Case 5:11-cv OLG-JES-XR Document Filed 12/04/14 Page 1 of 21

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1 Case 5:11-cv OLG-JES-XR Document Filed 12/04/14 Page 1 of 21 IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION SHANNON PEREZ, et al., v. Plaintiffs, STATE OF TEXAS, et al., CIVIL ACTION NO. SA-11-CA-360-OLG-JES-XR [Lead case] Defendants. DEFENDANT RICK PERRY S OBJECTIONS AND RESPONSES TO TEXAS LATINO REDISTRICTING TASK FORCE PLAINTIFFS SECOND SET OF INTERROGATORIES TO: Plaintiffs Texas Latino Redistricting Task Force, et al., by and through their attorney of record, Nina Perales, 110 Broadway Street, #300, San Antonio, TX Defendant Rick Perry, in his official capacity as Governor, by and through his counsel of record, the Attorney General of Texas, hereby serves his Objections and Responses to the Second Set of Interrogatories of Plaintiffs Texas Latino Redistricting Task Force, et al. ( TLRTF or Plaintiffs ), pursuant to Rule 33 of the Federal Rules of Civil Procedure. GENERAL OBJECTIONS Defendant objects to each interrogatory: (1) insofar as it seeks information not in Defendant s possession, custody, or control; (2) insofar as it seeks information that was prepared for or in anticipation of litigation, constitutes attorney work 1

2 Case 5:11-cv OLG-JES-XR Document Filed 12/04/14 Page 2 of 21 product, contains attorney-client communications, or is otherwise protected by legislative privilege, deliberative process privilege, or any other applicable privilege, protection, doctrine, or immunity; (3) insofar as it seeks information which is publicly available or otherwise equally available and/or uniquely or equally available from third parties; (4) insofar as it seeks information that does not specifically refer to the events which are the subject matter of this litigation; and (5) insofar as it seeks information not relevant to the subject matter of this litigation nor reasonably calculated to lead to the discovery of admissible evidence. These responses and objections are made on the basis of information now known to Defendant and are made without waiving any further objections to, or admitting the relevancy or materiality of, any of the information requested. Defendant s investigation, discovery, and preparation for proceedings are continuing and all answers are given without prejudice to Defendant s right to introduce or object to the discovery of any documents, facts, or information discovered after the date hereof. Defendant likewise does not waive the right to object, on any and all grounds, to (1) the evidentiary use of the information contained in these responses and objections; and (2) discovery requests relating to these objections and responses. Defendant will provide his responses based on terms as they are commonly understood, and consistent with the Federal Rules of Civil Procedure. Defendant objects to and will refrain from extending or modifying any words employed in the requests to comport with expanded definitions or instructions. 2

3 Case 5:11-cv OLG-JES-XR Document Filed 12/04/14 Page 3 of 21 OBJECTIONS AND RESPONSES TO INTERROGATORIES Interrogatory No. 1: In Paragraph 33 of your Answer to the Fourth Amended Complaint of Texas Latino Redistricting Task Force, et al. (hereinafter, Answer ), Defendants deny that the Legislature's adoption of plans C185 and H283 included departures from the normal procedural sequence and substantive departures from the factors usually considered important by the Legislature in redistricting. Please identify and describe all facts supporting your denial. Please include in your description the comparative legislation that represents the normal procedural sequence with which the procedures utilized by the Legislature in adopting Plans C185 and H283 were consistent and include in your description the adherence to substantive factors by the Legislature in adopting Plans C185 and H283. a relief defendant. Although Defendant signed the bills for maps C185 and H283, Defendant s involvement in the legislative process that created the maps was limited. Defendant objects to the use of the terms substantive departures and normal procedural sequence as vague and ambiguous and insofar as they involve questions of law. Defendant further objects to this interrogatory to the extent that it seeks disclosure of information subject to legislative privilege and/or deliberative process privilege. Subject to and without waiving these objections, Defendant contends that the Legislature s adoption of plans C185 and H283 complied with the rules of procedure of the Texas House of Representatives and the Texas Senate and the applicable provisions of the Texas Constitution regarding the adoption of legislation. Interrogatory No. 2: In Paragraph 35 of your Answer, Defendants deny that the House and Senate 3

4 Case 5:11-cv OLG-JES-XR Document Filed 12/04/14 Page 4 of 21 Redistricting Committees did not hold public hearings following the public release of plans C185 and H283 and prior to voting on plans C185 and H283. Please identify and describe all facts supporting your denial. Please identify in your description the time, place and location of committee meetings held regarding plans C185 and H283. a relief defendant. Although Defendant signed the bills for maps C185 and H283, Defendant s involvement in the legislative process that created the maps was limited. Subject to and without waiving these objections, Defendant refers Plaintiffs to the legislative record from the 82nd Texas Legislature s Regular Session and first called Special Session, which reflects that multiple public hearings and committee hearings were held regarding S.B. 4 and H.B. 150, which evolved into maps C185 and H283 respectively, prior to the vote on the plans. Interrogatory No. 3: In Paragraph 36 of your Answer, Defendants deny that Plan H283 contains one fewer Latino opportunity district when compared to the 2010 benchmark Texas House plan. Please identify, by district number, the Latino opportunity districts in Plan H283 and the Latino opportunity districts in the 2010 benchmark Texas House plan. a relief defendant. Although Defendant signed the bill for map H283, Defendant s involvement in the legislative process that created H283 was limited. Defendant objects to the use of the term Latino opportunity district as vague and ambiguous and insofar as it involves a question of law. Defendant further objects to the mischaracterization of the response the State Defendants provided to paragraph 36 of its Answer. Please refer to paragraph 36 in which the State Defendants respond, The allegations contained in this paragraph state a legal conclusion to which no 4

5 Case 5:11-cv OLG-JES-XR Document Filed 12/04/14 Page 5 of 21 responsive pleading is required, but to the extent they require admission or denial, they are denied. Subject to and without waiving these objections, upon information and belief, every Texas voter has the same opportunity to elect his or her candidate of choice in each Texas House district. Interrogatory No. 4: In paragraph 38 of your Answer, Defendants claim that Representative Lon Burnam s proposed amendment changing the boundaries of Texas House District 90 (HD 90) was acceptable to all affected members and adopted by the Texas Legislature in H358. Please identify the names and current contact information of all persons you consider all affected members in paragraph 38. information subject to legislative privilege and/or deliberative process privilege. Defendant also objects to this interrogatory to the extent that it seeks information from individuals who are not parties to this litigation. Subject to and without waiving these objections, please refer to House Journal Supplement 3rd Day dated June 20, 2013, page S29, in which Representative Burnam indicates that the affected members were himself, Craig Goldman, and Charlie Geren. The current contact information for these members is equally available to all parties on the Texas Legislature s website at Interrogatory No. 5: In paragraph 38 of your Answer, Defendants admit that Representative Burnam (HD 90) proposed an amendment that changed HD 90 by returning an African- American neighborhood, Como, back into his district. Please describe all facts within your knowledge regarding the boundaries of Como. 5

6 Case 5:11-cv OLG-JES-XR Document Filed 12/04/14 Page 6 of 21 information subject to legislative privilege. Subject to and without waiving these objections, Defendant refers Plaintiffs to House redistricting maps equally available to all parties through the Texas Legislative Council s District Viewer site, which reflect the changes made to HD 90 under H358. Interrogatory No. 6: In paragraph 38 of your Answer, Defendants admit that Representative Burnam (HD 90) proposed an amendment that changed HD 90 by returning an African- American neighborhood, Como, back into his district. Please identify all documents in your possession that show the boundaries of Como. objects to this interrogatory to the extent the information sought is overly broad, unduly burdensome, vague, ambiguous, and not reasonably specific. Defendant objects to this interrogatory to the extent that it seeks disclosure of information subject to legislative privilege. Defendant also objects to this interrogatory to the extent that it seeks the identification of documents in the custody, possession, or control of individuals who are not parties to this litigation. Subject to and without waiving these objections, based on a diligent search of Defendant s records, Defendant has not located any documents in his custody, possession, or control that are responsive to this request. Interrogatory No. 7: In paragraph 38 of your Answer, Defendants admit that Representative Burnam (HD 90) proposed an amendment that changed HD 90 by returning an African- American neighborhood, Como, back into his district. Please describe all facts 6

7 Case 5:11-cv OLG-JES-XR Document Filed 12/04/14 Page 7 of 21 that support your claim that Como is an African-American neighborhood. information subject to legislative privilege. Subject to and without waiving these objections, Defendant refers Plaintiffs to the legislative record from the 82nd Texas Legislature s Regular Session and the legislative record from the 83rd Texas Legislature s first called Special Session, which contained discussions about the Como neighborhood. Interrogatory No. 8: In paragraph 38 of your Answer, Defendants claim that Representative Lon Burnam s proposed amendment changing the boundaries of Texas House District 90 (HD 90) was acceptable to all affected members and adopted by the Texas Legislature in H358. Please describe all facts that support your claim that the amendment concerning HD 90 was acceptable to all affected members. involvement in the legislative process that created the maps was limited. Defendant information subject to legislative privilege. Defendant also objects to this interrogatory to the extent that it seeks information from individuals who are not parties to this litigation. Subject to and without waiving these objections, please refer to House Journal Supplement 3rd Day dated June 20, 2013, page S29, and House Journal 4th Day dated June 21, 2013, page These documents reflect the amendment was authored and presented by Representative Burnam. Representatives Craig Goldman and Charlie Geren voted to pass SB 3, as amended, on June 21,

8 Case 5:11-cv OLG-JES-XR Document Filed 12/04/14 Page 8 of 21 Interrogatory No. 9: In paragraph 39 of your Answer, Defendants deny that the Legislature s adoption of plan H358 included departures from the normal procedural sequence and substantive departures from the factors usually considered important by the Legislature in redistricting. Please identify and describe all facts supporting your denial. Please include in your description the comparative legislation that represents the normal procedural sequence with which the procedures utilized by the Legislature in adopting plan H358 were consistent and include in your description the adherence to substantive factors by the Legislature in adopting plan H358. objects to the use of the terms substantive departures and normal procedural sequence as vague and ambiguous and insofar as they involve questions of law. Defendant further objects to this interrogatory to the extent that it seeks disclosure of information subject to legislative privilege and/or deliberative process privilege. Subject to and without waiving these objections, Defendant contends that the Legislature s adoption of H358 complied with the rules of procedure of the Texas House of Representatives and the Texas Senate and the applicable provisions of the Texas Constitution regarding the Governor s power to convene a special session and the adoption of legislation. Interrogatory No. 10: In paragraph 40 of your answer, Defendants admit that an amendment to SB 3 was timely made on June 20, 2013, during the 83rd Legislature s first Special Session, considered by members of the Texas House, adopted, and ultimately became H358. Please identify, by date, time and place, any consideration of the 8

9 Case 5:11-cv OLG-JES-XR Document Filed 12/04/14 Page 9 of 21 amendment in committee and opportunities provided for public testimony on the amendment. information subject to legislative privilege. Subject to and without waiving these objections, Defendant refers Plaintiffs to the February 28, 2012 and March 19, 2012 Orders issued by the U.S. District Court for the Western District of Texas (the San Antonio Court ) adopting map H309 for the 2012 Texas House elections (ECF Nos. 682, 690) and the legislative record from the 83rd Texas Legislature s first called Special Session, including hearings conducted by the House Select Committee on Redistricting and the Senate Select Committee on Redistricting, all of which reflect public consideration of the House redistricting plan that evolved into H358. Interrogatory No. 11: Please identify all documents reflecting communications between House Redistricting Committee Chairman Drew Darby and his staff regarding the process by which the Committee would consider amendments to SB1, including but not limited to suggestions that proposed amendments be agreed upon by affected members and not raise concerns under the Voting Rights Act. objects to this interrogatory to the extent the information sought is overly broad, unduly burdensome, vague, ambiguous, and not reasonably specific. Defendant information subject to legislative privilege. Defendant also objects to this interrogatory to the extent that it seeks the identification of documents in the custody, possession, or control of individuals who are not parties to this litigation. Subject to and without waiving these objections, based on a diligent search of 9

10 Case 5:11-cv OLG-JES-XR Document Filed 12/04/14 Page 10 of 21 Defendant s records, Defendant has not located any documents in his custody, possession, or control that are responsive to this request. Interrogatory No. 12: Please identify all documents reflecting communications between Representative Lon Burnam or his staff and any other individuals or organizations regarding any amendments proposed by Rep. Burnam during any of the 83rd Legislature s regular or special sessions that relate to the boundaries of HD 90. objects to this interrogatory to the extent the information sought is overly broad, unduly burdensome, vague, ambiguous, and not reasonably specific. Defendant information subject to legislative privilege. Defendant also objects to this interrogatory to the extent that it seeks the identification of documents in the custody, possession, or control of individuals who are not parties to this litigation. Subject to and without waiving these objections, based on a diligent search of Defendant s records, Defendant has not located any documents in his custody, possession, or control that are responsive to this request. Interrogatory No. 13: Please identify all documents reflecting communications between Representative Lon Burnam and his staff, or between Rep. Burnam or his staff and any other individuals or organizations, regarding any amendments proposed by Rep. Burnam during any of the 83rd Legislature s regular or special sessions that relate to the boundaries of HD

11 Case 5:11-cv OLG-JES-XR Document Filed 12/04/14 Page 11 of 21 objects to this interrogatory to the extent the information sought is overly broad, unduly burdensome, vague, ambiguous, and not reasonably specific. Defendant information subject to legislative privilege. Defendant also objects to this interrogatory to the extent that it seeks the identification of documents in the custody, possession, or control of individuals who are not parties to this litigation. Subject to and without waiving these objections, based on a diligent search of Defendant s records, Defendant has not located any documents in his custody, possession, or control that are responsive to this request. Interrogatory No. 14: Please identify the names and current contact information of all persons, including members of the Legislature and any of their staff, who were involved in the adoption of any amendments proposed by Rep. Burnam relating to the boundaries of HD 90. This interrogatory includes persons who had knowledge of the amendment; persons who communicated with any member of legislature concerning the amendment; or persons who drafted any maps, s, or memoranda concerning the amendment. information subject to legislative privilege and/or deliberative process privilege. Defendant also objects to this interrogatory to the extent that it seeks information from individuals who are not parties to this litigation. Subject to and without waiving these objections, Defendant refers Plaintiffs to the Texas Legislative Council s District Viewer site, which contains House 11

12 Case 5:11-cv OLG-JES-XR Document Filed 12/04/14 Page 12 of 21 redistricting maps proposed by legislators during the 83rd Legislative Session, including maps H328 and H342 offered by Representative Burnam. Defendant also refers Plaintiffs to the legislative record from the 83rd Texas Legislature s first called Special Session, equally available to all parties online through the Texas Legislature at particularly the June 20, 2013 House Journal reflecting the introduction of, and debate regarding, Amendment No. 8 offered by Representative Burnam (plan H342). Interrogatory No. 15: Please identify all legislative committee meetings, public hearings, and other meetings, including those at which legislators and/or legislative staff were present, held during the 83rd Legislature s sessions in which the boundaries of HD 90 were discussed. information subject to legislative privilege. Subject to and without waiving these objections, Defendant refers Plaintiffs to the legislative record from the 83rd Texas Legislature s first Special Session, equally available to all parties online through the Texas Legislature at which includes listings of committee meetings and public hearings. Interrogatory No. 16: In paragraph 40 of your Answer, Defendants deny that redistricting Plan H358 was adopted as an amendment to SB3 on June 20, 2013, during the 83rd Texas Legislature s first Special Session, without consideration of the amendment in committee and without the opportunity for public testimony. Please identify all facts supporting your denial, including identifying the committee meetings held regarding any plans affecting the boundaries of HD 90 and the opportunities given 12

13 Case 5:11-cv OLG-JES-XR Document Filed 12/04/14 Page 13 of 21 for public testimony concerning those plans. information subject to legislative privilege. Subject to and without waiving these objections, Defendant refers Plaintiffs to the February 28, 2012 and March 19, 2012 Orders issued by the San Antonio Court adopting map H309 for the 2012 Texas House elections (ECF Nos. 682, 690) and the legislative record from the 83rd Texas Legislature s first called Special Session, particularly the hearings conducted by the House Select Committee on Redistricting and the Senate Select Committee on Redistricting reflecting public consideration of numerous House redistricting plans affecting the boundaries of HD 90, including but not limited to, the House redistricting plan that evolved into H358. Interrogatory No. 17: In paragraph 41 of your Answer, Defendants deny all allegations made by Texas Latino Redistricting Task Force Plaintiffs in paragraph 41 of their Fourth Amended Complaint. Identify and explain with specificity the basis for this denial. involvement in the legislative process that created H358 was limited. Subject to and without waiving these objections, Defendant disputes any implication by the Plaintiffs that the changes to HD 90 under H358 were intentionally discriminatory; these changes were made pursuant to an amendment offered by Representative Burnam, the Democratic incumbent representing HD 90. Defendant further submits that plan H358 was adopted in good faith and complies with federal and state law, and upon information and belief, it provides every Texas voter with the same opportunity to elect his or her candidate of choice in each Texas House district. 13

14 Case 5:11-cv OLG-JES-XR Document Filed 12/04/14 Page 14 of 21 Interrogatory No. 18: In Paragraph 42 of your Answer, Defendants deny that Plan C185 contains the same number of Latino opportunity districts when compared to the 2010 benchmark congressional plan. Please identify, by district number, the Latino opportunity districts in Plan C185 and the Latino opportunity districts in the 2010 benchmark congressional plan. a relief defendant. Although Defendant signed the bill for map C185, Defendant s involvement in the legislative process that created C185 was limited. Defendant objects to the use of the term Latino opportunity district as vague and ambiguous and insofar as it involves a question of law. Defendant further objects to the mischaracterization of the response the State Defendants provided to paragraph 42 of its Answer. Please refer to paragraph 42 in which the State Defendants respond, Sentence two contains allegations that state a legal conclusion to which no responsive pleading is required, but to the extent they require admission or denial, they are denied. Subject to and without waiving these objections, upon information and belief, every Texas voter has the same opportunity to elect his or her candidate of choice in each congressional district. Interrogatory No. 19: In Paragraph 57 of your Answer, Defendants deny that the Latino population of Texas is sufficiently geographically compact to comprise the majority of citizen voting age persons in at least seven congressional districts located in the southern and western portion of the state. Please identify and explain with specificity the basis for this denial. Defendant objects to this interrogatory because it exceeds the limitation of 25 interrogatories that Plaintiffs are allowed under Federal Rule of Civil Procedure 33(a). Defendant reserves the right to assert any and all further objections to this 14

15 Case 5:11-cv OLG-JES-XR Document Filed 12/04/14 Page 15 of 21 interrogatory. Interrogatory No. 20: In Paragraph 68 of your Answer, Defendants deny that the Latino population of Texas is sufficiently geographically compact to comprise the majority of citizen voting age persons in at least 33 Texas House districts. Please identify and explain with specificity the basis for this denial. Defendant objects to this interrogatory because it exceeds the limitation of 25 interrogatories that Plaintiffs are allowed under Federal Rule of Civil Procedure 33(a). Defendant reserves the right to assert any and all further objections to this interrogatory. 15

16 Case 5:11-cv OLG-JES-XR Document Filed 12/04/14 Page 16 of 21 DATED: February 13, 2014 Respectfully submitted, GREG ABBOTT Attorney General of Texas DANIEL T. HODGE First Assistant Attorney General DAVID C. MATTAX Deputy Attorney General for Defense Litigation J. REED CLAY, JR. Special Assistant and Senior Counsel to the Attorney General /s/ Patrick K. Sweeten PATRICK K. SWEETEN Chief, Special Litigation Division Texas Bar No P.O. Box 12548, Capitol Station Austin, TX (512) (512) (fax) ATTORNEYS FOR RICK PERRY 16

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18 Case 5:11-cv OLG-JES-XR Document Filed 12/04/14 Page 18 of 21 CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of Defendant Rick Perry s Objections and Responses to Texas Latino Redistricting Task Force Plaintiffs Second Set of Interrogatories was sent via to the following counsel of record on February 13, 2014: DAVID RICHARDS Richards, Rodriguez & Skeith LLP 816 Congress Avenue, Suite 1200 Austin, TX davidr@rrsfirm.com RICHARD E. GRAY, III Gray & Becker, P.C. 900 West Avenue, Suite 300 Austin, TX / (facsimile) Rick.gray@graybecker.com ATTORNEYS FOR PLAINTIFFS PEREZ, DUTTON, TAMEZ, HALL, ORTIZ, SALINAS, DEBOSE, and RODRIGUEZ JOSE GARZA Law Office of Jose Garza 7414 Robin Rest Dr. San Antonio, Texas garzpalm@aol.com MARK W. KIEHNE mkiehne@lawdcm.com RICARDO G. CEDILLO rcedillo@lawdcm.com Davis, Cedillo & Mendoza McCombs Plaza 755 Mulberry Ave., Ste. 500 San Antonio, TX / (facsimile) GERALD H. GOLDSTEIN ggandh@aol.com DONALD H. FLANARY, III donflanary@hotmail.com Goldstein, Goldstein and Hilley 310 S. St. Mary s Street San Antonio, TX / (facsimile) PAUL M. SMITH, MICHAEL B. DESANCTIS, JESSICA RING AMUNSON Jenner & Block LLP 1099 New York Ave., NW Washington, D.C J. GERALD HEBERT 191 Somervelle Street, # 405 Alexandria, VA hebert@voterlaw.com JESSE GAINES P.O. Box Fort Worth, TX gainesjesse@ymail.com ATTORNEYS FOR PLAINTIFFS QUESADA, MUNOZ, VEASEY, HAMILTON, KING and JENKINS 17

19 Case 5:11-cv OLG-JES-XR Document Filed 12/04/14 Page 19 of 21 JOAQUIN G. AVILA P.O. Box Seattle, WA / (facsimile) ATTORNEYS FOR MEXICAN AMERICAN LEGISLATIVE CAUCUS NINA PERALES MARISA BONO Mexican American Legal Defense and Education Fund 110 Broadway, Suite 300 San Antonio, TX / (facsimile) MARK ANTHONY SANCHEZ ROBERT W. WILSON Gale, Wilson & Sanchez, PLLC 115 East Travis Street, Ste San Antonio, TX / (facsimile) ATTORNEYS FOR TEXAS LATINO REDISTRICTING TASK FORCE, CARDENAS, JIMENEZ, MENENDEZ, TOMACITA AND JOSE OLIVARES, ALEJANDRO AND REBECCA ORTIZ JOHN T. MORRIS 5703 Caldicote St. Humble, TX JOHN T. MORRIS, PRO SE LUIS ROBERTO VERA, JR. Law Offices of Luis Roberto Vera, Jr Riverview Towers San Antonio, Texas GEORGE JOSEPH KORBEL Texas Rio Grande Legal Aid, Inc North Main San Antonio, TX ATTORNEYS FOR INTERVENOR- PLAINTIFF LEAGUE OF UNITED LATIN AMERICAN CITIZENS ROLANDO L. RIOS Law Offices of Rolando L. Rios 115 E Travis Street, Suite 1645 San Antonio, TX rrios@rolandorioslaw.com ATTORNEY FOR INTERVENOR- PLAINTIFF HENRY CUELLAR GARY L. BLEDSOE Law Office of Gary L. Bledsoe 316 W. 12 th Street, Ste. 307 Austin, TX / (facsimile) garybledsoe@sbcglobal.net ATTORNEY FOR INTERVENOR- PLAINTIFFS TEXAS STATE CONFERENCE OF NAACP BRANCHES, TEXAS LEGISLATIVE BLACK CAUCUS, EDDIE BERNICE JOHNSON, SHEILA JACKSON- LEE, ALEXANDER GREEN, HOWARD JEFFERSON, BILL LAWSON, and JUANITA WALLACE 18

20 Case 5:11-cv OLG-JES-XR Document Filed 12/04/14 Page 20 of 21 MAX RENEA HICKS Law Office of Max Renea Hicks 101 West Sixth Street Suite 504 Austin, TX /512/ (facsimile) ATTORNEY FOR PLAINTIFFS CITY OF AUSTIN, TRAVIS COUNTY, ALEX SERNA, BEATRICE SALOMA, BETTY F. LOPEZ, CONSTABLE BRUCE ELFANT, DAVID GONZALEZ, EDDIE RODRIGUEZ, MILTON GERARD WASHINGTON, and SANDRA SERNA STEPHEN E. MCCONNICO SAM JOHNSON S. ABRAHAM KUCZAJ, III Scott, Douglass & McConnico One American Center 600 Congress Ave., 15th Floor Austin, TX / (facsimile) ATTORNEYS FOR PLAINTIFFS CITY OF AUSTIN, TRAVIS COUNTY, ALEX SERNA, BALAKUMAR PANDIAN, BEATRICE SALOMA, BETTY F. LOPEZ, CONSTABLE BRUCE ELFANT, DAVID GONZALEZ, EDDIE RODRIGUEZ, ELIZA ALVARADO, JOSEY MARTINEZ, JUANITA VALDEZ-COX, LIONOR SOROLA- POHLMAN, MILTON GERARD WASHINGTON, NINA JO BAKER, and SANDRA SERNA KAREN M. KENNARD 2803 Clearview Drive Austin, TX (512) / (facsimile) ATTORNEY FOR PLAINTIFF CITY OF AUSTIN 19 VICTOR L. GOODE Asst. Gen. Counsel, NAACP 4805 Mt. Hope Drive Baltimore, MD / (facsimile) ATTORNEY FOR TEXAS STATE CONFERENCE OF NAACP BRANCHES ROBERT NOTZON Law Office of Robert S. Notzon 1507 Nueces Street Austin, TX / (facsimile) ALLISON JEAN RIGGS ANITA SUE EARLS Southern Coalition for Social Justice 1415 West Highway 54, Ste. 101 Durham, NC / (facsimile) ATTORNEYS FOR TEXAS STATE CONFERENCE OF NAACP BRANCHES, EARLS, LAWSON, WALLACE, and JEFFERSON DONNA GARCIA DAVIDSON PO Box Austin, TX / (facsimile) FRANK M. REILLY Potts & Reilly, L.L.P. P.O. Box 4037 Horseshoe Bay, TX / (facsimile) ATTY FOR DEFENDANT STEVE MUNISTERI

21 Case 5:11-cv OLG-JES-XR Document Filed 12/04/14 Page 21 of 21 DAVID ESCAMILLA Travis County Asst. Attorney P.O. Box 1748 Austin, TX (512) ATTORNEY FOR PLAINTIFF TRAVIS COUNTY CHAD W. DUNN K. SCOTT BRAZIL Brazil & Dunn 4201 FM 1960 West, Suite 530 Houston, TX / (facsimile) ATTORNEYS FOR INTERVENOR- DEFS TEXAS DEMOCRATIC PARTY and BOYD RICHIE RONALD C. MACHEN, JR., United States Attorney District of Columbia JOCELYN SAMUELS T. CHRISTIAN HERREN, JR. TIMOTHY F. MELLETT BRYAN SELLS JAYE ALLISON SITTON DANIEL J. FREEMAN MICHELLE A. MCLEOD U.S. Department of Justice Civil Rights Division, Voting Rights Room 7254 NWB 950 Pennsylvania Avenue, N.W. Washington, D.C (202) ; (202) ATTORNEYS FOR THE UNITED STATES /s/ Patrick K. Sweeten Patrick K. Sweeten 20