Defendant Wood's Motion for and Protective Order

    A PARTNERSHIP INCLUDING 

PorRTER & CLEMENTS 
FIRST REPUBLICBANK CENTER 

700 LOUISIANA, SUITE 3500 

HOUSTON, TEXAS 77002-2730 

ATTORNEYS 
  

TELEPHONE (713) 226-0600 
PROFESSIONAL CORPORATIONS 

TELECOPIER (713) 228-1331 

TELECOPIER (713) 224-4835 

EVELYN V. KEYES TELEX 775-348 

(713) 226-0611 

August 17, 1989 

Clerk, U.S. District Court FEDERAL EXPRESS 
200 FE. Viall 8+. Suite 316 
Midland, Texas 79702 

  

Re: No. MO88-CA-154; League of United Latin American 
Citizens (LULAC), et al. v. James. Mattox, Attorney 
General of Texas, et al.; In the United States District 
Court for the Western District of Texas, Midland-Odessa 
Division 

Dear Sir: 

Enclosed for filing in the above-referenced case are the 
following documents: 

(1) Defendant's Wood's Motion for Protective Order; and 

(2) Protective Order. 

Please return a file stamped copy of these documents in the 
enveloped provided. 

A copy of this filing is being mailed first class, postage 
prepaid, to all counsel of record. 

Sincerely yours, 

VCs a4 
Evelyn V. Keyes 

EVK/br 
enclosures 

 



Clerk, U.S. District Court 
August 17, 1989 
Page -2- 

Mr. William L. Garrett 
Ms. Brenda Hall Thompson 
Garrett, Thompson & Chang 
Attorneys at Law 

8300 Douglas, Suite 800 
Dallas, Texas 75225 

Mr. Rolando L. Rios 
Southwest Voter Registration & 

Education Project 
201 N. St, Mary's, Suite 521 
San Antonio, Texas 78205 

Ms. Susan Finkelstein 
Texas Rural Legal Aid, Inc. 
201"N. St. Mary's, Suite 600 
San Antonio, Texas 78205 

Mr. Julius Levonne Chambers 
Ms. Sherrilyn A. Ifill 

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

New York, New York 10013 

Ms. Gabrielle K. McDonald 

Matthews & Branscomb 

301 Congress Ave., Suite 2050 
Austin, Texas 78701 

Mr. Jim Mattox, Attorney General of Texas 
Ms. Mary F. Keller, First Assistant Attorney General 
Ms. Renea Hicks, Spec. Assistant Attorney General 
Mr. Javier Guajardo, Spec. Assistant Attorney General 
P., O, Box 12548 
Capitol Station 
Austin, Texas 78701 

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

3301 Elm Street 

Dallas, Texas 75226-1637 

Mr. E. Brice Cunningham 
777 So. R.L. Thornton Freeway, Suite 121 
Dallas, Texas 75203  



  

Clerk, U.S. District Court 
August 17, 1989 
Page -3- 

cc: Mr. Ken Oden 
Travis County Attorney 
P. O. Box 1748 
Austin, Texas 78767 

Mr. David R. Richards 
Special Counsel 
600 W. 7th Street 

Austin, Texas 78701 

Mr. Mark H. Dettman 

Attorney at Law 

P. O. Box 2559 

Midland, Texas 79702 

Mr. Robert H. Mow, Jr. 

Hughes & Luce 
2800 Momentum Place 

1717 Main Street 

Dallas, Texas 75201 

 



  

IN THE UNITED STATES DISTRICT COURT 

FOR THE WESTERN DISTRICT OF TEXAS 

MIDLAND-ODESSA DIVISION 

LEAGUE OF UNITED LATIN 

AMERICAN CITIZENS (LULAC), 

et al. 

Plaintiffs 

V. C. A. "NO. MO 88 CA 154 

JIM MATTOX, Attorney General 
of the State of Texas, et al. : 

Defendants. 

DEFENDANT WOOD'S MOTION FOR PROTECTIVE ORDER 
  

TO THE HONORABLE UNITED STATES DISTRICT JUDGE: 

Defendant Harris County District Judge Sharolyn Wood herein 

respectfully requests the entry of the attached Protective Order 

to maintain the confidentiality of documents produced by Hon. 

Mark Davidson, an expert witness for Judge Sharolyn Wood during 

the pendency of this action. 

The accompanying Protective Order, together with a Joint 

Motion for Protective Order, has been sent to Counsel for 

Plaintiffs, Rolando L. Rios, and Counsel for the Houston Lawyers 

Association, Sherrilyn A. Ifill and Gabrielle K. McDonald, in the 

form of an Agreed Order. Because of the short time remaining 

before the deposition of Judge Davidson, scheduled for Tuesday, 

August 22, 1989, and because both Ms. Ifill and Ms. McDonald are 

out of town and communications with them may not be completed in 

 



  

time, Counsel for Judge Wood files this Motion and Protective 

Order with the request that the Court enter the Protective Order 

without waiting for the Agreed Order if the executed Agreed Order 

is not received by the Court by Monday, August 21, and the Court 

finds that Defendant Wood's request has merit. 

Respectively submitted, 

ey Ber a VL a 

by Ely Vets 4) prmimncs 
Eudene Clements 

i one in-Charge for Defendant 
Intervenor Harris County District 
Judge Sharolyn Wood 
700 Louisiana, Suite 3500 

Houston, Texas 77002-2730 

(713) 226-0600 

  

OF COUNSEL: 

PORTER & CLEMENTS 

700 Louisiana, Suite 3500 
Houston, Texas 77002-2730 

(713) 226-0600 

CERTIFICATE OF SERVICE 
  

I hereby certify that on this | 7H aay of August, 1989, a 
true and correct copy of the above and foregoing Motion for 
Protective Order and accompanying Protective Order was served 
upon all counsel of record herein by placing a copy of same into 
the United States mail, postage prepaid. 

BG 
J. Eugene Clements 

V. Cees 
  

JEC:br 

WO0027:18 

 



  

IN THE UNITED STATES DISTRICT COURT 

FOR THE WESTERN DISTRICT OF TEXAS 

MIDLAND-ODESSA DIVISION 

LEAGUE OF UNITED LATIN 4 

AMERICAN CITIZENS (LULAC), 2 

et al. : 

Plaintiffs : 

NV. $ Ce. A. NO. MO 838 CA 154 

JIM MATTOX, Attorney General : 
Of the State of Texas, et al : 

Defendants. : 

PROTECTIVE ORDER 
  

Upon the Motion of Defendant Harris County District Judge 

Sharolyn Wood, the Court enters this Protective Order. It is 

ORDERED that: 

1, All documents produced by Hon. Mark Davidson, expert 

witness for Defendant/Intervenor Harris County District Judge 

Sharolyn Wood in this action shall be used solely in conjunction 

with the defense of this case. 

2, None of the documents, computer programs or 

computerized results produced or information contained in those 

documents shall be disclosed to third parties other than expert 

witnesses retained for use in the case who will execute written 

acknowledgments and agreements to be bound by this Order prior to 

the documents being delivered to them, with copies of such 

 



agreements to be delivered to counsel for Defendant/Intervenor 

Wood within five (5) business days thereafter. 

3. All copies of the documents produced by Hon. Mark 

Davidson are to be returned to counsel for Defendant Intervenor 

Wood upon completion of the case. 

SIGNED this day of 
  

  

UNITED STATES DISTRICT JUDGE 

WO0027:17/bld  



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SENT BY:Xerox Telegopier 7020 + 8-17-88 10:54AM ; fran 7992 

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

MIDLAND-QODESSEA DIVISION 

LEAGUE OF UNITED LATIN 
AMERICAN CITIZENS (LULAC), 
COUNCIL #4434; LULAC Counesl 

   

$4451; CHRISTINA MORENO 
AQUILLA WATSON; JAMES FULLER 
JUDGE MATTHEW W. PLUMMER, SR. 

and LULAC( ewide) 

Plaintiffs 

V. Sf A. NO. MO 8 

WILLIAM CLEMENTS, Governor of 
the State of Texas; TIM 
MATTOX, Attorney General of 
the State of Texas; JACK 
Rains, Secretary of State of 
the State of Texas, All in 
their official capacities: 
THOMAS R. PHILLIPS, Chief 
Justice of the Supreme Court 
of Texas; JOHN F. ONION, JR., 
Court of Criminal Appeals; 
RON CHAPMAN, Presiding Judge 
of the lst Administrative 

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ENT    BY: Xerox hy 7020 » 8-17-89 10:55AM » dai. “4 7582 8 4 

Judicial Region; RAY D, 
Anderson, Presiding Judge of 
the 9th Administrative 
Region; JOE SPURLOCK II, 
President, Texas Judicial 

Council, All in their official 
capacities as members of the 
Judicial Districts Board of 
the State of Texas, 

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JOINT MOTION FOR PROTECTIVE ORDER 
  

TO THE HONORABLE UNITED STATES DISTRICT JUDGE: 

Plaintiffs and Defendants herein respectfully request +he 

entry of the attached Agreed Protective Order to maintain the 

confidentiality of documents produced by Hon. Mark Davidson, an 

expert witness for Defendant/Intervenor Harris County District 

Judge Sharolyn Wood during the pendency of this action, 

Respectively submitted, 

  

lb
 

~ J.[ Eugene Clements “— 

Attorney=in=Charge for Defendant 
«. Intervenor Harris County District 
Judge Sharolyn Wood 
Federal Identification No, 928 
700 Louisiana, Sulte 3500 
Houston, Texas 77002-2730 
(713) 226-0600 

OF COUNSEL: 

PORTER & CLEMENTS 

700 Louisiana, Suite 3500 
Houston, Texas 77002=2730 
(713) 226-0600 

AUG 17 ‘89 (Z:i@D 132244835 PAGE. AR4 

 



   SENT BY: Xer 

  

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NAACP LAL DE. PENSH AND 
EDUCATIONAL FUND 
ede Re? Yr Le oy INA he of mY Ap 

99 Hudson Street, 
New York, New York 

(212) 219-1800 

16th Floor 
10013 

OF COUNSEL: 

MATTHEWS & BRANSCOMB 
Congress Avenue, 

Texag 78701 

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Suite 20 

RATION 

Sherrilyn A. Ifill 
Attorney-in=-Charge for Houston 
Lawyers Association 
899 Hudson Street, 16th Floor 
New York, New York 10013 
(212) 219-1900 

  

Gabrielle K. McDonald 
Attorney~in~Charge for The Black 
Legislative Caucus 
301 Congress Avenue, 
Austin, Texas 78701 

(512) 320-5055 

Suite 2050 

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CERTIFICATE OF SERVICE 
  

I hersby certify that on this day of August, 1889, a 
true and correct copy of the above art foregoing Joint } Motion for 
Protective Order and Agreed Protective Qrder was served upon all 
counsel of record herein by pl ein 1g a copy of same into th 
United States mail, postage prepaid. 

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SENT BY:Xerox Telecopier 7020 » 8-17 

  

-89 +10.56AM ane 7592 

IN THE UNITED STATES DISTRICT COQURT 
FOR THE WESTERN DIST 

MIDLAND=QDESSA DIVISION 

LEAGUE QF UNITED LATIN 
AMERICAN CITIZENS (LULAC), 

COUNCIL #4434; LULAC COUNCIL 

#4451; CHRISTINA MORENO; 
AQUILLA WATSON; JAMES FULLER: 

JUDGE MATTHEW W. PLUMMER, SR. 
and LULAC (Statewide) 

Plaintiffs 

L$ 4 
Va 

WILLIAM CLEMENTS, Governor of 
the State of Texas; JIM 
MATTOX, Attorney General of 

the State of Texas; JACK 
Raina, Ecpompokaey of Cents of 
the State of Texas, All in 

their official capacities: 
THOMAS R. PHILLIPS, Chief 
Justice of the Supreme Court 
of Texas; JOHN F. ONION, JR., 
Court of Criminal Appeals: 
RON CHAPMAN, Presiding Judge 
of the lst Administrative 
Judioial Region: THOMAS J. 
STOVALL, JR., Presiding Judge 
of the 2nd Administrative 

Judicial Region; JAMES FPF. 

CLAWSON, JR., Presiding Judge 
of the 3rd Administrative 

Judicial Region; JOE BE. 
KELLY, Presiding Judge of the 
4th Administrative Judicial 
Region; JOE B. EVINS, 
Presiding Judge of the 5th 
Administrative Judicial 
Region; SAM B. PAXON, 
Pregiding Judge of the 6th 
Administrative Judicial H 
Region; WELDON KIRK, Presiding 
Judge of the 7th Administra- 
tive Judicial Region; CHARLES 
J. MURRAY, presiding Judge of 
the 8th Administrative 

  

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SENT BY: XeroX "NY 7020 » 8-17-89 »10.56AM » ay 7592 

Judicial Region; RAY D, 
Anderson, Presiding Judge of 
the 9th Administrative 
Region; JOE SPURLOCK II, 

President, Texas Judicial 
Council, All in their official 

capacities as members of the 
Judicial Districts Board of 
the State of Texas. 

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Defndants. 

AGREED PROTECTIVE QRDER 
  

Upon the Joint Motion of Plaintiffs and Defendant, the Court 

enters this Agreed Protective Order. It is ORDERED that: 

1. All documents produced by Hon. Mark Davidson, expert 

witness for Defendant/Intervenor Harris County District Judge 

Sharolyn Wood in this action shall be used solely in conjunction 

with the defense of this casa. 

24 None of the documents, computer programs or 

computerized results produced or information contained in those 

acknowledgments and agreements to be bound by this Order prior to 

the documents being delivered to them, with copies of such 

agreements to be delivered to counsel for Defendant/Intervenor 

Wood within five (5) business days thereafter, 

3. All copies of the documents produced by Hon. Mark 

Davidson are to be returned to counsel for Defendant Intervenor 

Wood upon completion of the case, 

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