Notice of Oral Deposition and Request for Documents to Williams

    THE UNITED STATES DISTRICT COURT 
THE WESTERN DISTRICT OF TEXAS 

MIDLAND-ODESSA DIVISION 

LEAGUE OF UNITED LATIN AMERICAN 
CITIZENS (LULAC), et al. 

JIM MATTOX, Attorney General 

§ 

§ 

S 
V. § NO. MO-88-CA-154 

S 

S 
of the State of Texas, et al. § 

NOTICE OF ORAL DEPOSITION AND REQUEST FOR DOCUMENTS 
  

T0: Francis Williams, by and through his attorney of record, 
Sherrilyn A. Ifill, Esqg., NAACP Legal Defense and Education 
Fund, Inc., 99 Hudson Street, 16th Floor, New York, New York 

10013 

Please take notice that Defendant/Intervenor Harris County 

District Judge Sharolyn Wood will take the oral deposition of 

Plaintiff/Intervenor Francis Williams at 9:00 a.m. on August 30, 

1989, at the offices of Porter & Clements, 700 Louisiana, Suite 

3500, Houston, Texas 77002, before an officer authorized to 

administer oaths and pursuant to Federal Rules of Civil Procedure 

30(a) and 30(b) (1). Pursuant to Federal Rule of Civil Procedure 

30(b) (5), the witness shall produce for inspection and copying at 

the time of the taking of his deposition the documents and things 

designated in Exhibit "1" attached hereto. Counsel are invited 

to attend and to cross-examine should they so desire. 

DEFINITION OF DOCUMENTS: 
  

The term "document" means every writing or record of any 

type and description that is in your possession, control, or 

custody, including without limitation, checks, correspondence, 

memoranda, stenographic or handwritten notes, drafts, accounts, 

 



  

voice recordings, reports, statistical compilations, work papers, 

data processing cards, computer tapes or printouts, or any other 

writing or recordings of any kind. The term "documents" also 

includes every copy of a writing or record which contains any 

commentary or notation or any kind which does not appear on the 

original or any other copy. A document is deemed to be within 

your "control" if you have ownership, possession, or custody of 

the document or a copy thereof, or the right to secure the 

document or a copy thereof from any ‘other person or public or 

private entity having physical possession thereof. 

PORTER & CLEMENTS 
r= 

YU. Eugene Clements 
‘700 Louisiana, Suite 3500 

— ’Houston, Texas 77002-2730 

(713) 226-0600 

  

  

0 gn ri 

Byi=2icl NZ ln 

Darrell Smith =. 
Attorney at Law $ 
10999 Interstate Hwy. 10, #905 
San Antonio, Texas 78230 

(512) 641-9944 

  

( 

ATTORNEYS FOR HARRIS COUNTY 
DISTRICT JUDGE SHAROLYN WOOD 

OF COUNSEL: 

PORTER & CLEMENTS 
John E. O'Neill 
Evelyn V. Keyes 
700 Louisiana, Suite 3500 
Houston, Texas 77002-2730 

(713) 226-0600 

Michael J. Wood 

Attorney at Law 

440 Louisiana, Suite 200 
Houston, Texas 77002 

{713) 228-5105 

 



  

CERTIFICATE OF SERVICE 
  

I hereby certify that on the | 744 day of August, 1989, a 
true and correct copy of the above and foregoing Notice of Oral 
Deposition and Request for Documents was served upon counsel of 
record in this case by first class United States mail, postage 
prepaid, addressed as follows: 

Mr. William L. Garrett 
Ms. Brenda Hall Thompson 
Garrett, Thompson & Chang 
Attorneys at Law 
8300 Douglas, Suite 800 
Dallas, Texas 75225 

Mr. Rolando L. Rios 
Southwest Voter Registration & 

Education Project 
201 NN. St. Mary's, Suite 521 
San Antonio, Texas 78205 

Ms. Susan Finkelstein 

Texas Rural Legal Aid, Inc. 

201 N. St. Mary's, Suite 600 

San Antonio, Texas 78205 

Mr. Julius Levonne Chambers 
Ms. Sherrilyn A. Ifill 
NAACP Legal Defense and Educational Fund, Inc. 

99 Hudson Street 

16th Floor 

New York, New York 10013 

Ms. Gabrielle K. McDonald 

Matthews & Branscomb 

301 Congress Ave., Suite 2050 
Austin, Texas 78701 

Mr. Jim Mattox, Attorney General of Texas 

Ms. Mary F. Keller, First Assistant Attorney General 
Ms. Renea Hicks, Spec. Assistant Attorney General 
Mr. Javier Guajardo, Spec. Assistant Attorney General 
P. O. Box 12548 
Capitol Station 
Austin, Texas 78701 

Mr. Edward B. Cloutman, III 

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

Dallas, Texas 75226-1637 

 



Mr. E. Brice Cunningham 
777 So. R.L. Thornton Freeway 
Suite 121 
Dallas, Texas 75203 

Mr. Ken Oden 
Travis County Attorney 
P. O. Box 1748 
Austin, Texas 78767 

Mr. David R. Richards 

Special Counsel 
600 W. 7th Street 

Austin, Texas 78701 

Mr. Mark H. Dettman 

Attorney at Law 

P. O. Box 2559 

Midland, Texas 79702 

Mr. Robert H. Mow, Jr. 

Hughes & Luce 
2800 Momentum Place 

1717 Main Street 

Dallas, Texas 75201 

V. ey 
  

Evelyn V. Keyes 

WO002/53/cdf  



EXHIBIT NO. 1 
  

DOCUMENTS, FILES AND THINGS TO BE PRODUCED BY FRANCIS WILLIAMS 
  

1. All campaign contributions and expenditure reports for each 
race in which you have run as a candidate. 

All literature or other documents that reflect, refer, or 

pertain to any appeal to racism in any judicial race in 
Harris County. 

All documents that refer, relate or pertain to any plan or 
map that you propose to remedy any alleged discrimination 
against minorities in Harris County. 

All campaign literature that you have used in each race in 
which you have run as a candidate. 

All newspaper clippings, endorsements, campaign memorabilia, 
and similar materials that relate, refer, or pertain to each 
race in which you have run as a candidate.