scheckman, Mr. 

Halpin and Miss Guinier: List the civil rights cases in which 

you were lead counsel and the case was completed before the trial 

began in Major v. Treen. Do the same for voting rights cases.   

Compile your lists as follows: 

1) name of case 

2) court and court number of case 

a notation as to whether the case was voting rights 
or civil rights in general 

the citation to any reported opinions in the case 

how the case was resolved, i.e. settlement, prelim- 

inary motions, injunctions, trial and opinion. 

To Mr. Kellogg, Mr. Quigley, Mr. Scheckman, Mr. 

Halpin, Miss Guinier and Mr. Menefee: Produce all physical evi- 

dence which you intend to introduce into the record of this matter 

to prove that the following expenses were not part of the normal 

operating overhead of your firm or organization: long distance 

calls, travel, secretarial overtime, car rental. 

5. To Mr. Rellogg,; Mr. Quigley, Mr. Scheckman, Mr. 

Halpin, Miss Guinier and Mr. Menefee: Produce copies of all 

physical evidence in your possession or the possession of your 

£irm or organization of your "actual hourly billing rate" to 

paying clients in 1981, 1982, 1983, 1984, 1985 including but 

not limited to copies of retainer agreements, bills, actual receipts 

of payment. 

6. To Mr. Kellogg, Mr. Quigley, Mr. Scheckman: List 

the occupation and income of each of the original Major plaintiffs 

and their spouse in this matter. 

-3-  



7. Miss Guinier: How much was your lawclerk, Miss 
McCaughan paid? Produce documentary evidence which proves the 
rate you claim she was paid. 

Respectfully submitted, 

WILLIAM J, GUSTE, JR. 
ATTORNEY GENERAL 

KENDALL L. VICK 
ASSISTANT ATTORNEY GENERAL 

an Tol 
MRC TEE SY PATRICIA NALLEY BOWE 

ASSISTANT ATTORNEY GENERATI,— LOUISIANA DEPARTMENT OF JUSTICE 234 LOYOLA AVENUE, 7TH FLOOR NEW ORLEANS, LOUISIANA 70112 PHONE: (504) 568-5575 

CERTIFICATE OF SERVICE 
| certify that a copy of the foregoing pleading has been served upon counse| for all parties by mailing the Same to each, roperly addressed and postage : Postag Prepaid 

this, 0 day of 

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