Plaintiff's Request for Production of Documents

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June 1, 1982 - June 30, 1982

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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
- e5ede7fd-c703-ef11-a1fd-002248219001

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Case Files, Major v. Treen Hardbacks. Plaintiff's Request for Production of Documents, 1982. e5ede7fd-c703-ef11-a1fd-002248219001. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/ead1f665-ea90-4a9f-bf92-6618ddd78247/plaintiffs-request-for-production-of-documents. Accessed November 05, 2025.

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    UNITED STATES DISTRiCT COURT 

EASTERN DISTRICT OF LOUISIANA 

BARBARA MAJOR, et al., Civil Action No. 82-11° 

Plaintiffs Section D (O) 

~againsi- THREE JUDGE COURT CASF 

DAVID C. TREEN, etc., et al. CLASS ACTION 

REQUEST FOR PRODUCTION 

OF DOCUMENTS 
  

DAVID R. POYNTER 

KENNETH C. DEJEAN 

Attorneys for Defendants 

PLEASE TAKE NOTICE that you are requested to produce in accordance 

with Rule 34 of the Federal Rules of Civil Procedure the documents iisted 

Exhibit A. hereto on or before the 18th day of June, 1982 at 631 Si hy 2 VE 

Avenue, New Orleans, Louisiana, 70130. 

Respectfully submitted, 

R. JAMES KELLOGG 

WILLIAM P. QUIGLEY 

STEVEN SCHECKMA 

STANLEY HALTIN 

531 St. Charles Avenu 

New Orleans, Louisiana 

504/524-0016 

Jack Greenberg 

James M. Nabrit, 111 

Napoleon B. Williams 

Lani Guinier 

10 Columbus Circle 

Suite 2030 

New 'Ybrk, New'Ybrk 10019 

  

Attorney for Plaintiffs 

I hereby certify that I have served a copy of the foregoing upo 

opposing counsel, this day of Junc, 1982 by placing sam 

mails, postage prepaid. 

"R. JAMES KELLOGG  



EXHIBIT "A" 

Memorandum, Louisiana Legislative Council, 

"Governor's Fower toc Veto Legislature's 

Reapportionment Dili", January, 1981. 

Memorandum, Louisiana Legislative Council, 

"Judicial Interpretations Affecting 
Reapportionment'", January, 1981.     
Joint Legislative Committee on Reapportion- 

merit, Froposed Rules for Congressional 

Reapportionment. 

Memorandum, Louisiana House of Representatives, 

Legislative Services, "Reapportionment 
Jurisprudence", July 22, 1981. 

Memorandum, Louisiana House of Representatives, 

Legislative Services, ''Submission of 

Reapportioumenit Plans in Accordance with 

Saction 5 of the Voring Rights Act of 13865", 

July 23,198), 

"Legal Analysis Of Whether the Voting Rights 

Act Requires That a Black Majority Congressional 

District Be Created In a Covered State Having 

a Significant Black Population", Congressional 

Research Service, The Library of Congress, 

Michael V. Seitzinger, Legislative Attorney, 

American Law Division, October 9, 1981. 

"Legislative Gerymanding: Legal Limits and 
Remedies", Congressional Research Service, The 

Library of Congress, Thomas B. Ripy, Legislative 

Attorney, American Law Division, April 15, 198i. 

    
Memorandum, Louisiana Legisiative Starif, 

"Statement Of Reasons For the Reapportionment 
Change". 

Veto and DD. . 0. J. 

Memorandum, Louisiana Legislative Staff, 

"Congressional Redistricting 

Review", November 8, 198i. 

Memorandum, Louisiana Legislative Staff, 

"Congressional Redistricting Veto and D. C. J. 
Review', November 6, 1981. 

Memorandum, ILouisiana Senate, "Principles Of 

Reapportionment', October 21, 1281. 

Memorandum, to William J. Guste, Jr., Attorney 

Ceneral, from Office of the Governor (response 

relative to Paragraph 3) 

Senate Bill Number 4, Original, 1931 Extraordinary 

Session. 

     



Louisiana Legislative Calendar, Page 442, 

1281 Extraordinary Session.   
Louisiana Senate Journal, Pages 6 and 16. 

Congressional Reapportionment Statistical 

Analysis, Senate Bill No. 4, Original, 

November 2, 1981. 

Seinate Bill Number 

Senate Committee Amendment 

Sena Bill Number 5, Eungrossed 

Senate Floor Amendmeiits 

Senate Bill Number 5, Reengrossed 

House Committee Amendments 

Digest of Senate Bill No. 5 (inclusive 

of House Floor Amendments 

House Floor Amendments 

Conference Committee Report 

Congressional Reapportionment Statistical 

Analysis, November 2, 1981, Senate Bill 

Number 5, Origiiial 

Congressional Reapportionment Statistical 

Analysis, November 4, 1981, Senate Bill 

Number 5, Engirossed 

Congressional Reapportionment Statistical 

Anaiysis, November 4, 1981, Senate Dili 

No. 5, Reengrossed 

Congressional Reapportionmeni Statistical 

Analysis, November 11, 1981, Senate Biil 

No. 5, Couference Committee Report 

Senate Billi Nuwber 5, Enrolled 

[al 
Legislative Calendar, Pages 442-443 

Senate and llouse Journal (pages pertinent 
to Senate Bill Ko. 5) 

Senate Dill Number 29, Original 

Legislative Calendar, 1981 Extraordinary 

Session, Page 452 

Senate Journal, 1981 Extraordinary Sessiom, 

Pages 12, 13, 17, and 18 

House Bill Number 2, Original      



          

House Bill Number 2, Engrossed 

Bp] louse Bill Number 2, Reengrossed 

Legislative Caiendar, 1981 Extraordinary 

Session, Page 415 

House Journal, Pages 188, 189, 199, 216, 

220, 260, 270, 271, 272, and 273 

Senate Journal, Pages 63, 73, 88,.89,.90, 

98, 102, and 149 

House Bill Number 25, Original 

Legislative Calendar, Page 424 

House Journal, Pages 152 and 202 

Senate Bill Number 28, Original 

Legislative Calendar, Fage 452 

Senate Journal, Pages 12 and 17 

Minutes, Senate Committee on Senate and 

Governmental Affairs, November 3, 1981. 

Transcript, Committee ou Senate and 

Governmental Affairs, November 3, 1981, 

excerpt of discussion on Senate Bill No. 

Transcript, Committee of Senate and 

Governmental Affairs, November 10, 1981, 

excerpt of discussion on House Bill No. 2. 

Transcript, Senate Reapportionment Study 

Committee and Subcommittee of House and 

Governmental Affairs On Congressional and 

Public Scrvice Commission Reapportionment, 

August 21, 1981. 

Transcript, Committce on House and 

Governmental Affairs, November 6, 1981. 

Transcript, Committe on ilouse and 

Governmental Affairs, November 5, 1981. 

Transcript, Committee on House and 

Governmental Affairs, November 4, 1981. 

Transcript, Committee on louse and 

Governmental Affairs, October 15, 1381. 

Transcript, Subcommittee on House and 

Governmental Affairs on Congressional 

and Public Service Commission Reappor- 

tionment, October 15, 1981. 

Transcript, Senate Reapportionment Study 

Committee, and Subcommittee of louse and 

Governmental Affairs on Congressional 

and Public Service Reapportionment, 

October 7, 1981.  



Minutes and Transcript, Senate Reapportion- 

meiit Study Coumittee, and Subcommittee on 

House and Governmental Affairs on 

Congressional and Public Service Commission 

Reapportionment, September 29, 1981. 

Transcript, Senate Reapportionment Study 

Committee and Subcommittee of House and 

Governmental Affairs on Congressional and 

Public Service Commission Reapportionment, 

September 24, 1981. 

Transcript of the Joint Meeting cf 

Subcommittee on House of Representatives 

Reapportionment, Senate Reapportionment 

Study Committee, and Joint Committee on 

Congressional and Public Service Commission 

Reapportionment, September 16, 1981. 

Transcript, Reapportionment hearing, 

August 27, 1981. 

Transcript, House and Governmental Affairs 

Subcommittee on House, Congressional and 

Public Service Commission Reapportionment, 

July 23, 1281, 

Transcript, Conference Committee metting on 

Congressional Reqpportionment, Senate Bill 

No. 5, November 11, 198]. 

Memorandum, September 2%, 1681, to Lousiiana 

Congressional Delegation, from Senator Thomas 

H. Hudson and Representative john W. Scott. 

letter, October 23, 1981, to Senator Thomas H. 

Hudson, fiom Governor David C. Treen. 

Memorandum, July 13, 1981, to members of House 

and Governmental Affairs Committee, from 

Representative John W. Scott. 

Press Release, October 18, 1981, by Representative 

John W. Scott. 

Letter, August 15, 198C to Governor David 

Treen, from Mr. J. Allen Martin. 

Letter, January 27, 1981, to Govern David 

Treen, from Senator Thomas II. Hudson. 

Letter, June 18, 1981, to Governor David C. 

Treen, from Mr. J. Allen Martin, with 

attachments. 

File copy of a letter dated October 23, 1581, 

to all Louisiana State Legislators from 

Governor David C. Treen, with attachments. 

Letter, October 30, 1981, to Governor David 

C. Treen, from Representative Vincent J. Bella.        



Memorandum, November S$, 1981, to Louisiana 

Legislature from Governor David C. Treen, 

with attachments. 

Letter, March 22, 1932, io Attorney General 

William J. Guste, Jr., from Congressman 

W. Henson Moore, letter of transmittal. 

Letter, November 23, 1981, to Representative 

Tom McVea, from Congressman Henson Moore. 

Letter, November 23, 1981, to Representative 

Donald Ray Kennard, from Congressman Henson 

Moore.   Letter, November 23, 19281, to Representative 

Julius Blount, from Congressman Henson Moore. 

Letter, December 5, 1280, to Representative 

Ty Cobb Lanier, from Congressman llenson rooie. 

Letter, November 25, 1980, to Representative 

Ty Cobb Lanier, fiom Congressman Henson Moore. 

Letter, December 8, 1981, to Mr. Jewel Newman, 

City Councilman (Baton Rouge) from 

Congressman Henson Muore, with attachments. 

Leiter, June il, 1981, to Reprensentative 

Mike Thompson, from Congressman Henson Moore. 

Letter, June 1i, 1981, to Representative 

Charles D. Lancaster, from Congressman 

Ilenson Moore. 

Letter, June 11, 1981, to Representative Dennis 

llebert, from Congressman Henson Moore. 

Letter, June 11, 1981, to Representative Julius 

A. Blount, from Congressman Henson Moore. 

Letter, June 11, 1981, to Senator Joseph A. 

Sevario, III, from Congressman Henson Moore. 

Letter, June 11, 1981, to Senator Thomas H. 

Hudson, from Congressman ilenson Moore. 

Letter, February 26, 1982, to Attorney 

General William J. Guste, Jr., from 

Congresswoman Lindy Boggs. 

Letter, October 27, 1981, to Representative 

John W. Scott, from Congresswoman Lindy Boggs. 

Letter, November 20, 1981, to Senator ilanx 

Lauricella, from Congresswoman Lindy Boggs. 

Letter, March 3, 1932, to Kenneth C. DeJean, Chief 

Counsel, from Congressman Giilis W. Long.      



(92) Letter, February 24, 1982, to Attorney General 
liam J. Guste, Jr., from Congressman John 

aux (with attachments). 

Letter, October 12, 1281, to Congressman Gillis 

W. Long, from Representative John W. Scott. 

Memorandum, September 29, 1981, tu Louisiana 

Congressional delegation, from Senator Thomas 

fi. Hudson and Representative Jonn W. Scott. 

Letter of Notice, Octover 27, 1981, to Louisiana 

Legislature, irom Governor David C. Treen. 

Letter, October 5, 1981, to Joint Legislative 

Committee on Reapportionment from Louisiana 

Congressional delegatioii. 

Letter, June 10, 19281, to Louisiana Senate {roi 

Louisiana Congressional delegation (with proposais 

attached). 

Memorandum, April 7, 1982, to Attorney General 

William J. Guste, Ji., from Governor David C. 

Treen, with Attachment "A". 

Press release, Octubei 22, 1981, Cffice of the 

Governor. 

       



19. Witnesses called or listed by any other party 

20. Such other witnesses as may be necessary for 

proof of this case 

1982 

Respectfully submitted, 

R. JAMES KELLOGG 

WILLIAM P. QUIGLEY 

STEVEN SCHECKMAN 

STANLEY HALPIN 

631 St. Charles Avenue 

New Orleans, Louisiana 70130 

504/524-0016 

Jack Greenberg 

James M. Nabrit, 1171 

Napoleon B. Williams 

Lani Guinier 

10 Columbus Circie 

Suite 2030 

New York, New York 10019 

By: 

Attorney for Plaintiffs 
  

Pr — 
\ ify that a copy of the forog 

yeen se 

PREN———————— 

  

 



  UNITED STATES DISTRICT COURT   
EASTERN DISTRICT OF LOUISIANA 

BARBARA MAJOR, et al., Civil Action No. 82-1192 

Plaintiffs Section D (C) 

-against THR RE] E JUDG LX ( ) JRT CASE 

DAVID C. TREEN, etc., et al. CLASS ACTION 

PLAINTIFFS' LIST OF 
WITNESSES _ 

Plaintiffs herein set forth, in accordance with this Court's 

Order of June 7, 1982, the fellowing list of witnesses who may be called 

  at the preliminary injunction hearing scheduled for June 28, 1982: 

Govenor David Treen 

Secretary of State James Brown 

Elsa Cangelosi 

Samuel Nunez 

Glen Koepp 

Nancy Borringer 

Victor Bussie 

Lawtence E. Chehardy 

Robert Kwan 

Jan Scudemacher   Gillis Long 

Causen Killers 

John Hainkel 

Lindy Boggs   
Michael Baer 

Gordon Henderson 

An expert on racial bloc voting 

An expert in the history of racial 

discrimination in Louisiana

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Plaintiff's Request for Production of Documents

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