Plaintiff-Intervenors Houston Lawyers' Association's Second Set of Interrogatories and Requests for Production to Defendants

    May 17, 1989 

Renea Hicks, Esq. 
Javier Guajardo, Esq. 
Attorney General’s Office 
P.O. Box 12548 

Austin, TX 78711 

Re: 1UIAC, et al. v. Mattox, et al. 
  

Dear Counsel: 

Enclosed please find Plaintiff-Intervenors Houston Lawyers’ Association’s Second Set of Interrogatories and Requests for Production of Documents to defendants in the above captioned case. All counsel of record have been served. 

I look forward to your timely response. 

Ancerely, 
// : 7 < { 7 

Sherrie +:Ifi1) 
Counsel/ for Plaintiff-Intervenors 

SAI/dm 
encls. 

  
NINETY NINE HUDSON STREET, 16th FLOOR (212) 219-1900 NEW YORK, N.Y. 10013  



  

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, 

Houston Lawyers’ Association, Alice Bonner, 
Weldon Berry, Francis Williams, Rev. William 
Lawson, Deloyd T. Parker, Bennie McGinty, 

PLAINTIFF-INTERVENORS, 

Vv. 
No. MO-88-CA-154 

JAMES MATTOX, Attorney General of the State 
Of Texas, et al., 

DEFENDANTS. 

PLAINTIFF-INTERVENORS HOUSTON IAWYERS’ ASSOCIATION'S 
SECOND SET OF INTERROGATORIES AND REOUESTS FOR PRODUCTION 

TO DEFENDANTS 

  

  

  

Pursuant to Rules 33 and 34 of the Federal Rules of Civil 

Procedure, plaintiff-intervenors request that defendants answer 

fully in writing and under oath each of the following 

interrogatories within 15 days after service. These 

interrogatories shall be deemed continuing to the extent required 

by Fed. R. Civ. 26(e). 

In answering each interrogatory, defendants are requested to 

identify separately and in a manner suitable for use in a 

subpoena all source of information (whether human, documentary, 

or other) and all records maintained by the defendants or by any 

other person or organization on which the defendants relied in 

answering the interrogatories. 

 



  

For each request to produce, plaintiffs request that 

defendants produce all requested documents at the law office of 

Gabrielle K. McDonald, 301 Congress Avenue, Suite 2050, Austin, 

Texas 78701, within 15 days after service or at such time and 

place as is mutually agreed upon by counsel for the parties. 

Definitions 

  

l. ”Identify” when referring to a fact or document, means state 

the name and date of the fact or document, the type of document, 

the identity of the author of the document, and the location of 

the document or a copy of the document. 

2 ”Identify,” when referring to a person, means state the 

name, race, home and business address and position with any 

defendant or relation to any defendant, if any. 

3. “Document,” means the original or identical copy of any 

document (including writings, drawings, graphs, charts, 

photographs, phonorecords, audio recordings, and other data 

compilations from which information can be obtained, translated, 

if necessary, by the plaintiffs through detection services into 

reasonably usable form) and any tangible things which constitute 

or contain matters within the scope of Rule 26(b) of the Federal 

Rules of Civil Procedure. 

 



  

4. "Relating to” a subject or fact means containing, embodying, 

referring to, comprising, reflecting, explaining, or having a 

logical, factual or causal connection with the subject. 

5 "The Voting Rights Act” means the Voting Rights Act of 1965, 

as amended, 42 U.S.C. §1973, et seq. 

Interrogatories and Requests to Produce 
  

  

INTERROGATORY NO. 1: Explain and describe whether you oppose or 

do not support the election of district judges in the state of 

Texas from single member districts smaller in size than an entire 

county, including but not limited to, why you do or do not 

support the use of such an electoral scheme for the election of 

district judges in Texas, and whether you contend that the 

election of judges from single member districts would undermine 

any state policy or rationale related to district judges. 

REQUEST FOR PRODUCTION NO. 1: Please provide for inspection and   

copying any documents which support your answer to Interrogatory 

No. 1, or on which you base your answer to Interrogatory No. 1. 

  

INTERROGATORY NO. 2: Explain and describe whether or not you 

oppose or do not support the use of a non-exclusionary at large 

system, such as limited or cumulative voting, for the election of 

 



district judges in Texas, including but not limited to, why you 

do or do not support the use of such an electoral scheme for the 

election of district judges in Texas, and whether you contend 

that the election of district judges using such an electoral 

scheme, would undermine or violate any state policy or rationale 

related to district judges. 

  

REQUEST FOR PRODUCTION NO. 2: Please provide for inspection and 

copying any documents which support your answer to Interrogatory 

No. 2, or on which you base your answer to Interrogatory No. 2. 

Regpectfully submitted, 

  

JULIUS I./ CHAMBERS/ 
SHERRILYN A. IFILL 

NAACP Legal Defense & 
Educational Fund, Inc. 
99 Hudson Street, 16th Floor 
New York, New York 10013 
(212) 219-1900 

Of Counsel: GABRIELLE K. MCDONALD 
Matthews & Branscomb 301 Congress Avenue 
A Professional Corporation Suite 2050 

Austin, Texas 78701 
(512) 320-5055 

Attorneys for Plaintiff-Intervenors 
Houston Lawyers’ Association, 

et al. 

May [} 1989  



CERTIFICATE OF SERVICE 

I hereby certify that on this 17th day of May, 1989, a true 

and correct copy of the foregoing Plaintiff-Intervenors Houston 

Lawyers’ Association’s Second Set of Interrogatories and Requests 

For Production to Defendants was mailed to counsel of record in 

this case by first class United States mail, postage pre-paid, as 

follows: 

William L. Garrett J. Eugene Clements 
Brenda Hull Thompson John E. 0O’Neill 
Garrett, Thompson & Chang Evelyn V. Keys 
8300 Douglas, Suite 800 Porter & Clements 
Dallas, TX 75225 700 Louisiana, Suite 3500 

; Houston, TX 77002-2730 Rolando L. Rios 
Southwest Voter Registration 

Education Project Michael J. Wood 201 N. St. Mary’s, Suite 521 Attorney at Law 
San Antonio, TX 78205 440 Louisiana, Suite 200 

; : Houston, TX 77002 
Susan Finkelstein 
Texas Rural Legal Aid, Inc. Ken Oden 
201 N. St. Mary’s, Suite 521 Travis County Attorney San Antonio, TX 78205 P.O. Box 1748 

Austin, TX 78767 
Edward B. Cloutman, III 
Mullinax, Wells, Baab & David R. Richards 

Cloutman, P.C. Special Counsel 3301 Elm 600 W. 7th st. Dallas, TX 75226-9222 Austin, TX 78701 

Jim Mattox Robert H. Mow, Jr. Mary F. Keller Hughes & Luce Renea Hicks 2800 Momentum Place Javier Guajardo 1717 Main Street Attorney General’s Office Dallas, TX 75201 
P.O. Box 12548 

Austin, TX 78711 

: HL L 
wie A, Teil1? 
Atto y for Plaintiff-Intervenors 
Houstorg Lawyers’ Association 

   



  

May 17, 1989 

Renea Hicks, Esq. 
Javier Guajardo, Esq. 
Attorney General’s Office 
P.O. Box 12548 

Austin, TX 78711 

Re: LULAC, et al. v. Mattox, et al. 
  

Dear Counsel: 

Enclosed please find Plaintiff-Intervenors Houston Lawyers’ Association’s Second Set of Interrogatories and Requests for Production of Documents to defendants in the above captioned case. All counsel of record have been served. 

I look forward to your timely response. 

iincerely, Te 
lf  -7 7 J 
lero d A HL 
Sherripgh X. IfiYl 
Counsel’ for Plaintiff-Intervenors 

    

    

SAI/dm 

encls. 

  

NINETY NINE HUDSON STREET, 16th FLOOR . (212) 219-1900 ° NEW YORK, N.Y. 10013 

 



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, 

Houston Lawyers’ Association, Alice Bonner, 
Weldon Berry, Francis Williams, Rev. William 
Lawson, Deloyd T. Parker, Bennie McGinty, 

PLAINTIFF-INTERVENORS, 

Vv. 
No. MO-88-CA-154 

JAMES MATTOX, Attorney General of the State 
of Texas, et al., 

DEFENDANTS. 

PIAINTIFF-INTERVENORS HOUSTON LAWYERS’ ASSOCIATION’S 
SECOND SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION 

TO DEFENDANTS 

  

  

  

Pursuant to Rules 33 and 34 of the Federal Rules of Civil 

Procedure, plaintiff-intervenors request that defendants answer 

fully in writing and under oath each of the following 

interrogatories within 15 days after service. These 

interrogatories shall be deemed continuing to the extent required 

by Fed. R. Civ. 26(e). 

In answering each interrogatory, defendants are requested to 

identify separately and in a manner suitable for use in a 

subpoena all source of information (whether human, documentary, 

or other) and all records maintained by the defendants or by any 

other person or organization on which the defendants relied in 

answering the interrogatories.  



  

For each request to produce, plaintiffs request that 

defendants produce all requested documents at the law office of 

Gabrielle K. McDonald, 301 Congress Avenue, Suite 2050, Austin, 

Texas 78701, within 15 days after service or at such time and 

place as is mutually agreed upon by counsel for the parties. 

Definitions 

  

1. Identify” when referring to a fact or document, means state 

the name and date of the fact or document, the type of document, 

the identity of the author of the document, and the location of 

the document or a copy of the document. 

2. ”Identify,” when referring to a person, means state the 

name, race, home and business address and position with any 

defendant or relation to any defendant, if any. 

3. “Document,” means the original or identical copy of any 

document (including writings, drawings, graphs, charts, 

photographs, phonorecords, audio recordings, and other data 

compilations from which information can be obtained, translated, 

if necessary, by the plaintiffs through detection services into 

reasonably usable form) and any tangible things which constitute 

or contain matters within the scope of Rule 26(b) of the Federal 

Rules of Civil Procedure. 

 



  

4. “Relating to” a subject or fact means containing, embodying, 

referring to, comprising, reflecting, explaining, or having a 

logical, factual or causal connection with the subject. 

5. “The Voting Rights Act” means the Voting Rights Act of 1965, 

as amended, 42 U.S.C. §1973, et seq. 

Interrogatories and Requests to Produce 
  

  

INTERROGATORY NO. 1: Explain and describe whether you oppose or 

do not support the election of district judges in the state of 

Texas from single member districts smaller in size than an entire 

county, including but not limited to, why you do or do not 

support the use of such an electoral scheme for the election of 

district judges in Texas, and whether You contend that the 

election of judges from single member districts would undermine 

any state policy or rationale related to district judges. 

REQUEST FOR PRODUCTION NO. 1: Please provide for inspection and   

copying any documents which support your answer to Interrogatory 

No. 1, or on which you base your answer to Interrogatory No. 1. 

INTERROGATORY NO. 2: Explain and describe whether or not you   

oppose or do not support the use of a non-exclusionary at large 

system, such as limited or cumulative voting, for the election of 

 



  

district judges in Texas, including but not limited to, why you 

do or do not support the use of such an electoral scheme for the 

election of district judges in Texas, and whether you contend 

that the election of district judges using such an electoral 

scheme, would undermine or violate any state policy or rationale 

related to district judges. 

REQUEST FOR PRODUCTION NO. 2: Please provide for inspection and   

copying any documents which support your answer to Interrogatory 

No. 2, or on which you base your answer to Interrogatory No. 2. 

Regpectfully submitted, 

   
-— 

       
  

  

JULIUS V7 CHAMBERS/ 
SHERRILYXN A. IFILL 

NAACP Legal Defense & 
Educational Fund, Inc. 
99 Hudson Street, 16th Floor 
New York, New York 10013 
(212) 219-1900 

   

Of Counsel: GABRIELLE K. MCDONALD 
Matthews & Branscomb 301 Congress Avenue 
A Professional Corporation Suite 2050 

Austin, Texas 78701 
(512) 320-5055 

Attorneys for Plaintiff-Intervenors 
Houston Lawyers’ Association, 

et al. 

may [7 1989 

 



CERTIFICATE OF SERVICE 

I hereby certify that on this 17th day of May, 1989, a true 

and correct copy of the foregoing Plaintiff-Intervenors Houston 

Lawyers’ Association’s Second Set of Interrogatories and Requests 

For Production to Defendants was mailed to counsel of record in 

this case by first class United States mail, postage pre-paid, as 

follows: 

William L. Garrett 
Brenda Hull Thompson 
Garrett, Thompson & Chang 
8300 Douglas, Suite 800 
Dallas, TX 75225 

J. Eugene Clements 
John E. 0O’Neill 
Evelyn V. Keys 
Porter & Clements 
700 Louisiana, Suite 3500 

: Houston, TX 77002-2730 Rolando L. Rios 
Southwest Voter Registration 

Education Project 
201 N. St. Mary’s, Suite 521 
San Antonio, TX 78205 

Michael J. Wood 
Attorney at Law 
440 Louisiana, Suite 200 

; : Houston, TX 77002 
Susan Finkelstein 
Texas Rural Legal Aid, Inc. 
201 N. St. Mary’s, Suite 521 
San Antonio, TX 78205 

Ken Oden 
Travis County Attorney 
P.O. Box 1748 

Austin, TX 78767 
Edward B. Cloutman, III 
Mullinax, Wells, Baab & 

Cloutman, P.C. 
David R. Richards 
Special Counsel 

3301 Elm 

Dallas, TX 75226-9222 

Jim Mattox 
Mary F. Keller 
Renea Hicks 
Javier Guajardo 
Attorney General’s Office 
P.O. Box 12548 

Austin, TX 78711 

600 W. 7th St. 
Austin, TX 78701 

Robert H. Mow, Jr. 
Hughes & Luce 
2800 Momentum Place 
1717 Main Street 
Dallas, TX 75201 

Jl 
Sherrilim A. Tfii17 
Atto y for Plaintiff-Intervenors 
Houstong Lawyers’ Association