Plaintiffs' Motion for Correction of Clerical Errors; Proposed Order to Correct Errors

Public Court Documents
December 27, 1989

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Plaintiffs' Motion for Correction of Clerical Errors; Proposed Order to Correct Errors preview

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Includes Correspondence from Finkelstein to Clerk; Envelope to Ifill.

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
- 6487cfea-247c-f011-b4cc-6045bdd81421

Cite this item

Case Files, LULAC and Houston Lawyers Association v. Attorney General of Texas Hardbacks, Briefs, and Trial Transcript. Plaintiffs' Motion for Correction of Clerical Errors; Proposed Order to Correct Errors, 1989. 6487cfea-247c-f011-b4cc-6045bdd81421. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/3f8de289-ddb7-42dc-82cb-caa4aaabbb19/plaintiffs-motion-for-correction-of-clerical-errors-proposed-order-to-correct-errors. Accessed November 09, 2025.

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    LAW OFFICES OF 

TEXAS RURAL LEGAL AID, INC. 
201 NORTH ST. MARY'S ST.. SUITE 600 

SAN ANTONIO. TEXAS 78205 

(512) 222-2478 

  

December 27, 1989 

John D. Neil 

United States Courthouse 

200 East Wall Street 

Midland, Texas 79702 

Re: LULAC et al v Mattox et al 
Civil Action No. Mo-88-CA-154 
  

Dear Mr. Neil: 

I am enclosing an original and two copies of Plaintiffs' Motion for 
Correction of Clerical Errors and the accompanying proposed order. 
Could you please file them at your convenience? 

Also, could you please mark one of the copies with your file mark 
and return it to me in the enclosed return envelope? 

In advance, thank you for your help. 

Sincerely yours, 
2 

! 

: i / 

eo ACL r— | tbe te 
Susan Finkelstein 
Staff Attorney 

federal express 

XC: all counsel of record (certified) 

 



  

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

MIDLAND-ODESSA DIVISION 

LULAC, et al., 

Plaintiffs, 

vs, NO. MO-88-CA-154 

MATTOX, et al., 

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Defendants. 

PLAINTIFFS’ MOTION FOR CORRECTION OF CLERICAL ERRORS 

TO THE HONORABLE COURT: 

i. in accordance with F.R.Civ.P. 60, Plaintiffs respectfully 

request that the Court make the following corrections of clerical 

mistakes in its Memorandum Opinion and Order of November 8, 1989: 

2. On page 12, Plaintiffs request that the Opinion note that 

Jesse Oliver, a Black from Dallas, testified that he is a member 

of LULAC. Plaintiffs request this finding to Clarify that LULAC 

has standing to make claims on behalf of Blacks in Dallas County, 

despite Defendant-intervenor Entz’ assertion to the contrary. 

3: On page 17-8, the Opinion discusses the "Gingles 1" 
  

district of Hispanics in Travis County. The Opinion does not 

mention that it is possible to draw an appropriate. district in 

which Hispanics of voting age form a majority even if undocumented 

Hispanics are removed from consideration. Plaintiffs request that 

 



  

the following sentence be added to the end of the second complete 

paragraph of Paragraph 11, on page 18: "This remains true when 

Plaintiffs controlled for voting age population of non-United 

States citizens of Spanish origin." 

THEREFORE, Plaintiffs respectfully request that the Court make 

these corrections in its Order of November 8, 1989. 

Respectfully submitted: 

GARRETT, THOMPSON & CHANG 

ATTORNEYS AT LAW 

A Partnership of Professional 
Corporations 

William L. Garrett 

Brenda Hull Thompson 

8300 Douglas #800 
Dallas, Texas 75225 

(214) 369-1952 

LEAD COUNSEL 

ROLANDO L. RIOS 

ATTORNEY AT LAW 

201" N., St. Mary's #521 
San Antonio, Texas 78205 

(512)Y222-2102 

SUSAN FINKELSTEIN 

STAFF ATTORNEY 

TEXAS RURAL LEGAL AID, INC. 

201 N, St. Mary's #600 

San Antonio, Texas 78205 

(512) 222-2478 

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BY: ot Le IP 

/ ATTORNEY FOR PLAINTIFFS 
  

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IN THE UNITED STATES DISTRICT COURT 

FOR THE WESTERN ISTRICT OF TEXAS 

MIDLAND-ODESSA DIVISION 

LULAC, et al., 

Plaintiffs, 

NO. MO-88-CA-154 vs. 

MATTOX, et al., 

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Defendants. 

ORDER TO CORRECT CLERICAL ERRORS 

1. ln accordance with P.R.Civ.P. 60, the Court makes the 

following corrections of clerical mistakes in its Memorandum 

Opinion and Order of November 8, 1989: 

2. On page 12, the following sentence is added to Paragraph 

23 "Jesse Oliver, a Black from Dallas, testified that he is a 

member of LULAC." 

3. On page 18, the following sentence is added to the end 

of the second complete paragraph of Paragraph 11: "This remains 

true when Plaintiffs controlled for voting age population of non- 

United States citizens of Spanish origin." 

Done this day of : 
  

  

At Midland, Texas. 
  

  

UNITED STATES DISTRICT JUDGE 

 



  

CERTIFICATE OF SERVICE 
  

I, Susan Finkelstein, do hereby certify that a true and 

correct copy of Plaintiffs’ Motion for Correction of Clerical 

Errors has been mailed via first class mail, certified, to: 

  

  

  

ATTORNEY REPRESENTING 

Plaintiff - Intervenors 

Edward B. Cloutman, III Jesse Oliver 
MULLINAX, WELLS, BAAB & Joan Winn White 

CLOUTMAN, P. C. Fred Tinsley 
3301 Elm 

Dallas, TX 75226-9222 

214/939-9222 FAX: 214/939-9229 

E. Brice Cunningham Jesse Oliver 
Attorney at Law Joan Winn White 
777 8. R. L. Thornton Fwy, Suite 121 Fred Tinsley 
Dallas, TX 75203 

214/428-3793 

Julius Levonne Chambers Houston Lawyers Assn. 
Sherrilyn A, Ifill Francis Williams 
NAACP Legal Defense & Educational Rev. William Lawson 

Fund, Inc. 

99 Hudson St., 16th floor 

New York, NY 10013 

212/219-1900 

Gabrielle K. McDonald Houston Lawyers Assn. 
MATTHEWS & BRANSCOMB Francis Williams 
301 Congress Ave., Suite 2050 Rev. William Lawson 
Austin, TX 78701 Texas Legislative 
512/320-5055 Black Caucus 

 



  

Defendants 
  

Jim Mattox 

Mary F. Keller 

Renea Hicks 

Javier Guajardo 

Attorney General’s Office 
P., O. Boxi12548 

Austin, TX 78711 

512/463-2085 

Defendant-Intervenors 
  

J. Eugene Clements 

E. O'Neill 

Evelyn V. Keys 

PORTER & CLEMENTS 

700 Louisiana, Suite 3500 
Houston, TX 77002-2730 

713/226-0600 

Darrell Smith 

Attorney at Law 

10999 Interstate Highway 10, 
Suite 905 

San Antonio, TX 78230 

512/641-9944 

Michael J. Wood 

Attorney at Law 

440 Louisiana, Suite 200 

Houston, TX 77002 

713/228-5105 

Mark H. Dettman 

County Attorney 

P.O. Box .2559 

Midland, TX 79702 

915/688-1084 

All Defendants 

Judge Sharolyn Wood 

of Harris County 

Judge Sharolyn Wood 

of Harris County 

Judge Sharolyn Wood 

of Harris County 

Midland County & 

District Judges 

 



  

Ken Oden Travis County District 
Travis County Attorney Judges 
P., O.,: Box 1748 

Austin, TX 78767 

512/473-9415 

David R. Richards Travis County District 
Special Counsel Judges 
600 W. 7th St. 

Austin, TX 178701 

Robert H. Mow, Jr. Judge Harold Entz 
HUGHES & LUCE of Dallas County 
2800 Momentum Place 
1717 Main St. 

Pallas, TX 75201 

214/939-5500 

each at the correct address on this 27th day of December, 1989. 

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/ ATTORNEY FOR PLAINTIFF 

 



   

    

CERTIFIE       ! re I - 13h CL 3E Jab 
All NG. : AL 

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Sherrilyn Ifi11 

BE SOR 
NAACP Legal Defense Fund 

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99 Hudson, 16th floor New York, Ny 10013

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Plaintiffs' Motion for Correction of Clerical Errors; Proposed Order to Correct Errors

Impact area

Topic

LDF Attorneys

Cooperating Attorneys

Organizations

Matter

Case

U.S. state

Collection

Creator

Publisher

Taxonomy

Identifier

Cite this item

Copyright notice

Additional info

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