Defendant-Intervenor Wood's Answers and Objections to Plaintiffs' First Set of Interrogatories; Wood's Response to First Request for Production

    IN THE UNITED STATES DISTRICT COURT 

FOR THE WESTERN DISTRICT OF TEXAS 

MIDLAND-ODESSA DIVISION 

LULAC, et al., 

Plaintiffs, 

Vv. NO. MO-88-CA-154 

MATTOX, et al., 

Defendants. D
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DEFENDANT-INTERVENOR WOOD'S ANSWERS AND OBJECTIONS 
TO PLAINTIFFS' FIRST SET OF INTERROGATORIES 
  

  

TO: Plaintiffs, by and through +heir attorneys ‘of record, 
William L. Garrett and Brenda Hull Thompson, Garrett, 
Thompson & Chang, 8300 Douglas #800, Dallas, Texas 75225 

Pursuant to Rules 26 and 33 of the Federal Rules of Civil 

Procedure, Defendant-Intervenor Judge Sharolyn Wood ("Wood") 

responds to the Interrogatories of Plaintiffs as follows: 

GENERAL RESPONSE AND OBJECTIONS 
  

Defendant objects to the Interrogatories propounded by 

Plaintiffs insofar as they are excessively broad and vague or 

pose an undue hardship on Defendant. 

Defendant objects to the Interrogatories to the extent they 

call for the production of information or documents covered by 

the attorney/client privilege, the work product privilege, or any 

other applicable privilege or exemption. Defendant does not 

intend to waive any such privileges or exemption by her responses 

to these Interrogatories. 

 



  

SPECIFIC OBJECTIONS AND ANSWERS 
  

Without waiving any of the foregoing objections, Defendant 

makes the following specific objections and answers to the 

Interrogatories: 

INTERROGATORY NO. 1: Please identify by name, business and 
  

residential address, telephone number, place of employment and 

job title each of the persons known to you who has any knowledge 

regarding the facts that base any claim or defense that you plan 

to raise in this lawsuit. 

ANSWER TO INTERROGATORY NO. 1: Defendant objects to Interroga- 
  

tory No. 1 in that it is too vague and indefinite to permit a 

response. Subject to and without waiving the foregoing 

objection, Defendant replies that every district judge and every 

registered voter in Harris County, Texas during at least the last 

eight years has knowledge of the facts on which Defendant bases 

the claims and defenses that will be raised in this lawsuit. 

Defendant further objects that it would be unduly burdensome to 

require Defendant to list the names and addresses of all such 

persons; and Defendant further objects on the basis that this 

information is as readily available to Plaintiffs as it is to 

Defendants. 

INTERROGATORY NO. 2: Please identify by name, business and 
  

residential address, telephone number, place of employment and 

job title each of the expert witnesses you expect to call to 

testify should this case go to trial and state the nature of the 

testimony that you expect each expert witness to give. 

 



ANSWER TO INTERROGATORY NO. 2: Defendant has not designated any 
  

expert witnesses at this time. Defendant will timely supplement 

her answer to this interrogatory in compliance with Federal Rule 

of Civil Procedure 26 (4) when such a designation is made. 

INTERROGATORY NO. 3: Please state the nature of any claim or 
  

defense that you intend to present at trial that does not arise 
  

out of facts that took place, will take place or take place in 

Harris County. 

ANSWER TO INTERROGATORY NO. 3: Defendant objects to Interroga- 
  

tory No. 3 that it is overly broad and too vague to permit a 

response. Subject to that objection, Defendant's claims and 

defenses are set forth in her pleadings and are not circumscribed 

in scope as to Harris County. However, Defendant will focus on 

facts of relevance to the election of state district judges in 

Harris County, Texas. 

INTERROGATORY NO. 4: Please identify by year, type of election 
  

(general, Democratic/Republican primary, Democratic/Republican 

run off), candidate and type of office each election that you 

claim is relevant to your claims. 

ANSWER TO INTERROGATORY NO. 4: All Texas judicial elections in 
  

Plaintiffs' targeted counties are relevant to both Plaintiffs’ 

and Defendant's claims. Within that framework, however, all 

Harris County judicial elections since 1980 are of particular 

relevance to Defendant's claims, including all Democratic primary 

and run-off elections, and all general elections, but most  



  

particularly all elections in which minority candidates have run 

for judicial office in Harris County since 1980. 

  

SHAROLYN WOOD 4 
STATE OF TEXAS § 

S 
COUNTY OF HARRIS S 

BEFORE ME, the undersigned authority on this day personally 
appeared Sharolyn Wood, who, being by me duly sworn on her oath 
did depose and state that she is qualified and authorized in all 
respects to make this affidavit, that she has read the foregoing 
Defendant-Intervenor Wood's Answers and Objections to Plaintiffs’ 
First Set of Interrogatories and that the statements contained 
therein are to the best of her knowledge true and correct. 

Dacet rot 
SHAROLYN WOOD 
  

SUBSCRIBED and SWORN TO before me on this the li day of 
April, 1989. 

= 
gah Lg Sr 

a vl; Af Ll um 

Notary Public in arid for 
the State of Texas 

  

Rooms oN! BAS ID ISAS Sr % 
G 

5 03 3 MY COMMISSION EXPIRES 
Te or EY FEB. 9, 1993 rapa “arprnsest 

   



      
  

  

_-J.| Eugene Clements 
rney in Charge for Defendant 

ris County District Judge 
arolyn Wood 

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 

CERTIFICATE OF SERVICE 
  

I hereby certify that on the 27th day of April, 1989, a true 
and correct copy of the above and foregoing Defendant-Intervenor 
Wood's Answers and Objections to Plaintiffs' First Set of 
Interrogatories was served upon counsel of record in this case by 
Federal Express mail, or by first class United States mail, 
postage prepaid, addressed as follows: 

Mr. William L. Garrett 
Ms. Brenda Hull 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 221 
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, 1IY 
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. Ken Oden 
Travis County Attorney 
P..O, Box 1748 
Austin, Texas 78767 

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

Mr. Mark H. Dettman 

Attorney at Law 

P. O. Box 2559 
Midland, Texas 79702 

Mr. Robert H. Mow, Jr. 

Hughes & Luce 
2800 Momentum Place 
1717 Main Street 
Dallas, Texas 75201 

lnc 
  

Z in V Le, od 
Evelyn V. KeXes 

W0002/01/cdf 

 



  

IN THE UNITED STATES DISTRICT COURT 

FOR THE WESTERN DISTRICT OF TEXAS 

MIDLAND-ODESSA DIVISION 

LULAC, et al., 

Plaintiffs, 

Yo. NO. MO-88-CA-154 

MATTOX, et al., 

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Defendants. 

DEFENDANT-INTERVENOR WOOD'S RESPONSE TO 

PLAINTIFFS' FIRST REQUEST FOR PRODUCTION 
  

  

TO: Plaintiffs, by and through their attorneys of record, 
William L. Garrett and Brenda Hull Thompson, Garrett, 
Thompson & Chang, 8300 Douglas #800, Dallas, Texas 75225 

Pursuant to Rules 26 and 34 of the Federal Rules of Civil 

Procedure, Defendant-Intervenor Sharolyn Wood ("Wood") responds 

to Plaintiffs' First Request for Production to Defendant- 

Intervenor Wood as follows: 

GENERAL RESPONSE AND OBJECTIONS 
  

Defendant will permit the inspection of documents requested 

by Plaintiffs as set out specifically below subject to the 

following objections. 

Defendant objects to each Request for Production propounded 

by Plaintiffs insofar as it is excessively broad and vague or 

poses an undue hardship on Defendant. 

Defendant objects to the Request to the extent it calls for 

the production of information or documents covered by the 

attorney/client privilege, the work product privilege, or any 

 



other applicable privilege or exemption. Defendant does not 

intend to waive any such privileges or exemption by her responses 

to this Request for Production. 

Defendant objects to the Request insofar as it calls for the 

production of documents not in the possession, custody, or 

control of Defendant. 

SPECIFIC OBJECTIONS AND ANSWERS 
  

Without waiving any of the foregoing objections, Defendant 

makes the following specific objections and answers to Plain- 

tiffs' First Request for Production: 

REQUEST NO. 1: Please provide copies of all documents prepared 
  

by an expert on your behalf in this case. 

RESPONSE TO REQUEST NO. 1: Defendant objects to this request in 
  

that it calls for non-testifying experts' documents on its face 

and therefore ranges beyond the permissible scope of discovery as 

set forth in Pederal Rules of Civil Procedure 26 and, in 

particular, Rule 26(4). Defendant further objects that this 

Request fails to set forth with reasonable particularity the 

documents sought, as required by Federal Rule of Civil Procedure 

34 and is therefore too vague to permit Defendant to identify the 

documents sought. Subject to and without waiving the foregoing 

objections, Defendant has not yet identified any expert witness 

whom she expects to call at trial. Defendant will supplement 

this reply as required by Federal Rule 26(e) by producing, at a 

time and place mutually agreeable to counsel, those documents 

which can be identified as clearly responsive to Plaintiffs’  



  

Request and within the limits of permissible discovery under 

Federal Rule 26 (4). 

REQUEST NO. 2: Please provide copies of all documents provided 
  

to an expert on your behalf in this case. 

RESPONSE TO REQUEST NO. 2: Defendant objects to this request in 
  

that it, like Request No. 1, is overly broad on its face and 

ranges beyond the permissible scope of discovery as set forth in 

Federal Rules of Civil Procedure 26 and, in particular, Rule 

26 (4). Subject to and without waiving the foregoing objections, 

Defendant has not yet identified any expert witness whom she 

expects to call at trial. Defendant will supplement this reply 

as required by Federal Rule 26(e) by producing, at a time and 

place mutually agreeable to counsel, those documents which can be 

identified as clearly responsive to Plaintiffs' Request and 

within the limits of permissible discovery under Federal Rule 

26 (4). 

  

  

  

    torney in Charge for Defendant 
arris County District Judge 

Sharolyn Wood 
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 

 



  

CERTIFICATE OF SERVICE 
  

I hereby certify that on the 27th day of April, 1989, a true 
and correct copy of the above and foregoing Defendant-Intervenor 
Wood's Response to Plaintiffs' First Request for Production was 
served upon counsel of record in this case by Federal Express 
mail, or by first class United States mail, postage prepaid, 
addressed as follows: 

Mr. William L. Garrett 
Ms. Brenda Hull Thompson 
Garrett, Thompson & Chang 

Attorneys at Law 
8300 Douglas, Suite 800 
Dallas, Texas 75225 

Mr. Rolando L. Rios 
Southwest Voter Registration & 

Education Project 
201 KR. St. Mary's, Suite 221 
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 12543 
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. Ken Oden 
Travis County Attorney 
P. O. Box 1748 

Austin, Texas 78767 

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

Mr. Mark H. Dettman 

Attorney at Law 

P. 0. Box 2559 

Midland, Texas 79702 

Mr. Robert H. Mow, Jr. 

Hughes & Luce 
2800 Momentum Place 

1717 Main Street 
Dallas, Texas 75201 

  

Evelyn V. Keyes 

WO0002/02/cdf