Defendant-Intervenor Wood's Answers to Plaintiff-Intervenors' First Set of Interrogatories and Requests for Production

    IN THE UNITED STATES DISTRICT COURT 

FOR THE WESTERN DISTRICT OF TEXAS 

MIDLAND-ODESSA DIVISION 

LULAC, et al., 

Plaintiffs, 

v., NO. MO-88-CA-154 

MATTOX, et al., 

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Defendants. 

DEFENDANT-INTERVENOR WOOD'S ANSWERS 
TO PLAINTIFF-INTERVENORS' FIRST SET OF 

INTERROGATORIES AND REQUESTS FOR PRODUCTION 

  

  

  

TO: Plaintiff-Intervenors Houston Lawyers' Association c/o 
Julius L. Chambers, Sherrilyn A. Ifill, NAACP Legal Defense 
and Education Fund, Inc., 99 Hudson Street, 16th Floor, New 
York, New York 10013. 

Pursuant to Rules 26 and 33 of the Federal Rules of Civil 

Procedure, Defendant-Intervenor Judge Sharolyn Wood ("Wood") 

responds to the Interrogatories and Requests for Production of 

Plaintiff-Intervenors as follows: 

INTERROGATORY NO. 1: 
  

Please identify by year, type of elective office and term 

served, each and every elective office held by defendant- 

intervenor Wood. 

ANSWER TO INTERROGATORY NO. 1: 
  

Defendant has held the following elective offices: appoint- 

ed October 29, 1981, Judge, 295th District Court, served until 

end of 1982: Judge, 127th District Court, 1985-1988 term and 

1989-1992 term. 

 



INTERROGATORY NO. 2: 
  

Please identify by year, type of election, and type of 

office, each and every election in which defendant-intervenor 

Wood has run for elective office in Harris County, Texas, 

indicating whether or not she won that election. 

ANSWER TO INTERROGATORY NO. 2: 
  

Defendant has run for elective office in Harris County, 

Texas in the following elections: 

Year Type of Election Type of Office Result     

1980 Primary Judge Plurality 

1980 Run-Off Judge Won 

1980 General Judge Lost 

1982 Primary Judge Won 

1982 General Judge Lost 

1984 Primary Judge Won (Unopposed) 

1984 General Judge Won 

1988 Primary Judge Won (Unopposed) 

1988 General Judge Won 

INTERROGATORY NO. 3: 
  

Please identify each and every opposing candidate for the 

elections indicated in answer to Interrogatory No. 2 by ethnic 

race. 

ANSWER TO INTERROGATORY NO. 3:   

All opposing candidates were Caucasian. 

REQUEST FOR PRODUCTION NO. 1: 
  

Please provide for inspection and copying all documents 

related to elections in which Judge Wood ran for elective office 

in Harris County, including, but not limited +o, campaign  



  

contribution reports, campaign expenditure reports, election 

returns, campaign literature, written or reported endorsements by 

public officials, civic groups, bar associations, etc. 

ANSWER TO REQUEST FOR PRODUCTION NO. 1: 
  

Available for inspection at the offices of Porter & 

Clements, 700 Louisiana, Suite 3500, Houston, Texas 77002, at a 

time to be arranged by counsel. 

INTERROGATORY NO. 4   

Please identify your political party affiliation. 

ANSWER TO INTERROGATORY NO. 4   

Republican. 

INTERROGATORY NO. 5: 
  

Please identify any professional organizations, «civic 

associations, or other political, social or cultural organiza- 

tions of which you are a member, or in which you are an active 

participant. 

ANSWER TO INTERROGATORY NO. 5: 
  

Member, American Bar Association; Member, State Bar of 

Texas; Member, Houston Bar Association; Fellow, Texas Bar 

Foundation; Fellow, Houston Bar Foundation; Director, Gulf Coast 

Legal Foundation (1989- ); Member, Board of Governors, 

Association of Rice Alumni (1987- ) ; Member, St. Luke's United 

Methodist Church; Member, Magic Circle Republican Women's Club; 

Member, Houston Professional Republican Women's Club. 

 



  

INTERROGATORY NO. 6:   

Identify each expert which you have consulted in preparation 

for the trial of this matter. For each, give the subject matter 

on which the expert was consulted. 

ANSWER TO INTERROGATORY NO. 6: 
  

Defendant has not designated or consulted any expert 

witnesses, at this time, in preparation for the trial of this 

matter. Defendant will timely supplement her answer to this 

interrogatory in compliance with Federal Rule of Civil Procedure 

26 (4) if such consultation occurs. 

REQUEST FOR PRODUCTION NO. 2: 
  

Please produce for inspection and copying all documents you 

have directly or indirectly provided to or prepared for, each 

expert listed in response to Interrogatory No. 6, and any 

documents prepared by each expert for the use of defendant- 

intervenor Wood's participation in this case or which relates to 

the claims or defenses of defendant-intervenor Wood. 

ANSWER TO REQUEST FOR PRODUCTION NO. 2: 
  

Defendant has not designated nor consulted any expert 

witnesses in preparation for the trial of this matter. Defendant 

will comply with this production request 1in accordance with 

Federal Rule of Civil Procedure 26(4) if such consultation 

occurs. 

 



  

INTERROGATORY NO. 7:   

Describe the "nonprotected class," not covered by Section 2 

of the Voting Rights Act, as amended, to which defendant- 

intervenor Wood claims to belong. 

ANSWER TO INTERROGATORY NO. 7: 
  

The "nonprotected class" of the Voting Rights Act, Section 

2, is any person who is not a black or a member of a language 

minority group. 

INTERROGATORY NO. 8 
  

Describe the current district in which defendant-intervenor 

Wood currently serves as district judge, including the number of 

the district, the approximate number of cases on the docket each 

year in that district, the number of district judges currently 

serving in that district, and the date and year which each 

current judicial seat in that district was created. 

ANSWER TO INTERROGATORY NO. 8:   

Defendant currently serves as District Judge in the 127th 

Judicial District Court, with approximately 2700 cases currently 

pending; one district judge is currently serving in that 

district; and the judicial seat in that district was created 

effective September 1, 1939. 

REQUEST FOR PRODUCTION NO. 3: 
  

Please provide any and all documents which support your 

answer to Interrogatory No. 8. 

ANSWER TO REQUEST FOR PRODUCTION NO. 3: 
  

Attached. 

 



  

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THE STATE OF TEXAS § 

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COUNTY OF HARRIS § 

BEFORE ME, the undersigned authority on this day personally 
appeared Sharolyn Wood, who, being by me duly sworn on her oath 
did depose and state that she is qualified and authorized in all 
respects to make this Affidavit, that she has read the foregoing 
Defendant-Intervenor Wood's Answers to the Plaintiff-Intervenors' 
First Set of Interrogatories and Requests for Production and that 
the statements contained therein are to the best of her knowledge 
true and correct. 

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Oh Lael rol 
SHAROLYN WOOD 1 s 
  

SUBSCRIBED and SWORN TO BEFORE ME on this the 4 day of 
May, 1989. 

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the State of Texas 

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Notary Public 

La STATE OF TEXAS 
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J. Eugene Clements 
Attorney in Charge for Bete mint 
Harris County District Judge 
Sharolyn Wood 
700 Louisiana, Suite 3500 
Houston, Texas 77002-2730 

(713) 226-0600 
OF COUNSEL: 

PORTER & CLEMENTS 

John E. O'Neill 
Evelyn V. Keyes 
700 Louisiana, Suite 3500 
Houston, Texas 77002-2730 

(713) 226-0600 

 



  

CERTIFICATE OF SERVICE 
  

I hereby certify that on the /Hh day of May, 1989, a true 
and correct copy of the above and foregoing Defendant-Intervenor 
Wood's Answers to the Plaintiff-Intervenors' First Set of 
Interrogatories and Requests for Production was served upon 
counsel of record in this case first class United States mail, 
postage prepaid, addressed as follows: 

Mr. William L. Garrett 
Ms. Brenda Hull 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 221 
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 

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 

Lash V. Lig 
Evelyn V. Keyes 
  

WO0002/08/cdf