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

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CAR ly. YAGNER Midland-Odessa Division 
wii P. 0. Box 10708 

Midland, Texas 79702 

UNITED STATES DiIsTRICT COURT 
WESTERN DISTRICT OF TEXAS 

  

August 11, 1989 

Sherrilyn A. Ifill 

99 Hudson St., 16th Floor 

New York, NY 10013 

Re: LULAC vs. Mattox, et al 
Civil Action MO 88 CA 154 

Dear Attorney: 

Receipt of the following material is acknowledged: 

Plaintiff-Intervenor Houston Lawyers Motion for Leave of Court 
to File in Excess of Ten Requests for Admission 

The document described above is being returned for the following 
reason: 

xx Rule 300-1 of the Local Rules of this Court require that 
all pleadings in civil cases shall be furnished to the Clerk 
in duplicate by the parties to said cause 

You must include with the original and copy of the pleading 
filed with the Clerk a certificate stating the date a true 
and correct copy of the pleading was mailed to defendant or 
his counsel 

All pleadings must be signed by the moving party of his counsel 

Rule 300-1 of the Local Rules of this Court require that 
depositions, interrogatories, requests for documents, requests 
for admissions and answers and responses thereto shall not be 
filed unless on order of the court or unless they are needed 
for use in a trial or hearing. (copy of Rule 300-1 enclosed) 

  

—XX All motions submitted for filing must have a proposed order. 

Sincerely, 

CHARLES W. VAGNER. Clerk _ 

By; A BERT 

Encl 

 



August 8, 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: 

Enclosed for filing, please find Plaintiff-intervenors, Houston Lawyers’ Association’s Motion for Leave of Court to File in Excess of Ten Requests for Admission. Thank you. 

Sincerely, 

AA. UV, 4 

LY RGAS A 
/ “Sherril nA. Ifill 

SATI/dm 

encl. 

cc: All Attorneys of Record 

  

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



  

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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 

 



  

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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 Ffact- 

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, 
N py : 2 

A 32 7 
J/ ad oo yw & . — 
  

fil 
Ais Lf 5 CHAMBERS [/ 

/ 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 

 



® I 
CERTIFICATE OF SERVICE 

27% 
day of August, 1989, a 

  

  

I hereby certify that on this 

true and correct copy of the foregoing Plaintiff-intervenors 

Houston Lawyers’ Association’s Motion for Leave of Court to File 

in Excess of Ten Requests for Admission was mailed to counsel of 

record in this case by first class United States mail, postage 

pre-paid, as follows: 

William L. Garrett 
Brenda Hull Thompson 
Garrett, Thompson & Chang 
8300 Douglas, Suite 800 
Dallas, TX 75225 

Rolando L. Rios 
Southwest Voter Registration 

Education Project 
201 N. St. Mary’s, Suite 521 
San Antonio, TX 78205 

Susan Finkelstein 
Texas Rural Legal Aid, Inc. 
201 N. St. Mary’s, Suite 521 
San Antonio, TX 78205 

Edward B. Cloutman, III. 
Mullinax, Wells, Baab & 

Cloutman, P.C. 
3301 Elm 

Dallas, TX 75226-9222 

Jim Mattox 
Mary F. Keller 
Renea Hicks 
Javier Guajardo 
Attorney General’s Office 
P.O. Box 12548 

Austin, TX 78711 

J. Eugene Clements 
John E. O’Neill 
Evelyn V. Keys 
Porter & Clements 

700 Louisiana, Suite 3500 
Houston, TX 77002-2730 

Michael J. Wood 
Attorney at Law 
440 Louisiana, Suite 200 
Houston, TX 77002 

Ken Oden 

Travis County Attorney 
P.O. Box 1748 

Austin, TX 78767 

David R. Richards 
Special Counsel 
600 W. 7th Sst. 

Austin, TX 78701 

Robert H. Mow, Jr. 

Hughes & Luce 
2800 Momentum Place 

1717 Main Street 
Dallas, TX 75201 

  

[ / 9 Ed 
¥% Merrdip.- /N- - A L A 

Sherrilyn A.J Ifill 
Attorney for Plaintiff-Intervenors 
Houston Lawyers’ Association