Response in Opposition to HLA to Motions of Appellants (Entz and Bayoud) for Establishment of Expedited Briefing Scheduling

    IN THE UNITED STATES COURT OF APPEALS 
FIPTH CIRCUIT 

LEAGUE OF UNITED LATIN 

AMERICAN CITIZENS (LULAC), 
COUNCIL #4434 et al. 

Plaintiffs, 

and 

HOUSTON LAWYERS ASSOCIATION 

et al., 
Plaintiff-Intervenors, 

No. 90-8014 

Vv. 

JIM MATTOX, et al., 
State Defendants. Wh

 
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RESPONSE IN OPPOSITION OF HOUSTON LAWYERS ASSOCIATION, ET AL 
TO MOTIONS OF APPELLANTS (ENTZ AND BAYOUD) FOR ESTABLISHMENT 

OF EXPEDITED BRIEFING SCHEDULING 

  

  

  

TO THE HONORABLE COURT: 

NOW COME Houston Lawyers Association ("HLA"), Weldon Berry, 

Francis Williams, Alice A. Bonner, William Lawson, Deloyd T. 

Parker, Jr., and Bennie McGinty ("Plaintiff-Intervenors") and 

hereby respectfully submit their response to the Motions of 

Appellants' Judge Entz ("Entz") and Secretary of State George S. 

Bayoud, Jr. ("Bayoud") for Expedited Briefing Schedules in the 

above-styled matter, and respectfully pray that this Court deny 

said Motions and as grounds therefore would respectfully show as 

follows: 

I. 

Plaintiff, League of United Latin American Citizens 

("LULAC") has previously filed a response in opposition to the  



Motion of Appellant Entz for establishment of expedited briefing 

schedule. Plaintiff-Intervenors join in that response for the 

reasons stated in the response of LULAC. 

17. 
The issues that are presented to this Court as they relate 

to the Harris County voters, are complex and of such significance 

that it is necessary to have the normal briefing schedule in 

order to properly prepare. 

111. 

Defendant-Appellant George S. Bayoud, Jr. has filed a Motion 

dated January 24, 1990, joining in Judge Entz's Motion for 

Establishment of Expedited Briefing Schedule. For the reasons 

previously set forth in the Response in Opposition filed by 

Plaintiff-Appellee LULAC to Appellant Entz's Motion, 

Plaintiff-Intervenors oppose Bayoud's Motion. 

WHEREFORE, Plaintiff-Intervenors Houston Lawyers 

Association, et al., respectfully request this Court to deny the 

Motions for Establishment of Expedited Briefing Schedule filed by 

Entz and Bayoud and establish a briefing schedule which will 

provide all parties OP] ini to fully brief the complex 

Respectfully submitted, (ger 

JULIUS LEVONNE CHAMBERS 
SHERRILYN A. IFILL 

NAACP Legal Defense and 
Educational Fund, Inc. 

issues. 

   



99 Hudson Street, 16th Floor 
New York, New York 10013 
(212) 219-1900 

OF COUNSEL: 2s, 
GABRIELLE K. MCDONALD 7 

MATTHEWS & BRANSCOMB 301 Congress Avenue, Ste. 2050 
A Professional Corporation Austin, Texas 78701 

(512) 320-5055 

  

ATTORNEYS FOR PLAINTIFF- 
INTERVENORS 
HOUSTON LAWYER'S ASSOCIATION, 
ET AL. 

CERTIFICATE OF CERTIFICATE 
  

I certify that on this 25th day of January, 1990, I sent a 
copy of the foregoing document by first class U.S. mail to each 
of the following: William L. Garrett, Garrett, Thompson & Chang, 
8300 Douglas, Suite 800, Dallas, Texas 75225; Rolando Rios, 
Southwest Voter Registration & Education Project, 201 N. St. 
Mary's, Suite 521, San Antonio, Texas 78205; Sherrilyn A. Ifill, 
NAACP Legal Defense and Educational Fund, Inc., 99 Hudson Street, 
16th Floor, New York, New York 10013; Renea Hicks P.O. Box 12548, 
Capitol Station, Austin, Texas 78711-2548; Edward B. Cloutman, 
III, Mullinax, Wells, Baab & Cloutman, P.C., 3301 Elm Street, 
Dallas, Texas 75226-1637; J. Eugene Clements, Porter & Clements, 
700 Louisiana, Suite 3500, Houston, Texas 77002-2730; Robert H. 
Mow, Jr., Hughes & Luce, 2800 Momentum Place, 1717 Main Street, 
Dallas, Texas 75201; and John L. Hill, Jr. Liddell, Sapp, Livley, 
Hill & LaBoon, 3300 Texas Commerce Tower, Houston, Texas 77002. 

EAL An, 
ielle K. McDonald %