Judge Wood's Motion for Leave to File Supplemental Letter Brief

    PORTER & CLEMENTS 
A REGISTERED LIMITED LIABILITY PARTNERSHIP 

INCLUDING PROFESSIONAL CORPORATIONS 

ATTORNEYS AT LAW 
MAILING ADDRESS:   

700 LOUISIANA, SUITE 3500 

P.O. BOX 4744 EVELYN V. KEYES HOUSTON, TEXAS 77002-2730 
HOUSTON, TX 77210-4744 

  (713) 228-0820 

TELECOPIER (713) 228-1331 

TELEPHONE (713) 226-0600 

June 2, 1993 

Mr. Richard Windhorst, Clerk VIA FEDERAL EXPRESS 
United States Court of Appeals 
for the Fifth Circuit 

100 U.S. Court of Appeals Courthouse 
600 Camp Street 

New Orleans, Louisiana 70130 

Re: No. 90-8014 and No. 90-9003; League of United Latin American Citizens, 

Council No. 4434, et al., Plaintiffs-Respondents, v. William P. Clements, 

Governor of the State of Texas, et al., Defendants, Judge Sharolyn Wood, etc., 

Defendant-Appellant; In the United States Court of Appeals for the Fifth Circuit 

Dear Mr. Windhorst: 

Enclosed is the original and twenty copies of Judge Wood’s Motion for Leave to File 
Supplemental Letter Brief. 

All parties are being served with copies of this document by first class United States 
mail, postage prepaid. 

Very truly yours, 

lacbip dlls fos 
EVK:taw 

enclosures 

 



IN THE UNITED STATES COURT OF APPEALS 

FOR THE FIFTH CIRCUIT 

  

NO. 90-8014 and 
NO. 90-9003 

  

LEAGUE OF UNITED LATIN AMERICAN CITIZENS, 
COUNCIL NO. 4434, et al., 

Plaintiffs-Respondents, 

Versus 

WILLIAM P. CLEMENTS, GOVERNOR OF THE STATE 
OF TEXAS, et al., 

Defendants, 

JUDGE SHAROLYN WOOD, ETC., 

Defendant-Appellant. 

  

Appeal from the United States District Court 
for the Western District of Texas 

Midland Division 

  

JUDGE WOOD’S MOTION FOR LEAVE TO 
FILE SUPPLEMENTAL LETTER BRIEF 

  

PORTER & CLEMENTS, L.L.P. 
J. Eugene Clements 

Evelyn V. Keyes 

700 Louisiana, Ste. 3500 

Houston, Texas 77002-2730 
(713) 226-0600 

ATTORNEYS FOR APPELLANT/INTERVENOR/ 
DEFENDANT JUDGE WOOD  



  

IN THE UNITED STATES COURT OF APPEALS 

FOR THE FIFTH CIRCUIT 

  

NO. 90-8014 and 
NO. 90-9003 

  

LEAGUE OF UNITED LATIN AMERICAN CITIZENS, 
COUNCIL NO. 4434, et al., 

Plaintiffs-Respondents, 

Versus 

WILLIAM P. CLEMENTS, GOVERNOR OF THE STATE 

OF TEXAS, et al., 

Defendants, 

JUDGE SHAROLYN WOOD, ETC., 
Defendant-Appellant. 

  

Appeal from the United States District Court 
for the Western District of Texas 

Midland Division 

  

JUDGE WOOD’S MOTION FOR LEAVE TO 
FILE SUPPLEMENTAL LETTER BRIEF 

  

TO THE HONORABLE UNITED STATES COURT OF APPEALS: 

Defendant-Intervenor Appellant Harris County District Judge Sharolyn Wood ("Judge 

Wood") files this Motion for Leave to File Supplemental Letter Brief, and would show the Court 

the following: 

1: On or about May 28, 1993, Judge Wood, through her counsel, filed a 

supplemental letter brief with this Court pursuant to Federal Rule of Appellate Procedure 28 and 

the I.0.P. following Rule 28. 

 



  

2, The supplemental letter brief may be considered a supplemental brief, rather than 

a letter concerning new developments as authorized by the 1.0.P. following Federal Rule of 

Appellate Procedure 28. Therefore, Judge Wood respectfully moves the Court to grant leave 

for her supplemental letter brief to be filed with the Court. 

3 The supplemental letter brief provides additional information to the Court that is 

relevant to Judge Woods’s motion to realign Attorney General Morales and to disqualify him and 

his staff as counsel for the State of Texas in this case, and to her request that the Court extend 

her intervention, if necessary, so that she may continue to press the legal issues raised by her 

interlocutory appeal. Judge Wood urges that this supplemental letter brief be considered in 

conjunction with these motions. 

WHEREFORE, for the foregoing reasons Defendant-Intervenor Appellant Harris County 

District Judge Sharolyn Wood respectfully requests that the Court grant her Motion for Leave 

to File Supplemental Letter Brief, and that it grant Judge Wood such other and further relief in 

law and in equity to which she may show herself justly entitled. 

Respectfully submitted, 

PORTER & CLEMENTS, L.L.P. 

— — 
J. Eugene Clements 

Evelyn V. Keyes 
700 Louisiana, Suite 3500 

Houston, Texas 77002-2730 

Telephone: (713) 226-0600 

Facsimile: (713) 228-1331 

   

  

    

    

ATTORNEYS FOR APPELLANT/DEFENDANT/ 

INTERVENOR HARRIS COUNTY DISTRICT 

JUDGE SHAROLYN WOOD 

 



  

OF COUNSEL: 

Michael J. Wood 

Attorney at Law 

440 Louisiana, Suite 200 

Houston, Texas 77002 

Telephone: (713) 228-5101 

Facsimile: (713) 223-9133 

 



  

CERTIFICATE OF SERVICE 

I certify that on this < nd. day of June, 1993, a true and correct copy of the foregoing 
document was served by first class United States mail, postage prepaid, addressed as follows: 

William L. Garrett Walter L. Irvin 
Garrett, Thompson & Chang 5787 South Hampton Road 
8300 Douglas, Suite 800 Suite 210, Lock Box 122 
Dallas, Texas 75226 Dallas, Texas 75232-2255 

Rolando Rios Susan Finkelstein 
Attorney at Law Texas Rural Legal Aid, Inc. 
115 E. Travis, Suite 1024 405 N. St. Mary’s #910 
San Antonio, Texas 78205 San Antonio, Texas 78205 

Sherrilyn A. Ifill Renea Hicks 
NAACP Legal Defense & Special Assistant Attorney General 
Educational Fund, Inc. P. O. Box 12548 

99 Hudson Street, Suite 1600 Capitol Station 
New York, New York 10013 Austin, Texas 78711-2548 

Gabrielle K. McDonald Seagal V. Wheatley 
Walker & Satterwaite Wheatley & Sharpe, L.L.P. 
7800 Mopac, Suite 215 100 West Houston 
Austin, Texas 78759 Frost Bank Tower, Suite 1200 

San Antonio, Texas 78205 
Edward B. Cloutman, III 

Mullinax, Wells, Baab & Cloutman, P.C. Ms. Jessica Dunsay Silver 
3301 Elm Street Department of Justice 
Dallas, Texas 75226-1637 P. O. Box 66078 

Washington, D.C. 20035-6078 
Judith Sanders-Castro 

MALDEF Mr. Joseph D. Jamail 
140 E. Houston Jamail & Kolius 
San Antonio, Texas 78205 One Allen Center 

500 Dallas, Suite 3434 
Robert H. Mow, Jr. Houston, Texas 77002 
David Godbey 
Hughes & Luce 

2800 Momentum Place 
1717 Main Street 

Dallas, Texas 75201 NN 
 —__ 

gene Clements 

  

  

  

7630C:\DOCS\EVK\W0027001\074