Plaintiffs' First Set of Interrogatories and First Request for Production to Defendant-Intervenors Wood; Thirteen Defendant-Intervenors from Travis County; and to Entz

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

MIDLAND-ODESSA DIVISION 

LULAC, et al., 

Plaintiffs, 

VS. NO. MO-88-CA-154 

MATTOX, et al., 

 
%
*
 

%* 
* 

* 
* 

* 
* 

* 

Defendants. 

PLAINTIFFS’ FIRST SET OF INTERROGATORIES 
TO DEFENDANT-INTERVENOR WOOD 

TO: Defendant-Intervenor Wood c/o J. Eugene Clements, John E. 
O'Neill, Evelyn V. Keys, Porter and Clements, 700 Louisiana, Suite 
3500, Houston, Texas 77002-2730 and Darrell Smith, 10999 Interstate 
Highway 10, Suite 905, San Antonio, Texas 78230. 

Plaintiffs, by their attorneys, pursuant to Rules 26 and 33 

of the Federal Rules of Civil Procedure, request the Defendant- 

Intervenor, or any officer, agent or employee of Defendant- 

Intervenor who has such information as is available, to answer in 

writing and under oath, each and every one of the following 

interrogatories. Pursuant to the Court’s Order of February 27, 

1989, all responses are due within fifteen (15) days after service. 

These interrogatories are continuing to the extent required by Rule 

26 (e), Federal Rules of Civil Procedure. 

Unless otherwise stated, the terms "identify," "identity" or 

"identification" mean when used in reference to: 

A. A natural person, his or her: 

Y. full name; 

2. present or last known home and business address, 

 



  

including street name and number, city or town and 

state; 

3. present or last known home and business telephone 

number; and 

4. present or last known position, job title and job 

description. 

B. A company, corporation, association, partnership, joint 

venture, or any legal entity other than a natural person, its: 

1. full name and type of organization or entity; 

2. address of principal place of business; and 

3 business telephone number. 

A document, its: 

1. date and title; 

2. author; 

3. addressee; 

4 a precise description of the contents thereof; and 

5. the identity of the person having possession of the 

document. 

D. An election, the: 

1. date; 

2 type of election, specifically state, county, city, 

primary election, general election, or referendum: 

3. identity of the person having possession of the 

official returns by precinct. 

The terms, "document" or "documents" mean all writing of any 

kind (including the originals and all non-identical copies, whether 

different from the original by reason of any notation made on such 

 



  

copies or otherwise), regardless of their origin or location, 

including without limitation, correspondence, memoranda, notes, 

diaries, statistics, letters, telegrams, minutes, contracts, 

reports, studies, applications and proposals for federal and state 

financial assistance, checks, statements, receipts, returns, 

summaries, pamphlets, books, charts, maps, interoffice and 

intraoffice communications, notations of any sort of conversations, 

bulletins, printed matter, computer printouts, teletypes, telefax, 

worksheets and drafts, alterations, modifications, changes, and 

amendments of any of the foregoing, graphic or aural records or 

representations of any kind (including without limitation, 

photographs, charts, graphs, microfiche, videotapes, recordings, 

motion pictures) and electronic, mechanical or electric records or 

representations of any kind (including without limitation, tapes, 

cassettes, mag cards, disks, and recordings). 

The term "all documents" means every document as above defined 

known to you and every such document which can be located or 

discovered by reasonably diligent efforts. 

The term "person" means any natural person, corporation, 

partnership, proprietorship, association, organization or group of 

natural persons. 

The terms "you" or "your" mean the Defendant-Intervenor and 

all other persons acting or purporting to act on her behalf. 

If a request is made for the identification of documents which 

are no longer in your possession or subject to your control, state 

when and what disposition was made of them. 

For each interrogatory, or part of an interrogatory, which you 

 



  

refuse to answer on the grounds of privilege (the term "privilege" 

includes work product): 

a. state the nature of the privilege and the basis upon 

which the claim of privilege is made; and 

b. in addition, if the claim of privilege is asserted 

with regard to a document, a precise description of 

the contents of the documents. 

INTERROGATORY NO. 1: Please identify by name, business and 

residential address, telephone number, place of employment and job 

title each of the persons known to you who has any knowledge 

regarding the facts that base any claim or defense that you plan 

to raise in this lawsuit. 

INTERROGATORY NO. 2: Please identify by name, business and 

residential address, telephone number, place of employment and job 

title each of the expert witnesses who you expect to call to 

testify should this case go to trial and state the nature of the 

testimony that you expect each expert witness to give. 

INTERROGATORY NO. 3: Please state the nature of any claim or 

defense that you intend to present at trial that does not arise out 
  

of facts that took place, will take place or take place in Harris 

County. 

INTERROGATORY NO. 4: Please identify by year, type of election 

(general, Democratic/Republican primary, Democratic/Republican run 

off), candidate and type of office each election that you claim is 

relevant to your claims. 

Dated: April 11, 1989 

 



  

Respectfully submitted: 

GARRETT, THOMPSON & CHANG 
ATTORNEYS AT LAW 
A Partnership of Professional 
Corporations 

William L. Garrett 
Brenda Hull Thompson 
8300 Douglas #800 
Dallas, Texas 75225 
(214)369-1952 
LEAD COUNSEL 

ROLANDO L. RIOS 

ATTORNEY AT LAW 

201 N. St. Mary's #521 
San Antonio, Texas 78205 
(512)222-2102 

SUSAN FINKELSTEIN 

STAFF ATTORNEY 
TEXAS RURAL LEGAL AID, INC. 
201 N. St. Mary's #600 
San Antonio, Texas 78205 
(512)222-2478 

ATTORNEY FOR PLAINTIFFS 
  

CERTIFICATE OF SERVICE 
  

I, Susan Finkelstein, do hereby certify that a true and 

correct copy of Plaintiff's First Set of Interrogatories to 

Defendant-Intervenor Wood has been mailed via certified mail with 

correct postage to: 

 



  

ATTORNEY 
  

Plaintiff - Intervenors 
  

Edward B. Cloutman, III 
MULLINAX, WELLS, BAAB & 

CLOUTMAN, P. C. 
3301 Elm 
Dallas, TX 75226-9222 
214/939-9222 FAX: 214/939-9229 

E. Brice Cunningham 
Attorney at Law 
777 S. R. L. Thornton Fwy, Suite 121 
Dallas, TX 75203 
214/428-3793 

Julius Levonne Chambers 
Sherrilyn A. Ifill 
NAACP Legal Defense & Educational 

Fund, Inc. 
99 Hudson St., 16th floor 
New York, NY 10013 
212/219-1900 

Gabrielle K. McDonald 
MATTHEWS & BRANSCOMB 
301 Congress Ave., Suite 2050 
Austin, TX 78701 
512/320-5055 

Defendants 

Jim Mattox 
Mary F. Keller 
Renea Hicks 
Javier Guajardo 
Attorney General’s Office 
P. O. Box 12548 
Austin, TX 78711 
512/463-2085 

Defendant-Intervenors 

  

J. Eugene Clements 
E. O'Neill 
Evelyn V. Keys 
PORTER & CLEMENTS 
700 Louisiana, Suite 3500 
Houston, TX 77002-2730 
713/226-0600 

REPRESENTING 
  

Jesse Oliver 

Joan Winn White 

Fred Tinsley 

Jesse Oliver 

Joan Winn White 

Fred Tinsley 

Houston Lawyers Assn. 

Francis Williams 

Rev. William Lawson 

Houston Lawyers Assn. 
Francis Williams 
Rev. William Lawson 
Texas Legislative 

Black Caucus 

All Defendants 

Judge Sharolyn Wood 
of Harris County 

 



  

Darrell Smith 
Attorney at Law 
10999 Interstate Highway 10, 
Suite 905 
San Antonio, TX 78230 
512/641-9944 

Michael J. Wood 
Attorney at Law 
440 Louisiana, Suite 200 
Houston, TX 77002 
713/228-5105 

Mark H. Dettman 
County Attorney 
P. O. Box 2559 
Midland, TX 79702 
915/688-1084 

Ken Oden 
Travis County Attorney 
P. O. Box 1748 
Austin, TX 78767 
512/473-9415 

David R. Richards 
Special Counsel 
600 W. 7th St. 
Austin, TX 78701 

Robert H. Mow, Jr. 
HUGHES & LUCE 
2800 Momentum Place 
1717 Main St. 
Dallas, TX 75201 
214/939-5500 

Judge Sharolyn Wood 
of Harris County 

Judge Sharolyn Wood 
of Harris County 

Midland County & 
District Judges 

Travis County District 
Judges 

Travis County District 
Judges 

Judge Harold Entz 
of Dallas County 

each at the correct address on this 11th day of April, 1989. 

  

ATTORNEY FOR PLAINTIFF 

 



  

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

MIDLAND-ODESSA DIVISION 

LULAC, et al., 

Plaintiffs, 

vs. NO. MO-88-CA-154 

MATTOX, et al., 

* 
* 

OF
 

OF
 

F 
* 

* 
* 

* 

Defendants. 

PLAINTIFFS’ FIRST REQUEST FOR PRODUCTION 
TO DEFENDANT-INTERVENOR WOOD 

TO: Defendant-Intervenor Wood c/o J. Eugene Clements, John E. 
O'Neill, Evelyn V. Keys, Porter and Clements, 700 Louisiana, Suite 
3500, Houston, Texas 77002-2730 and Darrell Smith, 10999 Interstate 
Highway 10, Suite 905, San Antonio, Texas 78230. 

Plaintiffs, by their attorneys, pursuant to Rules 26 and 34 

of the Federal Rules of Civil Procedure, request the Defendant- 

Intervenor, or any officer, agent or employee of Defendant- 

Intervenor who has such information as is available, to answer in 

writing and under oath, each and every one of the following 

requests. Pursuant to the Court’s Order of February 27, 1989, 

responses are due within fifteen (15) days after service. These 

requests are continuing to the extent required by Rule 26(e), 

Federal Rules of Civil Procedure. Furthermore, please produce any 

requested documents as they are kept in the normal course of 

business or organize and label them to correspond with the 

categories in this request. 

As used in this Request, the terms, "identify," "identity" or 

"identification" mean when used in reference to: 

 



  

A. A natural person, his or her: 

l. full name; 

2. present or last known home and business address, 

including street name and number, city or town and 

state; 

3. present or last known home and business telephone 

number; and 

4. present or last known position, job title and job 

description. 

B. A company, corporation, association, partnership, joint 

venture, or any legal entity other than a natural person, 

its: 

1, full name and type of organization or entity; 

2 address of principal place of business; and 

3 telephone number of principal place of business. 

C. A document, its: 

l. date and title; 

2. author: 

3. addressee; 

4, a precise description of the contents thereof; and 

5. the identity of the person having possession of the 

document. 

D. An election, the: 

1. date; 

v5 type of election, specifically state, county, city, 

primary election, general election, or referendum; 

3. identity of the person having possession of the 

 



  

official returns by precinct. 

As used in this Request, the terms, "document" or "documents" 

mean all writings of any kind (including the originals and all non- 

identical copies, whether different from the original by reason of 

any notation made on such copies or otherwise), regardless of their 

origin or location, including without limitation, correspondence, 

memoranda, notes, diaries, statistics, letter, telegrams, minutes, 

contracts, reports, studies, applications and proposals for federal 

and state financial assistance, checks, statements, receipts, 

returns, summaries, pamphlets, books, charts, maps, interoffice and 

intraoffice communications, notations of any sort of conversations, 

bulletins, printed matter, computer printouts, teletypes, telefax, 

worksheets and drafts, alterations, modifications, changes, and 

amendments of any of the foregoing, graphic or aural records or 

representations of any kind (including without limitation, 

photographs, charts, graphs, microfiche, videotapes, recordings, 

motion pictures) and electronic, mechanical or electric records or 

representations of any kind (including without limitation, tapes, 

cassettes, mag cards, disks, and recordings). 

The term "all documents" means every document as above defined 

known to you and every such document which can be located or 

discovered by reasonably diligent efforts. 

The term "person" means any natural person, corporation, 

partnership, proprietorship, association, organization or group of 

natural persons. | 

The terms "you" or "your" mean the Defendant-Intervenor and 

all other persons acting or purporting to act on her behalf. 

 



  

If a request is made for the identification of documents which 

are no longer in your possession or subject to your control, state 

when and what disposition was made of them. 

For each request, or part of a request, which you refuse to 

answer on the grounds of privilege (in this Request, the term 

"privilege" includes work product): 

a. state the nature of the privilege and the basis upon 

which the claim of privilege is made; and 

b. in addition, if the claim of privilege is asserted 

with regard to a document, a precise description of 

the contents of the documents. 

REQUEST NO. 1: Please provide copies of all documents prepared by 

an expert on your behalf in this case. 

REQUEST NO. 2: Please provide copies of all documents provided to 

an expert on your behalf in this case. 

Dated: April 11, 1989 

Respectfully submitted: 

GARRETT, THOMPSON & CHANG 
ATTORNEYS AT LAW 
A Partnership of Professional 
Corporations 

William L. Garrett 
Brenda Hull Thompson 
8300 Douglas #800 
Dallas, Texas 75225 
(214)369-1952 
LEAD COUNSEL 

ROLANDO L. RIOS 

ATTORNEY AT LAW 
201 N. St. Mary’s #521 
San Antonio, Texas 78205 
(512)222-2102 

 



  

SUSAN FINKELSTEIN 
STAFF ATTORNEY 
TEXAS RURAL LEGAL AID, INC. 

201 N. St. Mary's #600 
San Antonio, Texas 78205 
(512)222-2478 

BYs a 
  

ATTORNEY FOR PLAINTIFFS 

CERTIFICATE OF SERVICE 
  

I, Susan Finkelstein, do hereby certify that a true and 

correct copy of Plaintiffs’ First Request for Production to 

Defendant-Intervenor Wood has been mailed via certified mail with 

correct postage to: 

ATTORNEY 
  

Plaintiff - Intervenors 
  

Edward B. Cloutman, III 
MULLINAX, WELLS, BAAB & 

CLOUTMAN, P. C. 
3301 Elm 
Dallas, TX 75226-9222 

214/939-9222 FAX: 214/939-9229 

E. Brice Cunningham 
Attorney at Law 
777 S. R. L. Thornton Fwy, Suite 121 
Dallas, TX 75203 
214/428-3793 

Julius Levonne Chambers 
Sherrilyn A. Ifill 
NAACP Legal Defense & Educational 

Fund, Inc. 
99 Hudson St., 16th floor 
New York, NY 10013 
212/219-1900 

REPRESENTING 
  

Jesse Oliver 

Joan Winn White 

Fred Tinsley 

Jesse Oliver 

Joan Winn White 

Fred Tinsley 

Houston Lawyers Assn. 

Francis Williams 

Rev. William Lawson 

 



  

Gabrielle K. McDonald 
MATTHEWS & BRANSCOMB 

301 Congress Ave., Suite 2050 
Austin, TX 78701 

512/320-5055 

Defendants 
  

Jim Mattox 
Mary F. Keller 
Renea Hicks 
Javier Guajardo 
Attorney General’s Office 
P. O. Box 12548 
Austin, TX 78711 
512/463-2085 

Defendant-Intervenors 
  

J. Eugene Clements 
E. O'Neill 
Evelyn V. Keys 
PORTER & CLEMENTS 

700 Louisiana, Suite 3500 
Houston, TX 77002-2730 
713/226-0600 

Darrell Smith 
Attorney at Law 
10999 Interstate Highway 10, 
Suite 905 
San Antonio, TX 78230 
512/641-9944 

Michael J. Wood 
Attorney at Law 

440 Louisiana, Suite 200 
Houston, TX 77002 
713/228-5105 

Mark H. Dettman 

County Attorney 
P. 0. Box 2559 
Midland, TX 79702 
915/688-1084 

Ken Oden 
Travis County Attorney 
P. O. Box 1748 
Austin, TX 78767 
512/473-9415 

Houston Lawyers Assn. 
Francis Williams 
Rev. William Lawson 
Texas Legislative 

Black Caucus 

All Defendants 

Judge Sharolyn Wood 
of Harris County 

Judge Sharolyn Wood 
of Harris County 

Judge Sharolyn Wood 
of Harris County 

Midland County & 
District Judges 

Travis County District 
Judges 

 



  

David R. Richards 
Special Counsel 
600 W. 7th St. 
Austin, TX 78701 

Robert H. Mow, Jr. 
HUGHES & LUCE 
2800 Momentum Place 

1717 Main St. 
Dallas, TX 75201 
214/939-5500 

Travis County District 
Judges 

Judge Harold Entz 
of Dallas County 

each at the correct address on this 11th day of April, 1989. 

| ola i 
  

ATTORNEY FOR PLAINTIFF 

 



  

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

MIDLAND-ODESSA DIVISION 

LULAC, et al., 

Plaintiffs, 

VS. NO. MO-88-CA-154 

MATTOX, et al., 

* 
% 

oF
 

* 
%* 

¥ 
* 

* 
% 

Defendants. 

PLAINTIFFS’ FIRST SET OF INTERROGATORIES TO 
THE THIRTEEN DEFENDANT-INTERVENORS FROM 

TRAVIS COUNTY 

TO: Defendant-Intervenors Clark, Davis, Dellana, Dibrell, Hart, 
Jones, Lowry, McCown, Meurer, Perkins, Thurman, Williams and Wisser 
c/o David Richards, Special Counsel, 600 W. 7th Street, Austin, 
Texas 78701 and Ken Oden, Travis County Attorney, P. O. Box 1748, 
Austin, Texas 78767 

Plaintiffs, by their attorneys, pursuant to Rules 26 and 33 

of the Federal Rules of Civil Procedure, request the Defendant- 

Intervenors, or any officer, agent or employee of Defendant- 

Intervenors who has such information as is available, to answer in 

writing and under oath, each and every one of the following 

interrogatories. Pursuant to the Court’s Order of February 27, 

1989, all responses are due within fifteen (15) days after service. 

These interrogatories are continuing to the extent required by Rule 

26 (e), Federal Rules of Civil Procedure. 

Unless otherwise stated, the terms "identify," "identity" or 

"identification" mean when used in reference to: 

A. A natural person, his or her: 

1. full name; 

 



  

2. present or last known home and business address, 

including street name and number, city or town and 

state; 

3. present or last known home and business telephone 

number; and 

4. present or last known position, job title and job 

description. 

B. A company, corporation, association, partnership, joint 

venture, or any legal entity other than a natural person, its: 

1. full name and type of organization or entity; 

2. address of principal place of business; and 

3. business telephone number. 

Cc, A document, its: 

1. date and title; 

2. author; 

3. addressee; 

4. a precise description of the contents thereof; and 

5. the identity of the person having possession of the 

document. 

D. An election, the: 

1. date; 

v.43" type of election, specifically state, county, city, 

primary election, general election, or referendum; 

3 identity of the person having possession of the 

official returns by precinct. 

The terms, "document" or "documents" mean all writing of any 

kind (including the originals and all non-identical copies, whether 

 



different from the original by reason of any notation made on such 

copies or otherwise), regardless of their origin or location, 

including without limitation, correspondence, memoranda, notes, 

diaries, statistics, letters, telegrams, minutes, contracts, 

reports, studies, applications and proposals for federal and state 

financial assistance, checks, statements, receipts, returns, 

summaries, pamphlets, books, charts, maps, interoffice and 

intraoffice communications, notations of any sort of conversations, 

bulletins, printed matter, computer printouts, teletypes, telefax, 

worksheets and drafts, alterations, modifications, changes, and 

amendments of any of the foregoing, graphic or aural records or 

representations of any kind (including without limitation, 

photographs, charts, graphs, microfiche, videotapes, recordings, 

motion pictures) and electronic, mechanical or electric records or 

representations of any kind (including without limitation, tapes, 

cassettes, mag cards, disks, and recordings). 

The term "all documents" means every document as above defined 

known to you and every such document which can be located or 

discovered by reasonably diligent efforts. 

The term "person" means any natural person, corporation, 

partnership, proprietorship, association, organization or group of 

natural persons. 

The terms "you" or "your" mean the Defendant-Intervenors and 

all other persons acting or purporting to act on their behalf. fI 

a request is made for the identification of documents which are no 

longer in your possession or subject to your control, state when 

and what disposition was made of them.  



  

For each interrogatory, or part of an interrogatory, which you 

refuse to answer on the grounds of privilege (the term "privilege" 

includes work product): 

a. state the nature of the privilege and the basis upon 

which the claim of privilege is made; and 

b. in addition, if the claim of privilege is asserted 

with regard to a document, a precise description of 

the contents of the documents. 

INTERROGATORY NO. 1: Please identify by name, business and 

residential address, telephone number, place of employment and job 

title each of the persons known to you who has any knowledge 

regarding the facts that base any claim or defense that you plan 

to raise in this lawsuit. 

INTERROGATORY NO. 2: Please identify by name, business and 

residential address, telephone number, place of employment and job 

title each of the expert witnesses who you expect to call to 

testify should this case go to trial and state the nature of the 

testimony that you expect each expert witness to give. 

INTERROGATORY NO. 3: Please state the nature of any claim or 

defense that you intend to present at trial that does not arise out 
  

of facts that took place, will take place or take place in Travis 

County. 

INTERROGATORY NO. 4: Please identify by year, type of election 

(general, Democratic/Republican primary, Democratic/Republican run 

off), candidate and type of office each election that You claim is 

relevant to your claims. 

Dated: April 11, 1989 

 



  

Respectfully submitted: 

GARRETT, THOMPSON & CHANG 
ATTORNEYS AT LAW 
A Partnership of Professional 
Corporations 

William L. Garrett 
Brenda Hull Thompson 
8300 Douglas #800 
Dallas, Texas 75225 
(214)369-1952 
LEAD COUNSEL 

ROLANDO L. RIOS 

ATTORNEY AT LAW 

201 N. St. Mary's #521 
San Antonio, Texas 78205 
(512)222-2102 

SUSAN FINKELSTEIN 

STAFF ATTORNEY 

TEXAS RURAL LEGAL AID, INC. 
201 N. St. Mary’s #600 
San Antonio, Texas 78205 
(512)222-2478 

ATTORNEY FOR PLAINTIFFS 
  

CERTIFICATE OF SERVICE 
  

1, Susan Finkelstein, do hereby certify that a true and 

correct copy of Plaintiffs’ First Set of Interrogatories to the 

Thirteen Defendant-Intervenors from Travis County has been mailed 

via certified mail with correct postage to: 

 



  

ATTORNEY 
  

Plaintiff - Intervenors 
  

Edward B. Cloutman, III 
MULLINAX, WELLS, BAAB & 

CLOUTMAN, P. C. 
3301 Elm 

Dallas, TX 75226-9222 
214/939-9222 FAX: 214/939-9229 

E. Brice Cunningham 
Attorney at Law 
777 S. R. L. Thornton Fwy, Suite 121 
Dallas, TX 75203 
214/428-3793 

Julius Levonne Chambers 
Sherrilyn A. Ifill 
NAACP Legal Defense & Educational 

Fund, Inc. 
99 Hudson St., 16th floor 
New York, NY 10013 
212/219-1900 

Gabrielle K. McDonald 
MATTHEWS & BRANSCOMB 
301 Congress Ave., Suite 2050 
Austin, TX 78701 
512/320-5055 

Defendants 

Jim Mattox 
Mary F. Keller 
Renea Hicks 
Javier Guajardo 
Attorney General's Office 
P. O. Box 12548 
Austin, TX 78711 
512/463-2085 

Defendant-Intervenors 
  

J. Eugene Clements 
E. O'Neill 
Evelyn V. Keys 
PORTER & CLEMENTS 
700 Louisiana, Suite 3500 
Houston, TX 77002-2730 
713/226-0600 

REPRESENTING 
  

Jesse Oliver 

Joan Winn White 

Fred Tinsley 

Jesse Oliver 

Joan Winn White 

Fred Tinsley 

Houston Lawyers Assn. 
Francis Williams 

Rev. William Lawson 

Houston Lawyers Assn. 
Francis Williams 
Rev. William Lawson 
Texas Legislative 

Black Caucus 

All Defendants 

Judge Sharolyn Wood 
of Harris County 

 



  

Darrell Smith 
Attorney at Law 
10999 Interstate Highway 10, 
Suite 905 
San Antonio, TX 78230 
512/641-9944 

Michael J. Wood 
Attorney at Law 
440 Louisiana, Suite 200 
Houston, TX 77002 
713/228-5105 

Mark H. Dettman 
County Attorney 
P. O. Box 2559 
Midland, TX 79702 
915/688-1084 

Ken Oden 
Travis County Attorney 
P. O. Box 1748 
Austin, TX 78767 
512/473-9415 

David R. Richards 
Special Counsel 

"600 W. 7th St. 
Austin, TX 78701 

Robert H. Mow, Jr. 
HUGHES & LUCE 
2800 Momentum Place 
1717 Main St. 
Dallas, TX 75201 
214/939-5500 

Judge Sharolyn Wood 
of Harris County 

Judge Sharolyn Wood 
of Harris County 

Midland County & 
District Judges 

Travis County District 
Judges 

Travis County District 
Judges 

Judge Harold Entz 
of Dallas County 

each at the correct address on this 11th day of Sori, 1989. 

4 LTE: 
  

VASE FOR PLAINTIFF 

 



  

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

MIDLAND-ODESSA DIVISION 

LULAC, et al., 

Plaintiffs, 

vs. NO. MO-88-CA-154 

MATTOX, et al., 

* 
* 

F 
% 

* 
* 

%*
 

* 
% 

Defendants. 

PLAINTIFFS’ FIRST REQUEST FOR PRODUCTION OF 
DOCUMENTS TO THE THIRTEEN 

DEFENDANT-INTERVENORS FROM TRAVIS COUNTY 

TO: Defendant-Intervenors Clark, Davis, Dellana, Dibrell, Hart, 
Jones, Lowry, McCown, Meurer, Perkins, Thurman, Williams and Wisser 
c/o David Richards, Special Counsel, 600 W. 7th Street, Austin, 
Texas 78701 and Ken Oden, Travis County Attorney, P. O. Box 1748, Austin, Texas 78767 

Plaintiffs, by their attorneys, pursuant to Rules 26 and 34 

of the Federal Rules of Civil Procedure, request the Defendant- 

Intervenors, or any officer, agent or employee of Defendant- 

Intervenors who has such information as is available, to answer in 

writing and under oath, each and every one of the following 

requests. Pursuant to the Court’s Order of February 27, 1989, 

responses are due within fifteen (15) days after service. These 

requests are continuing to the extent required by Rule 26(e), 

Federal Rules of Civil Procedure. Furthermore, please produce any 

requested documents as they are kept in the normal course of 

business or organize and label them to correspond with the 

categories in this request. 

As used in this Request, the terms, "identify," "identity" or 

 



  

"identification" mean when used in reference to: 

A. A natural person, his or her: 

1. full name; 

2. present or last known home and business address, 

including street name and number, city or town and 

state; 

3. present or last known home and business telephone 

number; and 

4. present or last known position, job title and job 

description. 

B. A company, corporation, association, partnership, joint 

venture, or any legal entity other than a natural person, 

its: 

3. full name and type of organization or entity; 

2. address of principal place of business; and 

3. telephone number of principal place of business. 

C. A document, its: 

l. date and title; 

2. author; 

3. addressee; 

4. a precise description of the contents thereof; and 

5. the identity of the person having possession of the 

document. 

D. An election, the: 

1. date; 

2. type of election, specifically state, county, city, 

primary election, general election, or referendum; 

 



  

3. identity of the person having possession of the 

official returns by precinct. 

As used in this Request, the terms, "document" or "documents" 

mean all writings of any kind (including the originals and all non- 

identical copies, whether different from the original by reason of 

any notation made on such copies or otherwise), regardless of their 

origin or location, including without limitation, correspondence, 

memoranda, notes, diaries, statistics, letter, telegrams, minutes, 

contracts, reports, studies, applications and proposals for federal 

and state financial assistance, checks, statements, receipts, 

returns, summaries, pamphlets, books, charts, maps, interoffice and 

intraoffice communications, notations of any sort of conversations, 

bulletins, printed matter, computer printouts, teletypes, telefax, 

worksheets and drafts, alterations, modifications, changes, and 

amendments of any of the foregoing, graphic or aural records or 

representations of any kind (including without limitation, 

photographs, charts, graphs, microfiche, videotapes, recordings, 

motion pictures) and electronic, mechanical or electric records or 

representations of any kind (including without limitation, tapes, 

cassettes, mag cards, disks, and recordings). 

The term "all documents" means every document as above defined 

known to you and every such document which can be located or 

discovered by reasonably diligent efforts. 

The term "person" means any natural person, corporation, 

partnership, proprietorship, association, organization or group of 

natural persons. 

The terms "you" or "your" mean the Defendant-Intervenors and 

 



all other persons acting or purporting to act on their behalf. 

If a request is made for the identification of documents which 

are no longer in your possession or subject to your control, state 

when and what disposition was made of them. 

For each request, or part of a request, which you refuse to 

answer on the grounds of privilege (in this Request, the term 

"privilege" includes work product): 

a. state the nature of the privilege and the basis upon 

which the claim of privilege is made; and 

in addition, if the claim of privilege is asserted 

with regard to a document, a precise description of 

the contents of the documents. 

REQUEST NO. 1: Please provide copies of all documents prepared by 

an expert on your behalf in this case. 

REQUEST NO. 2: Please provide copies of all documents provided to 

an expert on your behalf in this case. 

Dated: April 11, 1989 

Respectfully submitted: 

GARRETT, THOMPSON & CHANG 
ATTORNEYS AT LAW 
A Partnership of Professional 
Corporations 

William L. Garrett 
Brenda Hull Thompson 
8300 Douglas #800 
Dallas, Texas 75225 
(214)369-1952 
LEAD COUNSEL  



  

ROLANDO L. RIOS 

ATTORNEY AT LAW 

201 N. St. Mary's #521 
San Antonio, Texas 78205 
(512)222-2102 

SUSAN FINKELSTEIN 

STAFF ATTORNEY 
TEXAS RURAL LEGAL AID, INC. 
201 N. St. Mary's #600 
San Antonio, Texas 78205 
(512)222-2478 

% BY: Cal Lil. 
ATTORNEY FOR PLAINTIFFS 
  

CERTIFICATE OF SERVICE 
  

I, Susan Finkelstein, do hereby certify that a true and 

correct copy of Plaintiffs’ First Request for Production of 

Documents to the Thirteen Defendant-Intervenors from Travis County 

has been mailed via certified mail with correct postage to: 

ATTORNEY REPRESENTING 
  

Plaintiff - Intervenors 
  

Edward B. Cloutman, III Jesse Oliver 
MULLINAX, WELLS, BAAB & Joan Winn White 

CLOUTMAN, P. C. Fred Tinsley 
3301 Elm 
Dallas, TX 75226-9222 
214/939-9222 FAX: 214/939-9229 

E. Brice Cunningham Jesse Oliver 
Attorney at Law Joan Winn White 777 S. R. L. Thornton Fwy, Suite 121 Fred Tinsley 
Dallas, TX 75203 
214/428-3793 

 



Julius Levonne Chambers 
Sherrilyn A. Ifill 
NAACP Legal Defense & Educational 

Fund, Inc. 

99 Hudson St., 16th floor 
New York, NY 10013 
212/219-1900 

Gabrielle K. McDonald 
MATTHEWS & BRANSCOMB 
301 Congress Ave., Suite 2050 
Austin, TX 78701 
512/320-5055 

Defendants 
  

Jim Mattox 
Mary F. Keller 
Renea Hicks 
Javier Guajardo 
Attorney General’s Office 
P. O. Box 12548 
Austin, TX 78711 
512/463-2085 

Defendant-Intervenors 

J. Eugene Clements 
E. O'Neill 
Evelyn V. Keys 
PORTER & CLEMENTS 
700 Louisiana, Suite 3500 
Houston, TX 77002-2730 
713/226-0600 

Darrell Smith 
Attorney at Law 
10999 Interstate Highway 10, 
Suite 905 
San Antonio, TX 78230 
512/641-9944 

Michael J. Wood 
Attorney at Law 
440 Louisiana, Suite 200 
Houston, TX 77002 
713/228-5105 

Mark H. Dettman 

County Attorney 
P. O. Box 2559 
Midland, TX 79702 
915/688-1084 

Houston Lawyers Assn. 
Francis Williams 

Rev. William Lawson 

Houston Lawyers Assn. 
Francis Williams 
Rev. William Lawson 
Texas Legislative 

Black Caucus 

All Defendants 

Judge Sharolyn Wood 
of Harris County 

Judge Sharolyn Wood 
of Harris County 

Judge Sharolyn Wood 
of Harris County 

Midland County & 
District Judges  



  

Ken Oden Travis County District 
Travis County Attorney Judges 
P. O. Box 1748 
Austin, TX 78767 
512/473-9415 

David R. Richards Travis County District 
Special Counsel Judges 
600 W. 7th St. 
Austin, TX 78701 

Robert H. Mow, Jr. Judge Harold Entz 
HUGHES & LUCE of Dallas County 
2800 Momentum Place 
1717 Main St. 
Dallas, TX 75201 
214/939-5500 

each at the correct address on this 11th day of April, 1989. 

  

ATTORNEY FOR PLAINTIFF 
/ 

/ 

 



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

MIDLAND-ODESSA DIVISION 

LULAC, et al., 

Plaintiffs, 

vs. NO. MO-88-CA-154 

MATTOX, et al., 

* 
% 

% 
* 

% 
%* 

* 
¥*

 
* 

Defendants. 

PLAINTIFFS’ FIRST SET OF INTERROGATORIES TO 
DEFENDANT-INTERVENOR ENTZ 

TO: Defendant-Intervenor Entz, c/o Robert H. Mow, Jr., Hughes and 
Luce, 2800 Momentum Place, 1717 Main Street, Dallas, Texas 75201. 

Plaintiffs, by their attorneys, pursuant to Rules 26 and 33 

of the Federal Rules of Civil Procedure, request the Defendant- 

Intervenor, or any officer, agent or employee of Defendant- 

Intervenor who has such information as is available, to answer in 

writing and under oath, each and every one of the following 

interrogatories. Pursuant to the Court’s Order of February 27, 

1989, all responses are due within fifteen (15) days after service. 

These interrogatories are continuing to the extent required by Rule 

26(e), Federal Rules of Civil Procedure. 

Unless otherwise stated, the terms "identify," "identity" or 

"identification" mean when used in reference to: 

A. A natural person, his or her: 

1. full name; 

2. present or last known home and business address, 

including street name and number, city or town and  



  

state; 

3. present or last known home and business telephone 

number; and 

4, present or last known position, job title and job 

description. 

B. A company, corporation, association, partnership, joint 

venture, or any legal entity other than a natural person, its: 

1. 

2 

3 

A 

1. 

2 

3 

4 

5 

full name and type of organization or entity; 

address of principal place of business; and 

business telephone number. 

document, its: 

date and title; 

author; 

addressee; 

a precise description of the contents thereof; and 

the identity of the person having possession of the 

document. 

D. An election, the: 

1. 

2. 

date; 

type of election, specifically state, county, city, 

primary election, general election, or referendum; 

identity of the person having possession of the 

official returns by precinct. 

The terms, "document" or "documents" mean all writing of any 

kind (including the originals and all non-identical copies, whether 

different from the original by reason of any notation made on such 

copies or otherwise), regardless of their origin or location, 

 



  

including without limitation, correspondence, memoranda, notes, 

diaries, statistics, letters, telegrams, minutes, contracts, 

reports, studies, applications and proposals for federal and state 

financial assistance, checks, statements, receipts, returns, 

summaries, pamphlets, books, charts, maps, interoffice and 

intraoffice communications, notations of any sort of conversations, 

bulletins, printed matter, computer printouts, teletypes, telefax, 

worksheets and drafts, alterations, modifications, changes, and 

amendments of any of the foregoing, graphic or aural records or 

representations of any kind (including without limitation, 

photographs, charts, graphs, microfiche, videotapes, recordings, 

motion pictures) and electronic, mechanical or electric records or 

representations of any kind (including without limitation, tapes, 

cassettes, mag cards, disks, and recordings). 

The term "all documents" means every document as above defined 

known to you and every such document which can be located or 

discovered by reasonably diligent efforts. 

The term "person" means any natural person, corporation, 

partnership, proprietorship, association, organization or group of 

natural persons. 

The terms "you" or "your" mean the Defendant-Intervenor and 

all other persons acting or purporting to act on his behalf. 

If a request is made for the identification of documents which 

are no longer in your possession or subject to your control, state 

when and what disposition was made of them. 

For each interrogatory, or part of an interrogatory, which you 

refuse to answer on the grounds of privilege (the term "privilege" 

 



  

includes work product): 

a. state the nature of the privilege and the basis upon 

which the claim of privilege is made; and 

b. in addition, if the claim of privilege is asserted 

with regard to a document, a precise description of 

the contents of the documents. 

INTERROGATORY NO. 1: Please identify by name, business and 

residential address, telephone number, place of employment and job 

title each of the persons known to you who has any knowledge 

regarding the facts that base any claim or defense that you plan 

to raise in this lawsuit. 

INTERROGATORY NO. 2: Please identify by name, business and 

residential address, telephone number, place of employment and job 

title each of the expert witnesses who you expect to call to 

testify should this case go to trial and state the nature of the 

testimony that you expect each expert witness to give. 

INTERROGATORY NO. 3: Please state the nature of any claim or 

defense that you intend to present at trial that does not arise out 
  

of facts that took place, will take place or take place in Dallas 

County. 

INTERROGATORY NO. 4: Please identify by year, type of election 

(general, Democratic/Republican primary, Democratic/Republican run 

off), candidate and type of office each election that you claim is 

relevant to your claims. 

Dated: April 11, 1989 

 



  

Respectfully submitted: 

GARRETT, THOMPSON & CHANG 
ATTORNEYS AT LAW 
A Partnership of Professional 
Corporations 

William L. Garrett 
Brenda Hull Thompson 
8300 Douglas #800 
Dallas, Texas 75225 
(214)369-1952 
LEAD COUNSEL 

ROLANDO L. RIOS 

ATTORNEY AT LAW 

201 N. St. Mary's #521 
San Antonio, Texas 78205 
(512)222-2102 

SUSAN FINKELSTEIN 

STAFF ATTORNEY 

TEXAS RURAL LEGAL AID, INC. 

201 N. St. Mary's #600 
San Antonio, Texas 78205 
(512)222-2478 

BY vm Le im 
  

TTORNEY FOR PLAINTIFFS 

CERTIFICATE OF SERVICE 
  

1, Susan Finkelstein, do hereby certify that a true and 

correct copy of Plaintiffs’ First Set of Interrogatories to 

Defendant-Intervenor Entz has been mailed via certified mail with 

correct postage to: 

 



  

ATTORNEY 
  

Plaintiff - Intervenors 
  

Edward B. Cloutman, III 
MULLINAX, WELLS, BAAB & 

CLOUTMAN, P. C. 
3301 Elm 
Dallas, TX 75226-9222 
214/939-9222 FAX: 214/939-9229 

E. Brice Cunningham 
Attorney at Law 
777 S. R. L. Thornton Fwy, Suite 121 
Dallas, TX 75203 
214/428-3793 

Julius Levonne Chambers 
Sherrilyn A. Ifill 
NAACP Legal Defense & Educational 

Fund, Inc. 
99 Hudson St., 16th floor 
New York, NY 10013 
212/219-1900 

Gabrielle K. McDonald 
MATTHEWS & BRANSCOMB 

301 Congress Ave., Suite 2050 
Austin, TX 78701 
512/320-5055 

Defendants 
  

Jim Mattox 
Mary F. Keller 
Renea Hicks 
Javier Guajardo 
Attorney General’s Office 
P. O. Box 12548 
Austin, TX 78711 
512/463-2085 

Defendant-Intervenors 
  

J. Eugene Clements 
E. O'Neill 
Evelyn V. Keys 
PORTER & CLEMENTS 
700 Louisiana, Suite 3500 
Houston, TX 77002-2730 
713/226-0600 

REPRESENTING 
  

Jesse Oliver 

Joan Winn White 

Fred Tinsley 

Jesse Oliver 

Joan Winn White 

Fred Tinsley 

Houston Lawyers Assn. 
Francis Williams 

Rev. William Lawson 

Houston Lawyers Assn. 
Francis Williams 
Rev. William Lawson 
Texas Legislative 

Black Caucus 

All Defendants 

Judge Sharolyn Wood 
of Harris County 

 



  

Darrell Smith Judge Sharolyn Wood 
Attorney at Law of Harris County 
10999 Interstate Highway 10, 
Suite 905 
San Antonio, TX 78230 
512/641-9944 

Michael J. Wood Judge Sharolyn Wood 
Attorney at Law of Harris County 
440 Louisiana, Suite 200 
Houston, TX 77002 
713/228-5105 

Mark H. Dettman Midland County & 
County Attorney District Judges 
P. O. Box 2559 
Midland, TX 79702 
915/688-1084 

Ken Oden Travis County District 
Travis County Attorney Judges 
P. O. Box 1748 
Austin, TX 78767 
512/473-9415 

David R. Richards Travis County District 
Special Counsel Judges 
600 W. 7th St. 
Austin, TX 78701 

Robert H. Mow, Jr. Judge Harold Entz 
HUGHES & LUCE of Dallas County 
2800 Momentum Place 
1717 Main St. 
Dallas, TX 75201 
214/939-5500 

each at the correct address on this 11th day of April, 1989. 

  

ATTORNEY FOR PLAINTIFF 

 



  

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

MIDLAND-ODESSA DIVISION 

LULAC, et al., 

Plaintiffs, 

vs. NO. MO-88-CA-154 

MATTOX, et al., 

* 
% 

* 
¥ 

* 
* 

* 
* 

* 

Defendants. 

PLAINTIFFS’ FIRST REQUEST FOR 
PRODUCTION TO DEFENDANT-INTERVENOR ENTZ 

TO: Defendant-Intervenor Entz, c/o Robert H. Mow, Jr., Hughes and 
Luce, 2800 Momentum Place, 1717 Main Street, Dallas, Texas 75201. 

Plaintiffs, by their attorneys, pursuant to Rules 26 and 34 

of the Federal Rules of Civil Procedure, request the Defendant- 

Intervenor, or any officer, agent or employee of Defendant- 

Intervenor who has such information as is available, to answer in 

writing and under oath, each and every one of the following 

requests. Pursuant to the Court’s Order of February 27, 1989, 

responses are due within fifteen (15) days after service. These 

requests are continuing to the extent required by Rule 26(e), 

Federal Rules of Civil Procedure. Furthermore, please produce any 

requested documents as they are kept in the normal course of 

business or organize and label them to correspond with the 

categories in this request. 

As used in this Request, the terms, "identify," "identity" or 

"identification" mean when used in reference to: 

 



  

A natural person, his or her: 

1. full name; 

2. present or last known home and business address, 

including street name and number, city or town and 

state; 

3. present or last known home and business telephone 

number; and 

4. present or last known position, job title and job 

description. 

A company, corporation, association, partnership, joint 

venture, or any legal entity other than a natural person, 

its: 

1. full name and type of organization or entity; 

2. address of principal place of business; and 

3. telephone number of principal place of business. 

A document, its: 

1. date and title; 

2. author; 

3. addressee; 

4. a precise description of the contents thereof; and 

5, the identity of the person having possession of the 

document. 

An election, the: 

1. date; 

2. type of election, specifically state, county, city, 

primary election, general election, or referendum; 

3. identity of the person having possession of the 

 



  

official returns by precinct. 

As used in this Request, the terms, "document" or "documents" 

mean all writings of any kind (including the originals and all non- 

identical copies, whether different from the original by reason of 

any notation made on such copies or otherwise), regardless of their 

origin or location, including without limitation, correspondence, 

memoranda, notes, diaries, statistics, letter, telegrams, minutes, 

contracts, reports, studies, applications and proposals for federal 

and state financial assistance, checks, statements, receipts, 

returns, summaries, pamphlets, books, charts, maps, interoffice and 

intraoffice communications, notations of any sort of conversations, 

bulletins, printed matter, computer printouts, teletypes, telefax, 

worksheets and drafts, alterations, modifications, changes, and 

amendments of any of the foregoing, graphic or aural records or 

representations of any kind (including without limitation, 

photographs, charts, graphs, microfiche, videotapes, recordings, 

motion pictures) and electronic, mechanical or electric records or 

representations of any kind (including without limitation, tapes, 

cassettes, mag cards, disks, and recordings). 

The term "all documents" means every document as above defined 

known to you and every such document which can be located or 

discovered by reasonably diligent efforts. 

The term "person" means any natural person, corporation, 

partnership, proprietorship, association, organization or group of 

natural persons. 

The terms "you" or "your" mean the Defendant-Intervenor and 

all other persons acting or purporting to act on his behalf. 

 



  

If a request is made for the identification of documents which 

are no longer in your possession or subject to your control, state 

when and what disposition was made of them. 

For each request, or part of a request, which you refuse to 

answer on the grounds of privilege (in this Request, the term 

"privilege" includes work product): 

a. state the nature of the privilege and the basis upon 

which the claim of privilege is made; and 

b. in addition, if the claim of privilege is asserted 

with regard to a document, a precise description of 

the contents of the documents. 

REQUEST NO. 1: Please provide copies of all documents prepared by 

an expert on your behalf in this case. 

REQUEST NO. 2: Please provide copies of all documents provided to 

an expert on your behalf in this case. 

Respectfully submitted: 

GARRETT, THOMPSON & CHANG 

ATTORNEYS AT LAW 

A Partnership of Professional 
Corporations 

William L. Garrett 
Brenda Hull Thompson 
8300 Douglas #800 
Dallas, Texas 75225 
(214)369-1952 
LEAD COUNSEL 

ROLANDO L. RIOS 

ATTORNEY AT LAW 

201 N. St. Mary's #521 
San Antonio, Texas 78205 
(512)222-2102 

 



SUSAN FINKELSTEIN 
STAFF ATTORNEY 
TEXAS RURAL LEGAL AID, INC. 
201 N. St. Mary's #600 
San Antonio, Texas 78205 
(512)222-2478 

Serres 

BY: eh lTE 
ATTORNEY FOR PLAINTIFFS 
  

CERTIFICATE OF SERVICE 
  

I, Susan Finkelstein, do hereby certify that a true and 

correct copy of Plaintiffs’ First Request for Production to 

Defendant-Intervenor Entz has been mailed via certified mail with 

correct postage to: 

ATTORNEY REPRESENTING 
  

  

Plaintiff - Intervenors 
  

Edward B. Cloutman, III Jesse Oliver 
MULLINAX, WELLS, BAAB & Joan Winn White 

CLOUTMAN, P. C. Fred Tinsley 
3301 Elm 
Dallas, TX 75226-9222 
214/939-9222 FAX: 214/939-9229 

E. Brice Cunningham Jesse Oliver 
Attorney at Law Joan Winn White 
777 S. R. L. Thornton Fwy, Suite 121 Fred Tinsley 
Dallas, TX 75203 
214/428-3793 

Julius Levonne Chambers Houston Lawyers Assn. 
Sherrilyn A. Ifill Francis Williams 
NAACP Legal Defense & Educational Rev. William Lawson 

Fund, Inc. 
99 Hudson St., 16th floor 
New York, NY 10013 
212/219-1900  



  

Gabrielle K. McDonald 
MATTHEWS & BRANSCOMB 
301 Congress Ave., Suite 2050 
Austin, TX 78701 

512/320-5055 

Defendants 
  

Jim Mattox 
Mary F. Keller 
Renea Hicks 
Javier Guajardo 
Attorney General’s Office 
P. O. Box 12548 
Austin, TX 78711 
512/463-2085 

Defendant-Intervenors 
  

J. Eugene Clements 
E. O'Neill 
Evelyn V. Keys 
PORTER & CLEMENTS 
700 Louisiana, Suite 3500 
Houston, TX 77002-2730 
713/226-0600 

Darrell Smith 

Attorney at Law 
10999 Interstate Highway 10, 
Suite 905 
San Antonio, TX 78230 
512/641-9944 

Michael J. Wood 
Attorney at Law 
440 Louisiana, Suite 200 
Houston, TX 77002 
713/228-5105 

Mark H. Dettman 
County Attorney 
P. O. Box 2559 
Midland, TX 79702 
915/688-1084 

Ken Oden 
Travis County Attorney 
P. O. Box 1748 
Austin, TX 78767 
512/473-9415 

Houston Lawyers Assn. 
Francis Williams 
Rev. William Lawson 
Texas Legislative 

Black Caucus 

All Defendants 

Judge Sharolyn Wood 
of Harris County 

Judge Sharolyn Wood 
of Harris County 

Judge Sharolyn Wood 
of Harris County 

Midland County & 
District Judges 

Travis County District 
Judges 

 



  

David R. Richards 
Special Counsel 
600 W. 7th St. 
Austin, TX 78701 

Robert H. Mow, Jr. 
HUGHES & LUCE 

2800 Momentum Place 
1717 Main St. 
Dallas, TX 75201 
214/939-5500 

» 

Travis County District 
Judges 

Judge Harold Entz 
of Dallas County 

each at the correct address on this 11th day of April, 1989. 

i 
  

ie FOR PLAINTIFF