Correspondence from Rios to Hicks Re: Supplement to Interrogatories

Correspondence
July 17, 1989

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Impact area
- Political Participation
Topic
- Voting Legislation and Constitutional Amendments
LDF Attorneys
Cooperating Attorneys
Organizations
Matter
- LULAC and Houston Lawyers Association v. Attorney General of Texas
Case
- LULAC and Houston Lawyers Association v. Attorney General of Texas
U.S. state
- Texas
Collection
- Case Files
Creator
Publisher
Taxonomy
Identifier
- f0e21cb8-247c-f011-b4cc-6045bdd81421

Cite this item

Case Files, LULAC and Houston Lawyers Association v. Attorney General of Texas Hardbacks, Briefs, and Trial Transcript. Correspondence from Rios to Hicks Re: Supplement to Interrogatories, 1989. f0e21cb8-247c-f011-b4cc-6045bdd81421. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/16a50d96-2ce0-4fac-95c4-75349ba2f30a/correspondence-from-rios-to-hicks-re-supplement-to-interrogatories. Accessed November 07, 2025.

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    ROLANDO L. RIOS 
Attorney At Law 

201 N. ST. MARY'S, SUITE 521 
SAN ANTONIO, TEXAS 78205 

512-222-2102 
512-222-0224 

LEGAL DIRECTOR 
FOR 

SOUTHWEST VOTER REGISTRATION 
EDUCATION PROJECT 

July 17, 1989 

Mr. Renea Hicks 
Special Assistant Attorney General 
P.O. Box 12548, Capitol Station 
Austin, Texas 78711-2548 

Re: LULAC #4434 et al. v. Mattox et al. 
CA-MO 88 CA 154 

Dear Mr. Hicks, 

This is a supplement to Plaintiffs’ Responses to Defendants’ First Set of 
Interrogatories and Request for Production. 

SUPPLEMENTAL RESPONSES TO INTERROGATORY #1:   

Richard Reyna 
4203 Woodcock 

Suite 103 
San Antonio, Texas 78228 

Testimony concerning socio-economic stratification in all areas at issue 
in this case. 

SUPPLEMENTAL RESPONSE TO INTERROGATORY #2: 
  

John Davis - testimony about local political realities in Jefferson County 
for minority voters and minority candidates based upon his personal 
experiences. 

SUPPLEMENTAL RESPONSE TO INTERROGATORY#4: 
  

Also, the Legislative History of Art. 5, Section 7 of the Texas Constitution. 
These documents, all public records are available at the Legislative Reference 
Library in Austin, Texas. The House Committee Coordinatory also in Austin has 
tapes of the House debates. The Senate Staff Service Office in Austin has tapes 
of the Senate debates. 

SUPPLEMENTAL RESPONSE TO INTERROGATORY_ #6 
  

Willard Pen Conrad 

15214 Riding Wood 
Houston, Texas 77489 
Precinct 2051 

 



  

Maryellen Hicks 
2444 Robert Bums Dr. 

Fort Worth, Texas 76119 

Precinct 1104 

Emest M. Deckard 
1317 N. Pegues Ave. 
Tyler, Texas 75702 
Precinct 11 

James Thomas 

1122 55th St. 
Galveston, Texas 77551 

Precinct 16 

Theodore Hogrobrooks 
1522 N. Ross 
Tyler, Texas 75702 
Precinct 13 

Gene Collins 
717 Oxford Dr. 
Odessa, Texas 79764 
Precinct 1 

Jim Conley 
127 Medford 
San Antonio, Texas 78209 
Precinct 4007 

Joan Ervin 

2806 Walnut 
Lubbock, Texas 79404 

Precinct 6 

Al Price 

3685 Blossom Dr. 
Beaumont, Texas 77705 

Precinct 85 

Volma Overton 

1403 Springdale 
Austin, Texas 78721 

Precinct 124 

Matthew Plummer 

3438 Lydia 
Houston, Texas 77021 

Precinct 31 

 



  

SUPPLEMENTAL RESPONSE TO INTERROGATORY #7: 

COUNTY #MEMBERS 
Dallas 372 
Harris 530 
Tarrant 167 

Travis 61 
Jefferson 43 

El Paso, Hudspeth, Culberson 223 
Bexar 250 

Galveston 150 

Smith 0 
Wood 0 
Lubbock 110 
Mc Clennan 58 
Ft. Bend 50 
Galveston 165 

LULAC does not record the race/ethnicity of its members or ‘their status as 
voters. 

E TORY 

Plaintiffs assume that this interrogatory addresses the GINGLES I 
requirement that the minority population "is sufficiently large and 
geographically compact to constitute a majority in a single-member district.” 
For this purpose, in each area at issue in this case, according to present 5th 
Circuit Law, the minority population must be at least one more than fifty 
percent of the voting age population in at least one district. If this 
interrogatory addresses remedy, Plaintiffs will respond when and if this case 
proceeds to the remedy stage. 

  

The at-large system in the El Paso County illegally dilutes minority 
voting strength as does the at-large system in the El Paso, Hudspeth, and 
Culberson three county area. 

  

Rolando L. Rios 

Attorney at Law 
cc: Council of Record 

 



  

CERTIFICATE OF SERVICE 

WILLIAM L. GARRETT 
BRENDA HULL THOMPSON 
Garrett, Thompson & Chang 
8300 Douglas, Suite 800 
Dallas, Texas 75225 

JULIUS L. CHAMBERS 
SHERRILYN A. IFILL 
NAACP Legal Defense & Educational 

Fund, Inc. 

99 Hudson Street, 16th Floor 

New York, N.Y. 10013 

SUSAN FINKELSTEIN 
Texas Rural Legal Aid, Inc. 
201 N. St. Mary's, Suite 600 
San Antonio, Texas 78205 

EDWARD B. CLOUTMAN, III 
Mullinax, Wells, Baab & Cloutman, P.C. 

3301 Elm 

Dallas, Texas 75226-9222 

GABRIELLE K. McDONALD 
Matthews & Bramscomb 
301 Congress Ave., Suite 2050 
Austin, Texas 78701 

I hereby certify that on the 17th day of July, 1989, a true and correct copy of 
the above and foregoing document was served upon counsel of record in this: 
case by first class United States mail, postage prepaid, addressed as follows: 

J. EUGENE CLEMENTS 
JOHN E. O'NEILL 
EVELYN V.KEYS 
PORTER & CLEMENTS 
700 Louisiana, Suite 3500 
Houston, Texas 77002-2730 

MICHAEL J. WOOD 
Attorney at Law 
440 Louisiana, Suite 200 
Houston, Texas 77002 

DARRELL SMITH, Esq. 

10999IH-10, 
Suite 905 
San Antonio, Tx. 78230 

ROBERT H. MOW, Jr. 
Hughes & Luce 
2800 Momentum Place 
1717 Main Street 

Dallas, Texas 75201 

RENEA HICKS 
Spec. Assistant Attorney 
General 
P.O. Box 12548 
Austin,/Tekas 78701 

i wy ir { ¥ 
  

ROLANDO L. RIOS 
Attorney for Plaintiffs

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Correspondence from Rios to Hicks Re: Supplement to Interrogatories

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