Plaintiff-Intervenor HLA's Motion for Leave of Court to File in Excess of Ten Requests for Admission

    FEDERAL EXPRESS 
  

August 21, 1989 

Hon. John Neil 

Deputy Clerk, U.S. Courthouse 

P.O. Box 10708 

200 E. Wall, Room 316 

Midland, Texas 79702 

Re: Civil Action No. MO-88-CA-154 

LULAC, et al. v. Jim Mattox, et al. 

Dear Mr. Neil: 

A Motion for Leave of Court to File in Excess of Ten Requests for 
Admission in connection with the above named case, was mailed by 
first class mail to your office on August 8, 1989, and copies 
sent to all attorneys of record. Since you have advised that the 
motion has not been received, I am enclosing another original and 
one copy of Plaintiff-intervenors, Houston Lawyers' Association's 
Motion for Leave of Court to File in Excess of Ten Requests for 
Admission, which I trust can now be properly filed with the 
Court. 

Sincerely, 

Sonn Ctl go Sherrilyn A. Ifill 
   

/dm 

encl. 

  

NINETY NINE HUDSON STREET, 16th FLOOR . (212) 219-1900 ° NEW YORK, N.Y. 10013 

 



  

FEDERAL EXPRESS 
  

August 21, 1989 

Hon. John Neil 

Deputy Clerk, U.S. Courthouse 
P.O. Box 10708 
200 E. Wall, Room 316 

Midland, Texas 79702 

Re: Civil Action No. MO-88-CA-154 

LULAC, et al. v. Jim Mattox, et al. 

Dear Mr. Neil: 

A Motion for Leave of Court to File in Excess of Ten Requests for 
Admission in connection with the above named case, was mailed by 
first class mail to your office on August 8, 1989, and copies 
sent to all attorneys of record. Since you have advised that the 
motion has not been received, I am enclosing another original and 

one copy of Plaintiff-intervenors, Houston Lawyers' Association's 
Motion for Leave of Court to File in Excess of Ten Requests for 
Admission, which I trust can now be properly filed with the 
Court. 

Sincerely, 

Sherrilyn A. Ifill 
   

/dm 

encl. 

  

NINETY NINE HUDSON STREET, 16th FLOOR u (212) 219-1900 ° NEW YORK, N.Y. 10013 

 



  

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

MIDLAND-ODESSA DIVISION 

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

Plaintiffs, 

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

Plaintiff-Intervenors, 

vs. No. 88-CA-154 
  

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

Defendants. 

PLAINTIFF-INTERVENOR HOUSTON LAWYERS’ 
MOTION FOR LEAVE OF COURT TO FILE IN 
EXCESS OF TEN REQUESTS FOR ADMISSION 
  

In accordance with Rule 300-6(f), plaintiff-intervenors seek 

leave of this Court to suspend the operation of the local rule 

limiting requests for admission for the pendency of this lawsuit. 

This request is made with good cause. 

On June 1, 1989, plaintiff-intervenors’ Houston Lawyers’ 

Association served upon State defendants in the above-captioned 

case twenty Requests for Admission. On June 21, 1989, State 

defendants objected and refused to answer the last ten requests 

 



  

for admission on the ground that pursuant to Local Rule 300-6(f), 

admissions are limited to only ten requests. 

On March 1, 1989, this Court entered an order permitting 

plaintiffs in this action to request more than ten admissions of 

the State defendants. In light of the complex, and fact- 

intensive nature of this case, and to facilitate productive 

discovery, plaintiff-intervenors Houston Lawyers’ Association, 

et al, similarly seek leave of this Court to request more than 

ten admissions of the defendants. 

For the aforementioned reasons which constitute good cause, 

plaintiff-intervenors respectfully request that this Court 

suspend the operation of Local Rule 300-6 (f) for the duration of 

this lawsuit. 

Respectfully submitted, 

dis { : fet Sle 
/JULIUS L. €HAMBERS V 
SHERRILYN A. IFILL 

99 Hudson Street, 16th Floor 
New York, New York 10013 

  

Of Counsel: GABRIELLE McDONALD 
MATTHEWS & BRANSCOMB 301 Congress Avenue 
A Professional Corporation Suite 2050 

Austin, Texas 78701