Judge Wood's Objection to Request for Judicial Notice; Hardy Deposition Summary; Wood's Supplement to Exhibit List; Wood's List of Exhibits

    PORTER & CLEMENTS 
FIRST REPUBLICBANK CENTER 

700 LOUISIANA, SUITE 3500 

HOUSTON, TEXAS 77002-2730 

ATTORNEYS   
A PARTNERSHIP INCLUDING 

PROFESSIONAL CORPORATIONS 

EVELYN V. KEYES 

TELEPHONE (713) 226-0600 

TELECOPIER (713) 228-1331 

TELECOPIER (713) 224-4835 

TELEX 775-348 
(713) 226-0611 

September 15, 1989 

VIA FEDERAL EXPRESS 

Mr. John Neil 

Clerk, U.5. District Court 

200 E."Wall St., Suite 316 
Midland, Texas 79702 

  

Re: No, MO88-CA-154; League of United Latin American 
Citizens (LULAC), "et al. 'v. James Mattox, Attorney 
General of Texas, et al.; In the United States District 
Court for the Western District of Texas, Midland-Odessa 
Division 

Dear Sir: 

Enclosed for filing in the above-referenced case are the 
following: 

1. Harris County District Judge Sharolyn Wood's Objections to 
Request for Judicial Notice; and 

. Deposition Summary of Ray Hardy. 

3. Defendant Wood's Supplement to Her Exhibit List. 

Please return a file stamped copy of these document in the 
enveloped provided. 

A copy of this filing is being served on counsel of record 
either by Federal Express or by first class mail, postage 
prepaid. 

Sincerely yours, 

Lolo Ve dict 
Evelyn V. Keyes 

EVK/cdf 
enclosures 

cor Mr... William I... Garrett 
Ms. Brenda Hall Thompson 
Garrett, Thompson & Chang 
Attorneys at Law 

8300 Douglas, Suite 800 
Dallas, Texas - 75225 

 



   
» 

  

*y 

PorRTER & CLEMENTS 

Clerk, U.S. District Court 
September 15, 1989 
Page -2- 

CC: Mr. Rolando L. Rios 
Southwest Voter Registration & 

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

Ms. Susan Finkelstein 
Texas Rural legal Aid, Inc. 
201 NN. St. Mary's, Suite 800 
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 112548 
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. Robert H. Mow, Jr. 

Hughes & Luce 
2800 Momentum Place 

1717 Main Street 

Dallas, Texas 75201 

  

WO003/A 

 



    

THE UNITED STATES DISTRICT COURT 
THE WESTERN DISTRICT OF TEXAS 

MIDLAND-ODESSA DIVISION 

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

V. NO. MO-88-CA-154 

JIM MATTOX, Attorney General 
of the State of Texas, et al. N

D
 

Wh
 
W
h
 

Wh
 

HARRIS COUNTY DISTRICT JUDGE SHAROLYN WOOD'S 
OBJECTIONS TO REQUEST FOR JUDICIAL NOTICE 
  

  

Like Defendant/Intervenor Judge Entz, Defendant/Intervenor 

Judge Wood objects to the requests for Judicial notice by 

Plaintiffs and Plaintiff/Intervenors for the following reasons: 

1. Plaintiffs and Plaintiff/Intervenors for Harris County 

have requested the Court to take judicial notice of certain cases 

and Department of Justice letters. It is unclear from the 

Requests whether they are requesting the Court to take notice of 

the existence of the referenced letters and cases, or to take 

judicial notice of the factual conclusions and findings reflected 

in the letters and cases. 

2. In the event that Plaintiffs and Plaintiff/Intervenors 

simply desire the Court to take notice of the existence of the 

letters and cases (i.e., that the letters exist and that the 

copies attached are correct copies of the actual letter), then 

Judge Wood does not object to that form of judicial notice. 

 



    

3. In ‘the alternative, if Plaintiffs and Plaintiff/ 

Intervenors want the Court in this action to take judicial notice 

of all of the factual conclusions reflected in the letters and 

cases as being applicable factual conclusions in the context of 

this case, then Judge Wood most strongly objects to such judicial 

notice and requests a hearing on this issue, as required by Fed. 

R. Evid. 201 (e). 

4. With regard to the cases, Judge Wood was not a party to 

the earlier actions and cannot be bound by findings in them. 

More significantly, even were those facts correct at the time, 

there is no indication that they are pertinent to judicial races 

or to the present time frame. Finally, court opinions per se are 

not adjudicative facts, but are legislative facts outside the 

scope of Rule 201. 

5. With respect to the Department of Justice letters, they 

do not on their face explain what was done to investigate the 

allegations they discuss and they certainly do not reflect the 

kind of fact contemplated by Rule 201(b) for notice. Even were 

they proper evidence (which Judge Wood does not concede), they 

would not conclusively establish the factual conclusions. In 

effect, that is what Plaintiffs and Plaintiff/Intervenors are 

asking the Court to do through the guise of judicial notice. 

6. Accordingly, Judge Wood objects to Plaintiffs' and 

Plaintiff/Intervenors' request for judicial notice and urges the 

Court to deny that request. 

 



  

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 

(713) 228-5105 

77002 

  

Respectfully submitted, 

PORTER & CLEMENTS 

    

     J} Eugene Clements 
P/O. Box 4744 

ouston, Texas 

(713) 226-0600 

spctiine l Son tC 

Darrell Smith 

    

77210-4744 

  

A   Attorney at L 

10999 Intersta vw 10, #905 
San Antonio, Te 8230 
(512) 641-9944 

ATTORNEYS FOR HARRIS COUNTY 
DISTRICT JUDGE SHAROLYN WOOD 

 



    

CERTIFICATE OF SERVICE 
  

I hereby certify that on the 15th day of September, 1989, a 
true and correct copy of the above and foregoing Harris County 
District Judge Sharolyn Wood's Objections to Request for Judicial 
Notice was served upon counsel of record in this case either by 
Federal Express or by first class United States mail, postage 
prepaid, 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 N, 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 
Supreme Court Building, 7th Floor 
1401 Colorado Street 
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 Frwy., Suite 121 
Dallas, Texas 75203 

Mr. Robert H. Mow, Jr. 

Hughes & Luce 
2800 Momentum Place 

1717 Main Street 
Dallas, Texas 75201 

  

Evelyn V. Keyes 

WO004/21/cdf 

 



  

Page 

10 

  

DEPOSITION SUMMARY OF RAY HARDY 7/26/89 
  

Description 
  

EXAMINATION BY MR. CLEMENTS: 

Hardy Exhibit - Deposition subpoena. 

The witness attended Sam Houston State Teachers College. 
Upon leaving college in 1946, he went to Carpenters Paper 
Company for a short period of time and has been employed 
in Harris County since 1949, starting as Deputy District 
Clerk. He was appointed District Clerk in 1967 and has 
been elected continuously since that time. 

The district clerk is the records manager for all the 
courts in Harris County, including District Courts, 
County Criminal Courts at law, family trial division 
district courts, criminal district courts and juvenile 
trial division district courts. He is also jury manager. 
There are now 59 district courts in Harris County. 

Hardy believes that there are 25 district courts in 
Harris County that are on the civil trial division. He 
believes 23 are assigned to the criminal trials, 3 
juvenile and 9 family law courts. These courts have been 
specialized either by legislative action or by their own 
informal arrangement for as long as Hardy can remember 
since he has been in the District Clerk's office. 

Each numbered district court in Harris County has only 
one judge for that particular specific designation, with 
the exception of visiting judges who serve from time to 
time. 

Each of the 59 district courts has a different number and 
only one judge. Each judge is elected from a district 
that extends to the boundaries of Harris County. No 
district court judges in Harris County are elected in any 
geographical district smaller than the county. Harris 
County district judges have been elected from districts 
coextensive with the county as long as Hardy can 
remember. 

 



  

Page 

15 

16 

17 

18 

  

Description 
  

In the 40 years the witness has been with the District 
Clerk's office he has occasionally observed tinges of 
racism or ethnic discrimination but none that over- 
shadowed the electoral process. 

For the last 15 years, witness is aware of no incidents 
in which the ethnic or background of the candidate for 
judge has been a factor in an election and in his opinion 
the racial or ethnic background of candidates has not 
been a factor. 

During that time both blacks and Hispanics have been 
elected as civil district judges in Harris County. 

Witness has never observed within the administration of 
the court system any bias or discrimination against 
sitting judges who were either black or Hispanic or other 
minority or ethnic background. He is not aware of any 
official or unofficial discrimination between judges 
based on their racial or ethnic background. 

Lawsuits are filed in Harris county by bringing the 
lawsuit to the central intake division where it is filed 
randomly into one of the courts. 

Witness is generally familiar with the venue laws enacted 
by the state legislature as it pertains to the district 
court's function. Those venue laws govern which county 
within the state is the proper venue for a suit to be 
brought. 

There has never been any differentiation made by the 
venue within Harris County of the plaintiff who is 
bringing a lawsuit or a group of plaintiffs bringing a 
lawsuit. 

The jury pool is selected from all registered voters in 
Harris County. The pool is assigned to specific jury 
panels for service in specific district courts by a 
random number generator. 

The random selected group is called in the order in which 
they appear on the list as a court ‘calls for a jury 
panel, A central jury facility is used, 

Witness believes that it is important to have random 
assignment of jury panels to make sure that the makeup of 

 



  

Page 

19 

21 

23 

24 

  

Description 
  

the county is represented by that panel that's presented 
to the court. 

Random assignment is important to avoid forum shopping 
and to preclude cases going to any particular court other 
than by chance. 

The civil trial division assigns a number to the case as 
it's filed and assigns a court to it based on the random 
selection at that time. That file is maintained in the 
civil district courts, as opposed to the criminal cases 
which are maintained in a central file bank. 

It 1s important to the computerization, the record- 
keeping, and the maintenance of pending cases that all of 
the courts be centrally located and easily acceptable to 
the District Clerk's office. To do otherwise would 
create havoc to the maintenance of files for these 
courts. It would fragment it and fragment the public's 
access to the records. 

One of witness's functions is as the county statistician 
with respect to its judicial records. It facilitates the 
district clerk's offices functioning to have centralized 
files and centralized access to court records. 

Witness believes that the creation of 59 individual 
geographical distinct district courts within Harris 
County would impact his office's function. 

If the records were isolated to a particular area of the 
county, that would create a fragmentation of the record 
system and the ability of the public to determine where 
cases are pending. Witness believes it would create 
venue problems as when an event occurred in a certain 
location and the residences of the people are in another 
location. Witness also believes it would create tremen- 
dous expense to the county and possibly be divisive to 
the litigation itself. 

Since we are still on a manual system, the creation of 
smaller geographical districts accompanied by the right 
of a plaintiff to bring his suit in the smaller geograph- 
ical district in which he resides and would, in effect, 
require setting up 59 different district clerks' office 
to handling the filing of those cases in the location of 
the filing, then creating an information system that 

 



    

25 

  

Description 
  

would allow the clerks to know at all times where the 
cases are pending, who the parties are, etc. 

As things are now plaintiffs have a right to request that 
a case be tried in the count of residence. He assumes 
that same application would apply to segments within the 
county. 

If plaintiffs wanted to bring their lawsuits in the 
geographical district areas of the courts where they 
reside that would have an economic impact on the office 
because there would be considerably more litigation in 
making those decisions that would take up valuable court 
time. 

Witness believes that the creation of geographical 
districts less than countywide could result in forum 
shopping unless appropriate rules were established to 
preclude. 

If a right to venue within the part of the county where 
the plaintiff resided were accompanied by the right to a 
jury made up of people residing in the same geographical 
area served by the Court, the witness believes that the 
implications for the assignment of jury panels and 
calling of potential jurors are that it would be divisive 
for the county to have jurors set up from segments of the 
county and that it would create a budgetary drain on the 
county in that 59 different pools for jury calls would 
have to be set up. By combining the pool we have been 
able to serve the counts economically based on the number 
of courts. There would be considerably more waste in the 
number of jurors you need to call and you would have to 
overcall to compensate for long trials. They [currently] 
compensate for that by having a central panel with the 59 
judges pulling from that panel so that we can call the 
needs of the court and be assured that we have enough 
jurors there but at the same time not overcall and better 
schedule the potential jurors for the court's use. It is 
costing us now approximately $1,500 to $2,000 a year to 
provide this list to the courts and if we divide it 59 
different ways the cost would probably escalate at least 
by the number of jurisdictions added. 

The creation of 59 different mini courthouses within 
Harris County would increase the staffing requirements 
per court, wherein we now have a combination of clerks 

 



    

29 

31 

32 

33 

34 

36 

  

Description 
  

serving various courts and can minimize the actual 
requirement of personnel. The staffing for relief, for 
peak time would drastically increase the cost. 

The witness believes the administrative job of main- 
taining 59 mini courthouses with their own docket of 
pending cases in their geographical areas, their own jury 
pools, their own plaintiff/defendant index staples, and 
their own venue problems would create administrative 
problems for getting justice administered efficiently. 

You would have to have all general jurisdiction courts 
without any specialized courts unless you create special 
districts for specialized courts, otherwise the numbers 
wouldn't go around. 

The creation of 27 district courts assigned approximately 
two judges each rather than 59 districts would just be 
the lesser of two problems. 

The answer would be the same if ten judges were assigned 
to the five state senatorial districts. Again, it could 
probably create some divisiveness in the number, particu- 
larly in jury selection, as to whether you are getting a 
disparity in whites, blacks, or Hispanics within the jury 
panels themselves. 

The district clerk's office is now doing everything to 
see that there is no discrimination. In witness' 
opinion, if you were to break up the county into many 
districts along racial or ethnic lines, witness believes 
it would encourage discriminatory jury panels and 
potential jurors. 

If you assume that there are 13 or 14 inner City 
districts that are geographically distinct and that the 
balance of the 45 or 46 judges would run at large from 
the remainder of the county, the witness' conclusions 
with respect to the administrative difficulties would 
still be the same. 

EXAMINATION BY MR. TODD: 
  

Witness is a member of the County of District Clerks’ 
Association of Texas, National Association of Court 
Management and Metropolitan Courts Conference. 

 



  

41 

45 

  

Description 
  

Witness believes that the courts in other counties will 
be similarly impacted. 

If you are a black defendant accused of a crime in Harris 
County, witness believes that as the system of jury 
selection stands now, that person would have an equal 
chance of having blacks on the jury panel as whites. If 
Harris County were divided into judicial districts that 
were less than countywide and each district had its own 
jury pool, witness does not believe that a black defen- 
dant would have an equal chance of having blacks on his 
jury panel because if it's in a district that is =a 
primarily white district, all of the selection process 
would be white or basically white. 

Witness has 460 permanent deputies, with temporaries 
close to 540. 

Witness' office is funded by the county through the tax 
and fees that the office collects. From witness' experi- 
ence, if Harris County were divided into jurisdictional 
districts, each one smaller than the county, each 
district would not generate an equal amount of litigation 
and criminal prosecutions. If cases are assigned 
according to the district when the cause of action arose 
or the crime occurred, that would result in some judges 
having a lot of cases to try and some having fewer. 
Right now, the load is pretty well distributed because of 
the random filing system. 

EXAMINATION BY MS. IFILL: 

The jury pool is compiled for a list of registered voters 
in Harris County. This comes from the tax assessor/ 
collector or the voter registrar in Harris County. They 
get that list about every three years. 

The district clerk's office does not receive any informa- 
tion that relates to the race of registered voters in 
Harris County. The current system that is used to select 
jurors in Harris County has been changed from the 
original system used when the witness entered the 
District Clerk's office in 1949, which was the voter 
registration list combined with the tax rolls. 

 



    

  

Page Description 

48 The original system was changed in 1967 because trying 0 
match the rolls and eliminate duplications was a fiasco. 
The percentage of blacks currently in the pool for jury 
selection in Harris County matches the census tract. 

49 The panels match the percentage numbers from the Bureau 
of the Census. The percentage of the various ethnic 
groups presented to the court represents their proportion 
in the population. The election of district judges 
countywise has been the case since the formation of the 
state. 

52 The witness believes there are currently three black 
district judges in Harris County. He believes there are 
four Hispanic judges in Harris County. Judge Louis Moore 
is incorrectly listed in the pleadings as white. He is 
Hispanic. 

FURTHER EXAMINATION BY MR. CLEMENTS: 

53 Witness has never seen any indication at all that the 
system of having Harris County judges run countywide was 
being perpetuated in order to discriminate against the 
election of either black or Hispanic judges. He has seen 
no evidence that would indicate that having judges run 
countywise is being done with an eye toward decreasing 
the number of black or Hispanic judges. 

CJC7:18:vlc 

W0027/001 

 



    

THE UNITED STATES DISTRICT COURT 

THE WESTERN DISTRICT OF TEXAS 

MIDLAND-ODESSA DIVISION 

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

Vv. NO. MO-88-CA-154 

JIM MATTOX, Attorney General 
of the State of Texas, et al. W

D
 

WD
 
W
D
 

I
A
W
 

DEFENDANT WOOD'S SUPPLEMENT TO HER EXHIBIT LIST 
  

In reliance on the advice of the Clerk of the Court that 

depositions are not to be filed with the Court, but that narra- 

tive summaries are to be filed instead, and in compliance with 

Local Rule 300-1, Defendant-Intervenor Harris County District 

Judge Sharolyn Wood ("Judge Wood") has not heretofore filed with 

the Court the deposition excerpts and depositions she identified 

in the Pre-Trial Order and has instead provided narrative 

summaries and a list of excerpted pages and line numbers to the 

Court and to counsel for all parties. However, for purposes of 

appellate review, and because the necessity of using the 

underlying deposition transcripts can be reasonably anticipated, 

Defendant Wood supplements her Exhibit List by the addition of 

the deposition transcripts and excerpts she listed in the 

Pre-Trial Order and for which she has filed summaries. A copy of 

Defendant-Intervenor Wood's List of Exhibits as supplemented is 

attached. 

 



  

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 

  

Respectfully submitted, 

PORTER & CLEMENTS 

By: : 

J../Eugene Clements 
700 Louisiana, Suite a 
Houston, Texas 77002-2730 

(713) 226-0600 

By: on, Yow Gy Cal, 
Darrell Smith V 4 
Attorney at Law —y 
10999 Interstate Hwy. 10, #905 
San Antonio, Texas 78230 
(512) 641-9944 

  Ft te 

ATTORNEYS FOR HARRIS COUNTY 
DISTRICT JUDGE SHAROLYN WOOD 

 



    

CERTIFICATE OF SERVICE 
  

I hereby certify that on the 15th day of September, 1989, a 
true and correct copy of the above and foregoing Defendant Wood's 
Supplement to Her Exhibit List 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 N, 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. Robert H. Mow, Jr. 

Hughes & Luce 
2800 Momentum Place 

1717 Main Street 
Dallas, Texas 75201 

  
[Ces 

Evelyn V. Keyes = 

WO0004/25/cdf 

 



  

un
 

LJ 

10, 

11. 

12, 

13. 

14. 

  

DEFENDANT-INTERVENOR WOOD'S 

LIST OF EXHIBITS 
  

  

Results of Harris County General Elections (Judicial Races) 
for 1980 through 1988 

Results of Harris County Democratic Primary Elections 
(Judicial Races) for 1982 through 1988 

Houston Bar Association 1988 Judicial Preference Poll 
Results 

Houston Bar Association 1986 Judicial Preference Poll 
Results 

Houston Bar Association 1984 Judicial Preference Poll 
Results 

Houston Bar Association 1982 Judicial Preference Poll 
Results 

Houston Bar Bulletin - Results of Judicial Preference Poll, 
April 2.1980. 

Article from Houston Post dated October 22, 1983 entitled 
"Judge files suit in response to state bar panel's rep- 
rimand" 

Article from Houston City Magazine dated July 1980 entitled 
"Rating the Judges" 

Article from Houston Post dated February 7, 1978 entitled 
"Open ballot slots attract Democratic contenders for 
primary" 

State Bar of Texas - Membership Department Breakdown of 
Active Attorneys by Ethnic Origin dated February 1, 1989 

Untitled Report prepared by Richard Murray for Democratic 
judges in 1982 (Murray Exhibit 1). 

Report entitled "Election Prospects for the Houston Area 
Appellate Courts: November 1982) prepared by Richard Murray 
(Murray Exhibit 2). 

Report entitled "Judicial Contests in Harris County 1982" 
prepared by Richard Murray (Murray Exhibit 3). 

 



  

P
t
 

wl
 

* 

16. 

17% 

29, 

30. 

  

Report entitled "Judicial Elections in Harris County: A 
Review of the Judges Committee Campaign Effort" prepared by 
Richard Murray in 1986 (Murray Exhibit 4). 

Report entitled "Partisan Judicial Elections in Harris 
County, Texas" prepared by Richard Murray in 1986 (Murray 
Exhibit 5), 

Report entitled "The Selection of Judges in Texas" prepared 
by Richard Murray in March, 1989. 

Report entitled "Preliminary Campaign Suggestions" prepared 
by Richard Murray in June, 1984. 

The Hon. Mark Davidson's precinct-by-precinct analysis of 
discretionary judicial voting. 

Article from The Jewish Herald-Voice dated October 28, 1982 
entitled "Recommendations for the November 2 election”. 

Article from The Jewish Herald-Voice dated November l, 1984 
entitled "Voters' Guide" 

Article from The Jewish Herald-Voice dated October 30, 1986 
entitled "Our Endorsements in the Nov. 4 General Election" 

Article from The Jewish Herald-Voice dated November 3, 1988 
entitled "Political endorsements for your consideration" 

Articles from The Houston Chronicle dated November 4, 1980 
entitled "The Chronicle recommends" 

Article from The Houston Chronicle dated November 1, 4982 
entitled "The Chronicle recommends" 

Article from the Houston Chronicle dated November 5, 1984 
entitled "The Chronicle recommends" 

Article from The Houston Chronicle dated November 3, 1986 
entitled "The Chronicle recommends" 

Article from The Houston Chronicle dated November 7, 1988 
entitled "The Chronicle recommends" 

Article from The Houston Post dated November 6, 1984 
entitled "Post recommends" 

Article from The Houston Post dated November 3, 1986 
entitled "Post recommends" 

 



Article from The Houston Post dated November 4, 1988 
entitled "District court judges” 

Article from The Houston Post dated November 7, 1988 
entitled "Post recommends" 

Article from The Houston Chronicle dated April 20, 1982 
entitled "Election '83 - Attorneys favor most incumbents in 
judicial preference poll" 

Article prepared by United Press International dated July 
11, 1988 entitled "Lawsuit filed against at-large method of 
electing state judges" 

Article from The Houston Post dated May 1, 1989 entitled 
"Judges to remain elected" 

List of 1980 Campaign Contributors to Judicial Candidate 
Alice Bonner 

Sworn Statement of Contributions and Expenditures of 
Candidate Alice Bonner for the period: Dec. 7, 19278 through 
Jan. 15,1979 

Contributions and Expenditures of Candidate Alice Bonner for 
Jan.-Feb, .1978 

Contributions and Expenditures for Candidate Alice Bonner 
for the period Feb. 1 through Mar. 27, 1978 

Contributions and Expenditures for Candidate Alice Bonner 
for Jan.-Apr. 1978 

Sworn Statement of Contributions and Expenditures for 
Candidate Alice Bonner for the period Mar. 28 through Apr. 
27, 1978 

Sworn Statement of Contributions and Expenditures for 
Candidate Alice Bonner for the period Apr. 27 through May 
24, 1978 

Sworn Statement of Contributions and Expenditures for 
Candidate Alice Bonner for the period May 25 through June 
28,1978 

Sworn Statement of Contributions and Expenses of Judge Alice 
Bonner dated Jan. 15, 1980 

Miscellaneous campaign expenditures of Alice Bonner for 1979 
and 1980  



PA ¢ 

List of Contributors to 1978 Campaign of Candidate Alice 
Bonner 

List of Contributors and Expenditures of Candidate Alice 
Bonner 

Expenditure for Advertising for 1978 Campaign of Candidate 
Alice Bonner 

Excerpts of the Deposition of Matthew Plummer taken July 
1989 

Excerpts of the Deposition of Weldon Berry taken August 
1989 

Excerpts of the Deposition on Written Questions of 
Richard Murray taken September 5, 1989 

Excerpts of the Deposition of Alice Bonner taken July 
1989 

Excerpts of the Deposition of Bonnie Fitch taken August 30, 
1989 

Excerpts of the Deposition of the Honorable Manuel Leal 
taken August 14, 1989 

Excerpts of the Deposition of Francis L. Williams taken 
August 30, 1989 

The Deposition of the Honorable Ray Hardy taken July 26, 
1989 

WO0/04/10/ht 
WwOo000/001