Dallas County Judge Entz's Answers to Plaintiffs Complaints

    HUGHES & LUCE 
2800 MOMENTUM PLACE 

1717 MAIN STREET 

  

DALLAS, TEXAS 75201 1500 FIRST STATE BANK BUILDING 

400 WEST 15TH STREET 

(214) 939-5500 
AUSTIN, TEXAS 78701 

TELECOPIER (214) 939-6100 
(512) 482-6800 

TELEX 730836 
TELECOPIER (512) 474-4258 

Direct Dial Number 

(214) 939-5581 

May 23, 1989 

VIA FEDERAL EXPRESS   
Mr. John Neill 

United States District Court 

Western/District of Texas 

Midland-Odessa Division 

316 ¥.8. Courthouse 
200 /East Wall Street 
Midland, Texas 79701 

Re: League of United Latin American Citizens (LULAC), et 

al. v. Jim Mattox, et al., Civil Action MO 88 CA 154 

Dear Mr. Neill: 

Enclosed please find the originals and two copies each of 

the following documents for filing in the above-referenced 

cause: 

1. Dallas County District Judge F. Harold Entz's First 

Amended Answer to LULAC'S Second Amended Complaint 

2. Dallas County District Judge F. Harold Entz's Answer 

to Legislative Black Caucus of Texas’ First Amended 

Complaint 

3. Dallas County District Judge F. Harold Entz's Answer 

to Plaintiff Intervenors Oliver, White, and Tinsley 

™ . . : 
Please return file-marked copies to me 1n the enclosed 

envelope. Please note that copies of the above pleadings are 

\-- being mailed certified mail return receipt requested to the 

other parties. 

If you have any questions, please call. Thank you. 

cerely, 

pavid C. Godlee befor 

DCG: phl 

Enclosures 

CC? Counsel of Record 

5280010:69 

 



  

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

MIDLAND-ODESSA DIVISION 

LEAGUE OF UNITED LATIN 

AMERICAN CITIZENS 

(LULAC), etal, 

Plaintiffs, 
CIVIL ACTION NO. 

Vv. MO 88 CA 154 

JIM MATTOX, etal, 

C2
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Defendants. 

DALLAS COUNTY DISTRICT JUDGE 
F. HAROLD ENTZ'S FIRST AMENDED ANSWER 
TO LULAC'S SECOND AMENDED COMPLAINT 
  

TO THE HONORABLE JUDGE BUNTON: 

The Honorable F. Harold Entz ("Judge Entz") files his 

First Amended Answer to LULAC's Second Amended Complaint as 

follows: 

RESPONSE TO NUMBERED PARAGRAPHS 
  

1. Judge Entz lacks knowledge and information sufficient 

to form a belief regarding the specific membership of LULAC, 

the various LULAC councils, and the named individual 

plaintiffs, but has no reason to doubt that: they ' are 

Mexican-American and African-American citizens of the State of 

Texas. Judge Entz need not respond to the legal statement 

with respect to the purported statutory bases for the instant 

action, but specifically denies that any of the Dallas County 

Plaintiffs have been denied any of their rights, privileges, 

or immunities secured by the laws of the United States of 

JUDGE ENTZ'S AMENDED ANSWER TO 
LULAC'S SECOND AMENDED COMPLAINT page - 1 

 



  

America. 

vy Judge Entz denies that the Dallas County Plaintiffs 

are entitled to any of the relief sought. 

3. Judge Entz does not contest jurisdiction at this 

time, but denies that any cause of action exists with respect 

to Dallas County. 

4... - 37. Judge Entz lacks knowledge or information 

sufficient to. form a belief as to the. truth of these 

allegations. 

18. Judge Entz admits that the persons named hold the 

identified offices. The balance of the paragraph alleges a 

legal conclusion that Judge Entz neither admits nor denies. 

19. Admitted as to Dallas County. 

20. Denied because of the ambiguous terms used. Dallas 

County Judicial Districts are coterminous with county lines 

and Judges are elected by majority vote in differing years. 

21. w= 23, Judge Entz lacks knowledge or information 

sufficient to form a belief "as to: the truth of Lhese 

allegations. 

23. Judge Entz denies that Mexican-Americans are 

sufficiently geographically compact in Dallas County to 

constitute a safe majority in any single member district if a 

single member districting plan was employed in Dallas County. 

Judge Entz lacks knowledge or information sufficient to form a 

belief as to the truth of the balance of the allegations in 

the paragraph. 

JUDGE ENTZ'S AMENDED ANSWER TO 

LULAC'S SECOND AMENDED COMPLAINT page - 2 

 



  

24. - 26. Denied with respect to Dallas County. 

27. Admitted with respect to Dallas County. 

28. - 29. Denied with respect to Dallas County. 

30. This paragraph alleges a legal conclusion that Judge 

Entz neither admits nor denies. i 

31. - 32. Denied with respect to Dallas County. 

33. Judge Entz denies that Plaintiffs are entitled to 

the relief sought with respect to Dallas County. 

AFFIRMATIVE DEFENSES 
  

34. For purposes of preserving appellate review, Judge 

Entz affirmatively claims that neither the Voting Rights Act 

nor the 14th and 15th amendments of the United States 

Constitution apply to judicial selection. 

35. The lack of electoral success, if any, of minority 

candidates for judicial office was not caused by the electoral 

practices that Plaintiffs challenge. Neither the Voting 

Rights Act nor the 14th and 15th amendments of the United 

States Constitution apply to electoral practices that do not 

cause the lack of electoral success, if any, of minority 

candidates. 

36. Electoral success of judicial candidates in Dallas 

County depends on the partisan affiliation of the candidate, 

rather than the race of the candidate. Neither the Voting 

Rights Act nor the 14th and 15th amendments of the United 

States Constitution ensure the right of minority voters to 

elect judicial candidates from the political party of their 

JUDGE ENTZ'S AMENDED ANSWER TO 
LULAC'S SECOND AMENDED COMPLAINT page - 3 

 



  

choice. 

37. Neither the Voting Rights Act nor the 14th and 15th 

amendments of the United States Constitution permit 

aggregating distinct minority groups to prove dilution. 

38. Application of either the Voting Rights Act or the 

14th and 15th amendments of the United States Constitution to 

judicial elections is unconstitutional because it violates the 

separation of powers doctrine, the 10th amendment of the 

United States Constitution, and fundamental principles of 

federalism. 

39. Application of either the Voting Rights Act or the 

14th and 15th amendments of the United States Constitution to 

alter electoral practices that did not cause the lack of 

electoral success, if any, of minority judicial candidates or” 

the underrepresentation, if any, of minorities among 

successful judicial candidates would be unconstitutional under 

the equal protection and due process clauses of the United 

States Constitution. 

40. Application of the Voting Rights Act or the 14th and 

15th amendments of the United States Constitution to require 

single member districts .for judicial elections 1in Dallas 

County without adjusting Texas state law venue and jury 

selection provisions to provide coterminous districts for 

venue and jury selection purposes would violate the due 

process and equal protection clauses and the 6th and 7th 

amendments of the United States Constitution. 

JUDGE ENTZ'S AMENDED ANSWER TO 
LULAC'S SECOND AMENDED COMPLAINT page - 4 

 



  

41. Application of the Voting Rights Act or the 14th and 

15th amendments of the United States Constitution to adjust 

Texas state law venue and jury selection provisions would 

violate the Guaranty Clause and 10th amendment of the United 

States Constitution, as well as fundamental principles of 

federalism. 

42. Application of the Voting Rights Act or the 14th and 

15th amendments of the United States Constitution to Dallas 

County to require single member judicial districts, based on a 

showing that minorities are unable to elect non-minority 

candidates of the political party of the minorities 

preference, would unconstitutionally interfere in the 

political process by favoring the political party currently 

enjoying the support of the minority population, as opposed to 

removing any alleged remaining obstacles to the elections of 

minority candidates. 

43. Minorities are overrepresented on the Dallas County 

State District Courts in proportion to the number of 

minorities in Dallas County eligible for such judicial offices. 

44. Plaintiffs' claims should be dismissed for failure 

to join all district judges within the "target counties” and 

all appellate judges as defendants in that these judges are 

necessary or indispensable parties under Rule 19. 

WHEREFORE, Dallas County District Judge F. Harold Entz 

respectfully requests that the Plaintiffs' claims be dismissed 

with respect to the system for electing district judges within 

JUDGE ENTZ'S AMENDED ANSWER TO 
LULAC'S SECOND AMENDED COMPLAINT page - 5 

 



  

Dallas County and that judgment be entered in his favor and 

that he recover all other relief to which he may show himself 

justly entitled. 

Respectfully submitted, 

yd Ll, 
Robert H.' Mow, JI. 

David C. Godbey 
Bobby M. Rubarts 

Esther R. Rosenblum 

  

of HUGHES & LUCE 

2800 Momentum Place 

1717 Main Street 
Dallas, Texas 75201 

214/939-5500 

ATTORNEYS FOR DALLAS 

COUNTY DISTRICT JUDGE 
F. HAROLD ENTZ 

CERTIFICATE OF SERVICE 
  

1 hereby certify that a true and correct copy of the 

foregoing document was served on counsel of record on 

this gl day of May, 1989. 

PRR mi 
{ vo   

JUDGE ENTZ'S AMENDED ANSWER TO 
LULAC'S SECOND AMENDED COMPLAINT page - 6 

 



  

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

MIDLAND-ODESSA DIVISION 

LEAGUE OF UNITED LATIN 
AMERICAN CITIZENS 
(LULAC), etal, 

Plaintiffs, 
CIVIL ACTION NO. 

v. MO 88 CA 154 

JIM MATTOX, etal., 

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Defendants. 

DALLAS COUNTY DISTRICT JUDGE 
F. HAROLD ENTZ'S ANSWER TO LEGISLATIVE 

BLACK CAUCUS OF TEXAS' FIRST AMENDED COMPLAINT 
  

TO THE HONORABLE JUDGE BUNTON: 

The Honorable F. Harold Entz ("Judge Entz"), to the 

extent the Legislative Black Caucus of Texas ("Intervenor") 

has not abandoned its pleading by joining in LULAC's Second 

Amended Complaint, files his Answer to Intervenor's First 

Amended Complaint as follows: 

RESPONSE TO NUMBERED PARAGRAPHS 
  

1. Judge Entz lacks knowledge and information sufficient 

to form a belief regarding the specific membership of 

Intervenor and the named individual plaintiffs, but has no 

reason to doubt that they are who they claim to be. Judge 

Entz need not respond to the legal statement with respect to 

the purported statutory and legal bases for the instant 

action, but specifically denies that Intervenor or any of the 

the Dallas County Plaintiffs have been denied any of their 

JUDGE ENTZ'S ANSWER TO THE 
LEGISLATIVE BLACK CAUCUS' FIRST 
AMENDED ORIGINAL COMPLAINT Page - 1 

 



  

rights, privileges, or immunities secured by the laws of the 

United States of America. Moreover, neither Intervenor nor 

any of the Dallas County Plaintiffs are entitled to any of the 

relief sought with respect to Dallas County. 

2. Judge Entz does not contest jurisdiction at this 

time, but denies that any cause of action exists with respect 

to Dallas County. 

BJ i= a, Judge Entz lacks knowledge or information 

sufficient to form a bellef as to the truth of these 

allegations. 

5 rms Judge Entz admits that the persons named hold 

the identified offices. The balance of the paragraphs allege 

legal conclusions that Judge Entz neither admits nor denies. 

8. This paragraph calls for no responsive pleading. 

9, vee 10% Judge Entz admits that Texas officially has 

discriminated against Blacks in the past, but denies that it 

has any bearing on Judicial elections in Dallas County today 

and in the recent past. With regard to the remaining 

allegations Judge Entz lacks knowledge or information 

sufficient to form a belief as to the remainder of the 

allegations. 

11. - 13. Denied as to Dallas County. 

14. Judge Entz lacks knowledge or information sufficient 

to form a belief as to the truth of these allegations. 

15. Admitted, on information and belief. 

JUDGE ENTZ'S ANSWER TO THE 
LEGISLATIVE BLACK CAUCUS' FIRST 
AMENDED ORIGINAL COMPLAINT Page - 2 

 



  

16. Judge Entz admits that judges in Dallas County are 

elected on a county-wide basis, but denies that system is 

"exclusionary." 

1%. = 18, Judge Entz lacks knowledge or information 

sufficient to form a belief as to the truth of these 

allegations. 

19. Denied with respect to Dallas County. 

206 =: 22, These paragraphs contain legal and other 

conclusions that Judge Entz neither admits nor denies. 

23. Denied with respect to Dallas County. 

24. Judge Entz denies that Intervenor or any of the 

Dallas County Plaintiffs are entitled to the relief sought 

with respect to Dallas County. 

AFFIRMATIVE DEFENSES 
  

25. For purposes of preserving appellate review, Judge 

Entz affirmatively claims that neither the Voting Rights Act 

nor the 14th and 15th amendments of the United States 

Constitution apply to judicial selection. 

26. The lack of electoral success, if any, of minority 

candidates for judicial office was not caused by the electoral 

practices that Plaintiffs challenge. Neither the Voting 

Rights Act nor the 14th and 15th amendments of the United 

States Constitution apply to electoral practices that do not 

cause the lack of electoral success, if any, of minority 

candidates. 

JUDGE ENTZ'S ANSWER TO THE 
LEGISLATIVE BLACK CAUCUS' FIRST 
AMENDED ORIGINAL COMPLAINT Page - 3 

 



  

27. Electoral success of judicial candidates in Dallas 

County depends on the partisan affiliation of the candidate, 

rather than the race of the candidate. Neither the Voting 

Rights Act nor the 14th and 15th amendments of the United 

States Constitution ensure the right of minority voters to 

elect judicial candidates from the political party of their 

choice. 

28. Neither the Voting Rights Act nor the 14th and 15th 

amendments of the United States Constitution permit 

aggregating distinct minority groups to prove dilution. 

29. Application of either the Voting Rights Act or the 

14th and 15th amendments of the United States Constitution to 

judicial elections is unconstitutional because it violates the 

separation of powers doctrine, the 10th amendment of the- 

United States Constitution, and fundamental principles of 

federalism. 

30. Application of either the Voting Rights Act or the 

14th and 15th amendments of the United States Constitution to 

alter electoral practices that did not cause the lack of 

electoral success, if any, of minority judicial candidates or 

the underrepresentation, if any, of minorities among 

successful judicial candidates would be unconstitutional under 

the equal protection and due process clauses of the United 

States Constitution. 

31. Application of the Voting Rights Act or the 14th and 

15th amendments of the United States Constitution to require 

JUDGE ENTZ'S ANSWER TO THE 
LEGISLATIVE BLACK CAUCUS' FIRST 
AMENDED ORIGINAL COMPLAINT Page - 4 

 



  

4 : # 

single member districts for judicial elections in Dallas 

County without adjusting Texas state law venue and jury 

selection provisions to provide coterminous districts for 

venue and jury selection purposes would violate the due 

process and equal protection clauses and the 6th and 7th 

amendments of the United States Constitution. 

32. Application of the Voting Rights Act or the 14th and 

15th amendments of the United States Constitution to adjust 

Texas state law venue and jury selection provisions would 

violate the Guaranty Clause and 10th amendment of the United 

States Constitution, as well as fundamental principles of 

federalism. 

33. Application of the Voting Rights Act or the 14th and 

15th amendments of the United States Constitution to Dallas 

County to require single member judicial districts, based on a 

showing that minorities are unable to elect non-minority 

candidates of the political party of the minorities 

preference, would unconstitutionally interfere in the 

political process by favoring the political party currently 

enjoying the support of the minority population, as opposed to 

removing any alleged remaining obstacles to the elections of 

minority candidates. 

34. Minorities are overrepresented on the Dallas County 

State District Courts in proportion to: the - number * of 

minorities in Dallas County eligible for such judicial offices. 

35. Plaintiffs' claims should be dismissed for failure 

JUDGE ENTZ'S ANSWER TO THE 
LEGISLATIVE BLACK CAUCUS' FIRST 
AMENDED ORIGINAL COMPLAINT Page - 5 

 



  

to join all district judges within the "target counties" and 

all appellate judges as defendants in that these judges are 

necessary or indispensable parties under Rule 19. 

WHEREFORE, Dallas County District Judge F. Harold Entz 

respectfully requests that the Plaintiffs' claims be dismissed 

with respect to the system for electing district judges within 

Dallas County and that judgment be entered in his favor and 

that he recover all other relief to which he may show himself 

justly entitled. 

Respectfully submitted, 

Robert H.! Mow, Jr. <’ 
David C. Godbey 
Bobby M. Rubarts 
Esther R. Rosenblum 

  

of HUGHES & LUCE 

2800 Momentum Place 

1717 Main Street 
Dallas, Texas 75201 

214/939-5500 

ATTORNEYS FOR DALLAS 
COUNTY DISTRICT JUDGE 
F. HAROLD ENTZ 

CERTIFICATE OF SERVICE 
  

I hereby certify that a true and correct copy of the 

foregoing ocument was served on counsel of record on 

this AT day of May, 1989. 

Dale 
  

JUDGE ENTZ'S ANSWER TO THE ial 

LEGISLATIVE BLACK CAUCUS' FIRST 
AMENDED ORIGINAL COMPLAINT Page - 6 

 



  

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

MIDLAND-ODESSA DIVISION 

LEAGUE OF UNITED LATIN 

AMERICAN CITIZENS 

(LULAC), etal., 

Plaintiffs, 
CIVIL ACTION NO. 

Vv. MO 88 CA 154 

JIM MATTOX, etal, 

CP
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Defendants. 

DALLAS COUNTY DISTRICT JUDGE 
F. HAROLD ENTZ'S ANSWER TO PLAINTIFF 
INTERVENORS OLIVER, WHITE, AND TINSLEY 
  

TO THE HONORABLE JUDGE BUNTON: 

The Honorable F. Harold Entz ("Judge Entz"), to the 

extent that Plaintiff Intervenors Oliver, White, and Tinsley 

have not abandoned their Complaint in Intervention by joining 

in LULAC's Second Amended Complaint, responds as follows: 

RESPONSE TO NUMBERED PARAGRAPHS 
  

1. Judge Entz admits that Jesse Oliver, Fred Tinsley, 

and Joan Winn White ("Intervenors") are former state district 

judges of Dallas County. He need not respond to the legal 

statement with respect to the purported statutory bases for 

the instant action, but specifically denies that Intervenors 

or any of the Dallas County Plaintiffs have been denied any of 

their rights, privileges, or immunities secured by the laws of 

the United States of America. 

JUDGE ENTZ'S ANSWER TO PLAINTIFF 
INTERVENORS OLIVER, WHITE, AND TINSLEY 

Page - 1 

 



  

2. Judge Entz denies that Intervenors or any of the 

Dallas County Plaintiffs are entitled to any of the relief 

sought with respect to Dallas County. 

3. Judge Entz does not contest jurisdiction at this 

time, but denies that any cause of action exists with respect 

to Dallas County. 

4. Judge Entz lacks knowledge or information sufficient 

to form a belief as to the truth of these allegations. 

54 Judge Entz admits that the persons named hold the 

identified offices. The balance of the paragraph alleges a 

legal conclusion that Judge Entz neither admits nor denies. 

6. Admitted as to Dallas County. 

7. Denied because of the ambiguous terms used. Dallas 

County Judicial Districts are coterminous with county lines 

and Judges are elected by majority vote in differing years. 

8. bh. 017, Judge Entz lacks knowledge or information 

sufficient to form a belief as (0 the truth of these 

allegations, except that Judge Entz admits that Dallas County 

contains multiple judicial districts and denies that the 

Hispanic population in Dallas County is sufficiently compact 

to form a majority in any single member district that could be 

drawn. 

18. Judge Entz denies that Mexican-Americans are 

sufficiently geographically compact in Dallas County to 

constitute a safe majority in any single member district if a 

single member districting plan was employed in Dallas County. 

JUDGE ENTZ'S ANSWER TO PLAINTIFF 

INTERVENORS OLIVER, WHITE, AND TINSLEY 

Page - 2 

 



  

Judge Entz lacks knowledge or information sufficient to form a 

belief as to the truth of the balance of the allegations in 

the paragraph. 

19. - 21. Denied with respect to Dallas County. 

22. This paragraph calls for no responsive pleading. 

23. - 24. Denied with respect to Dallas County. 

25. This paragraph alleges a legal conclusion that Judge 

Entz neither admits nor denies. 

26. - 27. Denied with respect to Dallas County. 

28. Judge Entz denies that Intervenors or any of the 

Dallas County Plaintiffs are entitled to the relief sought 

with respect to Dallas County. 

AFFIRMATIVE DEFENSES 
  

29. For purposes of preserving appellate review, Judge 

Entz affirmatively claims that neither the Voting Rights Act 

nor the 14th and 15th amendments of the United States 

Constitution apply to judicial selection. 

30. The lack of electoral success, if any, of minority 

candidates for judicial office was not caused by the electoral 

practices that Plaintiffs challenge. Neither the Voting 

Rights Act nor the 14th and 15th amendments of the United 

States Constitution apply to electoral practices that do not 

cause the lack of electoral success, if any, of minority 

candidates. 

31. Electoral success of judicial candidates in Dallas 

County depends on the partisan affiliation of the candidate, 

JUDGE ENTZ'S ANSWER TO PLAINTIFF 

INTERVENORS OLIVER, WHITE, AND TINSLEY 

Page - 3 

 



  

rather than the race of the candidate. Neither the Voting 

Rights Act nor the 14th and 15th amendments of the United 

States Constitution ensure the right of minority voters to 

elect judicial candidates from the political party of their 

choice. 

32. Neither the Voting Rights Act nor the 14th and 15th 

amendments of the United States Constitution permit 

aggregating distinct minority groups to prove dilution. 

33. Application of either the Voting Rights Act or the 

14th and 15th amendments of the United States Constitution to 

judicial elections is unconstitutional because it violates the 

separation of powers doctrine, the 10th amendment of the 

United States Constitution, and fundamental principles of 

federalism. No 

34. Application of either the Voting Rights Act or the 

14th and 15th amendments of the United States Constitution to 

alter electoral practices that did not cause the lack of 

electoral success, if any, of minority judicial candidates or 

the underrepresentation, if any, of minorities among 

successful judicial candidates would be unconstitutional under 

the equal protection and due process clauses of the United 

States Constitution. 

35. Application of the Voting Rights Act or the 14th and 

15th amendments of the United States Constitution to require 

single member districts for judicial elections in Dallas 

County without adjusting Texas state law venue and jury 

JUDGE ENTZ'S ANSWER TO PLAINTIFF 

INTERVENORS OLIVER, WHITE, AND TINSLEY 

Page - 4 

 



  

selection provisions to provide coterminous districts for 

venue and jury selection purposes would violate the due 

process and equal protection clauses and the 6th and 7th 

amendments of the United States Constitution. 

36. Application of the Voting Rights Act or the 14th and 

15th amendments of the United States Constitution to adjust 

Texas state law venue and jury selection provisions would 

violate the Guaranty Clause and 10th amendment of the United 

States Constitution, as well as fundamental principles of 

federalism. 

37. Application of the Voting Rights Act or the 14th and 

15th amendments of the United States Constitution to Dallas 

County to require single member judicial districts, based on a 

showing that minorities are unable to elect non-minority 

candidates of the political party of the minorities 

preference, would unconstitutionally interfere in the 

political process by favoring the political party currently 

enjoying the support of the minority population, as opposed to 

removing any alleged remaining obstacles to the elections of 

minority candidates. 

38. Minorities are overrepresented on the Dallas County 

State District: Courts in. proportion +o the number of 

minorities in Dallas County eligible for such judicial offices. 

39. Plaintiffs' claims should be dismissed for failure 

to join all district judges within the "target counties" and 

all appellate judges as defendants in that these judges are 

JUDGE ENTZ'S ANSWER TO PLAINTIFF 

INTERVENORS OLIVER, WHITE, AND TINSLEY 

Page - 5 

 



  

necessary or indispensable parties under Rule 19. 

WHEREFORE, Dallas County District Judge F. Harold Entz 

respectfully requests that Intervenors and the Dallas County 

Plaintiffs' claims be dismissed with respect to the system for 

electing district judges within Dallas County and that 

judgment be entered in his favor and that he recover all other 

relief to which he may show himself justly entitled. 

Respectfully submitted, 

Fawa Ally 
  

Robert H. Mow, Jr. 

David C. Godbey 
Bobby M. Rubarts 
Esther R. Rosenblum 

of HUGHES & LUCE 
2800 Momentum Place 

1717 Main Street 
Dallas, Texas 75201 

214/939-5500 

ATTORNEYS FOR DALLAS 
COUNTY DISTRICT JUDGE 
F. HAROLD ENTZ 

CERTIFICATE OF SERVICE 
  

I hereby certify that a true and correct copy of the 

Forsgoinl J has: was served on counsel of record on 

this BEG day of May, 1989, 

Daf Cll,   

52800010:67 

JUDGE ENTZ'S ANSWER TO PLAINTIFF 
INTERVENORS OLIVER, WHITE, AND TINSLEY 
Page - 6