Plaintiff Response to Defendants' Second Set of Interrogatories and Request for Production of Documents

Public Court Documents
July 19, 1989

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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
- cde85de8-257c-f011-b4cc-6045bdd81421

Cite this item

Case Files, LULAC and Houston Lawyers Association v. Attorney General of Texas Hardbacks, Briefs, and Trial Transcript. Plaintiff Response to Defendants' Second Set of Interrogatories and Request for Production of Documents, 1989. cde85de8-257c-f011-b4cc-6045bdd81421. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/62e05f8a-f209-4783-b7c3-83ddb4c793b6/plaintiff-response-to-defendants-second-set-of-interrogatories-and-request-for-production-of-documents. Accessed November 07, 2025.

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UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF TEXAS
MIDLAND/ODESSA DIVISION

LULAC COUNCIL #4434, et al., §
Plaintiffs, §

§
VS. § Civil Action No.

§ MO 88 CA 154
JIM MATTOX, et al., §

Defendants. §

See plaintiffs supplemental response dated July 17, 1989.

LULAC represents the interest of Blacks in those areas where they are members of LULAC. LULAC does not maintain record on race/ethnicity of its
members.

RESPONSE TO INTERROGATORY NO, 3:

Lubbock County has a 1980 population of 211,651. Crosby County has a county population of 8,400. If one of the five district judges that is elected in Lubbock County has to also run in Crosby County, this in no way changes our basic claim that at large elections in Lubbock County discriminate against
minorities.

Smith County has a 1980 population of 128,347. Wood County has a population of 28,200. If one of the four district judges that is elected in Smith County has to also run in Wood County, this does not in any way change our basic clai that at large elections in Smith County discriminate against minorities. :

RESPONSE TO INTERROGATORY NO, 5:

We have requested that our experts look at those elections in which a minority
ran against a non minority for judicial office. The election results are a
matter of public record at the Secretary of States Office or the local county
elections office.

RESPONSE TO INTERROGATORY NO, 6:

Our claim is that all Zimmer factors exist in all the relevant areas except for
slatting and racial campaigns. There appears to be some evidence of racial
campaigns in Dallas County (see campaign between Charles Ben Howell and
Joan Winn-White). We will not be presenting any evidence on responsiveness
unless the issue is raised by the defendants or the defendant intervenors.

RESPONSE TO INTERROGATORY NO, 7:

We do not, at this time, make any such claim.

RESPONSE TO INTERROGATORY NO, §:

Yes, given the wealth of information available, cases previously cited to you,
the legislative history of attempts to create district elections, any reason for
maintaining at large elections for district judges is tenuous. Also, defendants
have offered no legitimate state interest for maintaining the present at large
election structure.
Case citations for history of discrimination including challenges to at large
election structures have been previously provided to you.

List of cases on history of discrimination that affect voting rights have been
previously provided to you., List of letters of objection have been previously
provided to you.

RESPONSE TO INTERROGATORY NO, 10;

See response to interrogatory number 6.

RESPONSE TO INTERROGATORY NO, 11:

See response to interrogatory number 6.

RESPONSE TO INTERROGATORY NO, 12:

The names of all the candidates for district judges is a matter of public record
as previously stated. Plaintiffs do not have a particular list of minority
candidates for district judge for each county challenged in this lawsuit.

RESPONSE TO REQUEST FOR PRODUCTION NO, 1

Plaintiffs do not posses any such computer printouts and summaries.

Dated: July 19, 1989 Respéotfully submitted,

ROLANDO L. RIOS
Attorney for Plaintiffs
201 N. St. Mary's, Suite 521
San Antonio, Texas 78205
(512) 222-2102
State Bar No. 16935900

CERTIFICATE OF SERVICE

I hereby certify that on this 9th day of July, 1989 a true and correct copy of

WILLIAM L. GARRETT °
BRENDA HULL THOMPSON
Garrett, Thompson & Chang
8300 Douglas, Suite 800
Dallas, Texas 75225

JULIUS L. CHAMBERS
SHERRILYN A. IFILL
NAACP Legal Defense & Educational

Fund, Inc.

99 Hudson Street, 16th Floor
New York, N.Y. 10013

SUSAN FINKELSTEIN
Texas Rural Lega! Aid, Inc.
201 N. St. Mary's, Suite 600
San Antonio, Texas 78205

EDWARD B. CLOUTMAN, III
Mullinax, Wells, Baab & Cloutman, P.C.
3301 Elm
Dallas, Texas 75226-9222

JIM MATTOX
MARY F. KELLER
RENEA HICKS
JAVIER GUAJARDO
P.O. Box 12548
Captial Station

the above and foregoing document was mailed to counsel of record in this case
by first class United States mail, postage pre-paid, addressed as follows:

J. EUGENE CLEMENTS
JOHN E. O'NEILL
EVELYN V. KEYS
PORTER & CLEMENTS
700 Louisiana, Suite 3500
Houston, Texas 77002-2730

MICHAEL J. WOOD
Attorney at Law
440 Louisiana, Suite 200
Houston, Texas 77002

GABRIELLE K. McDONALD, Esq.
Matthews & Branscomb
301 Congress, Avenue
suite 2050
Austin, Texas 78701

ROBERT H. MOW, Jr.
Hughes & Luce
2800 Momentum Place
1717 Main Street
Dallas, Texas 75201

E. BRICE CUNNINGHAM, Exsq.
777 So. R.L. Thornton Freeway
Suite 121
Dallas, Texas 75203

Austin, Texas 78701

Mark H. Dettman

Attorney at Law
P.O. Box 2559
Midland, Texas 79702

Darrell Smith, Esq.
Attorney at Law
10999 Interstate Highway 10
Suite 905
San Antonio, Texas 78230

ne”

ROLANDO L. RIOS
Attorney for Plaintiffs

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Plaintiff Response to Defendants' Second Set of Interrogatories and Request for Production of Documents

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