Jeffers v. Clinton Plaintiffs' Responses to Defendants' Expert Witness Interrogatories

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IN THE UNITED STATES DTSTRICT COURT
EASTERN DISTRICT OF ARKANSAS

EASTERN DTVTSION

-xM. C. JEFFERS, €t a1.,

PLATNTIFFS

v.

BILL CLINTON, Bt dl. ,

No. H-C-89-OO4

DEFENDANTS.

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PLATNTTFFS' RESPONSES TO DEFENDANTS,
EXPERT WITIIESS INTERROGATORIES

INTERROGATORY I{o. 1: Have you employed an expert to test,analyze or examine iny data hriih rega;d to this action or 1n anyway to give you expert advice regarding this action?
RESPONSE TO INTERROGATORY NO. 1, ly"=.

INTERBOGATORY NO. 2: If the answer to fnterrogatory No. 1 is, y€s, for each expert, state! 
..

"aa""l3' ;Jalr"#i;:';"r,ET: or other means or identirication,

(b) The expertrs profession or occupation, and the field inwhich helshe is alJ.egedly an expert;
(c) Th: name or description of the data that was tested,analyzed or examined or the nature of the advice given;
(d) whether you intend to call the expert as a witnessduring the trial of this action.

O. 2: plalntif fs have retal.ned two

experts. The answers to Interrogatory No. 2 are set out
', separately for each expert.



(a) Richard L. Engstrom, ph.D.
Department of potltlcal Sclence
Unlverslty of New Orleans
New OrLeans, Louisiana ?O14g
(so4) 286-667L

(b) Professor of poLltlcal science, university of Neworleans; Expert in Vote Dilution, Black politics
(c) Dr. Engstrom ls anaryzlng electlon returns to determinethe degree of racial bloc voting in Arkansas. Dr.

Engstrom also is analyzing socloeconomic data from theBureau of the census and voter registration andparticipation rates.
(d) Plaintiffs intend to carl Dr. Engstrom to testify attrial.

(a) Jerry Wilson, Esq.
Southern Regional Council
60 Walton Street
Atlanta, Georgia 3O3O3-2199
(4O4) 522-A764

Demographer; expert in the field of redistricting and
reapportionment :

(c) Mr. wilson is analyzing the effect of the 1981
redistricting plan on black voters. Mr. t^Iirson is
using the following data in his analysis: p.L. g4-1z]-
census data, unit populati6n counts with raciar

. composition, Township populations, County populations,
General Assembly District population information and
Justice of the Peace District populati.on information.

(d) Plaintiffs intend to call Mr. Wilson to testify at

(b)

trial.\

INTERROGATORY NO. g: Has the expert referred
education in his/her field?

: Yes.

to had a formaL

INTERROGATORY NO. 4: If so, state:
(a) The name and address of each school where the expertreceived special education or training in this field;
(b) The dates when the expert attended each school;



(c) The name or descrlptlon of each degree the expertreceived, lncluding the date when each was receiried, and the -nane
of the school from which received.

RESPONSE TO INTERROGATORY NO. 4: Please refer to the attached
resumes of Dr. Engstrom and Mr. Wllson.

TNTFRFOG+TO$,Y No. s: Did the expert have other speciarizedtralnlng in his/her field?

RESPONSE TO INTERROGATORY NO.5: Please refer to the attached
resumes of Dr. Engstrom and Mr. Wilson.

' INTERROGATORY NO. 6: If the answer to the previous fnterrogatoryis yes, state:

(a) The type of training the expert received;
(b) The name and address of the school or place where theexpert received his/her training;
(c) The dates when the expert received this training.

RESPONSE TO INTERROGATORY NO. 6: , Please refer to the attached
resumes of Dr. Engstrom and Mr. Wilson.

INTERROGATORY No. ?: Is the expert a member of any professionaL
or trade association in his/her field?

RESPONSE TO INTERROGATORY NO. ?: Pleas6 refer to the attached
resumes 6f Dr. Engstrom and Mr. trlilson.

INTERRocAToRY No. 8: rf the answer to the precedingInterrogatory is yes, state:

(a) Th'e naure of each professional. trade association;
(b) The date the expert became a member;

(c) The descrJ.ption of each office the expert has hel.d ineach association.

RBSPONSE TO INTERROGATORY NO. 8: Please refer to the attached
resumes of Dr. Engstrom and Mr. Wilson.

TNTERBOGATORY -No. 9: Has the expert written books, papers, orarticles on subject in his/her field?

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RESPONSE TO INTERROGATORY NO. 9: Please refer to the attached
resumes of Dr. Engstrom and Mr. t{ilson.

fNTERROGATORY No. 1o: rf the answer for the precedingrnterrogatory is yes, for each book, paper and artLcl.e state:
(a) Title and subJect matter;
(b) The name and the address of the publisher;
(c) The date of publication.

RESPONSE TO INTERROGATORY NO. 10: Please refer to the attached
resurnes of Dr. Engstrom and Mr. g{ilson.

TNIERRQGATORY No. 11: rs the expert licensed by any governmentalauthority to practice in his/her fietd?
RESPONSE TO INTERROGATORY NO. 11: Mr. t^Iilson is a member of the
State Bar of Georgia.

fN.TERRoGAToRY No. 12: rf the answer to the precedingfnterrogatory is yes, state, :
i

(a) The designation of the arlthority by whom the expert wasI icensed;

(b) The date the expert was licensed;
(c) The general reguirements that the expert had to meet toobtain this'license;

(d) How the expert fulfilLed these reguirements.
RESPONSE TO.fNTERROGATORY NO. 12: Mr. Wilson was admitted to the
Bar in 198s pursuant to the staters requirements.

IryrE:RRoc+ToRY No. 19: was the expertrs license to practice inhis/her field ever revoked or suspended?

: No.

LI.TERRoGAToRy No. 14: rf the answer to the precedingrnterrogatory is yes, for each revocatlon or suspension, state:
(a) The Lnclusive dates;



(b) The _designatlon of the authorlty who revoked orsuspended the lLcense;

(c) The charges preferred;

(d) The punishment imposed.

RESPONSE To TNTERRocAToRy No. 14: Not appllcabre.

: Has the expert practlced or worked inhis,/her field during the past twenty -tzot yearsz

: please refer to the attached
resuttres of Dr. Engstrom and Mr. Wll.son.

TNTERRocAToRy No. 16: rf the r.esponse to the preceding
ate:

(a) t^Ihether the expert was serf -employed, employed bysomeone else or associated as a partner;
(b) Each address where the expert practiced or wasemployed;

(c) The type of duty the,expert performed with eachemployer

RESPONSE TO INTERROGATORY NO. 16:.'] Please refer to the attached
resumes of Dr. Engstrom and Mr. Wi1son.

INTERR9GATORY NO. 1? : [.lhat experj.ence, .bther than that statedabove has the expert had in his/her field?
: please refer to the attached

resumes of Dr. Engstrom and Mr. Wilson.

INTE-RBOGATOR} Io._ 1g: Has the expert had any previous experiencein his,/her fieLd which involvLs problems similar to thoseencountered in this action?

: This interrogatory is unclear.
Dr' Engstromrs and Mr. Wilsonts previous experience is descrl.bed
in the attached resunes.

INTEFR99ATORY No. 19: If so, describe each simllar problem withwhich the expert has had experience.



RESPONSE TO I@:
No. 18.

See Response to Interrogatory

At what address Ls the expert presently

See Response to
Interrogatories No. 2(a) and 4.

TNTERROQSTORY No. 21: Between what dates has the expert been soemployed?

RESPO-NSB To TNTERRocAToRy No. 21: please refer to
resumes of Dr. Engstrom and Mr. g{llson.

TNTERROGATORY No. 22: what are the expert,s present

: p.Iease refer to
resumes of Dr. Engstrom and Mr. Wilson.

the attached

duties?

the attached

9{11-son

stated

TNTEB,ROGATORY No . 2 3 : what did the expert test, analyze orexamine?

IESPOrySE TO INTERR , i See Response to InterrogatoryNo. 2(c) !

TNTERROGATORY No- 24: During what dates did thetest, analysis, or examination?
expert make such

: Neither Dr. Engstromrs nor Mr.
[^lilson.'s ana]yses has been completed.

TNTEBROG4'TORY No. 2s: At what ad,dress was this test, anarysis orexamination made?

RESPONSE To TNTERRocAToRy No. 2s: Dr. Engstrom and Mr.
each work "o. " .;u;""ses of whlch are
in the Response to Interrogatory No. 2(a).

+NTERRO9+TORY No. 26: what facts or information were youhaving this test, analysis or examl.natlon conducted?
seeklng

: plaintiffs object to this
Interrogatory on the ground that the informatl.on requested is

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attorney work product and is not dlscoverable under Fed. Rule
Civ. Proc . 26(b) (4) .

INTERROGATORY No. 2z: Explain in detail the steps used in thistest, analysis or examination.

: When Dr. Engstrom and Mr.
['Iilson have completed their anaryses, plaintiffs will provide a
statement of their facts and opinions and a summary of the ground

for each opinion, pursuant to Fed. Rure civ. proc . 26(b) (4).
TNTERROGATORY No. 28: Did anyone assist the expert?

: please refer to the Response

to Interrogatory No. 27.

fNTERROGATORY NO. 29: If so, state:
(a) The name and address of each person who gaveassistance;

(b) The type or amount of assistance given;
(c) The inclusive dates that each person gave suchassistance.

RESPONSE TO. INTERROGATORY NO. 29: Please refer to the Response

to Interrogatory No. 27.

INTERR9GAT0RY No. 30: Were any results or conclusions reached asa result-ot-this-tE5t, analysii or examination?

RESPONSE To-rNTERRoGAToRy.No. 30: please refer to the response
to rnterrogatory No. 27. rn addition, Mr. wilson's prellminary
findings regarding potential maJority black districts are
described in the Plaintiffst Responses to Defendantsr First
fnterrogatories and Requests for Production of Documents, Nos.

17 , 18 and 24.

INTERROGATORY NO. 31:
conclusions?

If so, what were the results or

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Please refer to the Response

to Interrogatory No. gO.

INTER.R9SATORY No. 32: what is the name or other means ofidentification, and address of the person who has present custodyof each item that was tested, analyied or examined?

: plaintiffs do not believe that
the term "item that was tested, analyzed, or examined,, applies to
the data analysis being performed by Dr. Engstrom and Mr. wilson.
Dr. Engstrom and Mr. wiLson are analyzing data from the u.s.
Bureau of Census and other public sources.

fNTERROGATORY NO. gg: On what date did each person obtaincustody of each item?

: please

to Interrogatory No. 92.

refer to the Response

INTERRocAToRy No. 94: How did each,person obtain custody of eachitem? 
i

RESPONSE To INTERROGATORY No. 34: Please refer to the Response
to Interrogatory No. 32.

INTERRQGATORY No.. 35: Will you permit the separate defendants toinspect each'such item at a reasonab].e place and time?

: please refer to the Response
to the Interrogatory No. 32.

\
TNTERRQ9ATORY No. 36 z Tf not, what reasons do you have for yourrefusal?

. 36: Not appllcable.

ldentified above submit aINTERROGATORY NO. 3?: Dld any expertsreport of their objective findingJ?
RESPONSE TO INTERROGATORY NO. 3?:
Response to Interrogatory No. 27.

No. Please refer to the



INTERROGATORY NO. 38: If so, state:
(a) The date this report was submitted;

(b) The name or other identification of the person to whomthis report was submitted;

(c) The name and address of the person who has presentcustody of this report.
RESPONSE To TNTERRocAToRy No. 38: Not applicabl.e.
TIITERROGATORY No. 39: please attach a copy of any reports madeby this expert on the basis of his/her tests, analysis orexamination, to your ans$rers to these interrogatories.
RESPONSE TO INTERROGATORY NO. 39: Not applicabte.
,-r 

"";":. 

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any expert identif iedabove, is the expert to be compensated for his/her work andefforts in connection with this action?

RESPONSE TO INTERROGATORY NO. 40: yes.

INTERROGATORY NO. 41: If so, how much is the expert to be
compensated?

RESPoNSE To TNTERRocAToEI___N-e_r---AL: Dr . Engstrom is to be
.!

compensated at a rate of $6s per hour, plus expenses. Mr. wilson
is to be compensated at a rate of $?5 per hour, plus expenses.

TNTERROGATORY No. 42: rs he/she to receive any additionalcompensation if you are successful in this action?
RESPONSE TO INTERROGATORY NO. 42l. No.

* , ;""a are the terms of thisaaai@z
RESPONSE TO INTERROGATORY NO. 49: Not applicable.
INTERROGATORY NO. 44: Has helshe already been paid?

RESPONSE TO INTERROGATORY NO. 44: No.

TNTERROGATORY No. 4s: rf not, when will he/she be paid?

RBSPONSE To TNTERROGATORY No. 4s: upon compJ.etlon of thelr
analyses and submission of bil1s and invoices.

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INTEJEROG:AIORY No. {6: wlll you conelder theee rnterrogatorles aecontlnulng in nafure and iupplenent your responaea when suchsupplemental lnformatlon becomes aval.lable?

: PlalntlffE will eupplement
thelr responses aa requlred under Fed. Rule Clv. Proc. 26(g).

Respectfully subnitted,
-/-Gz-<-?ffi @^do. D. lt"td

Wllson and Bell
8O1. Perry Street
Helena, Arkansas 22942
( 501 ) 338-64S?

OLLY NEAL
33 North poplar Street
Marianna, Arkansas Z2!60
(5O1 | 2e5-2578

P.A. HOTLINGSIIIORTH
Ho.Llingsworth Law Firn
415 Main Street
Littl.e Rock, Arkansas Z22Ot
( 501 ) 324-3420

DON E. GLOVER
P.O. Box 219
Dermott, Arkansas ?163S
( 501 ) 538-9O?1

Dated: June ?, 1999

PENDA D. HAIR
L275 K Street, N.W.
Suite 3O1
Washington, D.C. 2OOO5
(2021 682-13OO

JULIUS L. CHAIIBERS
SHERRITYN IFILL

99 Hudson Street, 16th Floor
New York, New york 1OO13
(2L2) 219-1sOO

L.T. SIMES' Simes and Associates
P.O. Box 28ZO

r West Helena, Arkansas 72ggo(501) 572-3796

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