Correspondence from Kellogg to Cassimere

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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
- 138151ca-c703-ef11-a1fd-002248219001

Cite this item

Case Files, Major v. Treen Hardbacks. Correspondence from Kellogg to Cassimere, 1982. 138151ca-c703-ef11-a1fd-002248219001. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/f546a0ec-75c4-451f-94db-3bfef7c43916/correspondence-from-kellogg-to-cassimere. Accessed November 05, 2025.

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    LAW OFFICES OF 

QUIGLEY & SCHECKMAN 
631 ST. CHARLES AVENUE 

NEW ORLEANS, LOUISIANA 70130 

TELEPHONE: 504-524-0016 

WILLIAM P. QUIGLEY IN ASSOCIATION WITH 

STEVEN SCHECKMAN R. JAMES KELLOGG 

MARK S. GOLDSTEIN 

RONALD J. PURSELL 

October 29, 1982 

Dr. Raphael Cassimere, Jr. 

History Department 

University of New Orleans 

New Orleans, Louisiana 

Re: ’ Major v. Treen   

Dear Ralph: 

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, we probably want you to testify on the following issues: 

1) Racist history of Louisiana history virtually every aspect of 

life, focusing on period up to but not including 1960 school 

desegregation battles. This hisbory will necessarily include: 

a) Reconstruction and its aftermath including use of 

Jim Crowe laws, disfranchisement of blacks including use of 

grandfather clauses 

b) racial appeals in electoral campaigns, including 

Third Party Politics 

c) efficacy of Third Parties in Louisiana 

d) comparison of voter registration statistics prior 

to VRA with statistics after VRA  



Dr. Raphael cassimere, Jr. 

Major v. Treen 

Page 2 

  

  

2) The use of various disfranchisement techniques by Louisiana officials 

including literacy tests, poll taxes, white primaries, property own- 

ership requirements, etc. 

I realize this deliniation may be somewhat broader than we spoke earlier, but 

I don't think you will have any problem. If you feel you are unable to develop 

any of these areas, please get in touch with me. We have some material on 

Treen (including his biography) if you fell it would be of any use. 

After looking at our budget, I find we will be able to pay you a fee of four 

hundred ($400) dollars. Obviously, however, if our requests involve signi- 

ficantly more time than anticipated, we are willing to 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 a preliminary re- 

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

final report by January 3. We expect 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 question, please 

get in touch with me at your earliest convenience. 

Welcome aboard! 

Sincerely, 

i, 

ine etary 
¥ 

R. James Kellogg 

cc: Lani Guinier 

Stan Halpin 
Bill Quigley 

Steve Scheckman

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Correspondence from Kellogg to Cassimere

LDF Attorney

Matter

Case

U.S. state

Collection

Creator

Publisher

Taxonomy

Identifier

Cite this item

Copyright notice

Additional info

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