Notice of Intention to Take Deposition by Written Questions; Cross-Interrogatories to Rodeheaver

    MATTHEWS & BRANSCOMB 
A PROFESSIONAL CORPORATION 

ATTORNEYS AT LAW 

301 CONGRESS AVENUE, SITE 2050 

  

1800 FIRST CITY BANK TOWER AUSTIN, TEXAS 7870I ONE ALAMO CENTER 

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

512-888-9261 TELECOPIER 512-320-5013 512-226-4211 

August 10, 1989 

Ms. Sherrilyn A. Ifill 
NAACP Legal Defense and 
Educational Fund, Inc. 

Suite 1600 
99 Hudson Street 
New York, New York 10013 

RE: "LULAC et al. v. Mattox, et al.i Our File 
#A-12465-0001 
  

  

Dear Sherrilyn: 

Pursuant to my letter of August 8, 1989, I enclose herewith 
a copy of the Notice of Intention to Take Deposition by Written 
Questions of Anita Rodeheaver, Harris County Clerk. 

Please call me if you have any questions regarding the 
foregoing. 

Sincerely yours, 

MATTHEWS & BRANSCOMB 
A Professional Corporation 

~ 0 . y dr 7 $ J 

A Z oF EAA 25 Zl ¢ 

Michael Breck 
Legal Assistant 

6GKMdd:klr 

Encls. 

 



“confidential” communications international, inc. 

houston 
the buckley building 

9225 katy freeway, suite 322 

houston, texas 77024 

(713) 827-1555 

san antonio 
5372 fredencksburg rd. 

suite 105 

san antonio, texas 78229 

(512) 34246475 

dallas/ft. worth 
1545 w. mockingbird In. 

suite 2044 

dallas, texas 75235 

(214) 638-0028 

metro no. 263-1190 

corpus christi 

the wilson plaza 

615 leopard, suite 715 

corpus christi, texas 78476 

(512) 884-2092 

el paso 
texas commerce bank - el paso 

201 e. main, suite 123 

el paso, texas 79901 

(945) 533-3672 

beaumont 
the petroleum building 

550 fannin street 

beaumont, texas 77704 

(409) 832-6848 

midiand-odessa, f.d. 

840 n. dixie #107 

odessa, texas 79761 

(945) 337-3994 

mcallen 
3525 n. 10th, suite | 

mcallen, texas 78501 

(512) 631-7441 

amarillo 
pioneer plaza, plaza IT 
500 s. tyler, suite 204 

lobby box #243 

amarillo, texas 79184 

(804) 374-3833 

lubbock 

republic bank - university plaza 

1901 university, suite 302 

lubbock, texas 79408 

(8068) 747-6411 

brownsville 

855 w. price road, suite 8 

brownsville, texas 78520 

(512) 542.7292 

Attention: 

» 9 RECEIVED 
JuL 2 7 1989 austin 

petroleum tuilding 

SCOMB 1524 south i-h 35, suite 130 
MATTHEWS & BRAN austin, texcs 78704 

(512) 443-0331 

Date. JULY 26..1989 
  

GABRIELLE K. MCDONALD 
  

MATTHEWS & BRANSCOMB 
  

Causa it MO-88-CA-154 
  

WILLIAM CLEMENTS, GOVERNOR OF THE   

LEAGUE OF UNITED LATIN AMERICAN VS. 
  

CITIZENS (LULAC)., ET AL STATE OF TEXAS, ET AL   

Records pertain to: 

Custodian: 

see DthoY 

  

HARRIS COUNTY VOTERS 
  

HARRIS COUNTY CLERK/ANITA RODEHEVER 
  

More information is needed to locate the records/custodian. 

Unable to locate the records, would you like an Affidavit of No Record? 

Records have been destroyed, would you like an Affidavit of No Record? 

Custodian is charging $ 
custodian fee acceptable to you? 

Additionally there will be our normal fees. Is the   

Custodian will not release the records without an authorization. 

Records are included with those of 
therefore, we are cancelling this part of your order unless further advised by your office. 
  

The opposing counsel will not waive the notice period. The waiver period is up on 
AUGUST 11, 1939 we will obtain the records after this date.   

  

  

Please advise. 
  

  

  

| am handling your order. If | can be of further assistance, please contact me. Thank you for your continued 
support.  



  

  

  

  

IN THE FEDERAL COURT OF THE UNITED STATES R E CE | VE D 
OF THE WESTERN DISTRICT OF TEXAS 

MIDLAND-ODESSA DIVISION AUG 1989 

LEAGUE OF UNITED LATIN AMERICAN U. o DISTRI: Loud] 
CITIZENS (LULAC), ET AL By wh ER 

PLAINTIFF Ba 

VS. MO-88—CA-154 

WILLIAM CLEMENTS, GOVERNOR OF THE CIVIL ACTION NUMBER __ pr 
STATE OF TEXAS: JIM MATTOX, ATTORNEY CLERK, US. D190 ne Texas 
GENERAL OF THE STATE OF TEXAS: JACK SOUTHERN NED 

RAINS, SECRETARY OF STATE OF THE STATE TARE 
OF TEXAS, ET AL 8 1989 

DEFENDANT AUG 

NOTICE OF INTENTION TO TAKE DEPOSITION BY WRITTEN QUESTIONS ~LERY 
JESSE E. CLARK, CL="7 

To: DEFENDANTS /ALL by and through their 
  

attorney(s) of record JIM MATTOX 
  

  To other party/parties by and through their attorney(s) of record _ SEE ATTACHMENT 

  

You will please take notice that after thirty (30) days from the service of a copy hereof with attached questions, a 

deposition by written questions will be taken of the 

Custodian of Records For: _ HARRIS COUNTY CLERK/ANITA RODEHEVER LOCATED IN HOUSTON, 
  

HARRIS COUNTY, TEXAS 

before a Notary Public in the State of Texas for 
CONFIDENTIAL COMMUNICATIONS INTERNATIONAL, INC. 

1524 SOUTH I-H 35, SUITE 130, AUSTIN, TEXAS 78704 

  

Which deposition with attached questions may be used in evidence upon the trial of the above styled and numbered 

cause pending in the above named court. 

Notice is further given that request is here made as authorized under Rule 45, Federal Rules of Civil Procedure, to 

the officer authorized to take this deposition to issue a subpoena duces tecum and cause it to be served on the 

witness 10 produce all documents indicating the 1980, 1988 and 1989 total number of registered 

voters for Harris County; all documents indicating the number of registered voters by 

ethnic race (Black, White, Hispanic, Native American, Asian) in Harris County for 1980, 

1988 and 1989; all documents describing the methods used by you, your employees and the 

Harris County Clerk's office to register voters in Harris County and a map of electoral 

precincts in Harris County for the following years: 1980, 1982, 1984, 1986, 1988 and 1989. 

and to turn all such records over to the officer authorized to take thjs deposition so that photographic reproduc- 

tions of the same may be made and attached to said deposition. LA ATA 

( GABRIELLE K. MCDONALD 

  

  

    

  

  

Attorney for 

PLAINTIFF/HOUSTON LAWYERS ASSOCIATION 

( INTERVENING PLAINTIFFS) 

Should you desire copies of the so obtained, TX$#03546000 
contact our firm. 512-443-0331 

 



CERTIFICATE OF SERVICE 

® » 
+ § certify that a true and exact copy of the 1oregoing Notice Of Intention To Take Deposition by Written Ques. 

tions was transmitted to the respective parties and/or attorneys of record by registered mail, postage prepaid, 

    

    

or hand delivered. 

Datsd: JULY 20, 1989 by Sylva] oe Peg ir 
) NERY) 

DARRELL SMITH JIM MATTOX 
ATTORNEY AT LAW MARY F. KELLER 
10999 INTERSTATE HWY 10, #905 RENEA HICKS 
SAN ANTONIO, TX 78230 
(512) 641-9944 
DEF: DISTRICT JUDGE SHAROLYN WOOD 

JAVIER GUAJRARDO 
P.O. BOX 12548 
CAPITOL STATION 
AUSTIN TX 78701 

JOHN E. O'NEILL DEFENDANTS 
J. EUGENE CLEMENTS 

EVELYN V. KEYES KEN ODEN 
PORTER & CLEMENTS 

700 LOUISIANA #3500 P.O. BOX 1748 
BOUSTON TX 77002-2730 AUSTIN TX 78767 

(713) 226-0600 DEF. INTERVENORS: TRAVIS QOUNTY DISTRICT 
DEF: DISTRICT JUDGE SHAROLYN WOOD JUDGES 

TRAVIS COUNTY ATTORNEY 

MICHAEL J. WOOD 
ATTORNEY AT LAW 

4400 LOUISIANA $200 600 W. 7TH STREET 
BOUSTON TX 77002 AUSTIN TX 78701 

(713) 228-5105 DEF. INTERVENORS: TRAVIS COUNTY DISTRICT 
DEF: DISTRICT JUDGE SHAROLYN WOOD GES 

DAVID R. RICHARDS 
SPECIAL COUNSEL 

WILLIAM L. GARRETT 
GARRETT, THOMPSON & CHANG 

ROBERT H. MOW, JR. 
BUGHES & LUCE 

8300 DOUGLAS #800 
DALLAS TX 75225 
PL: LEAGUE OF UNITED LATIN 

AMERICAN CITIZENS 

ROLANDO L. RIOS 
ATTORNEY AT LAW 
201 N. ST. MARY'S #221 
SAN ANTONIO TX 78205 

SUSAN FINKELSTEIN 

ATTORNEY AT LAW 
201 N. ST. MARY'S #600 
SAN ANTONIO TX 78205 
PL: TEXAS RURAL AIDE INC. ° 

EDWARD B. CLOUTMAN,III 
MULLINAX, WELLS, BAAB & CLOUTMAN 

3301 ELM STREET 
DALLAS TX 75226-1637 
PL. INTERVENORS: JESSE OLIVER, FRED 

TINSLEY AND JOAN WINN WHITE 

E. BRICE CUNNINGHAM 
777 SO. R.L. THORNTON FREEWAY $121 
DALLAS TX 75203 
PL. INTERVENORS: JESSE OLIVER, FRED 

TINSLEY AND JOAN WINN WHITE 

2800 MOMENTUM PLACE 
1717 MAIN STREET 
DALLAS TX 75201 
DEF. INTERVENORS: JUDGE HAROLD ENTZ 

MARK H. DETTMAN 
ATTORNEY AT LAW 
P.O. BOX 2559 
MIDLAND TX 79702 
DEF. INTERVENORS: MIDLAND COUNTY AND 

DISTRICT JUDGES 

 



   
AO 90 “(Rev. 5/85) Deposition Subpoena @ 

 Hnited States Bistrict (Tourt 
  
  

SOUTHER TRICT OF 7 , HOUSTON DIVISION 
WESTERN _ pSTRICT OF — TEXAS 

MIDLAND—-ODESSA DIVISION 

  
  

LEAGUE OF UNITED LATIN AMERICAN : 
CITIZENS (LULAC) , ET AL DEPOSITION SUBPOENA 

WILLIAM CLEMENTS, GOVERNOR OF 

THE STATE OF TEXAS, ET AL CASE NUMBER: MO-88-CA-154 

  

TYPE OF CASE SUBPOENA FOR 

XciviL CeriMinaL CJ person [3 DOCUMENT(S) or OBJECTS)   
  

TO: 

HARRIS COUNTY CLERK/ANITA RODEHEVER 

1001 PRESTON STREET 
HOUSTON TX 77002 

YOU ARE HEREBY COMMANDED to appear at the place, date, and time specified below to testify at the taking of a 

deposition in the above case. 
  

PLACE DATE AND TIME 

AT THE OFFICE OF: 1001 PRESTON STREET 
HOUSTON: TX 77002 INSTANTER 1989 

  
  

YOU ARE ALSO COMMANDED to bring with you the following document(s) or object(s):* 

FOR INSPECTION AND PHOTOCOPYING OF ALL DOCUMENTS INDICATING THE 1980,1988 AND 1989 TOTAL 

NUMBER OF REGISTERED VOTERS FOR HARRIS COUNTY; ALL DOCUMENTS INDICATING THE NUMBER OF 

REGISTERED VOTERS BY ETHNIC RACE (BLACK, WHITE, HISPANIC, NATIVE AMERICAN, ASIAN) IN 

HARRIS COUNTY FOR 1980, 1988 AND 1989; ALL DOCUMENTS DESCRIBING THE METHODS USED BY YOU, 

YOUR EMPLOYEES AND THE HARRIS COUNTY CLERK'S OFFICE TO REGISTER VOTERS IN HARRIS COUNTY 

AND A MAP OF ELECTORAL PRECINCTS IN HARRIS COUNTY FOR THE FOLLOWING YEARS: 1980, 1982, 

1984, 1986, 1988 AND 1989. 

[J Please see additional information on reverse 

Any subpoenaed organization not a party to this suit is hereby admonished pursuant to Rule 30(b)(6), Federal Rules of Civil Proce- 

dure, to file 8 designation with the court specifying one or more officers, directors, or managing agents, or other persons who con- 

sent to testify on its behalf, and setting forth, for each person designated, the matters on which he will testify or product docu- 

ments or things. The persons so designated shall testify as to matters known or reasonably available to the organization. 

  

  

  
  

U.S. MAGISTRATE OR CLERK OF COURY DATE 

JESSE E. CLARK, Clerk : 

| AUG 8 ws 
BY) En Alpin 

Sv 

Lo QUESTIONS MAY BE ADDRESSED TO: 

elon is issued/¥pon application of the: GABRIELLE K. MCDONALD V 

MATTHEWS & BRANSCOMB 

I Pisintitt [J Defendant [ u.s. Attomey 301 CONGRESS AVENUE #2050 
: : AUSTIN TX 78701 512-320-5055 . 

ATTORNEY'S NAME, ADDRESS AND PHONE NUMBER   
  

*%f not sophcable, emer “none”. 

 



    AO 90 (Rew. 5/85) Deposition A 

  

RETURN OF SERVICE) 
  

  

    
  

  

  

  
  

  

RECEIVED DATE PLACE 

BY SERVER 

DATE i PLACE 

SERVED 

SERVED ON (NAME) : FEES TENDERED 

Ovyes [Ono AMOUNT $ 

SERVED BY TITLE 

STATEMENT OF SERVICE FEES 
TRAVEL SERVICES TOTAL 

    
  DECLARATION OF SERVERI(2) 
  

| declare under penalty of perjury under the laws of the United States of America that the foregoing 

information contained in the Return of Service and Statement of Service Fees is true and correct. 

Executed on 
  

Date Signature of Server 

  

Address of Server 

  
ADDITIONAL INFORMATION 

    
  

(1) As to who may serve a subpoena and the manner of its service see Rule 17(d), Federal Rules of Criminal Procedurs, or Rule 45(c), Federal Rules of Civil 

Procedure. 

(2) "Fees and mileage need not be tendered to the deponent upon service of a subpoena Issued on behalf of the United States or an officer or agency thereof 

(Rule 45(c), Federal Rules of Civil Procedure; Rule 17(d), Federal Rules of Criminal Procedure) or on behalf of certain indigent parties and criminal 

defendants who are unable to pay such costs (28 USC 1825, Rule 17(b) Federal Rules of Criminal Procedures)’. 

 



  

» 

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

MIDLAND-ODESSA DIVISION 

  

PLAINTIFFS 

  

CIVIL ACTION NUMBER 

  

DEFENDANTS 

DIRECT QUESTIONS TO BE PROPOUNDED TO THE WITNESS, CUSTODIAN OF RECORDS FOR: 

  

STATE YOUR NAME, ADDRESS AND OCCUPATION. 

STATE HOW LONG YOU HAVE SERVED IN YOUR PRESENT OCCUPATION. 

STATE WHETHER YOU WERE ELECTED OR APPOINTED TO OFFICE, AND IF APPOINTED, BY 

WEOM. 

PLEASS STATE THE TOTAL NUMBER OF REGISTERED VOTERS IN HARRIS COUNTY. 

PLEASE STATE THE TOTAL VOTING AGE POPULATION FOR HARRIS COUNTY. 

PLEASE STATE THE TOTAL NUMBER OF REGISTERED VOTERS WHO ARE BLACK, WHITE, HISPANIC, 

NATIVE AMERICAN AND ASIAN IN HARRIS COUNTY. 

PLEASE DESCRIBE THE METHODS USED BY YOU, YOUR EMPLOYEES AND THE HARRIS COUNTY 

CLERK'S OFFICE TO REGISTER VOTERS IN HARRIS COUNTY, INCLUDING HOW LONG THESE 

METHODS HAVE BEEN PRACTICED BY THE PERSONNEL AND EMPLOYEES OF THE HARRIS COUNTY 

CLERK'S OFFICE. 

PLEASE IDENTIFY EACH METHOD BY WHICH AN ELIGIBLE VOTER CAN REGISTER TO VOTE IN 

HARRIS COUNTY. 

 



  

10. 

ll. 

J. 

13. 

STATE WHETHER OR NOT YOU HAVE IN YOUR CUSTODY OR SUBJECT TO YOUR CONTROL ANY 

AND ALL DOCUMENTS AS DEFINED IN EXHIBIT 1 ATTACHED HERETO. 

PLEASE HAND TO THE NOTARY PUBLIC TAKING THIS DEPOSITION THE ORIGINALS OF ALL 

SUCH DOCUMENTS. 

PLEASE STATE WHETHER OR NOT THE RECORDS YOU HAVE FURNISHED TO THE NOTARY 

PUBLIC IN RESPONSE TO REQUEST NO. 9 WERE KEPT IN THE REGULAR COURSE OF YOUR 

BUSINESS. 

PLEASE STATE WHETHER THESE RECORDS YOU HAVE FURNISHED TO THE NOTARY PUBLIC 

ARE KEPT IN THE REGULAR COURSE OF BUSINESS OR TRANSMITTED IN THE REGULAR 

COURSE OF BUSINESS TO OR BY YOU OR ONE OF YOUR EMPLOYEES WITH PERSONAL 

KNOWLEDGE OF THE ACTS RECORDED. 

PLEASE STATE WHETHER OR NOT THE RECORDS YOU HAVE FURNISHED TO THE NOTARY 

PUBLIC IN RESPONSE TO THE FOREGOING QUESTIONS WERE MADE AT OR NEAR THE TIME 

OF THE ACTS WHICH ARE RECORDED, OR REASONABLY SOON AFTER. 

 



  

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

MIDLAND-ODESSA DIVISION 

  

VS 

PLAINTIFFS 

  

CIVIL ACTION NUMBER 

  

DEFENDANTS 

ANSWER SHEET FOR DIRECT QUESTIONS PROPOUNDED TO THE WITNESS: 

  

  

  

  

  

  

  

  

  

  

  

  

  

  

  

  

  

 



  

  

  

  

  

  

  

  

  

  

  

  

  

  

  

  

  

  

  

  

  

  

  

  

  

  

  

  

  

   



  

  

WITNESS (CUSTODIAN OF RECORDS) 

BEFORE ME, THE UNDERSIGNED AUTHORLTY, ON THL1S DAY PERSONALLY 

APPEARED » CUSTODIAN OF 
  

RECORDS FOR HARRIS COUNTY CLERK 

KNOWN T0 ME TO BEC TIE FERSON WIIOSE NAHL 15 SUNSCRIBED TO TIE FOREGOING IN- 

STRUMENT 1N TUE CAPACLTY THEREIN STATED, AND BCING DULY SWORN, ACKNOWLEDGED 

T0 ME THAT THE ANSWERS 10 THE FOREGOLNG QUESTIONS ARE TRUE AS STATED. 

  

GIVEN UNDER MY HAND AND SEAL OF OFFICE, TILS DAY OF 
  

  

19 . 
  

  

NOTARY PUBLIC IN AND FOR 
THE STATE OF TEXAS 

MY COMMLISS1ON EXPIRES 
  

GABRIELLE K. MCDONALD TX.#03546000 
  

ATTORNEY FOR 
HOUSTON LAWERY ASSOCIATION 

 



  

IN THRE UNITED STATES DISTRICT COURT 

FOR THE WESTERN DISTRICT OF TEXAS 

MIDLAND-ODESSA DIVISION 

LEAGUE OF UNITED LATIN AMERICAN 
CITIZENS (LULAC), ET AL 

Vs. 
C. A. MO-88-CA-154 

WILLIAM CLEMENTS, GOVERNOR OF THE 

STATE OF TEXAS, JIM MATTOX, 

ATTORNEY GENERAL OF THE STATE OF 

TEXAS, JACK RAINS, SECRETARY OF 

STATE OF THE STATE OF TEXAS, ET AL A
W
 

W
D
D
 

D
W
 

CROSS-INTERROGATORIES 
  

TO: Anita Rodeheaver, County Clerk, 1001 Preston, 4th Floor, 

Houston, Texas 77002 

Pursuant to the Federal Rules of Civil Procedure, Judge 

Sharolyn Wood, Defendant-Intervenor, requests that Anita 

Rodeheaver, County Clerk for Harris County, Texas, answer the 

following Cross-Interrogatories. 

INSTRUCTIONS 
  

1. When responding to the following interrogatories, 

please consider all necessary reports, incidents, and/or 

observations which occurred in the last ten (10) years. 

2. Please attach all copies of reports and/or documents 

mentioned in your responses, and please include any documents 

and/or reports which both form the basis of your opinions and 

commemorate any incidents described in your responses. 

i: 38 Each Cross-Interrogatory below shall operate and be 

construed independently, and unless otherwise indicated no 

 



  

OF COUNSEL: 

PORTER & CLEMENTS 

700 Louisiana, Suite 3500 
Houston, Texas 77002-2730 

713/226-0600 

CERTIFICATE OF SERVICE 
  

T hereby certify that astrue and correct copy of the 

foregoing Cross-Interrogatories has been forwarded to all counsel 

of record on this  ~...: day of -X WE , 1989, 
as follows: i / 

    

Rolando L. Rios 
Southwest Voter Registration & 

Education Project 
201 N. St. Mary's, Suite 521 
San Antonio, Texas 78205 

Mr. Jim Mattox 
Attorney General's Office 
P. O. Box 12548 
Austin, Texas 78711 

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

Mr. Robert H. Mow, Jr. 

Hughes & Luce 
2800 Momentum Place 

1717 Main 
Dallas, Texas 75201 

Mr. Darrell Smith 
10999 Interstate Hwy. 10, #905 
San Antonio, Texas 78230 

Mr. William L. Garrett 
Garrett, Thompson & Chang 
8300 Douglas, Suite 800 
Dallas, Texas 75225 

Ms. Susan Finkelstein 
Texas Rural Legal Aid, Inc. 
201 N. 8t. Mary's, Suite 600 

San Antonio, Texas 78205 

 



  

Mr. Julius Levonne Chambers 
NAACP Legal Defense and 

Educational Fund, Inc. 
99 Hudson Street, 16th Floor 
New York, New York 10013 

Ms. Gabrielle K. McDonald 

Matthews & Branscomb 

301 Congress Avenue, Suite 2050 

Austin, Texas 78701 

Mr. Edward B. Cloutman, III 

Mullinax, Wells, Baab & Cloutman 
3301 Elm SE. 
Dallas, Texas 75226-1637 

Mr. E. Brice Cunningham 
777 8S. R. 1... Thornton Pwy, Ste. 121 
Dallas, Texas 75203 

Mr. Ken Oden 
Travis County Attorney 
P. O. Box 1748 
Austin, Texas 78767 

Mr. David R. Richards 
Special Counsel 
600 W. 7th Street 
Austin, Texas 78701 

Mr. Mark H. Dettman Ms. Sherrilyn A. Ifill 

Attorney at Law NAACP Legal Defense and 

P.- 0. Box 2559 Educational Fund, Inc. 

Midland, Texas 79702 99 Hudson Street, 16th Floor 

New York, New York 10013 

\ 

EEE, (I i ee LE TI 
/ > — 

FT. Eugene Clements 
  

— 

DJs/dd 
DJS/004 

 



  

Cross-Interrogatory limits the scope of any other 

Cross-Interrogatory. 

4. In answering these Cross-Interrogatories, you are 

requested to furnish such information as is avallable to you, 

including information which you are able to obtain by due 

diligence from your staff, employees, agents, or other persons 

acting on your behalf. 

CROSS-INTERROGATORIES 
  

1, Please state how long you have been the County Clerk for 

Harris County, Texas. 

2. Please describe the responsibilities of your office with 

respect to elections for district court judges in Harris 

County. 

3. Specifically, state whether it is one of the 

responsibilities of your office to receive claims of (a) 

vote fraud, (b) voter discrimination and/or (c) electoral 

discrimination. 

4. Please state whether any racially or ethnically motivated 

incidents of voting-related discrimination during a Harris 

County election for district judges have been reported +o 

your office. 

5. If so, please describe any such reports, and state the dates 

when they were filed or attach copies. 

6. Please state whether any reports have come to your attention 

during any Harris County election for district judge where 

racially or ethnically motivated actions or statements by a 

candidate affected the election process, or, in your 

opinion, determined an election outcome. 

 



If so, please describe any reports which form the basis of 
your answer, and state the dates when they were filed. 

Please state whether any political group has been able to 

control the selection of a slate of candidates for district 
judge in Barris County so as to inhibit’ the ‘election of 
Blacks and Hispanics to judicial office, and if so, please 
identify both the groups and candidates involved. 

Please state whether any campaign for a district judgeship 
in Harris County has included appeals or issues relating 
directly or indirectly to discrimination based on race or 

ethnicity. 

If so, please give the dates of such campaigns, the names of 
the candidates and describe the specific issues involved. 

Please state whether, in any campaign for district judge in 
Harris County, any political parties or groups have directly 
or indirectly either excluded Blacks and/or Hispanics from, 
or restricted their access to, the political process in any 

race for a district judge position in Harris County. 

If so, please identify the groups and candidates involved 
and state the date of the campaigns during which such 

incidents occurred. 

Please state whether during any campaign for district judge 
in Harris County it has been reported to your office that 
any candidate has made overt or subtle racial or ethnic 
voter appeals, and if so, please describe. 

Please state whether during any campaign for district Judge 
in Harris County it has been reported to your office that 
any organization or group has made overt or subtle racial or 

ethnic voter appeals, and if so, please describe. 

Please state whether any group or organization has been 
reported to have either attempted to influence or coerce 
White voters or White groups into voting against Hispanic or 
Black candidates in a Harris County election for district 

judge.  



  

16. Please state whether any "Black or ‘Hispanic ‘group or 

organization has been reported to have either attempted to 
influence or to coerce Black or Hispanic voters or Black or 
Hispanic groups into voting against White candidates in a 

Harris County election for district judge. 

17. Please state whether any law, rule or regulation pertaining 
to a Harris County election prohibits bullet voting. 

18. Please state whether any incidents of racial hostility or 
tension between Hispanic or Black and White candidates 
during any campaign or election for district judge in Harris 
County have been reported to your office. 

19. If so, please describe any such reports, and state the dates 

when they were filed. 

20. Please state whether, in your opinion, during any election 
for Harris County district judge White bloc voting has 
impaired the access of Blacks or Hispanics to the electoral 
process and/or minimized or cancelled Black or Hispanic 
voters' abilities to elect representatives of their own 
choice. If so, please explain your answer fully. 

21. Please state whether, in your opinion, Blacks .and/or 
Hispanics, individually or collectively, form a politically 
cohesive group in Harris County, Texas. 

Respectfully submitted, 

PORTER & CLEMENTS 

  

  

  

: : 

=< SG 
Neer Ar 

\ Jl. Eugene Clements - 

\. ~~ Federal ID Number 928 
hi, 00 Louisiana, Suite 3500 
Np 00 rou Texas 77002-2730 

713/226-0600 

ATTORNEY-IN-CHARGE FOR DEFENDANT- 

INTERVENOR JUDGE SHAROLYN WOOD 

 



=) IN THE FEDERAL COURT OF THE UNITED STATES 

FOR THE WESTERN DISTRICT OF TEXAS 

MIDLAND-ODESSA DIVISION 

- 

  

LEAGUE OF UNITED LATIN AMERICAN 
CITIZENS (LULAC), ET AL 

PLAINTIFF 
  

VS. 

WILLIAM CLEMENTS, GOVERNOR OF THE 
STATE OF TEXAS: JIM MATTOX, ATTORNEY MO-88-CA-154 
GENERAL OF THE STATE OF TEXAS: JACK CIVIL ACTION NUMBER 
RAINS, SECRETARY OF STATE OF THE STATE 

OF TEXAS, ET AL 

  

  

DEFENDANT 

ANSWERS TO CRUSS QUESTIONS PROPOUNDED TO THE WITNESS, CUSTODIAN OF RECORDS FOR: 

HARRIS COUNTY CLERK/ANITA RODEHEAVER 
  

  

  

  

  

  

  

  

  

  

  

  

  

  

  

  

  

 



  

11. 

12. 

13. 

13. 

leo. 

17. 

18. 

lo. 

20. 

21. 

  

  

  

  

  

  

  

  

  

  

  

  

  

  

  

  

  

  

  

  

  

  

  

  

  

  

 



  

  

WITNESS (CUSTODIAN OF RECORDS) 

BEFORE ME, THE UNDERSIGNED AUTHORITY, ON THIS DAY PERSONALLY 

APPEARED : s CUSTODIAN OF 
  

RECORDS FOR HARRIS COUNTY CLERK/ANITA RODEHEAVER 

KNOWN TO ME TO BE THE PERSON WHOSE NAME IS SUBSCRIBLD TO THE FOREGOING IN- 

STRUMENT IN THE CAPACITY THEREIN STATED, AND BEING DULY SWORN, ACKNOWLEDGED 

T0 ME THAT THE ANSWERS TO THE FOREGOING QUESTIONS ARE TRUE AS STATED. I 

FURTHER CERTIFY THAT THE RECORDS ATTACHED HERETO ARE EXACT DUPLICATES OF 

THE ORIGINAL RECORDS. 

  

GIVEN UNDER MY HAND AND SEAL OF OFFICE, THIS DAY OF 5 
  

  

19 ® 

  

  

NOTARY PUBLIC IN AND FOR 
THE STATE OF TEXAS 

MY COMMISSION EXPIRES 
  

J. EUGENE CLEMENTS 
  

ATTORNEY FOR 

DEFENDANT/JUDGE SHAROLYN WOOD 

FEDERAL ID NUMBER 928