Intervenor/Plaintiffs Oliver, Tinsley, and Whites' Answers to and Judge Entz's Interrogatories; Verifications; Responses to and Request for Production of Documents

    MuLLiNAX, WELLS, BaaB & CLourMmaN, P.C. 

ATTORNEYS AT LAW 

3301 ELM STREET/DALLAS TEXAS 75226-1637 

  

EDWARD B. CLOUTMAN, III May 5, 1989 PHONE (214) 939-9222 
Board Certified-Labor Law 5 METRO 263-1547 

Texas Board of Legal Specialization - TELECOPIER (214) 939-9229 

CERTIFIED MAIL, RRR 
  

Mr. Robert H. Mow, Jr. 

Mr. David C. Godbey 
Mr. Bobby M. Rubarts 
Ms. Esther R. Rosenblum 

Hughes & Luce 
2800 Momentum Place 

1717 Main Street 
Dallas, Texas 75201 

RE: LULAC Council No. 4434, et al. 

vs. Mattox, et al. 

Dear Sir/Madam: 

Enclosed please find 1Intervenor/Plaintiffs Jesse 
Oliver's, Fred Tinsley's and Joan Winn White's Answers to Dallas 
County District Judge F. Harold Entz's Interrogatories and 
Intervenor/Plaintiffs Jesse Oliver's, Fred Tinsley's and Joan 
Winn White's Responses to Dallas County District Judge F. Harold 
Entz's First Request for Production of Documents in regard to 
the above referenced matter. 

We are in the process of obtaining our clients’ 
signatures on said documents and executed copies will be 
provided to you upon their return to our offices. 

Should there be any questions or problems, please do 
not hesitate to call. 

Very truly yours, 

MULLINAX, WELLS, BAAB 
& CLOUTMAN, P.C. 

By: . vi y 
thy Patrick 

fo dward B. Cloutman 

  

/klp 
Encl. 

   



  

Page 2 
May 5, 

CC: Mr. 
Mr. 
Ms. 
Mr. 
Ms. 
Ms. 
Ms. 
Mr. 
Mr. 
Mr. 
Mr. 
Mr. 
Mr. 

1989 

William L. Garrett 
Rolando L. Rios 
Susan Finkelstein 
E. Brice Cunningham 
Sherrilyn A. Ifill 
Gabrielle K. McDonald 

Mary F. Keller 
J. Eugene Clements 
Darrell Smith 
Michael J. Wood 

Mark H. Dettman 

Ken Oden 

David R. Richards 

 



  

IN THE UNITED STATES DISTRICT COURT 
FOR THE WESTERN DISTRICT OF TEXAS 

MIDLAND-ODESSA DIVISION 

LULAC COUNCIL NO. 4434, S 
ET AL. § CIVIL ACTION NO. 

S 
vs. § MO-88-CA-154 

N 
JIM MATTOX, ET AL. § 

TO: 

INTERVENOR/PLAINTIFFS JESSE OLIVER'S, FRED TINSLEY'S 
AND JOAN WINN WHITE'S ANSWERS TO DALLAS COUNTY 
DISTRICT JUDGE F. HAROLD ENTZ'S INTERROGATORIES 
  

Dallas County District Judge F. Harold Entz, by and 
through his attorneys of record, Mr. Robert H. Mow, 
Jr., Mr. David C. Godbey, Bobby M. Rubarts and Ms. 
Esther R. Rosenblum, Hughes & Luce, 2800 Momentum 
Place, 1717 Main Street, Dallas, Texas 75201. 

Respectfully submitted, 

MULLINAX, WELLS, BAAB 

& CLOUTMAN, P.C. 
3301 Elm Street 
Dallas, Texas 75226-1637 

(214) 939-9222 

al Bete 
  

Edward B. Cloutman, III 

COUNSEL FOR INTERVENOR/PLAINTIFFS 
OLIVER, TINSLEY AND WHITE 

 



  

IN THE UNITED STATES DISTRICT COURT 
FOR THE WESTERN DISTRICT OF TEXAS 

MIDLAND-ODESSA DIVISION 

LULAC COUNCIL NO. 4434, etal. 

Plaintiffs, 

CIVIL ACTION NO. 

Ve 

MO-88-CA-154 

JIM MATTOX, et al. etal 

Defendants. C
1
)
 

LI
 

LP
I 

LP
I 

CA
 
A
I
A
 

DALLAS COUNTY DISTRICT JUDGE 

F. HAROLD ENTZ'S INTERROGATORIES TO 

JESSE OLIVER, FRED TINSLEY, and JOAN WINN WHITE 
  

TO: Plaintiffs Jesse Oliver, Fred Timsley, and Joan Winn 
White, by and through their attorney of record, 
Edward B. Cloutman III, Mullinax, Wells, Baab & Cloutman, 

P.C., 3301 Elm Street, Dallas, Texas 75226: 

Judge F. Harold Entz submits his first interrogatories to 

Plaintiffs Jesse Oliver, Fred Tinsley, and Joan Winn White 

("Respondents") in accordance with Rule 33 of the Federal 

Rules of Civil Procedure as follows: 

DEFINITIONS 
  

: 3 "Document" means the original and any non-identical 

copy of any document (including writings, drawings, graphs, 

charts, photographs, phonorecords, audio recordings, and other 

data compilations from which information can be obtained, 

translated, if necessary, by the Respondents through detection 

devices into reasonably usable form) and any tangible things 

which constitute or contain matters within the scope of Rule 

26(b) of the Federal Rules of Civil Procedure. 

JUDGE ENTZ'S INTERROGATORIES TO OLIVER, etal. - Pagl 
a 

te, iia Ie MAG . { i bY Ay “ Ak 
CLV oe 1 Fish ww J wy wr “o 

 



  

2% "Communication" means any oral or written 

communication between or among any identified parties, 

including but not limited to telephone calls, meetings, 

discussions, correspondence, memoranda, or other messages 

conveyed from one party to another regardless of medium. 

Se "ldentify," or any form of that word used in 

connection with a document, means to state: (a) the name, date 

and subject of the document; (b) the type of document (e.qg., 

letter, memorandum, note, report); (c) the identity of the 

author and all recipients of the document; (d) the identity of 

the custodian or possessor of the document or a copy of the 

document; and (e) the location of the document or a copy of 

the document. 

4. "Identify," or any form Of that word used . in 

connection with a person, if that person is an individual, 

means to state (a) the name; (b) the present employer, if 

known; and (c) the present or last known business and home 

addresses and telephone numbers. 

5. "Identify," or any form of . that word. used ‘in 

connection with a person, if the person 1s a corporation, 

partnership, or other legal entity, means to (a) state the 

name; (b) identify the state of legal formation; (c) identify 

all officers, directors, partners and/or principals; and (4d) 

state the person's principal place of business. 

6. “Identify,” . or any ‘form ‘of that word used in 

connection with a communication, means to identify the parties 

to the communication, identify the medium of the communication 

JUDGE ENTZ'S INTERROGATORIES TO OLIVER, etal. - Page 2 

 



  

(e.g., phone conversation, letter, etc.), and state the date 

of the communication. 

7. "You" or "Your" means Plaintiffs Jesse Oliver, Fred 

Tinsley, and Joan Winn White. 

8. "Relating to" a subject means containing, embodying, 

referring to, comprising, reflecting. explaining, or having 

any significant logical, factual or causal connection with the 

subject. 

INSTRUCTIONS 
  

1. Answer each interrogatory fully in writing under 

oath, unless the interrogatory is subject to objection, in 

which case the reasons for objection must be stated in lieu of 

answer. If precise information is not available for answer, 

an estimate identified as such may be provided. 

2. The interrogatories are continuing in nature and your 

responses should be supplemented as required by Rule 33 of the 

Federal Rules of Civil Procedure. 

3. All answers and other responses to the 

interrogatories must be served upon the undersigned counsel 

within fifteen (15) days after service of these 

. interrogatories upon Respondents. 

INTERROGATORIES 
  

l. Identify each person you expect to call as an expert 

witness at trial and state the subject matter on which the 

expert is expected to testify. Include within your answer the 

substance of the facts and opinions to which the expert is 

JUDGE ENTZ'S INTERROGATORIES TO OLIVER, etal. - Page 3 

 



  

INTERROGATORY NO. 1: 
  

Identify each person you expect to call as an expert 

witness at trial and state. the subject matter on which the 

expert is expected to testify. Include within your answer the 

substance of the facts and opinions to which the expert is 

expected to testify and a summary of the grounds for each such 

opinion. 

ANSWER: 

Dan Weiser 
c/o Mullinax, Wells, Baab & Cloutman, P.C. 
3301 Elm Street 
Dallas, Texas 75226-1637 

Mr. Weiser will testify as to the conduct of past elections 

within Dallas County including those for county-wide office, 

City of Dallas office and any other races in which the witness 

can compare the success of black versus white candidates in at- 

large elections within the confines of any race held in Dallas 

County, Texas. He will further testify as to racial polariza- 

tion in context of analysis of which candidate is black and 

which candidate is white voters have voted for historically 

within Dallas County races as identified above. He will further 

testify as to incidents amounting to appeals to race during 

electorial contests between black and white candidates in Dallas 

County, Texas as identified above. He will further testify by 

example as to possible solutions to dilution of black voters’ 

strength caused by the at-large election of district judges 

 



  

within Dallas County. At this point in time, it is uncertain 

as to what other matters the witness may be asked to testify to 

within his expertise. Of course, these answers will be supple- 

mented as will all answers succeeding this one, if and when 

further information becomes available to intervenor /plaintiffs. 

INTERROGATORY NO. 2: 
  

If you claim that blacks and hispanics are politically 

cohesive in Dallas County, please state the factual bases for 

such a claim. 

ANSWER: 

Unknown at this time. 

INTERROGATORY NO. 3: 
  

If you claim that voting in wvallas County is racially 

polarized, please state the factual bases for such a claim. 

ANSWER: 

Yes. Witness's analysis of past voting races in which 

white and black candidates were in contest for electorial 

position. The specifics of each race of political candidates 

that intervenor /plaintiffs contend had initial polarization will 

be answered by intervenor /plaintiffs' expert over the subject 

of his expert testimony. 

1NTERROGATORY NO. 4: 
  

Identify every Dallas County election you have 

analyzed, describing fully your method of analysis, and the 

 



  

results of such analysis. 

ANSWER: 

Intervenor/plaintiffs are unclear as to the term 

"Dallas County election". But if such means every election held 

within Dallas County, intervenor/plaintiffs' expert will analyze 

or offer testimony upon analysis previously performed of 

elections within Dallas County, including for Dallas County-wide 

position, City of Dallas position, state legislative races and 

any others that are germane from approximately 1970 forward. 

1The result of such anAlysis are better answered by intervenor/- 

plaintiffs' expert, but in general indicate that what has been 

racially polarized and that black candidates fare poorly in at- 

large elections contrasted with those held in single-member 

districts for black candidates. 

INTERROGATORY NO. 5: 
  

Identify every candidate for public office in Dallas 

County whom you have sponsored or preferred in the last twenty 

years. Include within your answer the date of the race, the 

position the race was intended to fill, the identity of the 

winner of the race, and the percentage of blacks, whites, and 

hispanics respectively voting for your sponsored or preferred 

candidate. 

 



  

ANSWER: 

Intervenor/plaintiffs are unclear as to the meaning 

of Interrogatory No. 5. If the terms "sponsored" or "preferred" 

indicate those that intervenor /plaintiffs have donated money to 

or who were voted for, intervenor/plaintiffs are unable to 

answer the question as stated. Otherwise, intervenor /plaintiffs 

would request clarification of the interrogatory prior to 

attempting any answer. 

INTERROGATORY NO. 6: 
  

Identify every factor and circumstance present in 

Dallas County with respect to the political processes leading 

to the nomination or election of candidates to public office in 

Dallas County that you claim is not equally open to participa- 

tion by blacks and that you claim gives blacks less opportunity 

than other members of the electorate to participate in the 

political process and to elect representatives of their choice. 

ANSWER: 

The factors that intervenor /plaintiffs assert operate 

to prevent equal participation by black candidates are the at- 

large election features of the Dallas County District Judge 

elections. Because black voters are in a numerical minority 

within Dallas County, and because such elections are held at- 

large with all voters in the county eligible to cast votes on 

all thirty-six (36) judicial district races, black vote is 

 



  

submerged and is unable to be given its full and proper weight 

in selecting candidates of black voters' collective choice. 

INTERROGATORY NO. 7: 
  

If you claim that any part of the established system 

in Dallas County for electing state district judges dilutes 

black voting strength, state the factual bases for your claim, 

if any, that the reasons for adopting such a system are tenuous. 

ANSWER: 

See answer to Interrogatory No. 6. 

INTERROGATORY NO. 8: 
  

If you claim that the system of electing state 

district judges in Dallas County is intentionally designed to 

discriminate against minorities, please state the factual bases 

for such a claim. 

ANSWER: 

Intervenor /plaintiffs are uncertain as to the inten- 

tion of present county or state officials with respect to their 

discrimination against minorities. Dallas County has had a 

judicially documented history of discrimination against black 

and hispanic voters. Judgments have been rendered to such end 

in state legislative and City of Dallas City Council issues in 

the near past. 

 



  

INTERROGATORY NO. 9: 
  

If you claim that blacks in Dallas County have been 

denied access to a candidate slating process, please state the 

factual bases for such a claim. 

ANSWER: 

It is unclear that black voters have access on an 

equal basis to any candidate slating process involving the 

Republican Party of Dallas County and/or the State of Texas. 

Although partisan, such party domination of Dallas county 

politics recently has resulted in a slating contest by the 

Republican Party. 

INTERROGATORY NO. 10: 
  

If you claim that blacks in Dallas County are hindered 

in their ability to participate effectively in the political 

process, state your factual bases for such a claim. 

ANSWER: 

See previous answers. 

INTERROGATORY NO. 11: 
  

If you claim that political campaigns in vallas County 

have been characterized by overt or subtle racial appeals, state 

your factual bases for such a claim. 

ANSWER: 

Insofar as intervenor /plaintiffs are personally aware 

at this time, some political campaigns in Dallas County histori- 

 



  

cally have been characterized by overt or subtle racial appeals. 

Those have been documented in state legislative and City of 

Dallas cltyicoumetl litigation in the recent past. Moreover, 

appeals to raise for overt and/or subtle in at least two (2) 

judicial district races within the last decade involving 

plaintiff Joan Winn White and unsuccessful candidate for 

vistrict Attorney, Royce West. 

INTERROGATORY NO. 12: 
  

If you claim that there is a significant lack of 

responsiveness on the part of the elected judges in Dallas 

county to the particularized needs of blacks, state your factual 

bases for such a claim. 

ANSWER: 

The responsiveness of the current elected judges for 

Dallas County is unknown. 

INTERROGATORY NO. 13: 
  

Describe the location and population of each and every 

single member district you claim could and/or should be drawn 

in Dallas County with respect to electing state district judges. 

ANSWER: 

The location and population of each and every single 

member district intervenor/plaintiffs claim should or can be 

drawn within Dallas County is better left to intervenor /plain- 

tiffs' expert. Such plans have not yet been drawn but are in 

 



  

the planning stages at this point. 

  

INTERROGATORY NO. 14: 

With respect to your answer to Interrogatory No. 14, 

state the percentage of anglo, black, and hispanic members of 

the voting age population in each such district. 

ANSWER: 

Interrogatory 14 is unclear if it refers, in fact, to 

answers to Interrogatory 13, intervenor/plaintiffs are again 

required to defer to the expertise of their expert witness, Dan 

Weiser, whose preparation is incomplete at this point. 

INTERROGATORY NO. 15: 
  

For each person identified in response to Interrogato- 

ry No. 1, please list every engagement of the expert in which 

the expert was hired potentially to testify and in which Section 

2 of the Voting Rights Act was involved. include within your 

answer the person or group by whom the expert was retained. 

ANSWER: 

Intervenor/plaintiffs' expert to their knowledge has 

not been hired to testify in any matter in which Section 2 of 

the Voting Rights Act as presently worded has been involved. 

INTERROGATORY NO. 16: 
  

If you claim that blacks in Dallas .ounty are politi- 

cally cohesive, state the factual bases for such a claim. 

 



  

ANSWER: 

Intervenor/plaintiffs do claim that blacks or African 

American voters in Dallas County are politically cohesive. The 

factual basis for such claims are voting returns known to 

intervenor /plaintiffs and also the analysis presently being 

conducted by their expert witness, Dan Weiser. Such analysis 

is incomplete at this point. 

INTERROGATORY NO. 17: 
  

If you claim that white voters in Dallas County vote 

as a bloc usually to defeat your preferred candidates, state the 

factual bases for such a claim. 

ANSWER: 

White voters in Dallas County do vote as a block to 

defeat preferred candidates. Several instances, white candi- 

dates running against black candidates for reasons that could 

bear little or no relationship to merit, experience or qualifi- 

cation have nonetheless prevailed and have done so with a 

substantial block of the white vote weighing the substantial 

bloc of the black vote for the unsuccessful candidate. 

INTERROGATORY NO. 18: 
  

Identify all documents relating to your answers to 

Interrogatories 1-17. 

ANSWER: 

No documents were referred to. 

10 

 



  

INTERROGATORY NO. 19: 
  

Identify by name, address, and telephone number each 

person assisting in the preparation of the answers to interroga- 

tories 1-18 above. 

ANSWER: 

The persons answering these interrogatories are: 

Jesse Oliver 

600 Arma Drive 

Austin, Texas 78752 

Fred Tinsley, Jr. 
400 S. Zang 
Suite 400 
Dallas, Texas 75208 

Joan Winn White 

3809 Crownshore Dr. 

Dallas, Texas 75234 

Edward B. Cloutman, III 

Mullinax, Wells, Baab & Cloutman, P.C. 

3301 Elm Street 
Dallas, Texas 75226-1637 

Dan Weiser 

c/o Mullinax, Wells, Baab & Cloutman, P.C. 
3301 Elm Street 

Dallas, Texas 75226-1637 

11 

 



  

VERIFICATION 
  

STATE OF TEXAS § 

COUNTY OF DALLAS § 

BEFORE ME, the undersigned authority personally 

appeared Jesse Oliver, who being by me duly sworn on his oath, 

deposes and said that he is one of the intervenor/plaintiffs in 

the above referenced cause and that he has read the above and 

foregoing answers to interrogatories and that to the best of his 

knowledge and belief, every statement contained therein is true 

and correct. 

  

Jesse Oliver 

SUBSCRIBED AND SWORN to before me, on this the 

day of May, 1989. 

  

NOTARY PUBLIC, in and for 

the State of Texas 

12 

 



  

VERIFICATION 
  

STATE OF TEXAS § 

COUNTY OF DALLAS § 

BEFORE ME, the undersigned authority personally 

appeared Fred Tinsley, Jr., who being by me duly sworn on his 

oath, deposes and said that he is one of the intervenor /plain- 

tiffs in the above referenced cause and that he has read the 

above and foregoing answers to interrogatories and that to the 

best of his knowledge and belief, every statement contained 

therein is true and correct. 

  

Fred Tinsley, Jr. 

SUBSCRIBED AND SWORN to before me, on this the Te 

day of May, 1989. 

  

NOTARY PUBLIC, in and for 

the State of Texas 

13 

 



  

VERIFICATION 
  

STATE OF TEXAS § 

COUNTY OF DALLAS § 

BEFORE ME, the undersigned authority personally 

appeared Joan Winn White, who being by me duly sworn on her 

oath, deposes and said that she is one of the intervenor/plain- 

tiffs in the above referenced cause and that she has read the 

above and foregoing answers to interrogatories and that to the 

best of her knowledge and belief, every statement contained 

therein is true and correct. 

  

Joan Winn White 

SUBSCRIBED AND SWORN to before me, on this the 

day of May, 1989. 

  

NOTARY PUBLIC, in and for 

the State of Texas 

14 

 



  

CERTIFICATE OF SERVICE 
  

I hereby certify that a true and correct copy of the 

foregoing instrument has been served upon counsel of record, by 

placing same in the United States Mail, postage prepaid, on this 

Edward B. Cloutman, III 

the 5. sy of May, 19809. 

  

15 

 



  

IN THE UNITED STATES DISTRICT COURT 
FOR THE WESTERN DISTRICT OF TEXAS 

MIDLAND-ODESSA DIVISION 

LULAC COUNCIL NO. 4434, § 
ET AL. § CIVIL ACTION NO. 

§ 
VS. § MO-88-CA-154 

§ 

§ JIM MATTOX, ET AL. 

INTERVENOR/PLAINTIFFS JESSE OLIVER'S, FRED TINSLEY'S 
AND JOAN WINN WHITE'S RESPONSES TO DALLAS COUNTY 
DISTRICT JUDGE F. HAROLD ENTZ'S FIRST REQUEST FOR 

PRODUCTION OF DOCUMENTS 
  

TO: Dallas County District Judge F. Harold Entz, by and 
through his attorneys of record, Mr. Robert H. Mow, 
Jr., Mr. David C. Godbey, Bobby M. Rubarts and Ms. 
Esther R. Rosenblum, Hughes & Luce, 2800 Momentum 

Place, 1717 Main otreet, Dallas, Texas 75201. 

Respectfully submitted, 

MULLINAX, WELLS, BAAB 

& CLOUTMAN, P.C. 

3301 Elm Street 
Dallas, Texas 75226-1637 
(214) 939-9222 

Edward B. Cloutman, III 
  

COUNSEL FOR INTERVENOR/PLAINTIFFS 
OLIVER, TINSLEY AND WHITE 

 



  

IN THE UNITED STATES DISTRICT COURT 
FOR THE WESTERN DISTRICT OF TEXAS 

MIDLAND-ODESSA DIVISION 

LULAC COUNCIL NO. 4434, etal. § 

§ 
Plaintiffs, § 

§ CIVIL ACTION NO. 

v. § 
§ MO-88-CA-154 

JIM MATTOX, etal. § 

§ 
Defendants. § 

DALLAS COUNTY DISTRICT JUDGE 
F. HAROLD ENTZ'S 

FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO 
JESSE OLIVER, FRED TINSLEY, and JOAN WINN WHITE 
  

TO: Plaintiffs Jesse Oliver, Fred Tinsley, and Joan Winn 
White, by and through their attorney of record, 
Edward B. Cloutman III, Mullinax, Wells, Baab & Cloutman, 
P.C., 3301 Elm Street, Dallas, Texas 75226: 

Pursuant to Rule 34 of the Federal Rules of Civil 

Procedure, Judge Entz submits the following request for 

production of documents to Plaintiffs Jesse Oliver, Fred 

Tinsley, and Joan Winn White ("Respondents"): 

DEFINITIONS 
  

Xs "Document" means the original and any non-identical 

copy of any document (including writings, drawings, graphs, 

charts, photographs, phonorecords, audio recordings, and other 

data compilations from which information can be obtained, 

translated, if necessary, by the Respondents through detection 

devices into reasonably usable form) and any tangible things 

which constitute or contain matters within the scope of Rule 

JUDGE ENTZ'S DOCUMENT REQUEST TO OLIVER, etal. - Page 1 
Mr MADD 0 Son 

ReooiVeD BARS bb wal 

 



  

26(b) of the Federal Rules of Civil Procedure. 

2 "You," or "Your" means the Plaintiffs Jesse Oliver, 

Fred Tinsley, and Joan Winn White. 

3. "Relating to" a subject means containing, embodying, 

referring to, comprising, reflecting. explaining, or having 

any significant logical, factual or causal connection with the 

subject. 

INSTRUCTIONS   

1. Respondents shall produce for inspection and copying 

all documents described below within its possession custody 

and control at the offices of Hughes & Luce, 2800 Momentum 

Place, 1717 Main Street, Dallas, Texas 75201, or such other 

place as may be mutually agreed, within fifteen (15) days of 

service of this request upon Respondents. 

2. Respondents shall serve a written response to this 

request upon the undersigned counsel within fifteen (15) days 

of service of this request upon Respondents. 

3. For all documents withheld from production based upon 

a claim of privilege or work product immunity, Respondents 

shall state a brief description of the nature of the document, 

the person or persons creating the document, all recipients of 

the document, all persons who have seen or been permitted 

access to the document, a brief summary of the contents of the 

document, and the factual basis for the privilege or immunity 

claimed. 

4, If any document was, but is no longer, within 

Respondents's possession, custody, or control, state the 

JUDGE ENTZ'S DOCUMENT REQUEST TO OLIVER, etal. - Page 2 

 



  

disposition made of such document, including that date, method 

of, and reason for such disposition and identify, if known, 

any person now having possession, custody, or control of the 

document or a copy of the document. 

DOCUMENTS TO BE PRODUCED 
  

Respondents shall produce all documents relating to: 

1. All documents required to be identified by you in response 

to Judge Entz's written interrogatories 

2. Anything reviewed by any of your experts. 

3. The elections in Dallas County which you contend 

demonstrate racially polarized voting in Dallas County. 

4. Your claims, if any, that Blacks and Hispanics in Dallas 

County are politically cohesive. 

5. Your claims, if any, that Blacks are politically cohesive 

in Dallas County. 

6. The geographic location and racial make-up of the single 

member districts that you claim could be drawn in Dallas 

County with respect to the election of state district judges. 

7. Any statistical studies upon which you rely in support of 

any of your claims. 

8. Any statistical analysis or other analysis of elections in 

Dallas County performed by you or on your behalf in connection 

with this lawsuit. 

9. Anything prepared by any of your experts. 

10. The curriculum vitae of each of your experts. 

11. Anything submitted by you to any of your experts. 

JUDGE ENTZ'S DOCUMENT REQUEST TO OLIVER, etal. - Page 3 

 



  

RESPONSES TO REQUEST FOR PRODUCTION NOS. 1-18: 
  

Intervenor/plaintiffs will produce any and all 

documents that are germane to the responses to interrogatories 

as presently rendered or as supplemented. However, none are 

presently in existence. These responses will, of course, be 

supplemented consistent with the Rules of Discovery, Federal 

Rules of Civil Procedure. 

CERTIFICATE OF SERVICE 
  

I hereby certify that a true and correct copy of the 

foregoing instrument has been served upon counsel of record, by 

placing same in the United States Mail, postage prepaid, on this 

oll... = 
Wy 

the, I day of May, 1989. 

  

Edward B. Cloutman, III