Plaintiffs' Response to Houston Lawyer's Association Motion to Intervene

Public Court Documents
February 2, 1989

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Plaintiffs' Response to Houston Lawyer's Association Motion to Intervene preview

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Includes Correspondence from Garrett to Clerk.

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
- e32193f8-1e7c-f011-b4cc-6045bdffa665

Cite this item

Case Files, LULAC and Houston Lawyers Association v. Attorney General of Texas Hardbacks, Briefs, and Trial Transcript. Plaintiffs' Response to Houston Lawyer's Association Motion to Intervene, 1989. e32193f8-1e7c-f011-b4cc-6045bdffa665. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/76954fea-955a-468c-88ea-20fcea67db93/plaintiffs-response-to-houston-lawyers-association-motion-to-intervene. Accessed November 07, 2025.

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    GARRETT, THOMPSON & CHANG 
ATTORNEYS AND COUNSELORS AT Liaw 

8300 DouGLAS AVENUE 

Suite 800 

PrEsTON CENTER 

DavLrLas. TExas 75225 

WILLIAM L. GARRETT. P.C. 
BRENDA HULL THOMPSON. P.C. 

SUE J. CHANG. PC. 

214-369-1952 

214-363-1022 

214-987-9887 

February 2, 1989 

U. .S. District Clerk 

200 FE. Vall 

Midland, TX 79702 

Re: MO 88 CA 154 

LULAC, et al. v. Mattox, et al. 
  

Dear Clerk: 

Enclosed for filing please find the original and one copy 

of Plaintiffs' Response to Houston Lawyer's Association Motion 

to Intervene, 

By copy of this letter, a copy of the response is being 

furnished to all counsel of record. 

— 

rr ie i TT 
’” Aol vd qT — 
Yours truly, } 

/ / fon ony 
/ A : / ™\ [fy Lo den 
LY / «7 es ’ 4 

Sls 
: William L. Garrett 

cc: NAACP Legal Defense &« 

Education fund, Inc. 

Gabrielle K. McDonald 

Renea Hicks 

 



  

IN THE UNITED STATES DISTRICT COURT 
FOR THE WESTERN DISTRICT OF TEXAS 

MIDLAND-ODESSA DIVISION 

LULAC, ET Al. 

Plaintiffs 

VS 

CIVIL ACTION NO. 

JIM MATTOX, ET AL. 
MO-88-CA-154 

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Defendants 

PLAINTIFFS' RESPONSE TO HOUSTON LAWYER'S ASSOCIATION 
MOTION TO INTERVENE 
  

Plaintiffs, LULAC, ET aAl., do. not oppose Houston lawyer's 
  

Association Plaintiffs Motion to Intervene. 

Permissive Intervention. Houston Lawyer's Association has 
  

sought permissive intervention under Rule 24h) 12). Such 

intervention ‘is wholly discretionary with the district court. 

New Orleans Public Service, supra, at 470-471. In deciding upon 
  

whether to grant a permissive intervention, a district court 

should look at (1) whether the intervenor's interests are 

adequately represented by other parties, and (2) whether they 

will significantly contribute to full development of the 

underlying factual issues in the suit. New Orleans Public 
  

Service, supra, at 472. 
  

Houston Lawyer's Association request meets these 

requirements. The participation of the NAACP Legal Defense and 

PLAINTIFFS! RESPONSE TO MOTION TO INTERVENE - PAGE 1 27/r-m-inv.ok 

 



  

Education Fund, Inc. was sought by the original plaintiffs 

herein for the purpose of assembling the data and assisting with 

the proof of the Harris County part of the litigation. Lawyers 

for that organization have spent subtantial time and resources 

gathering and analyzing that data. Theiy participation ‘will 

enable original plaintiffs to spend their limited resources on 

other parts of the litigation. 

In the alternative, in the event that the Court should 

determine that intervention 1s not proper, the original 

plaintiffs would request that the lawyers for the NAACP Legal 

Defense and Education Fund, Inc. and Hon. Gabrielle K. MacDonald 

be entered as additional attorneys of record for the black 

plaintiffs herein. 

For the foregoing reasons, Plaintiffs respectfully request 

this Court to GRANT Houston Lawyer's Association Pliantiffs 

Motion to Intervene. 

Respectfully submitted, 

GARRETT, THOMPSON & CHANG 
ATTORNEYS AT LAW 
A Partnership of 

Professional Corporations 
8300 Douglas, Suite 800 
Dallas, TX 75225 

214/ 369-1952 

ROLANDO L. RIOS 

ATTORNEY AT LAW 
SOUTHWEST VOTER REGISTRATION & 

EDUCATION PROJECT 
201 N.. St. Mary's, Suite 521 
San Antonio, TX 78205 
512/ 222-2102 

PILAINTIFFS' RESPONSE TO MOTION TO INTERVENE - PAGE 2 27/r-m~inv,.ok 

 



  

SUSAN FINKELSTEIN 
TEXAS RURAL LEGAL AID, INC. 
201 N. St. Mary's, Suite 600 
San Antonio, TX 78205 
512/ 222-2478. 

5, 

By: “ Z, \Z= i pe — 

WILLIAM L. GAPRETT 07700000   

ATTORNEYS FOR PLAINTIFFS 

CERTIFICATE OF SERVICE 
i Nc 
  

  

ail J 

certify that on this L day of February, 1989, I served 

the foregoing document on all attorneys of record, certified 

mail, return receipt requested. 7 per 

2 fo fa gt” yi 

4 7 y : {5 Pn Ltn). ms 7 
pe I GY am BT 

“——fiilliam-Ls Garrett =e 

PLAINTIFFS' RESPONSE TO MOTION TO INTERVENE - PAGE 3 27/r-m—inv.ok

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Plaintiffs' Response to Houston Lawyer's Association Motion to Intervene

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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