Plaintiff-Intervenors' First Set of Interrogatories and Requests for Production to Defendant-Intervenor Judge Wood

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AND EDUCATIONAL FUND, INC. New York, N.Y. 10013 (212) 219-1900 Fax: (212) 226-7592 

May 3, 1989 

J. Eugene Clements 
Porter & Clements 
700 Louisiana, Suite 3500 
Houston, TX 77002-2730 

Re: Lulac et al., v. Mattox, et al. 

Dear Mr. Clements: 

Enclosed please find Plaintiff-Intervenor Houston Lawyers’ 
Association First Set of Interrogatories & Requests for Produc- tion of Documents to Defendant-Intervenor Wood. 

I look forward to your timely response. 
’ 

lyn A. Ifill 
Counsel for Plaintiff- 

incerely 

  

   
Intervenors 

SAI/dm 
encls. 

Regional Offices 

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Board, program, staff, office and budget. 3 Fax: (202) 682-1312 Fax: (213) 624-0075 

 



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

MIDLAND-ODESSA DIVISION 

LEAGUE OF UNITED LATIN AMERICAN CITIZENS, 
(LULAC) , 

PLAINTIFF, 

Houston Lawyers’ Association, Alice Bonner, 
Weldon Berry, Francis Williams, Rev. William 
Lawson, Deloyd T. Parker, Bennie McGinty, 

Plaintiff-Intervenors 

Ve ; No. MO-88-CA-154 

JAMES MATTOX, Attorney General of the 
State of Texas, et al., 

DEFENDANTS. 

PLAINTIFF-INTERVENORS’ FIRST SET OF INTERROGATORIES 
AND REQUESTS FOR PRODUCTION TO DEFENDANT-INTERVENOR 

JUDGE SHAROLYN WOOD | 

  

  

  

Pursuant to Rules 33 and 34 of the Federal Rules of Civil 

Procedure, plaintiffs request that defendants answer fully in 

writing and under oath each of the following interrogatores 

within 30 days after service. These interrogatories shall be 

deemed continuing to the extent required by Fed. r. Civ. 26 (e). 

In answering each interrogatory, defendants are requested to 

identify separately and in a manner suitable for use in a 

subpoena all sources of information (whether human, documentary, 

or other) and all records maintained by the defendants or by any 

other person or organization on which the defendants relied in 

answering the interrogatories. 

 



  

For each request to produce, plaintiffs request that 

defendants produce all requested documents at the law office of 

Gabrielle K. McDonald, 301 Congress Avenue, Austin, Texas, 

78701, within 15 days after service or at such time and place as 

is mutually agreed upon by counsel for the parties. 

Definitions 

1. ”Identify” when referring to a fact or document, means state 

the name and date of the fact or document, the type of document, 

the identity of the author of the document, and the location of 

the document or a copy of the document. 

2. ”"Identify,” when referring to a person, means state the name, 

race, home and business address and position with any defendant 

or relation to any defendant, if any. 

3. “Document” means the original or identical copy of ‘any 

document (including writings, drawings, graphs, charts, 

photographs, phonorecords, audio recordings, and other data 

compilations from which information can be obtained, translated, 

if necessary, by the Respondents through detection services into 

reasonably usuable form) and any tangible things which constitute 

or contain matters within the scope of Rule 26 (b) of the Federal 

Rules of Civil Procedure. 

4. "Relating to” a subject means containing, embodying, 

referring to, comprising, reflecting, explaining, or having a 

logical, factual or causal connection with the subject. 

 



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5. ”The Voting Rights Act” means the Voting Rights Act of 1965, 

as amended, 42. U.S. C. §1973, et seq. 

Interrogatories and Requests to Produce 
  

INTERROGATORY NO. 1: Please identify by year, type of elective 

office and term served, each and every elective office held by 

defendant-intervenor Wood. 

INTERROGATORY NO. 2: Please identify by year, type of election, 

and type of office, each and every election in which defendant- 

intervenor Wood has run for elective office in Harris County, 

Texas, indicating whether or not she won that election. 

INTERROGATORY NO. 3: Please identify each and every opposing   

candidate for the elections indicated in answer to Interrogatory 

No. 2 by ethnic race. 

REQUEST FOR PRODUCTION NO. 1: Please provide for inspection and   

copying all documents related to elections in which Judge Wood 

ran for elective office in Harris County, including, but not 

limited to, campaign contribution reports, campaign expenditure 

reports, election returns, campaign literature, written or 

reported endorsements by public officials, civic groups, bar 

associations, etc. 

 



  

  

INTERROGATORY NO. 4: Please identify your political party 

affiliation. 

INTERROGATORY NO. 5: Please identify any professional   

organizations, civic associations, or other political, social or 

cultural organizations of which you are a member, or in which you 

are an active participant. 

INTERROGATORY NO. 6: Identify each expert which you have   

consulted in preparation for the trial of this matter. For each, 

give the subject matter on which the expert was consulted. 

  

REQUEST FOR PRODUCTION NO. 2: Please produce for inspection and 

copying all documents you have directly or indirectly provided to 

or rYeparsd for, each expert listed in response to Interrogatory 

No. 6, and any documents prepared by each expert for the use of 

defendant-intervencr Wood's participation in this case or which 

relates to the claims or defenses of defendant-intervenor Wood. 

INTERROGATORY NO. 7: Describe the "nonprotected Class," not   

covered by Section 2 of the Voting Rights Act, as amended, to 

which defendant-intervenor Wood claims to belong. 

INTERROGATORY NO. 8: Describe the current district in which   

defendant-intervenor Wood currently serves as district judge, 

including the number of the district, the approximate number of 

 



  

cases on the docket each year in that district, the number of 

district judges currently serving in that district, and the date 

and year when each current judicial seat in that district was 

created. 

REQUEST FOR PRODUCTION NO. 3: Please provide any and all   

documents which support your answer to Interrogatory No. 8. 

Of Counsel: 

Matthews & Branscomb 

A Professional Corpoation 

May 4, 1989 

  

Regpectfully submitted, 

Hutt 
J 4 

vowed CHAMBERS 
SHERRILYN A. IFILL 

NAACP Legal Defense & 
Educational Fund, Inc. 
99 Hudson Street, 16th Floor 
New York, New York 10013 
(212) 219-1900 

  

GABRIELLE K. MCDONALD 
301 Congress Avenue 
Suite 2050 
Austin, Texas 78701 
(512) 320-5055 

Attorneys for Plaintiff-Intervenors 
Houston Lawyers’ Association, 

et al. 

 



  

CERTIFICATE OF SERVICE 

I hereby certify that on this a % of May, 1989, a Gite 

and correct copy of the foregoing Plaintiff-intervenors Houston 

Lawyers’ Association’s First Set of Interrogatories and Requests 

For Production to Defendant-intervenor Judge Sharolyn Wood was 

mailed to counsel of record in this case by first class United 

States mail, postage pre-paid, as follows: 

William L. Garrett 
Brenda Hull Thompson 
Garrett, Thompson & Chang 
8300 Douglas, Suite 800 
Dallas, TX 75225 

Rolando L. Rios 
Southwest Voter Registration 

Education Project 
201 N. St. Mary’s, Suite 521 
San Antonio, TX 78205 

Susan Finkelstein 
Texas Rural Legal Aid, Inc. 
201 N. St. Mary’s, Suite 521 
San Antonio, TX 78205 

Edward B. Cloutman, III 
Mullinax, Wells, Baab & 

Cloutman, P.C. 
3301 Elm 
Dallas, TX 75226-9222 

Jim Mattox 
Mary F. Keller 
Renea Hicks 
Javier Guajardo 
Attorney General’s Office 
P.O. Box 12548 

Austin, TX 78711 

J. Eugene Clements 
John E. O’Neill 
Evelyn V. Keys 
Porter & Clements 

700 Louisiana, Suite .3500 
Houston, TX 77002-2730 

Michael J. Wood 
Attorney at Law 

440 Louisiana, Suite 200 
Houston, TX 77002 

Ken Oden 
Travis County Attorney 
P.O. Box 1748 

Austin, TX 78767 

David R. Richards 
Special Counsel 
500 W. 7th St. 

Austin, TX 78701 

Robert H. Mow, Jr. 
Hughes & Luce. 
2800 Momentum Place 

1717 Main Street 
Dallas, TX 75201 

  

Sherri)yn AX. Ifill] 
Attor for Plaintiff-Intervenors 
Houston Lawyers’ Association . 

 



  

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

MIDLAND-ODESSA DIVISION 

CD ED GE SD GE Gh SD GND GED GD GED GED ED GED GED GE GED GED GE GED GED GED GED GED GED GED GED GED GED GED CED GED GED GHD GED GED GHD CED CED CHD WED CED = 

LEAGUE OF UNITED LATIN AMERICAN CITIZENS, 
(LULAC) , 

PLAINTIFF, 

Houston Lawyers’ Association, Alice Bonner, 
Weldon Berry, Francis Williams, Rev. William 
Lawson, Deloyd T. Parker, Bennie McGinty, 

Plaintiff-Intervenors 

Ve. No. MO-88-CA-154 

JAMES MATTOX, Attorney General of the 
State of Texas, et al., 

DEFENDANTS. 

PLAINTIFF-INTERVENORS’ FIRST SET OF INTERROGATORIES 
AND REQUESTS FOR PRODUCTION,TO DEFENDANT-INTERVENOR 

JUDGE SHAROLYN WOOD 

  

  

  

Pursuant to Rules 33 and 34 of the Federal Rules of Civil 

Procedure, plaintiffs request that defendants answer fully in 

writing and under oath each of the following interrogatores 

within 30 days after service. These interrogatories shall be 

deemed continuing to the extent required by Fed. r. Civ. 26 (e). 

In answering each interrogatory, defendants are requested to 

identify separately and in a manner sultable for use in a 

subpoena all sources of information (whether human, documentary, 

or other) and all records maintained by the defendants or by any 

other person or organization on which the defendants relied in 

answering the interrogatories. 

 



  

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For each request to produce, plaintiffs request that 

defendants produce all requested documents at the law office of 

Gabrielle K. McDonald, 301 Congress Avenue, Austin, Texas, 

78701, within 15 days after service or at such time and place as 

is mutually agreed upon by counsel for the parties. 

Definitions 
  

l. “Identify” when referring to a fact or document, means state 

the name and date of the fact or document, the type of document, 

the identity of the author of the document, and the location of 

the document or a copy of the document. 

2. “Identify,” when referring to a person, means state the name, 

race, home and business address and position with any defendant 

or relation to any defendant, if any. 

3. Document” means the original or identical copy of any 

document (including writings, drawings, graphs, charts, 

photographs, phonorecords, audio recordings, and other data 

compilations from which information can be obtained, translated, 

if necessary, by the Respondents through detection services into 

reasonably usuable form) and any tangible things which constitute 

or contain matters within the scope of Rule 26 (b) of the Federal 

Rules of Civil Procedure. 

4. “Relating to” a subject means containing, embodying, 

referring to, comprising, reflecting, explaining, or having a 

logical, factual or causal connection with the subject. 

  

er rr



    

FOF SER IRN A LAA EE EL ZS Ta FIER TA 

5. "The Voting Rights Act” means the Voting Rights Act of 1965, 

as amended, 42. U.S. C. §1973, et seq. 

Interrogatories and Requests to Produce 
  

INTERROGATORY NO. 1: Please identify by year, type of elective   

office and term served, each and every elective office held by 

defendant-intervenor Wood. 

INTERROGATORY NO. 2: Please identify by year, type of election, 

  

and type of office, each and every election in which defendant- 

intervenor Wood has run for elective office in Harris County, 

Texas, indicating whether or not she won that election. 

INTERROGATORY NO. 3: Please identify each and every opposing   

candidate for the elections indicated in answer to Interrogatory 

No. 2 by ethnic race. 

REQUEST FOR PRODUCTION NO. 1: Please provide for inspection and   

copying all documents related to elections in which Judge Wood 

ran for elective office in Harris County, including, but not 

limited to, campaign contribution reports, campaign expenditure 

reports, election returns, campaign literature, written or 

reported endorsements by public officials, civic groups, bar 

associations, etc. 

 



  

  

INTERROGATORY NO. 4: Please identify your political party 

affiliation. 

INTERROGATORY NO. 5: Please identify any professional 
  

organizations, civic associations, or other political, social or 

cultural organizations of which you are a member, or in which you 

are an active participant. 

INTERROGATORY NO. 6: Identify each expert which you have   

consulted in preparation for the trial of this matter. For each, 

give the subject matter on which the expert was consulted. 

REQUEST FOR PRODUCTION NO. 2: Please produce for inspection and   

copying all documents you have directly or indirectly provided to 

or prepared for, each expert listed in response to Interrogatory 

No. 6, and any documents prepared by each expert for the use of 

defendant-intervenor Wood’s participation in this case or which 

relates to the claims or defenses of defendant-intervenor Wood. 

INTERROGATORY NO. 7: Describe the "nonprotected class," not   

covered by Section 2 of the Voting Rights Act, as amended, to 

which defendant-intervenor Wood claims to belong. 

INTERROGATORY NO. 8: Describe the current district in which   

defendant-intervenor Wood currently serves as district judge, 

including the number of the district, the approximate number of 

4 

 



  

cases on the docket each year ‘in that district, the number of 

district judges currently serving in that district, and the date 

and year when each current judicial seat in that district was 

created. 

  

REQUEST FOR PRODUCTION NO. 3: Please provide any and all 

documents which support your answer to Interrogatory No. 8. 

Reggpectfully submitted, 

  

  

. 7 : 

pss. CHAMBERS 

SHERRILYN A. IFILL 

NAACP Legal Defense & 
Educational Fund, Inc. 
99 Hudson Street, 16th Floor 
New York, New York 10013 
(212) 219-1900 

Of Counsel: GABRIELLE K. MCDONALD 
Matthews & Branscomb 301 Congress Avenue 
A Professional Corpoation Suite 2050 

Austin, Texas 78701 
(512) 320-5055 

Attorneys for Plaintiff-Intervenors 
Houston Lawyers’ Association, 

et al. 

May 4, 1989 

 



  

CERTIFICATE OF SERVICE 

: rd 
I hereby certify that on this 3 day of May, 1989, a true 

and correct copy of the foregoing Plaintiff-intervenors Houston 

Lawyers’ Association’s First Set of Interrogatories and Requests 

For Production to Defendant-intervenor Judge Sharolyn Wood was 

mailed to counsel of record in this case by first class United 

States mail, postage pre-paid, as follows: 

William L. Garrett 
Brenda Hull Thompson 
Garrett, Thompson & Chang 
8300 Douglas, Suite 800 
Dallas, TX 75225 

Rolando L. Rios 
Southwest Voter Registration 

Education Project 
201 N. St. Mary’s, Suite 521 
San Antonio, TX 78205 

Susan Finkelstein 
Texas Rural Legal Aid, Inc. 
201 N. St. Mary’s, Suite 521 
San Antonio, TX 78205 

Edward B. Cloutman, III 
Mullinax, Wells, Baab & 

Cloutman, P.C. 
3301 Elm 
Dallas, TX 75226-9222 

Jim Mattox 
Mary F. Keller 
Renea Hicks 
Javier Guajardo 
Attorney General’s Office 
P.O. Box 12548 

Austin, TX 78711 

J. Eugene Clements 
John E. O0’Neill 
Evelyn V. Keys 
Porter & Clements 
700 Louisiana, Suite 3500 
Houston, TX 77002-2730 

Michael J. Wood 
Attorney at Law 

440 Louisiana, Suite 200 
Houston, TX 77002 

Ken Oden 

Travis County Attorney 
P.O. Box 1748 

Austin, TX 78767 

David R. Richards 
Special Counsel 
600 W. 7th St. 
Austin, TX 78701 

Robert H. Mow, Jr. 
Hughes & Luce 
2800 Momentum Place 
1717 Main Street 
Dallas, TX 75201 

  

Sherril}yn X. Ifill) 
Attor for Plaintiff-Intervenors 
Houston Lawyers’ Association