Correspondence from Kellogg to Engstrom

    LAW OFFICES OF 

QUIGLEY & SCHECKMAN 
631 ST. CHARLES AVENUE 

NEW ORLEANS, LOUISIANA 70130 

TELEPHONE: 504-524-0016 

WILLIAM P. QUIGLEY IN ASSOCIATION WIT} 
STEVEN SCHECKMAN R. JAMES KELLOGG 

MARK S. GOLDSTEIN 

RONALD J. PURSELL 

October 29, 1982 

Dr. Richard Engstrom 

Political Science Department 

University of New Orleans 

New Orleans, Louisiana 

Re: Major v. Treen   

Dear Dick: 

We are extremely pleased that you have agreed to testify as an expert witness 

for the plaintiffs in the above-captioned matter relating to the reapportion- 

ment of the Louisiana Congressional districts. This letter will set forth 

the details of our relationship, as I appreciate them. 

The trial begins in the federal courthouse in New Orleans on January 31, 1983 

before Federal District Judges Collins and Cassibry and Federal Circuit Judge 

Politz. Trial is expected to last five (5) days and our current best guess 

is that you will testify on the first or second day. 

Although the exact contours of your testimony have not been determined as of 

this date, probable areas are as follows: 

1) political-sociological evidence relating to the present effects 

of past discrimination against blacks in Orleans and Jefferson 

Parishes in the area of housing (including the role of the two 

parishes in providing housing), education (level and quality) 

voter registration, income (including rates of pay, 7 below 

the poverty level, Z in menial job, etc.) 

an analysis of whether or not the present effects of past discrim- 

ina ion are more pronounced in Jefferson than Orleans, 

the presence or absence of a unity of interests between Orleans 

and Jefferson including regional transit, new bridges over the 

Mississippi, metropolitan earnings tax, tax bases, growth pat- 

terns, electoral results, etc.  



Dr. Richard Engstrom 

Major v. Treen 

Page 2 

  

  

an analysis of the Governor's contention that the two districts 

being split between the two parishes is historically justified, 

and, 

an analysis of whether blacks are better off politically with a 

significant minority in two districts rather than a majority in 

in one district. 

I have agreed to facilitate the transfer of information from Gordon Henderson 

to you in the very near future. The information relates to items one and two 

above, for which items we will definitely need your testimony. The remaining 

items may be covered by other experts, but we will let you know in the near 

future. 

We have agreed to pay you a fee of four hundred dollars ($400). Obviously, 
however, if our requests involve significantly more time by you, we will 

renegotiate your fee. 

The Court has ordered that expert witness reports be exchanged by the parties 

on or before January 5, 1983. Accordingly, we would like to have a prelimin- 

ary report from you on or before December 6 (it need not be in writing) and 

the final report by January 3. We expect that the defendants will want to 

schedule your deposition in late December or early January, at a time and 

place convenient to you. 

We are very excited to be able to work with you and feel your experience and 

expertise will be a great asset to our case. 

If any matter in this letter is unclear or if you have any questions, please 

get in touch with me at your earliest convenience. 

Welcome aboard! 

Sincerely, 

p! irs 720 > 

“Hh Vas Kelley 

A 

R. James Kellogg 

Lani Guinier 

Stan Halpin 

Bill Quigley 

Steve Scheckman