Submission of Relevant Parts of Record in Support of Bayoud's Emergency Application for Stay Pursuant to Rule 8(a) FRAP

    IN THE UNITED STATES COURT OF APPEALS 
PIPTH CIRCUIT 

LEAGUE OF UNITED LATIN AMERICAN 

CITIZENS (LULAC), et al., 

Plaintiffs-Appellees, 

VY. NO. 90-8014 

JIM MATTOX, et al., 

wn
 

wn
 

wn
 

wn
 

wn
 

wn
 

Wn
 

wn
 

Wn
 

wn
 

Defendants-Appellants. 

SUBMISSION OF RELEVANT PARTS OF RECORD IN SUPPORT 

OF BAYOUD’S EMERGENCY APPLICATION FOR STAY 

PURSUANT TO RULE 8(a) FRAP 

COMES NOW George S. Bayoud, Jr., ("Bayoud") Defendant- 

Appellant herein, and files this, its Submission of Relevant Parts 

Of Record In Support of Bayoud’s Emergency Application for Stay, 

and would show the Court as follows: 

1. On or about January 5, 1990, Defendant-Appellant Bayoud 

filed his Emergency Application for Stay with this Honorable Court. 

To facilitate the expeditious filing of that Application for Stay, 

Bayoud incorporated by reference certain relevant portions of the 

record which were attached to Judge Entz’s Application for Stay, 

promising that all necessary parts of the record and supporting 

affidavits would be filed under separate cover as soon as possible. 

2. On or about January 10, 1990, Defendant-Appellant Bayoud 

filed his Supplement to Secretary of State George Bayoud’s 

Emergency Application For Stay, which attached sworn affidavits 

 



  

from George S. Bayoud, Jr., Secretary of the State of Texas, and 

Melinda Nickless, Program Administrator of the Elections Admin- 

istration Section of the Elections Division, in order to comply 

with that part of Rule 8(a) of the Federal Rules of Appellate 

Procedure, which states: "if the facts are subject to dispute the 

motion shall be supported by affidavits or other sworn statements 

or copies thereof." 

3. In order to comply with the remainder of Rule 8(a) of the 

Federal Rules of Appellate Procedure, which states: "with the 

motion shall be filed such parts of the record as are relevant," 

Defendant-Appellant Bayoud hereby files in support of his Emergency 

Application for Stay the following exhibits: 

EXHIBIT "A" November 8, 1989 Findings of 
Fact and Conclusions of Law and 

Court Order. 

EXHIBIT "B" Proposed Mattox-LULAC Plan 

EXHIBIT "OQ" Motion to Certify Liability 
Determination for Appeal 
Pursuant to 28 U.S.C. §1292(b) 

EXHIBIT "D" Bayoud’s Notice of Appeal 

EXHIBIT "E" Bayoud’s December 21, 1989 
Letter to Attorney General 
Mattox 

 



  

EXHIBIT "Pp Governor Clements’ December 11, 
1989 Letter 

Respectfully submitted, 
LIDDELL, SAPP, ZIVLEY, HILL 

& LABOON 

oa 
By; ans Wang 
~ John ‘L. Hill, Jr. 

/ tate Bar No. 00000027 
(_"Andy Taylor 

State Bar No. 19727600 

3300 Texas Commerce Tower 

Houston, Texas 77002 

(713) 226-1200 

  

ATTORNEYS FOR GEORGE S. BAYOUD, 

JR., SECRETARY OF STATE OF TEXAS 

 



  

CERTIFICATE OF SERVICE 

I hereby certify that a true and correct copy of the foregoing 

instrument has been served upon all counsel of record, by overnight 

federal express, on this /0 day of January, 1990. 

    

  

ohn L.. Hill, Jr. 

WAT\LULAC.10