Motion to Substitute

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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
- f98bda83-1e7c-f011-b4cc-6045bdffa665

Cite this item

Case Files, LULAC and Houston Lawyers Association v. Attorney General of Texas Hardbacks, Briefs, and Trial Transcript. Motion to Substitute, 1990. f98bda83-1e7c-f011-b4cc-6045bdffa665. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/618ec379-4880-42bb-b12b-7b13ef8c572a/motion-to-substitute. Accessed November 08, 2025.

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IN THE UNITED STATES COURT OF APPEALS 
FOR THE FIFTH CIRCUIT 

  

  

NO. 90-8014 

  

LEAGUE OF UNITED LATIN AMERICAN 
CITIZENS COUNCIL NO. 4434, 

Plaintiffs-Appellees, 

and 

JESSE OLIVER, et al., 
Intervening 
Plaintiffs-Appellees, 

versus 

WILLIAM P. CLEMENTS, ETC., et al., 

Defendants, 

JIM MATTOX, ET AL., 
Defendants-Appellees, 
Appellants 

versus 

JUDGE F. HAROLD ENTZ, ETC., 
JUDGE SHAROLYN WOOD, ETC., 

and GEORGE S. BAYOUD, JR., ETC., 
Defendants-Appellants, 

and 

TOM RICKHOFF, SUSAN D. REED, JOHN 

J. SPECIA, JR., SID L. HARLE, SHARON 

MACRAE and MICHAEL P. PEDAN, Bexar 

County, Texas State District Judges, 

Appellants. 

  

Appeal From the United States District Court 
For the Western District of Texas 

  

 



MOTION TO SUBSTITUTE 
  

COME NOW amici curiae, the State of Alabama, the Attorney 

General, the Chief Justice of the Alabama Supreme Court, and the 

Secretary of State, and respectfully move the Court to permit 

substitution of corrected copies of their amicus brief for 

copies filed June 7, 1990. For grounds, amici state that, due to 

a photocopying error, page seven of the original brief is 

illegible and page eight is omitted. 

Respectfully submitted, 

ERY a 
SUSAN E. RUSS 
Special Assistant Attorney General 

  

MILLER, HAMILTON, SNIDER & ODOM 

One Commerce Street 

Suite 802 

Montgomery, Alabama 36104 
(205) 834-5550 

bawid 2 Boyd. [ss 
DAVID R. BOYD i 
Special Assistant Attorney General 
(Counsel of Record) 

  

BALCH & BINGHAM 

Post Office Box 78 
Montgomery, Alabama 36101 
(205) 834-6500  



Proves V- Gale , or 
FOURNIER J. GALE, III 
Special Assistant Attorney General 

  

  

MAYNARD, COOPER, FRIERSON & GALE 

2400 AmSouth Tower - Harbert Plaza 
1901 6th Avenue, North 

Birmingham, Alabama 36101 
(205) 252-2889 

 



CERTIFICATE 
  

I HEREBY CERTIFY that a copy of the foregoing Motion for 
Leave to File Brief Amici Curiae and Conditicnally Filed Brief 
Amici Curiae, with this certificate of service appended thereto, 
has been served upon the following: Jim Mattox, Attorney General 
of Texas, Mary F. Keller, First Assistant Attorney General, 
Renea Hicks, Special Assistant Attorney General, and Javier 
Juajardo, Assistant Attorney General, P.O. Box 12548, Capitol 
Station, Austin, Texas 78711-2548; William L. Garrett, Garrett, 

Thompson & Chang, 8300 Douglas, Suite 800, Dallas, Texas 75225; 
Rolando Rios, Southwest Voter Registration & Education Project, 
201 N. St. Mary's, Suite 521, San Antonio, Texas 78205; 
Sherrilyn A. Ifill, NAACP Legal Defense and Educational Fund, 
Inc., 99 Hudson Street, 16th Floor, New York, New York 10013; 
Gabrielle K. McDonald, 301 Congress Avenue, Suite 2050, Austin, 
Texas 78701; Edward B. Cloutmann, III, Mullinax, Wells, Baab & 

Cloutman, P.C., 3301 Elm Street, Dallas, Texas 75226-1637; J. 
Eugene Clements, Porter & Clements, 700 Louisiana, Suite 3500, 

Houston, Texas 77002-2730; Robert H. Mow, Jr., Hughes & Luce, 

2800 Momentum Place, 1717 Main Street, Dallas, Texas 75201; John 
L. Hill, Jr., Liddell, Sapp, Zivley, Hill & LaBoon, 3300 Texas 
Commerce Tower, Houston, Texas 77002; Walter L. Irvin, 5787 
South Hampton Road, Suite 210, Lock Box 122, Dallas, Texas 
75232-2255; R. James George, Jr., Graves, Dougherty, Hearon & 
Moody, P.O. Box 98, Austin, Texas 78767; Seagal V. Wheatley, 
Oppenheimer, Rosenberg, Kelleher & Whatley, Inc., 711 Navarro, 

Sixth Floor, San Antonio, Texas 78205; and John R. Dunne, 

Assistant Attorney General, Jessica Dunsay Silver, Mark L. Gross 
and Susan D. Carle, Attorneys, Department of Justice, P.O. Box 

66078, Washington, D.C. 20035-6078, by depositing the same in 
the United States Mail, postage prepaid, properly addressed. 

All parties required to be served have been served. 
Montgomery County, Alabama, this the (2 +4 day of 

Syme , 1990. 
  

Onin. Ds 
Susan E. Russ / 

Of Counsel 

  

R4903.D07/SERFIRM

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Motion to Substitute

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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