State Defendants' First Set of Interrogatories and Request for Production of Documents

    THE ATTORNEY 42RNNRAL 

OF TEXAS 

JIM PIATTOX 

ATTORNEY GENERAL Ma y 30 1 0 80 
bd 

CERTIFIED MAIL NO. P990731518 
RETURN RECEIPT REQUESTED 

Sherrilyn A. Ifill 

NAACP Legal Defense 
and Educational Fund, Inc. 

99 Hudson Street, 16th Floor 

New York, New York 10013 

Re: LULAC Council #4434, et al. v. Mattox, et al., 

No. MO-88-CA-154 

Dear Ms. Ifill: 

Enclosed are the original and one copy of State Defendants’ First Set 
of Interrogatories and First Request for Production of Documents to 

Houston Lawyers’ Association, et al. 

Sincerely, 

Ns A oo INI > 

  

Renea Hicks 
Special Assistant Attorney General 

P.O. Box 12548, Capitol Station 

Austin, Texas 78711-2548 

(512) 463-2085 

RH:dr 

Enclosure 

4 Counsel of Record 

512/463-2100 SUPREME COURT BUILDING AUSTIN, TEXAS 78711-2548 

 



  

UNITED STATES DISTRICT COURT 

WESTERN DISTRICT OF TEXAS 
MIDLAND-ODESSA DIVISION 

LULAC COUNCIL #4434, et al., 

Plaintiffs, 

Civil Action No. 

MO-88-CA-154 

VS. 

JIM MATTOX, et al., 

Defendants. CO
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STATE DEFENDANTS' FIRST SET OF INTERROGATORIES 
AND FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO 

HOUSTON LAWYERS' ASSOCIATION, ET AL. 

TO: Plaintiff-Intervenors Houston Lawyers’ Association, Alice 
Bonner, Weldon Berry, Francis Williams, Rev. William Lawson, 

Deloyd T. Parker, and Bennie McGinty; through their Counsel of 
Record Sherrilyn A. Ifill, NAACP Legal Defense & Educational 

Fund, Inc., 99 Hudson Street, 16th Floor, New York, New York 

10013. 

Pursuant to Rules 33 and 34 of the Federal Rules of Civil Procedure, 

the plaintiff-intervenors hereby are required to answer in writing the 

following interrogatories and respond to the requests for production of 

documents. The State Defendants request that all responses be provided to 

them no later than fifteen days after service. 

INTERROGATORIES 

INTERROGATORY NO. 1 [to all HLA] 
  

Identify every electoral contest which you have requested your 

expert witness to analyze for purposes of this litigation. Provide the 

candidate, year of election, and office sought in connection with your 

answer. 

INTERROGATORY NO. 2 [to all HLA] 
  

Which of the Zimmer factors do you contend are present and support 

your claim of Section 2 violation? 

 



  

INTERROGATORY NO. 3 [to all HLA] 
  

Do you contend that any aspect of the current Texas law governing 

voting registration operates to disadvantage minority voters? iH s0, 

describe precisely all such statutory provisions and/or practices which you 

assert so operate. 

INTERROGATORY NO. 4 [to all] 
  

Do you contend that the state policy underlying use of the county- 

wide election for district judges is tenuous? If so, please provide the 

historical, political, and legal basis for such claim. 

INTERROGATORY NO. 3 [to all] 
  

To the extent that you claim that there is a history of "official 

discrimination" that touches the right of minority group member to 

register, to vote, or otherwise participate in the democratic process, please 

describe such discrimination and list all such "official discrimination” and 

the year or years in which such discriminatory practices were in effect. 

INTERROGATORY NO. 6 [to all] 
  

To the extent that you claim that there is in existence a candidate 

slating process, which has denied minority group members access to the 

process, list the name and/or identifying description of each such slating 

group and the years in which it has functioned. 

INTERROGATORY NO. 7 to all] 
  

To the extent you claim that political campaigns have been 

characterized by overt or subtle racial appeals, list every election 

campaign in which you so contend and the candidates or candidate 

supporters guilty of utilizing such appeals. 

INTERROGATORY NO. 8 
  

Identify every minority candidate for district judge in Harris County. 

 



  

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INTERROGATORY NO. 9 [to all non-HLA plaintiff-intervenors] 
  

Please identify by street address and voting precinct your residence. 

INTERROGATORY NO. 10 [to HLA] 
  

Please identify the voting precinct of the residence of each of your 

members. (The identity of your individual members is not sought through 

this interrogatory.) 

INTERROGATORY NO. 11 
  

If you claim to represent the interests of Mexican-American voters 

in this lawsuit, please specify the factual basis for the claim. 

INTERROGATORY NO. 12 
  

Please identify each of the persons, other than already-identified 

expert witnesses, that you expect to call as a witness at the trial of this 

action, specifying the subject matter upon which each is expected to testify 

and the substance of the facts of which each has knowledge as they pertain 

to the allegations and claims against the State Defendants. 

INTERROGATORY NO. 13 [to plaintiff-intervenors Bonner, Berry, and 

Williams] 

  

  

Please identify the organizations which endorsed you in your race or 

races for district judgeship in Harris County. 

INTERROGATORY NO. 14 [to HLA] 
  

Please explain why your charter to operate in Texas was forfeited in 

1968. 

INTERROGATORY NO. 15 [to HLA] 
  

Please explain whether your current purpose differs in any respect 

from the purposes enumerated in your 1965 Articles of Incorporation and, 

if so, how. 

 



  

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REQUEST FOR PRODUCTION OF DOCUMENTS 

REQUEST NO. 1   

Please provide a copy of all computer printouts and summaries of 

them, including preliminary or non-final ones, which any of your experts 

have reviewed or relied upon in connection with either of the following 

matters: (a) voter behavior, including matters of racially polarized voting; 

and (b) geographical compactness of an identifiable racial or ethnic group 

or groups. 

REQUEST NO. 2 
  

Please provide copies of any of your by-laws, charters, or operational 

rules. 

DATED: May 30, 1989. 

Respectfully submitted, 

JIM MATTOX 
Attorney General of Texas 

MARY F. KELLER 
First Assistant Attorney General 

\ 
V4 ! 

RENEA HICKS VAN 
Special Assistant Attorney General 

  

JAVIER GUAJARDO 

Assistant Attorney General 

P. O. Box 12548, Capitol Station 

Austin, Texas 78711-2548 

(512) 463-2085 

ATTORNEYS FOR STATE DEFENDANTS