Notice to Take Deposition Upon Oral Examination to Cloutman

    UNITED STATES DISTRICT COURT 

WESTERN DISTRICT OF TEXAS 
MIDLAND-ODESSA DIVISION 

LULAC COUNCIL #4434, et al., 

Plaintiffs, 

VS. Civil Action No. 

MO-88-CA-154 

JIM MATTOX, et al., 

Defendants. 

NOTICE TO TAKE DEPOSITION UPON ORAL EXAMINATION   

Edward B. Cloutman, III 

Mullinax, Wells, Baab & Cloutman, P.C. 

3301 .Elm Street 

Dallas, Texas 75226-1637 

Attorney for Plaintiff-Intervenors 

Please take notice that beginning at 9:00 A.M., Central Standard 

Time, on the 8th day of June, 1989, the State Defendants in the above- 

entitled action will take the deposition of Jesse Oliver at his address, 600 

Arma Drive, Austin, Texas, upon oral examination pursuant to the Federal 

Rules of Civil Procedure, before an officer authorized by law to administer 

oaths. The oral examination will continue from day to day until completed. 

Your are invited to attend and cross-examine. 

Dated: June 1, 1989. 

2% 

“Renea-Hicks 
Special Assistant Attorney General 

  ~  



  

Javier Guajardo 
Assistant Attorney General 

P.O, Box 12548, Capitol Station 

Austin, Texas 78711-2548 

(512) 463-2085 

CERTIFICATE OF SERVICE 

1 certify that on this lst day of June, 1989, 1 sent a copy of the 

foregoing Notice To Take Deposition Upon Oral examination by first class 
United States mail, postage prepaid, to each of the following: William L. 
Garrett, Garrett, Thompson & Chang, 8300 Douglas, Suite 800, Dallas, Texas 
75225; Sherrilyn A. Ifill, NAACP Legal Defense and Educational Fund, Inc., 

99 Hudson Street, 16th Floor, New York, New York 10013: Gabrielle K. 

McDonald, 301 Congress Avenue, Suite 2050, Austin, Texas 78701; I. 

Eugene Clements, Porter & Clements, 700 Louisiana, Suite 3500, Houston, 

Texas «77002-2730; "and Robert H. Mow, Jr., Hughes & Luce, 2800 

Momentum Place, 1717 Main Street, Dallas, Texas 75201. 

  

Renea Hicks 

 



  

UNITED STATES DISTRICT COURT 

WESTERN DISTRICT OF TEXAS 
MIDLAND-ODESSA DIVISION 

LULAC COUNCIL #4434, et al., 

Plaintiffs, 

Civil Action No. 

MO-88-CA-154 

VS. 

JIM MATTOX, et al., 

Defendants. CO
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NOTICE TO TAKE DEPOSITION UPON ORAL EXAMINATION 
AND SUBPOENA DUCES TECUM 
  

  

To: Edward B. Cloutman, III 

Mullinax, Wells, Baab & Cloutman, P.C. 

3301 Elm Street 

Dallas, Texas 75226-1637 

Attorney for Rlaintiff-Intervenors 

Please take notice that beginning at 9:00 A.M., Central Standard 

Time, on the 7th day of June, 1989, at 3301 Elm Street, Dallas, Texas, the 

State Defendants in the above-entitled action will take the deposition of 

Dan Weiser, upon oral examination pursuant to Rules 26, 31, and 45 of the 

Federal Rules of Civil Procedure, before an officer authorized by law :to 

administer oaths. The witness shall produce the documents designated in 

this “document for inspection and copying. The oral examination will 

continue from day to day until completed. Your are invited to attend and 

cross-examine. 

Definition of Documents 
  

 



The term "document" means every writing or record of any type and 

description that is in your possession, control, or custody, including without 

limitation, correspondence, memoranda, stenographic or handwritten 

notes, drafts, accounts, voice recordings, reports, statistical compilations, 

work papers, data processing cards, computer tapes or printouts, or any 

other writing or records of any kind. The term "document" also includes 

every copy of a writing or record which contains any commentary or 

notation of any kind which does not appear on the original or any other 

copy. A document is deemed to be within your "control" if you have 

ownership, possession, or custody of the document or a copy thereof, or the 

right to secure the document or a copy thereof from any other person or 

public or private entity having physical possession thereof. 

The following documents, files and things are to be produced: 

1. All docusents, computer printouts and summaries of them, 

including preliminary or non-final ones, relating to every electoral 

contest in Dallas County which you have analyzed for purposes of 

this litigation. 

2 All documents, computer printouts and summaries of them, 

including preliminary or non-final ones, relating to the role of race 

and/or ethnic background in Dallas County primary and gener: 

elections for judicial offices since 1970. 

3. All documents, computer printouts and summaries of them, 

including preliminary or non-final ones, relating to voter behavior, 

including matters of racially polarized voting in Dallas County. 

4. All documents, computer printouts and summaries of them, 

including preliminary or non-final ones, relating to geographical  



compactness of an identifiable racial or ethnic group or groups in 

Dallas County. Ig 

5. All documents, computer printouts and summaries of them, 

including preliminary or non-final ones, relating to the Zimmer 

factors which you contend are present and support your claim of a 

Section 2 violation in Dallas County. 

June 1, 1989. ee Loch 
Renea Hicks 
Special Assistant Attorney General 

  

Javier Guajardo 
Assistant Attorney General 

P. O. Box 12548, Capitol Station 

Austin, Texas 78711-2548 

(512) 463-2085 

CERTIFICATE OF SERVICE 

I certify that on this 1st day of June, 1989, I sent a copy of the 

foregoing pleading by first class United States mail, postage prepaid, to 
each of the following: William L. Garrett, Garrett, Thompson & Chang, 8300 

Douglas, Suite 800, Dallas, Texas 75225; Sherrilyn A. Ifill, NAACP legal 

Defense and Educational Fund, Inc., 99 Hudson Street, 16th Floor, New 

York, New York 10013; Gabrielle K. McDonald, 301 Congress Avenue, Suite 

2050, Austin, Texas 73701: J. Eugene Clements, Porter & Clements,” 700 

Louisiana, Suite 3500, Houston, Texas 77002-2730; and Robert H. Mow, Jr. 

Hughes & Luce, 2800 Momentum Place, 1717 Main Street, Dallas, Texas 

75201. mh 

Na ech, 
Renea Hicks 
   



UNITED STATES DISTRICT COURT 
WESTERN DISTRICT OF TEXAS 
MIDLAND-ODESSA DIVISION 

LULAC COUNCIL #4434, et al., 

Plaintiffs, 

VS. Civil Action No. 

MO-88-CA-154 

JIM MATTOX, et al., 

Defendants. 

NOTICE TO TAKE DEPOSITIONS UPON ORAL EXAMINATION 
  

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

3301 Elm: Street 

Dallas, Texas 75226-1637 

Attorney for Plaintiff-Intervenors 

Please take notice that beginning at 9:00 A.M., Central Standard 

Time, on the 7th day of June, 1989, at 3301 Elm Street, Dallas, Texas, the 

State Defendants in the above-entitled action will take the depositions of 

Joan Winn White whose address is 3809 Crownshore Drive, Dallas, Texas, 

and of Fred Tinsley, Jr., whose address is 400 S. Zang, Suite 400, Dallas, 

Texas, upon oral examination pursuant to the Federal Rules of Civil 

Procedure, before an officer authorized by law to administer oaths. The 

oral examination will continue from day to day until completed. Your are 

invited to attend and cross-examine. 

Dated: June 1, 1989. 

7 

Renea Hicks 
Special Assistant Attorney General 

LA 

   



  

Javier Guajardo 

Assistant Attorney General 

P. O. Box 12548, Capitol Station 

Austin, Texas 78711-2548 

(512) 463-2085 

CERTIFICATE OF SERVICE 

1 certify that on this 1st day of June, 1989, I sent a copy of the 

foregoing Notice To Take Depositions Upon Oral examination by first class 
United States mail, postage prepaid, to each of the following: William L. 

Garrett, Garrett, Thompson & Chang, 8300 Douglas, Suite 800, Dallas, Texas 

75225; Sherrilyn A. Ifill, NAACP Legal Defense and Educational Fund, Inc., 

09 Hudson Street, 16th Floor, New York, New York 10013; Gabrielle K. 

McDonald, 301 Congress Avenue, Suite 2050, Austin, Texas 78701; J. 

Eugene Clements, Porter & Clements, 700 Louisiana, Suite 3500, Houston, 

Texas 77002-2730; and Robert H, Mow, Jr., Hughes & luce, 2800 

Momentum Place, 1717 Main Street, Dallas, Texas 75201. 

. / 
L) 2 A 

  

Renea Hicks