State Defendants' Unopposed Motion for Extension of Time and Stay Pending Appeal and Plaintiffs' Motion for Interim Attorneys' Fees; Proposed Order

    State of Texas 

DAN MORALES 
ATTORNEY GENERAL 

March 19, 1993 

U. S. District Clerk 
P. O. Box 10708 = 
Midland, Texas 79702 k Ee 

RE: LULAC #4434 ,etal.v. Mattox, et al., 
Civ. Action No. MO-88-CA-154 

Dear Sir or Madam: 

Enclosed for filing in the above-referenced matter are the original and one copy of the 
State Defendants’ Unopposed Motion for Extension of Time to Respond to Motion for Interim 
Relief and Stay Pending Appeal and Plaintiffs’ Motion for Interim Attorneys’ Fees, along with a 
proposed Order. Thank you for your attention to this matter. 

Sincerely, 

State Solicitor 

P. O. Box 12548, Capitol Station 
Austin, Texas 78711-2548 
(512) 463-2085 

8 4 oi Counsel of record 

512/463-2100 ; P.O. BOX 12548 AUSTIN, TEXAS 78711-2548 
WPPORTUNITY EMPLOYER 

 



  

UNITED STATES DISTRICT COURT 
WESTERN DISTRICT OF TEXAS 
MIDLAND-ODESSA DIVISION 

LEAGUE OF UNITED LATIN AMERICAN § 
CITIZENS COUNCIL # 4434, et al., 

Plaintiffs, 

VS. Civil Action No. MO-88-CA-154 

JIM MATTOX, etc., et al., 
Defendants. On

 
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STATE DEFENDANTS' UNOPPOSED MOTION FOR EXTENSION OF TIME TO 
RESPOND TO MOTION FOR INTERIM RELIEF AND STAY PENDING APPEAL AND 

PLAINTIFFS' MOTION FOR INTERIM ATTORNEYS' FEES 

The State Defendants hereln (the Attorney General of Texas, the Secretary of State of 

Texas, and the members of the Judicial Districts Board of Texas, each in their official capacities) 

hereby move the Court for an extension of time to file to two Hions (the plaintiff and plaintiff- 

intervenors' Motion for Interim Relief and Stay Pending Appeal and the Plaintiffs’ Motion for 

Interim Attorneys’ Fees) filed by the plaintiffs and plaintiff-intervenors in the above-referenced 

cause: 

I The State Defendants seek an extension until April 2, 1993, to place in the mail 

their responses to the two pending motions. The press of events in this litigation and the delay in 

their receipt of the two motions (the interim relief motion not having been received until March 

15, 1993, and the interim attorney fee motion not having been received until today, March 19, 

1993) are the principal reasons the extension of time is being sought. 

o The below-signed counsel of record has conferred with the plaintiffs attorneys 

(Mr. Rios and Mr. Garrett) and the Harris County plaintiff-intervenor attorneys (Ms. Ifill and Ms. 

McDonald) and they have indicated that they do not oppose the extension being sought here. No 

conference was attempted with Mr. Cloutman, the attorney for the Dallas County plaintiff- 

intervenors, because of information that there had been an unfortunate death in his family, 

thereby making him unavailable. 

‘Based upon the foregoing matters, especially the unopposed nature of the motion, the 

State Defendants urge the Court to grant it and permit the responses to the two motions to be 

filed by placing them in the mail no later than April 2, 1993. 

 



  

Respectfully submitted, 

DAN MORALES 
Attorney General of Texas 

WILL PRYOR 
First Assistant Attorney General 

MARY F. KELLER 
Deputy Attorney General 

  

  

State Solicitor 
State Bar No. 09580400 
Attorney in Charge 
P. O. Box 12548, Capitol Station 
Austin, Texas 78711-2548 
(512) 463-2085 E 
FAX: (512) 463-2063 

JAVIER GUAJARDO 
Special Assistant Attorney General 

ATTORNEYS FOR STATE DEFENDANTS 

CERTIFICATE OF SERVICE 

I certify that on this |“]™ day of March, 1993, a true and correct copy of the foregoing 
document has been sent by first class United States mail, postage prepaid, to each of the 
following: William L. Garrett, Garrett, Thompson & Chang, 8300 Douglas, Suite 800, Dallas, 
Texas 75225; Rolando Rios, Milam Bldg., Suite 1024, 115 E. Travis St., San Antonio, Texas 
78205; Sherrilyn A. Ifill, NAACP Legal Defense and Educational Fund, Inc., 99 Hudson Street, 
16th Floor, New York, New York 10013; Gabrielle K. McDonald, 7800 N. Mopac, Suite 215, 
Austin, Texas 78750; Edward B. Cloutman, III, 3301 Elm Street, Dallas, Texas 75226-1637; E. 
Brice Cunningham, 777 South R. L. Thorton Frwy., Suite 121, Dallas, Texas 75203; J. Eugene 
Clements, Porter & Clements, 3500 NCNB Center, P. O. Box 4744, Houston, Texas 77210- 
4744; Robert H. Mow, Jr., Hughes & Luce, 1717 Main Street, Suite 2800, Dallas, Texas 75201; 
and Seagal V. Wheatley, Oppenheimer, Rosenberg, Kelleher & Wheatley, Inc., 711 Navarro, 
Sixth Floor, San Antonio, Texas 78205. 

  

 



  

UNITED STATES DISTRICT COURT 
WESTERN DISTRICT OF TEXAS 
MIDLAND-ODESSA DIVISION 

LEAGUE OF UNITED LATIN AMERICAN § 
CITIZENS COUNCIL # 4434, et al., $ 

Plaintiffs, § 

§ 
VS. § Civil Action No. MO-88-CA-154 

§ 
JIM MATTOX, etc., et al., § 

Defendants. § 

ORDER 

Having considered the State Defendants’ Unopposed Motion for Extension of Time to 

Respond to Motion for Interim Relief and Stay Pending Appeal by the plaintiffs and plaintiff- 

intervenors and Plaintiffs’ Motion for Interim Attorneys’ Fees, the Court is of the opinion that it 

is well taken and is GRANTED. The State Defendants are sonied an extension of time to 

respond to the two referenced motions and have until April 2, 1993, to place any response in the 

mail for filing. 

SIGNED and ENTERED this day of March, 1993. 

  

UNITED STATES DISTRICT JUDGE 

 



Office of the Attorney General 

State of Texas 

P.O. BOX 12548 
AUSTIN, TEXAS 78711-2548 

Sherrilyn A. Ifill 
NAACP Legal Defense and Educational Fund, Inc. 
99 Hudson Street, 16th Floor 
New York, New York 10013