Motion of American Jewish Congress for Leave to Submit a Brief Amicus Curiae and Memorandum in in Support Thereof; Order

    IN THE UNITED STATES DISTRICT COURT 

FOR THE WESTERN DISTRICT OF TEXAS 

LEAGUE OF UNITED LATIN 
AMERICAN CITIZENS, et al., 

Plaintiffs, 

vs. NO. MO-88-CA-154 

JAMES MATTOX, et al., 

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Defendants. 

MOTION OF AMERICAN JEWISH CONGRESS FOR LEAVE TO SUBMIT 
A BRIEF AMICUS CURIAE AND MEMORANDUM IN SUPPORT THEREOF 
  

American Jewish Congress moves this Court for leave to 

submit a brief amicus curiae in the above-captioned case. 
  

The American Jewish Congress is a not-for-profit 

organization of American Jews founded in 1918 to protect the 

civil, political, economic and religious rights of Americans. It 

is the Congress' belief that in a democracy, these rights depend 

upon free and fair access to the ballot and the political 

process. In accordance with that belief, the Congress has long 

advocated, both in legislatures and courts, vigorous protection 

of the right to vote. In particular, the Congress was an active 

supporter of the Voting Rights Act of 1965 and each of its 

extensions, and it was closely involved in 1982 with the 

amendments to Section 2. 

Because the decision in this case may turn on the 

construction of the amendments to Section 2, the Congress 

requests leave to submit its views on those amendments. The 

1  



  

undersigned counsel for the Congress was unaware, until October 

3, of the importance of the particular Section 2 issues to this 

case, and he could not therefore meet this Court's briefing 

schedule. Accordingly, the Congress requests that it have until 

October 15, 1989, to submit its views in a brief amicus curiae. 
  

Respectfully submitted, 

) 

Neil H. Cogan 
Attorney for American 

Jewish Congress 
Storey Hall (SMU) 
3315 Daniel Avenue 
Dallas, Texas 75275 

CERTIFICATE OF CONFERENCE 
  

I certify that I conferred with counsel for Plaintiffs, who 
consented to this Motion, but that I was unable to confer with 
counsel for Defendants herein. 

AA SL ; ( % or 

Neil H. Cogan   

CERTIFICATE OF SERVICE BY MAIL 
  

I certify that on October 5, 1989, I served this Motion for 
Leave and Memorandum and the accompanying Order upon all counsel 
herein by depositing true copies of same, enclosed in properly- 
addressed envelopes, postage prepaid, in a depository of the 
United States Postal Service. 

Neil H. Cogan 
  

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IN THE UNITED STATES DISTRICT COURT 

  

FOR THE WESTERN DISTRICT OF TEXAS 

LEAGUE OF UNITED LATIN 

AMERICAN CITIZENS, et al., 

Plaintiffs, 

VS. NO. MO-88-CA-154 

JAMES MATTOX, et al., 

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Defendants. 

ORDER 

Upon the Motion of the American Jewish Congress for leave to 

submit a brief amicus curiae, the papers in support thereof, and 
  

all the proceedings had herein, it is hereby 

ORDERED that leave is granted to the American Jewish 

Congress to file a brief amicus curiae; and it is further   

ORDERED that said brief shall be deemed timely filed if 

mailed first-class to the Court and parties on or before October 

15, 1989, 

ENTERED this day of October, 1989. 

  

HON. LUCIUS D. BUNTON, CHIEF JUDGE 
UNITED STATES DISTRICT COURT 

 



  

IN THE UNITED STATES DISTRICT COURT 

FOR THE WESTERN DISTRICT OF TEXAS 

LEAGUE OF UNITED LATIN 
AMERICAN CITIZENS, et al., 

Plaintiffs, 

vs. NO. MO-88-CA-154 

JAMES MATTOX, et al., 

Defendants. 

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ORDER 

Upon the Motion of the American Jewish Congress for leave to 

submit a brief amicus curiae, the papers in support thereof, and   

all the proceedings had herein, it is hereby 

ORDERED that leave is granted to the American Jewish 

Congress to file a brief amicus curiae; and it is further   

ORDERED that said brief shall be deemed timely filed if 

mailed first-class to the Court and parties on or before October 

15, 19390. 

ENTERED this day of October, 1989. 

  

HON. LUCIUS D. BUNTON, CHIEF JUDGE 

UNITED STATES DISTRICT COURT 

 



  

IN THE UNITED STATES DISTRICT COURT 
A 

FOR THE WESTERN DISTRICT OF TEXAS 7 

or Cr 
bo > “ 4 

LEAGUE OF UNITED LATIN ) eM 2, 
AMERICAN CITIZENS, et al., ) v0 by 

) 5 S$ 
Plaintiffs, ) hp, 

) ER 
vs. ) NO. MO-88-CA-154 

) 
JAMES MATTOX, et al., ) 

) 
Defendants. ) 

MOTION OF AMERICAN JEWISH CONGRESS FOR LEAVE TO SUBMIT 
A BRIEF AMICUS CURIAE AND MEMORANDUM IN SUPPORT THEREOF 
  

American Jewish Congress moves this Court for leave to 

submit a brief amicus curiae in the above-captioned case. 
  

The American Jewish Congress is a not-for-profit 

organization of American Jews founded in 1918 to protect the 

civil, political, economic and religious rights of Americans. It 

is the Congress' belief that in a democracy, these rights depend 

upon free and fair access to the ballot and the political 

process. In accordance with that belief, the Congress has long 

advocated, both in legislatures and courts, vigorous protection 

of the right to vote. In particular, the Congress was an active 

supporter of the Voting Rights Act of 1965 and each of its 

extensions, and it was closely involved in 1982 with the 

amendments to Section 2. 

Because the decision in this case may turn on the 

construction of the amendments to Section 2, the Congress 

requests leave to submit its views on those amendments. The 

1 

 



  

undersigned counsel for the Congress was unaware, until October 

3, of the importance of the particular Section 2 issues to this 

case, and he could not therefore meet this Court's briefing 

schedule. Accordingly, the Congress requests that it have until 

October 15, 1989, to submit its views in a brief amicus curiae.   

Respectfully submitted, 

) 9 rN 5 

{ 3 4 {ote Ml Sr 

o X 
Neil H. Cogan 

Attorney for American 
Jewish Congress 

Storey Hall (SMU) 
3315 Daniel Avenue 
Dallas, Texas 75275 

CERTIFICATE OF CONFERENCE 
  

I certify that I conferred with counsel for Plaintiffs, who 
consented to this Motion, but that I was unable to confer with 
counsel for Defendants herein. 

IA il 
( 20 A ¢ 

Neil -"H. Co gan 
  

CERTIFICATE OF SERVICE BY MAIL 
  

I certify that on October 5, 1989, I served this Motion for 
Leave and Memorandum and the accompanying Order upon all counsel 
herein by depositing true copies of same, enclosed in properly- 
addressed envelopes, postage prepaid, in a depository of the 
United States Postal Service. 

— 

Ix 2 (Re 
  

Neil H. Cogan