Houston Lawyers' Association Unopposed Motion to Extend Time for Response to Motion to Dismiss and Counterclaim; Proposed Order

    Sent Fed Exp 3/29/89 

March 29, 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 please find: 

3) Plaintiff-intervenor, Houston Lawyers' Association Motion to 
Extend Time for Answer to Defendant-intervenor Wood's Motion 
to Dismiss and Counterclaim, and 

2) Proposed Order. 

If you have any questions, please contact my office. 

  

cc: All Attorneys of Record 

  

NE HUDSON STREET . 212) 219-19 . NEW YORK, N.Y. 10013 

 



  

> 

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

MIDLAND-ODESSA DIVISION 

  

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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. 

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PLAINTIFF-INTERVENOR HOUSTON LAWYERS’ 
ASSOCIATION UNOPPOSED MOTION TO EXTEND 
TIME FOR RESPONSE TO DEFENDANT-INTERVENOR 
WOOD'’S MOTION TO DISMISS AND COUNTERCLAIM 
  

Plaintiff-intervenors, Houston Lawyers’ Association, et al., 

without opposition from any Defendant or Defendant-intervenor, 

move this court to extend the time for response to Defendant- 

intervenor Wood’s Motion to Dismiss atid counterclaim to 

Plaintiffs for an additional ten days. Plaintiff-intervenor’s 

answer would be due if this motion is granted, on April 20, 1989. 

 



This extension is requested because lead counsel for 

Plaintiff-intervenors Houston Lawyers’ Association, is currently 

preparing for trial in the case of Chisom v. Roemer, a challenge 
  

to the at large judicial election system in the First Supreme 

Court in the Eastern District of Louisiana. Trial in the Chisom 

case is scheduled to begin on April 5, 1989. 

Of Counsel: 
MATTHEWS & BRANSCOMB 

A Professional Corporation 

Respectfully submitted, 

  

JULIUS L/./CHAMBERS V 
SHERRILL A. IFILL 

99 Hudson Street, 16th Floor 
New York, New York 10013 

GABRIELLE McDONALD 
301 Congress Avenue 
Suite 2050 
Austin, Texas 78701 

 



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

MIDIAND-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. 

There being no opposition to Plaintiff-intervenor, Houston 

Lawyers’ Association, et al., motion to extend the time for 

answer to Defendant-intervenor Wood’s Motion to Dismiss and 

counterclaim an additional ten days, 

IT 18 SO ORDERED. 

Signed this day of March, 1989. 
  

  

UNITED STATES DISTRICT JUDGE  



  

CERTIFICATE OF CONFERENCE 
  

I certify that on March 29, 1989, I conferenced by telephone 

with the following attorneys for the following parties, and none 

had any opposition to the foregoing motion: 

Rene Hicks All defendants 
Eugene Clements Defendant-Intervenor Judge Sharolyn Wood 
David Richards Defendant-Intervenor Travis County 

District Judges 
Defendant-Intervenor Judge Harold Entz 

laid A IL 
74 Sherr/lyn A. Ifill 

Robert Mow 

  

CERTIFICATE OF SERVICE 
  

I certify that I served the foregoing document on all 

attorneys of record by Federal Express mail on this the 29th day 

of March, 1989. 

Juoihio A HL 
  i Sherrjyyn A. Ifil¥ 

 



  

March 29, 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. M0O-88-CA-154 

LOLAC, et al. v. Jim Mattox, et. al. 

Dear Mr. Neil: 

Enclosed please find: 

rg Plaintiff-intervenor, Houston Lawyers' Association Motion to 
Extend Time for Answer to Defendant-intervenor Wood's Motion 
to Dismiss and Counterclaim, and 

2) Proposed Order. 

If you have any questions, please contact my office. 

  

SAI/dm 

encls. 

cc: All Attorneys of Record 

  

TREET . 2) 219-19 . NEW YORK, N.Y. 10013 

 



  

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

MIDLAND-ODESSA DIVISION 

  

GC SED S00 GED CEP SED GUN MEP CSU GEC GHP MIP GID GES SED SER GA GHD ON ED GES EES GND GP EP GED GED GED SUN MED EWS GED GNP GES GES mm xX 

LEAGUE OF UNITED LATIN AMERICAN 

CITIZENS (LULAC), at 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. 

DD —————" — —— — — —— "5 — — = — — — -— — =D WE Wh w= =D w= w— .— — — = 3 

PLAINTIFF=INTERVENOR HOUSTON LAWYERS’ 
ASSOCIATION UNOPPOSED MOTION TO EXTEND 
TIME FOR RESPONSE TO DEFENDANT-INTERVENOR 
WOOD’S MOTION TO DISMISS AND COUNTERCIAIM 
  

Plaintiff-intervenors, Houston Lawyers’ Association, et al., 

without opposition fens any Defendant or Defendant-intervenor, 

move this court to extend the time for response to Defendant- 

intervenor Wood’s Motion to Dismiss and counterclaim to 

Plaintiffs for an additional ten days. Plaintiff-intervenor’s 

answer would be due if this motion is granted, on April 20, 1989. 

 



This extension is requested because lead. counsel for 

Plaintiff-intervenors Houston Lawyers’ Association, is currently 

preparing for trial in the case of Chisom v. Roemer, a challenge 
  

to the at large judicial election system in the First Supreme 

Court in the Eastern District of Louisiana. Trial in the Chisom 

case is scheduled to begin on April 5, 1989. 

Of Counsel: 
MATTHEWS & BRANSCOMB 

A Professional Corporation 

Respectfully submitted, 

  

JULIUS L/./CHAMBERS V 
SHERRIL A. IFILL 

99 Hudson Street, 16th Floor 
New York, New York 10013 

GABRIELLE McDONALD 
301 Congress Avenue 
Suite 2050 
Austin, Texas 78701 

 



  

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

MIDLAND-ODESSA DIVISION : 

  

CE CED ED ED ED GED CE GED GED GED CED GED GED CED GID GED GED GED GED GED GED GED GN GED GED GED GED GED GED GED GED GED GIO GED GED GED SED CED EEO Xx 

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. 

DD Cm tm —" —" nm —" —" —" — mn em em em a an em em am em es ew en em em em =m mn mm = em =" = a= a= Xx 

  

There being no opposition to Plaintiff-intervenor, Houston 

Lawyers’ Association, et al., motion to extend the time for 

answer to Defendant-intervenor Wood’s Motion to Dismiss and 

counterclaim an additional ten days, 

IT IS SO ORDERED. 

  

Signed this : day of March, 1989. 

  

UNITED STATES DISTRICT JUDGE 

 



  

CERTIFICATE OF CONFERENCE 
  

I certify that on March 29, 1989, I conferenced by telephone 

with the following attorneys for the following parties, and none 

had any opposition to the foregoing motion: 

Rene Hicks All defendants 
Eugene Clements Defendant-Intervenor Judge Sharolyn Wood 
David Richards Defendant-Intervenor Travis County 

District Judges 
Defendant-Intervenor Judge Harold Entz 

lane A HEL 
of Sherrylyn A. Ifiil 

Robert Mow 

  

CERTIFICATE OF SERVICE 
  

I certify that I served the foregoing document on all 

attorneys of record by Federal Express mail on this the 29th day 

of March, 1989. 

- 

Juihio A HLL 
  vi Sherrf yyn A. Ifi1Y