Response in Opposition of HLA to Motion of Appellant-Defendant-Intervenor Wood for Establishment of Expedited Briefing Scheduling

    MATTHEWS & BRANSCOMB 
A PROFESSIONAL CORPORATION 

ATTORNEYS AT LAW 

2OILCONGRESS AVENUE, SUITE 2050 

  

I8O0 FIRST CITY BANK TOWER AUSTIN, TEXAS 7870Il ONE ALAMO CENTER 

CORPUS CHRISTI, TEXAS 78477 TELEPHONE 512-320-5055 SAN ANTONIO, TEXAS 78205 

512-888-926 TELECOPIER 512-320-5013 512-226-421 

GABRIELLE K. MCDONALD 
January 29, 1950 

VIA FEDERAL EXPRESS 
  

Gilbert F. Ganucheau, Clerk 
U.S. Courtiof Appeals, 5th Circuit 
600 Camp Street 
New Orleans, Louisiana 70130 

RE: League of United Latin American Citizens (LULAC), 
et al. v. Jim Mattox, et al.; Cause No. 908014; 
In the United States Court of Appeals for the 
Fifth Circuit 

  

  

  

  

Dear Mr. Ganucheau: 

Enclosed please find an original and three (3) copies of the 
Response in Opposition of Houston Lawyers' Association, et al. to 
Motion of Appellant-Defendant-Intervenor Wood for Establishment 
of Expedited Briefing Scheduling in the above-styled and numbered 
cause. Please return the copies, file stamped and dated in the 
self-addressed, stamped envelope provided. 

Thank you for your consideration. 

Sincerely yours, 

MATTHEWS & BRANSCOMB 
A Professional Corporation 

hs K. McDonald 

     
5GKMdl :mld 

Enclosures 

 



IN THE UNITED STATES COURT OF APPEALS 
FIFTH CIRCUIT 

LEAGUE OF UNITED LATIN 
AMERICAN CITIZENS (LULAC), 
COUNCIL #4434, et al., 

Plaintiffs, 

and 

HOUSTON LAWYERS ASSOCIATION, 
et al., 

NO. 90-8014 

Plaintiff-Intervenors, 

Ve. 

JIM MATTOX, et al., 
State Defendants. D

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RESPONSE IN OPPOSITION OF HOUSTON LAWYERS' ASSOCIATION, et al. 
TO MOTION OF APPELLANT-DEFENDANT-INTERVENOR WOOD 
FOR ESTABLISHMENT OF EXPEDITED BRIEFING SCHEDULING 

  

  

  

TO THE HONORABLE COURT: 

NOW COME Houston Lawyers' Association ("HLA), Weldon Berry, 

Francis Williams, Alice A. Bonner, William Lawson, Deloyd T. Parker, 

Jr., and Bennie McGinty ("Plaintiff-Intervenors-Appellees") and hereby 

respectfully submit their response to the Motion of 

g Schedule in 

the above-styled matter, and respectfully pray that this Court deny 

said Motion and as grounds therefore would respectfully show as 

follows: 

I. 

Plaintiff, League of United Latin American Citizens ("LULAC") has 

previously filed a response in opposition to the Motion of Appellant 

Entz for establishment of expedited briefing schedule.  



  

Plaintiff-Intervenors-Appellees join in that response for the reasons 

stated in the response of LULAC. 

it. 

Defendant-Appellant George S. Bayoud, Jr. has filed a Motion 

dated January 24, 1990, joining in Judge _Entz's Motion for 

Establishment of Expedited Briefing Schedule. For the reasons 

previously set forth in the Response in Cpposition filed by 

Plaintiff-Appellee LULAC to Defendant-Intervenor-Appellant Entz's 

Motion, Plaintiff-Intervenors-Appellees oppose Bayoud's Motion. 

IIX. 

Defendant-Intervenor-Appellant Judge Wood has merely joined in 

the Motion of Judge Entz and for the reasons previously set forth in 

opposition to said Motion, Plaintiff-Intervenors-Appellees HLA, 

et al., oppose this Motion. 

lv. 

The issues that are presented to this Court as the relate to the 

Harris County voters, are complex and of such significance that it is 

necessary to have the normal briefing schedule in order to properly 

prepare. 

WHEREFORE, Plaintiff-Intervenors-Appellees Houston Lawyers 

Association, et al., respectfully request this Court to deny the 

Motion for Establishment of Expedited Briefing Schedule filed by 

Defendant-Intervenor-Appellant Wood and establish a briefing schedule 

that comports with the Court's usual time limitations which will 

provide all parties an opportunity to fully brief the complex issues 

presented in this matter. 

 



  

Respectfully submitted, 

JULIUS LEVONNE CHAMBERS 
SHERRILYN A. IFILL 

NAACP Legal Defense and 
Educational Fund, Inc. 
99 Hudson Street, l6th Floor 
New York, New York 10013 
(212) 219-1900 

OF COUNSEL: Cotihuin ty [hd Lan) 
GABRIELLE K. MCDONALD 

MATTHEWS & BRANSCOMB 301 Congress Avenue, Ste. 2050 
A Professional Corporation Austin, Texas 78701 

(512) 320-5055 

  

  

ATTORNEYS FOR PLAINTIFF- 
INTRVENORS-APPELLEES 
HOUSTON LAWYER'S ASSOCIATION, 

January 29, 1990 et al. 

CERTIFICATE OF CERTIFICATE 
  

I certify that on this. 29th day of January, 1990, I sent a 
copy of the foregoing document by first class U.S. mail to each 
of the following: 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; Renea Hicks P.O. Box 12548, 
Capitol Station, Austin, Texas 78711-2548; Edward B. Cloutman, 
TIT, 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; and John L. Hill, Jr. Liddell, Sapp, Livley, 
Hill & LaBoon, 3300 Texas Commerce Tower, Houston, Texas 77002. 

id 
ielle K. McDonald 

    

  

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5GKMdk:mld 

 



United States Court of Appeals 
FIFTH CIRCUIT 

OFFICE OF THE CLERK TEL SO SOASIE 

600 CAMP STREET 
NEW ORLEANS, LA 70130 

1990 

GILBERT F. GANUCHEAU 
CLERK 

January 30, 

Mr. Renea Hicks 

Special Assistant Attorney General 

Post Office Box 12548 

Captiol Station 

Austin, Texas 78711 

No. 90-8014 - League of United Latin American 

Citizens, Et Al. v. Judge Entz, Et Al. 

Receipt is acknowledged of the Attorney General of Texas’ motion 
to certify state law question or, alternatively, to disqualify 
counsel. Receipt is also acknowledged of appellant George S. 
Bayoud, Jr.’s response to motion to certify state law question, 
etc. and the Attorney General’s reply to that response. This is 
to advise that the above mentioned motion and responses will be 
submitted to the Court.upon completion of the briefing schedule. 

Very truly yours, 

GILBERT F. GANUCHEAU, Clerk 

By E00 & . tin altn 
Eileen C. Boudoin 

Case Manager 

  

ECB:afg 

cc: All counsel of record