Correspondence from Rios to Hicks Re: Supplements to Interrogatories; LULAC Certificate

    ROLANDO L. RIOS 
Attorney At Law 

201 N. ST. MARY'S, SUITE 521 
SAN ANTONIO, TEXAS 78205 

  

512-222-2102 

512-222-0224 LEGAL DIRECTOR 
FOR 

SOUTHWEST VOTER REGISTRATION 
EDUCATION PROJECT 

June 1, 1989 

Mr. Renea Hicks 
Special Assistant Attorney General 
P.O. Box 12548, Capitol Station 
Austin, Texas 78711-2548 

Re: LULAC #4434 et al. v. Mattox et al. 
CA-MO 88 CA 154 

Dear Mr. Hicks, 

In reference to your letter of May 30, 1989, we supplement as follows: 

SUPPLEMENT TO INTERROGATORY #2   

If the question is directed at finding out who we will call at trail. this relates to trial strategy and is not discoverable. However, if the question relates to who has knowledge about the facts involved in this case, then we provide the following answer: 

1. - All named plaintiffs have knowledge in their respective county of residence as specified in the second amended complaint. 

0)
 

| - Each of the following persons has knowledge of the facts 
in each specified county: 

a.) Dora Olivo - Fort Bend County 
) Maria Mercado - Lubbock County 

) Edia Hernandez - Midland 
.) Anthony Griffen - Galveston 

Each of the above individuals has knowledge of the political realities for minority voters and min rity candidates in their respective counties and such knowledge is based on their personal experiences. 

SUPPLEMENT TO INTERROGATORY #7   

According to the President of statewide LULAC, their membership records do not specify the race or ethnicity of the individual members; however, almost all members are Hispanic or Black. 

 



  

SUPPLEMEN N / 7 

The number of members statewide is estimated at 8,000. Again, they are not 
specified by race or ethnicity; however, most all of them are Hispanic or Black. 

SUPPLEMENT TO INTERROGATORY #9 
  

Generally case law uses 65% as the benchmark for a safe minority district; 
however, local circumstances may make other figures more appropriate. 

SUPPLEMENT TO INTERROGATORY #10 
  

This interrogatory is moot since we have added El Paso County to this 
lawsuit. 

SUPPLEMENT TO INTERROGATORY #11, #12 
  

Records are not kept by the organizations on who is a "qualified voter," 
therefore, we cannot provide the number of qualified voters. 

REQUEST NO. 3 
  

The state LULAC chapter operates under the charter, by laws and 
constitution of the national chapter. Those documents have already been 
provided to you. Enclosed is the incorporation certificate of LULAC #4451. 

These responses will be supplemented as it becomes necessary. Please call if 
you have any questions, 

Sincerely, 

‘Rolando L. Rios 
Attorney at Law 

cc: Council of Record 

 



  

is 

: Ny 
” Ny y TIA W 0) + 

Se 

$ 
I | 

  

3 : 

5 
IF 

> 
Mo 

i 3 
C 
5 
= 

IL 

w 
8 

8 

jo 
AR 1 : 

  
  Ae Se ee Ail

 

  
      

This Certifies That 
ODESSA LULAC 

Council, bas been duly organized under proper authority und is hereby incorporated as 
an affiliated member of the League of United Latin American Citizens, 

by authority of its National Executive Board as 

Council #4451 , County of _ECTOR , State of _TEXAS 
      

and by virtue of this charter said local council and its members are entitled to all rights, 
privileges and immunities granted under the Constitution of the 

League of United Latin American Citizens. 

In Witness Whereof, the name and official seal of The League of 
United Latin American Citizens affixed hereto by order of The 

National Executive Board of this23rd day ofMARCHA.D., 19_88 

am 0 ne nl DR] 
National Business Manager National President 
  

  QAI" RADA CAE Ca BC CO CE CC A YE NAN Ce 
72 IT NS ee