Defendant Judge Wood's First Set of Interrogatories and Requests for Production of Documents to Representatives Evans and Thompson

    THE UNITED STATES DISTRICT COURT 
THE WESTERN DISTRICT OF TEXAS 

MIDLAND-ODESSA DIVISION 

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

Plaintiffs, 

Vv. NO. MO-88-CA-154 

JIM MATTOX, et al., 

Defendants. 

DEFENDANT HARRIS COUNTY DISTRICT JUDGE SHAROLYN WOOD'S FIRST 

SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS 
TO REPRESENTATIVES LARRY Q. EVANS AND SENPHRONIA A. THOMPSON 

  

  

  

TO: .Larry Q.. Evans, by and through his attorney of record, 
Gabrielle K. McDonald, Esg., Matthews & Branscomb, 301 

Congress Ave., Suite 2050, Austin, Texas 78701 

Senphronia A. Thompson, by and through her attorney of 
record, Gabrielle K. McDonald, Esqg., Matthews & Branscomb, 

301 Congress Ave., Suite 2050, Austin, Texas 78701 

In accordance with the provisions of Rules 33 and 34 of the 

Federal Rules of Civil Procedure, Defendant Harris County 

District Judge Sharolyn Wood submits these Interrogatories and 

Requests for Production of Documents to Representatives Larry OQ. 

Evans and Senphronia A. Thompson ("Evans and Thompson") in the 

above captioned cause of action. 

Evans and Thompson are to produce all items responsive to 

these requests at the offices of Porter & Clements, 700 

Louisiana, Suite 3500, Houston, Texas, on or before 10:00 a.m. on 

May 15, 1989. 

 



  

DEFINITIONS AND INSTRUCTIONS 
  

DEFINITIONS:   

(a) “Definition of "request": request shall mean these 

Interrogatories and Requests for Production of Documents. 
  

(b) Definition. of “document”: for purposes of this 
  

request, a document shall include any method of reducing and 
  

recording information in written form, whether a memorandum, a 

letter, a note, etc, including without limitation papers, books, 

accounts, drawings, graphs, charts, photographs, electronic or 

videotape recordings, computer disks or tapes or other forms of 

computer memory storage, and other data compilations from which 

information can be obtained and translated, if necessary, by you, 

into reasonably usable form. The term document shall also be   

understood to include any other tangible thing which constitutes 

or contains matter relevant to the subject matter of this suit. 

{c) Definition of  Midentify": for purposes of this   

request, (i) when used with reference to a person or entity, the 

term "identify", shall mean to state the full name of such person 
  

or entity and his/her/its last known address and telephone 

number; (ii) when used with reference to a document, the term   

"identify" shall mean to describe the document, its date of     

creation and the name of its author. 

{d) Definition of "oxr":. for.purposes of this request, "or" 

shall mean and/or. 

 



  

INSTRUCTIONS:   

(a) The Interrogatories which follow are to be answered 

separately and fully, in writing and under oath, signed by the 

person making said answers; a copy of your answers should be 

served on the undersigned attorneys within thirty (30) days after 

your receipt hereof. 

(b) This request applies to all documents and information 
  

within the possession, custody or control of Defendant. 

(c) Documents produced in response hereto shall be 
  

organized and designated to correspond to the categories in this 

request or produced as they are kept in the usual course of 

business. 

(d) A copy of your response to each Request for Production 

should be served on the undersigned attorneys within thirty (30) 

days after your receipt hereof. 

(e) If privilege or work product protection is claimed as a 

ground for withholding production of one or more documents in 
  

whole or in part, the response hereto shall identify the date of 

the document, its author, its subject matter, its length, its   

attachments, if any, its present custodian and all recipients 

thereof, whether indicated on the document or otherwise, and   

shall describe the factual basis for the claim of privilege or 

work product protection in sufficient detail to permit the Court 

to adjudicate the validity of the claim of privilege or protec- 

tion. 

 



  

(f) In the event that a document called for by this request 
  

has been destroyed, the response hereto shall identify the 

preparer of the document, its addressor (if different),   

addressee, each recipient thereof, each person to whom distribut- 

ed or shown, date prepared, date transmitted (if different), date 

received, a description of its contents and subject matter, the 

date of its destruction, the manner of its destruction, the name, 

title and address of the person authorizing its destruction, and 

the reason(s) for its destruction, the name, title and address of 

the person destroying the document and a description of efforts   

to locate the document or recording and copies of it. 

{(g) This request: shall be deemed to be continuing so ‘as to 

require supplemental response in accordance with Rule 26(e) of 

the Federal Rules of Civil Procedure. 

INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS 
  

Interrogatory No. 1: 
  

If you claim +hat’ Blacks and Hispanics are politically 

cohesive in Harris County, please state the factual bases for 

such a claim. 

Request for Production No. 1: 
  

Produce for inspection and copying all documents that   

support or otherwise relate or pertain to your answer to Inter- 

rogatory No. 1. 

Interrogatory No. 2: 
  

If« you claim that voting in Harris County is racially 

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



Request for Production No. 2: 
  

Produce for inspection and copying all documents that 
  

support or otherwise relate or pertain to your answer to Inter- 

rogatory No. 2. 

Interrogatory No. 3: 
  

Identify every Harris County election you have analyzed, 

describing fully your method of analysis, and the results of such 

analysis. 

Request for Production No. 3: 
  

Produce for inspection and copying all documents that 
  

support or otherwise relate or pertain to your answer to Inter- 

rogatory No. 3. 

Interrogatory No. 4: 
  

ldentify every candidate for public office in Harris County 

whom you have 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 preferred candidate. 

Request for Production No. 4: 
  

Produce for inspection and copying all documents that 
  

support or otherwise relate or pertain to your answer to Inter- 

rogatory No. 4. 

Interrogatory No. 5: 
  

Identify every factor and circumstance present in Harris 

County with respect to the political processes leading to the  



  

nomination or election of candidates to public office in Harris 

County that you claim is not equally open to participation by 

minorities and that you claim gives minorities less opportunity 

than other members of the electorate to participate in the 

political process and to elect representatives of their choice. 

Interrogatory No. 6: 
  

If you claim that any part of the established system in 

Harris County for electing state district judges dilutes minority 

voting strength, state the factual bases for your claim, if any, 

that the reasons for adopting such a system are tenuous. 

Request for Production No. 5: 
  

Produce for inspection and copying all documents that 
  

support or otherwise relate or pertain to your answer to Inter- 

rogatory No. 6. 

Interrogatory No, 7: 
  

If you claim that the system of electing state district 

judges in Harris County is intentionally designed to discriminate 

against minorities, please state the factual bases for such a 

claim. 

Request for Production No. 6: 
  

Produce for inspection and copying all documents that 
  

support or otherwise relate or pertain to your answer to Inter- 

rogatory No. 7. 

 



  

Interrogatory No. 8: 
  

If you claim that minorities in Harris County have been 

denied access to a candidate slating process, please state the 

factual bases for such a claim. 

Request for Production No. 7: 
  

Produce for inspection and copying all documents that 
  

support or otherwise relate or pertain to your answer to Inter- 

rogatory No. 8. 

Interrogatory No. 9: 
  

If you claim that Blacks and Hispanics in Harris County are 

hindered in their ability to participate effectively in the 

political process, state your factual bases for such a claim. 

Request for Production No. 8: 
  

Produce for inspection and copying all documents that 
  

support or otherwise relate or pertain to your answer to Inter- 

rogatory No. 9. 

Interrogatory No. 10: 
  

If you claim that political campaigns in Harris County have 

been characterized by overt or subtle racial appeals, state your 

factual bases for such a claim. 

Request for Production No. 9: 
  

Produce for inspection and copying all documents that 
  

support or otherwise relate or pertain to your answer to Inter- 

rogatory No. 10. 

 



  

Interrogatory No. 11: 
  

If you claim that there is a significant lack of responsive- 

ness on the part of the elected judges in Harris County to the 

particularized needs of Blacks and Hispanics, state your factual 

bases for such a claim. 

Request for Production No. 10: 
  

Produce for inspection and copying all documents that 
  

support or otherwise relate or pertain to your answer to Inter- 

rogatory No. 11. 

Interrogatory No. 12: 
  

Describe the location and population of each and every 

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

Harris County with respect to electing state district judges. 

Request for Production No. 11: 
  

Produce for inspection and copying all documents that 
  

support or otherwise relate or pertain to your answer to Inter- 

rogatory No. 12. 

Interrogatory No. 13: 
  

With respect to your answer to Interrogatory No. 12, state 

the percentage of Anglo, Black, and Hispanic members of the 

voting age population in each such district. 

Request for Production No. 12: 
  

Produce for inspection and copying all documents that 
  

support or otherwise relate or pertain to your answer to Inter- 

rogatory No. 13. 

 



  

Interrogatory No. 14: 
  

If you claim that Hispanics in Harris County are politically 

cohesive, state the factual bases for such a claim. 

Interrogatory No. 15: 
  

If you claim that white voters in Harris County vote as a 

bloc usually to defeat your preferred candidates, state the 

factual bases for such a claim. 

Request for Production No. 13: 
  

Produce for inspection and copying all documents that 
  

support or otherwise relate or pertain to your answer to Inter- 

rogatory No. ‘15. 

Interrogatory No. 16: 
  

Describe with specificity the method you believe should be 

used to determine the size and location of state judicial 

election districts in Harris County, including the limits of any 

acceptable deviations from the ideal. 

Interrogatory No. 17: 
  

Describe with specificity how, under the system you 

envision, specialized courts would continue to coexist con- 

currently with single member districts drawn on racial lines. 

Interrogatory No. 18: 
  

Identify every report or study regarding election results or   

voting patterns in Texas or Harris County which you or any 

plaintiff or plaintiff-intervenor in this case have commissioned 

or received at any time. 

 



  

Request for Production No. 14: 
  

Produce for inspection and copying all documents that   

support or otherwise relate or pertain to your answer to Inter- 

rogatory No. 18. 

  

     

  

J. [Eugene Clements 
Attorney in Charge for 

rris County District Judge 
Sharolyn Wood 

Porter & Clements 
700 Louisiana, Suite 3500 
Houston, Texas 77002-2730 

(713) 226-0600 
OF COUNSEL: 

PORTER & CLEMENTS 

John E. O'Neill 
Evelyn V. Keyes 
700 Louisiana, Suite 3500 

Houston, Texas 77002-2730 

(713) 226-0600 

- 10 - 

 



  

CERTIFICATE OF SERVICE 
  

I hereby certify that on this VALS day of April, 1989 a 
true and correct copy of the above and foregoing document was 
mailed to counsel of record in this case by first class United 
States mail, postage pre-paid, addressed as follows: 

William L. Garrett, Esq. 
Brenda Hall Thompson, Esq. 
Garrett, Thompson & Chang 
Attorneys at Law 

8300 Douglas, Suite 800 
Dallas, Texas 75225 

Rolando L. Rios, Esq. 
Southwest Voter Registration & 

Education Project 
201 N. St. Mary's, Suite 221 
San Antonio, Texas 78205 

Susan Finkelstein, Esq. 
Texas Rural Legal Aid, Inc. 
201 N. St. Mary's, Suite 600 
San Antonio, Texas 78205 

Julius Levonne Chambers, Esq. 
Sherrilyn A. Ifill, Esq. 
NAACP Legal Defense and Educational Fund, Inc. 
99 Hudson Street 
16th Floor 
New York, New York 10013 

Gabrielle K. McDonald, Esq. 
Matthews & Branscomb 
301 Congress, Avenue 
Suite 2050 
Austin, Texas 78701 

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

Edward B. Bloutman, III, Esq. 
Mullinax, Wells, Baab & Cloutman, P.C. 

3301 Elm Street 

Dallas, Texas 75226-1637 

il] - 

 



  

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

Ken Oden, Esq. 
Travis County Attorney 
P. OO. Box 174% 
Austin, Texas 78767 

David R. Richards, Esq. 
Special Counsel 
600 W. 7th Street 
Austin, Texas 78701 

Mark H. Dettman 

Attorney at Law 

P-. 0. Box 2559 
Midland, Texas 79702 

Evelyn V. Keys 
  

WO0001/22/cdf 

LD