IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT …...Bartlit Beck Herman Palenchar & Scott LLP...
Transcript of IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT …...Bartlit Beck Herman Palenchar & Scott LLP...
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA
STATE OF TEXAS, Plaintiff, v. ERIC H. HOLDER, JR., in his official capacity as Attorney General of the United States, Defendant. ERIC KENNIE, et al., Defendant-Intervenors, TEXAS STATE CONFERENCE OF NAACP BRANCHES, et al., Defendant-Intervenors, TEXAS LEAGUE OF YOUNG VOTERS EDUCATION FUND, et al., Defendant-Intervenors. TEXAS LEGISLATIVE BLACK CAUCUS, et al., Defendant-Intervenors, VICTORIA RODRIGUEZ, et al., Defendant-Intervenors.
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CASE NO. 1:12-CV-00128 (RMC-DST-RLW) Three-Judge Court
ATTORNEY GENERAL’S MOTION TO COMPEL THE
PRODUCTION OF TES DOCUMENTS
Pursuant to Federal Rule of Civil Procedure 37, and pursuant to the briefing schedule set
out in this Court’s Order of May 21, 2012 (Doc. 128), Defendant Eric H. Holder Jr. respectfully
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moves for an order compelling the production of documents that the State of Texas has
improperly withheld from discovery. For the reasons set out in the Attorney General’s
Memorandum of Points and Authorities, the State has misapplied three categories of privilege:
the state legislative privilege, the attorney-client privilege, and the deliberative process privilege.
The Attorney General therefore respectfully requests that the Court enter the attached Proposed
Order Compelling the Production of Documents.
Date: May 25, 2012 Respectfully submitted, RONALD C. MACHEN, JR. THOMAS E. PEREZ United States Attorney Assistant Attorney General District of Columbia Civil Rights Division
/s/ Daniel J. Freeman T. CHRISTIAN HERREN, JR. MEREDITH BELL-PLATTS ELIZABETH S. WESTFALL BRUCE I. GEAR JENNIFER L. MARANZANO RISA BERKOWER DANIEL J. FREEMAN Attorneys Voting Section, Civil Rights Division U.S. Department of Justice 950 Pennsylvania Avenue, N.W. Washington, D.C. 20530 (800) 253-3931
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CERTIFICATE OF CONFERRAL
I hereby certify that on May 21, 2012, I met and conferred with counsel for the State of Texas in an effort to obtain the requested discovery without court intervention.
/s/ Elizabeth S. Westfall ELIZABETH S. WESTFALL U.S. Department of Justice 950 Pennsylvania Avenue, N.W. Washington, D.C. 20530 [email protected]
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CERTIFICATE OF SERVICE
I hereby certify that on May 25, 2012, I served a true and correct copy of the foregoing via the Court’s ECF system on the following counsel of record:
Jonathan Franklin Mitchell Adam W. Aston Matthew Hamilton Frederick Patrick Kinney Sweeten Office of the Attorney General of Texas [email protected] [email protected] [email protected] [email protected] Adam K. Mortara John M. Hughes Bartlit Beck Herman Palenchar & Scott LLP [email protected] [email protected] Counsel for Plaintiff John Tanner [email protected] Nancy G. Abudu M. Laughlin McDonald Katie O’Connor Arthur B. Spitzer American Civil Liberties Union [email protected] [email protected] [email protected] [email protected] Counsel Texas Legislative Black Caucus Intervenors
Debo P. Adegbile Leah C. Aden Elise C. Boddie Ryan Haygood Dale E. Ho Natasha Korgaonkar NAACP Legal Defense and Education Fund [email protected] [email protected] [email protected] [email protected] [email protected] [email protected] Michael Birney de Leeuw Douglas H. Flaum Adam M. Harris Fried, Frank, Harris, Shriver & Jacobson [email protected] [email protected] [email protected] Counsel for Texas League of Young Voters Intervenors
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Jon M. Greenbaum Mark A. Posner Lawyers’ Committee for Civil Rights [email protected] [email protected] Ezra David Rosenberg Michelle Hart Yeary Dechert LLP [email protected] [email protected] Robert Stephen Notzon [email protected] Gary L. Bledsoe Law Office of Gary L. Bledsoe and Associates [email protected] Myrna Perez Wendy Robin Weiser Ian Arthur Vandewalker The Brennan Center for Justice [email protected] [email protected] [email protected] Counsel for NAACP Intervenors
Nina Perales Amy Pederson Mexican American Legal Defense & Educational Fund, Inc. [email protected] [email protected] Counsel for Rodriguez Intervenors J. Gerald Hebert [email protected] Chad W. Dunn Brazil & Dunn [email protected] Counsel for Kennie Intervenors
s/ Daniel J. Freeman DANIEL J. FREEMAN Attorney, Voting Section Civil Rights Division U.S. Department of Justice 950 Pennsylvania Avenue, N.W. Washington, D.C. 20530
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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA
STATE OF TEXAS, Plaintiff, v. ERIC H. HOLDER, JR., in his official capacity as Attorney General of the United States, Defendant. ERIC KENNIE, et al., Defendant-Intervenors, TEXAS STATE CONFERENCE OF NAACP BRANCHES, et al., Defendant-Intervenors, TEXAS LEAGUE OF YOUNG VOTERS EDUCATION FUND, et al., Defendant-Intervenors. TEXAS LEGISLATIVE BLACK CAUCUS, et al., Defendant-Intervenors, VICTORIA RODRIGUEZ, et al., Defendant-Intervenors.
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CASE NO. 1:12-CV-00128 (RMC-DST-RLW) Three-Judge Court
MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF
THE ATTORNEY GENERAL’S MOTION TO COMPEL
The Attorney General seeks discovery concerning the State of Texas’s (“Texas” or “the
State”) claim that Texas’s photographic voter identification law, Senate Bill 14 (2011) (“SB
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14”), “neither has the purpose nor will have the effect of denying or abridging the right to vote
on account of race or color,” or language minority status in violation of Section 5 of the Voting
Rights Act, 42 U.S.C. § 1973c. The State of Texas’s overbroad assertions of numerous
evidentiary privileges – in a manner that overlaps nearly completely with relevance to the
purpose prong of Section 5 – yet again requires the Attorney General to seek from this Court an
order compelling discovery.
I. THE ATTORNEY GENERAL IS ENTITLED TO AN ORDER COMPELLING THE PRODUCTION OF DOCUMENTS.
The instant motion addresses the two supplemental privilege logs produced by the State
in response to this Court’s May 21, 2012 order, which gave Texas an additional chance to
establish the application of privileges to documents that the State has withheld from discovery.
See Order at 6-7 (Doc. 128). The first of these privilege logs is 196 pages long and asserts the
legislative privilege, deliberative process privilege, attorney-client privilege, and attorney work
product doctrine over hundreds of documents. See Revised Privilege Log (May 23, 2012) (Ex.
1) [hereinafter OOG Log].1
1 The Attorney General does not challenge the State’s assertions of the attorney work product doctrine.
The second is 181 pages long and asserts the legislative privilege
and attorney-client privilege over an even greater number of documents. See Texas Legislative
Council Second Revised Privilege Log (May 23, 2012) (Ex. 2) [hereinafter TLC Log]. Once
again the State’s claims of legislative privilege extend far beyond the possible scope of any
recognized legislative privilege. And once again, the State asserts the attorney-client privilege
over numerous documents that do not meet the well-established prerequisites for such protection.
Finally, although the State has heeded the Court’s advice and articulated the elements of the
deliberative process privilege with regard to each document withheld on that ground, see Order
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at 3-4 (Doc. 128), this privilege is also qualified and must yield with regard to critical
documents.2
The Attorney General is entitled to an order compelling the production of testimony and
documents over which the State has improperly asserted the state legislative privilege, attorney-
client privilege, and the deliberative process privilege. “A party seeking discovery may move for
an order compelling . . . production[] or inspection . . . if a party fails to respond that inspection
will be permitted – or fails to permit inspection – as requested under Rule 34.” Fed. R. Civ. P.
37(a)(3)(B)(iv). While a party moving to compel discovery bears the initial burden to prove that
the materials sought are relevant, the burden of demonstrating facts sufficient to establish a
privilege’s applicability rests on the proponent of a privilege. See In re Subpoena Duces Tecum,
439 F.3d 740, 750 (D.C. Cir. 2006); Alexander v. FBI, 192 F.R.D. 32, 33-34 (D.D.C. 2000). The
“basis of privilege” must be “adequately established in the record,” Liberty Lobby, Inc. v. Dow
Jones & Co., Inc., 838 F.2d 1287, 1303 (D.C. Cir. 1988), through evidence sufficient to establish
the privilege “with reasonable certainty,” FTC v. TRW, Inc., 628 F.2d 207, 213 (D.C. Cir. 1980).
For the reasons that follow, the State has failed to carry its burden with regard to each of the
privileges at issue.
2 The Attorney General incorporates by reference all of the arguments against Texas’s assertions of privilege presented in opposition to the State’s motion for a protective order, see Defendant’s Response in Opposition to Plaintiff’s Motion for a Protective Order (Doc. 57); United States’ Statement in Support of Its Request to Depose and Seek Documents from State Legislators and Staff (Doc. 69), in support of the Attorney General’s resolved motion to compel, see Memorandum of Points and Authorities in Support of the Attorney General’s Motion to Compel (Doc. 93-1); Reply Memorandum in Support of the Attorney General’s Motion to Compel (Doc. 104), and in support of the Attorney General’s pending motion to compel, see Memorandum of Points and Authorities in Support of the Attorney General’s Motion to Compel (Doc. 136-1).
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II. THE STATE HAS IMPROPERLY WITHHELD DOCUMENTS IN THE CUSTODY OF THE OFFICE OF THE GOVERNOR.
The State of Texas continues to withhold hundreds of admittedly relevant documents in
the possession of the Office of the Governor on the basis of the state legislative privilege, the
attorney-client privilege, and the deliberative process privilege. The latest iteration of the Office
of the Governor’s privilege log succeeds in establishing valid privilege claims over some of these
documents. However, for the reasons that follow, Texas has misapplied some basic principles
concerning the legislative privilege and attorney-client privilege. In addition, the State’s
invocation of the deliberative process privilege must yield with regard to documents that may
contain vital evidence of a discriminatory purpose.
A. The State Cannot Assert a Legislative Privilege over Documents in the Custody of the Office of the Governor.
The State of Texas has withheld three documents in the possession of the Office of the
Governor on the basis of the state legislative privilege. See Office of the Governor Contested
Document Index at 1 (Ex. 3) [hereinafter OOG Index]. However, for the reasons explained at
length in the Attorney General’s April 25, 2012 motion to compel the production of documents
and privilege logs, documents in the possession of executive agencies cannot be subject to a
legislative privilege. See Memorandum of Points and Authorities in Support of the Attorney
General’s Motion to Compel at 9-14 (Doc. 93-1); Reply Memorandum in Support of the
Attorney General’s Motion to Compel at 7-9 (Doc. 104). Moreover, the documents at issue are
quintessential instances of legislative lobbying of the executive branch. See, e.g., OOG Log at 1
(“Letter from State Representative Betty Brown regarding actions the Governor could take to
advance the legislative enactment of a voter ID law.”). Such documents are not protected by any
form of legislative privilege. See Doe v. McMillan, 412 U.S. 306, 313 (1973) (“Members of
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Congress may frequently be in touch with and seek to influence the Executive Branch of
Government, but this conduct ‘though generally done, is not protected legislative activity.’”
(quoting Gravel v. United States, 408 U.S. 606, 625 (1972))). Therefore these documents are
subject to immediate production.
B. The State Has Not Established Requisite Elements of the Attorney-Client Privilege.
The State of Texas appears to have claimed an attorney-client privilege over every
document in the possession of the Office of the Governor where an attorney was a party to the
conversation. See OOG Log at 1-190. However it is a basic hornbook law that the mere
presence of an attorney does not place communications under the aegis of the attorney-client
privilege. See, e.g., In re Lindsey, 158 F.3d 1263, 1270 (D.C. Cir. 1998) (citing 8 John Henry
Wigmore, Evidence in Trials at Common Law § 2292, at 554 (McNaughton rev. 1961))); see
also United States v. Brown, 478 F.2d 1038, 1040 (7th Cir. 1973). Rather, a party asserting the
attorney-client privilege “must conclusively prove each element of the privilege.” In re Lindsey,
148 F.3d 1100, 1106 (D.C. Cir. 1998); see also Coastal States Gas Corp. v. Dep’t of Energy, 617
F.2d 854, 863 (D.C. Cir. 1980).
The privilege applies only if (1) the asserted holder of the privilege is or sought to become a client; (2) the person to whom the communication was made (a) is a member of the bar of a court or his subordinate and (b) in connection with this communication is acting as a lawyer; (3) the communication relates to a fact of which the attorney was informed (a) by his client (b) without the presence of strangers (c) for the purpose of securing primarily either (i) an opinion on law or (ii) legal services or (iii) assistance in some legal proceeding, and not (d) for the purpose of committing a crime or tort; and (4) the privilege has been (a) claimed and (b) not waived by the client.
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In re Sealed Case, 737 F.2d 94, 98-99 (D.C. Cir. 1984) (quoting United States v. United Shoe
Machinery Corp., 89 F. Supp. 357, 358-59 (D. Mass. 1950)).3
First and foremost, the state has yet again failed to provide an adequate description of some
documents over which it continues to assert an attorney-client privilege. A description of a
document as “Confidential communications between Governor’s Office Attorneys and staff sent
for the purpose of seeking or providing legal advice regarding Voter ID,” OOG Log at 5-6, does
no more than articulate the legal standard and the subject matter of this case. This Court has
found a similar privilege log to “fall woefully short of what is required to permit this court to
determine whether a particular privilege was properly asserted.” See Alexander v. FBI, 186
F.R.D. 102, 107 (D.D.C. 1998) Thus documents for which the State has provided insufficient
information in its privilege log should be disclosed or provided to the Court for in camera review.
See OOG Index at 1.
Critically to this case, a
government attorneys’ advice on “political, strategic, or policy issues . . . would not be shielded from
disclosure by the attorney-client privilege.” In re Lindsey, 148 F.3d 1100, 1106 (D.C. Cir. 1998) (per
curiam).
The weakness of Texas’s privilege claims is evinced by the numerous communications
between officials that each communication with an attorney is subject to the attorney-client privilege
is belied by a sampling of the privilege log. For example, the State has asserted an attorney client
privilege over communications between the Chief of Staff of the Office of the Governor – who
3 In addition, communications from an attorney to a client are shielded only if “they rest on confidential information obtained from the client.” Id. at 99 (citing Mead Data Central, Inc. v. U.S. Dep’t of Air Force, 566 F.2d 242, 254 (D.C. Cir. 1977). Finally, “when an attorney conveys to his client facts acquired from other persons or sources, those facts are not privileged.” Id. (citing Brinton v. Dep’t of State, 636 F.2d 600, 604 (D.C. Cir. 1980)). See generally In re Lindsey, 158 F.3dd 1263, 1272 (D.C. Cir. 1998) (“[T]he attorney-client privilege must be strictly confined within the narrowest possible limits consistent with the logic of its principle.” (internal citations and quotation marks omitted)).
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happens to be an attorney – and the press staff of the Office of the Governor, providing edits to drafts
of public statements. E.g., OOG Log at 157-58.4
Moreover, the State has again asserted an attorney-client privilege across different agencies
of the State. For example, the State has asserted attorneys from the Office of the Governor and the
Office of the Secretary of State share an attorney-client privilege. See OOG Log at 14. These two
offices serve independent constitutional actors who are separately elected, see Tex. Const. art. IV, §§
1-2, and Texas law provides no basis for a privileged relationship between them. Cf. Tex. Gov’t
Code § 402.021 (providing for the Attorney General to “prosecute and defend all actions in which
the state is interested before the supreme court and courts of appeals”). The mere existence of a
shared policy preference between multiple attorneys cannot create an attorney-client relationship.
Because the State of Texas did not implement a litigation hold until the filing of its complaint in
early 2012, it cannot assert a common-interest privilege before that date. See United States v.
AT&T Co., 642 F.2d 1285, 1299 (D.C. Cir. 1980) (limiting the common interest privilege to
instances in which the “transferor and transferee anticipate litigation against a common adversary
on the same issue or issues”). Therefore the State must produce all communications between the
Office of the Secretary of State and the Office of the Governor over which the State has claimed an
attorney-client privilege. See OOG Index at 1; see also Order at 7 (Doc. 128) (requiring the
Similarly, the State has claimed an attorney-client
privilege over a draft of the Governor’s 2011 State of the State speech, based on the inclusion of the
Governor’s chief of staff to the communication. See OOG Log at 10-11. In sum, Texas has not
carried its burden to establish that documents superficially labeled as legal guidance are not in fact
political, strategic, or policy advice. See OOG Index at 1.
4 Cf. In re Sealed Case, 737 F.2d 94, 99 (D.C. Cir. 1984) (“We are mindful, however, that C was a Company vice president, and had certain responsibilities outside the lawyer’s sphere.”).
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production of documents withheld on the basis of attorney-client privilege between TLC attorneys
and Secretary of State Staff).
C. Any Deliberative Process Privilege Predating the Enactment of SB 14 Must Yield.
On May 7, the Court provided the State of Texas with an additional opportunity to
establish the deliberative process privilege and set out the necessary elements of such a privilege
claim. See Order at 3-4 (Doc. 128).5
5 As noted in the memorandum in support of the May 21 motion to compel, the Attorney General respectfully disagrees with the conclusion that Section 5 is not “directed at . . . the purpose or motivation of individual actors.” Order at 3 (Doc. 128). While the ultimate inquiry in a Section 5 preclearance case is of course the purpose of the legislation at issue, under Arlington Heights, contemporaneous statements constitute a critical category of relevant circumstantial evidence. See 429 U.S. at 268. Thus the court’s inquiry in Busbee v. Smith hinged on the racially charged statements of Georgia House Redistricting Chairman Joe Mack Wilson. See 549 F. Supp. at 500. In the broader context of discrimination law, “courts often must inquire into the motives of legislators and other government actors.” Grossbaum v. Indianapolis-Marion County Bldg. Auth., 100 F.3d 1287, 1292 (7th Cir. 1996); see also id. at 1292 n.3 (noting “the inquiry that courts occasionally make into the subjective ‘intent,’ ‘motive,’ or ‘actual purpose’ of government actors” and the analytical distinction from the broader purpose inquiry). In the analogous Establishment Clause context, the Court has inferred purpose from the detailed public comments of a statute’s sponsor. See Edwards v. Aguillard, 482 U.S. 578, 586-88 (1987); see also McCreary County v. ACLU of Kentucky, 545 U.S. 844, 861-63 (2005) (describing the contours of a practical purpose inquiry). To the extent that the Court determines that the deliberative process privilege need not otherwise yield with regard to the most probative subset of documents, the Attorney General requests that the Court reconsider its order in light of these precedents.
Although Texas has now belatedly set out the elements of
the deliberative process privilege with regard to each such privilege claim, see OOG Log 1-196,
the deliberative process privilege is merely qualified and rests on, as the State itself recognizes,
“considerations of competing policy claims.” Response in Opposition to Defendant and
Defendant-Intervenors’ Motions to Compel at 5 (Doc. 148). “Each time the deliberative process
privilege is asserted the district court must undertake a fresh balancing of the competing
interests, taking into account factors such as the relevance of the evidence, the availability of
other evidence, the seriousness of the litigation, the role of the government, and the possibility of
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future timidity by government employees.” In re Sealed Case, 121 F.3d 729, 737-38 (D.C. Cir.
1997) (internal modifications and quotation marks omitted).
In light of the qualified nature of the deliberative process privilege, this Court should
hold that the importance of disclosure outweighs the need for the privilege as to the subset of
withheld documents that relate to the Governor’s contemporaneous understanding of the purpose
and likely effect of SB 14. Not only are these contemporaneous statements highly relevant
evidence of the actual purpose of SB 14, see Reno v. Bossier Parish Sch. Bd. (Bossier Parish I),
520 U.S. 471, 489 (1997) (quoting Vill. of Arlington Heights v. Metro. Housing Dev. Corp., 429
U.S. 252, 266-68 (1977)), but they may be entirely distinct from officials’ public
pronouncements. See, e.g., Smith v. Clarkton, 682 F.2d 1055, 1064 (4th Cir. 1982) (noting that
“officials . . . seldom, if ever, announce on the record that they are pursuing a particular course of
action because of their desire to discriminate against a racial minority”). Thus expression of the
Governor’s understanding of the likely effect of SB 14 on minority voters in the context of the
deliberations is highly relevant to the purpose inquiry. Nor are these vital deliberations available to
the Attorney General in other forms. Cf. United States v. Nixon, 418 U.S. 683, 700-702 (1974)
(overcoming qualified privilege based on unavailability of recordings from any other source).
Finally, any chilling effect brought on by the disclosure of a possible purpose to reduce minority
voter turnout must be outweighed by the vital rights at issue and the seriousness of the Attorney
General’s enforcement of the Voting Rights Act. Thus the deliberative process privilege fails to
justify the further non-disclosure of these documents.
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III. THE STATE HAS IMPROPERLY WITHHELD DOCUMENTS IN THE CUSTODY OF THE TEXAS LEGISLATIVE COUNCIL.
The State of Texas also continues to withhold hundreds of admittedly relevant documents
in the possession of the Texas Legislative Council on the basis of the state legislative privilege
and attorney-client privilege. The Legislative Council’s newly produced privilege log reasserts
the attorney-client privilege claim that has been rejected by this court. See Texas v. United States
(Texas II), 279 F.R.D. 24, 34 (D.D.C. 2012), vacated after production of disputed documents,
No. 1:11-cv-1303, 2012 WL 1578390 (D.D.C. Jan. 6, 2012). Moreover, despite the Court’s prior
rebuke against the State’s invocation of legislative privilege on behalf of absent legislators, see
Order at 6 (Doc. 128), the State again asserts legislative privilege over communications with the
leading opponents of SB 14. However, for the reasons that follow, Texas has misapplied some
basic principles applicable to the legislative privilege and attorney-client privilege. In addition,
the State’s invocation of the deliberative process privilege must yield with regard to documents
that may contain vital evidence of a discriminatory purpose.
A. The Texas Legislative Council Does Not Maintain an Attorney-Client Relationship with Individual Legislators and Legislative Staff.
The State of Texas has once again asserted an attorney-client privilege over all
communications between the legal department of the Texas Legislative Council and Texas
legislators and staff. See TLC Log at 1-181; See Texas Legislative Council Contested Document
Index at 1 (Ex. 4) [hereinafter TLC Index]. As the Attorney General set out in previous briefing,
no such attorney-client relationship exists between these parties. See Memorandum of Points
and Authorities in Support of the Attorney General’s Motion to Compel at 17-21 (Doc. 93-1);
Reply Memorandum in Support of the Attorney General’s Motion to Compel at 9-14 (Doc. 104).
Although Texas has now remedied most of the fundamental flaws in its privilege logs that the
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Court had previously identified, see Order at 5 (Doc. 128), the State has not explained how an
attorney-client relationship has been established between legislators and the Legislative Council
in the absence of state statutory authorization. See Tex. Gov. Code § 323.006 (listing functions);
see also Texas II, 279 F.R.D. at 34 (“The Texas Government Code expresses no such
relationship or expectation.”). Nor has the State explained whether attorneys employed by the
Texas Legislative Council provide anything more than “neutral, objective analysis” of the
legality of proposed actions. See Tax Analysts v. IRS, 117 F.3d 607, 619 (D.C. Cir. 1997); see
also Coastal States Gas, 617 F.2d at 863 (distinguishing governmental inquiries into legal
principles or the legality of potential state action from a “private party seeking advice to protect
personal interests”). Finally, even if an attorney-client relationship attaches to communications
between individual legislators and the Legislative Council, logically waiver must occur if
Council attorneys share legal advice among multiple legislators. See, e.g., TLC Log at 60.6
B. The State of Texas Cannot Assert a Legislative Privilege Belonging Solely to Legislators.
In its May 21 Order, the Court directed the State to produce “all documents withheld on the
basis of legislative privilege where . . . . the specific legislators identified have not asserted a
legislative privilege.” Order at 6 (Doc. 128). Two days later, the State produced a privilege log
asserting legislative privilege on behalf of opponents of SB 14, such as Representative Roberto
Alonzo. See TLC Log at 48-51, 53, 55, 94, 118-119, 128, 158; see also Waivers (Doc. 136-18)
6 The possibility of waiver also raises the concern that varying and often opposing alignments of legislative interest among different legislators would create an untenable ethical conflict for an attorney if he or she were to form individual attorney-client relationships with each and every member of the Texas Legislator. Cf. Tex. Disciplinary R. of Prof’l Conduct 1.06, cmt. 16 (noting that representation of both a board and individual directors may create a “material risk that the dual role will compromise the lawyer’s independence of professional judgment”). This further weighs against recognition of an attorney-client privilege.
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(expressly waiving privilege). The right to assert a legislative privilege belongs solely to legislators.
See Gravel, 408 U.S. at 621-22 & n.13; Miller v. Transamerican Press, Inc., 709 F.2d 524, 530 (9th
Cir. 1983) (citing Gravel, 408 U.S. at 616-19). Nevertheless, the State of Texas appears to have
appropriated this power to the Office of the Attorney General with regard to legislators who had not
communicated waiver directly to the State. The State has no basis to continue to withhold documents
reflecting communications with legislators who expressly waived legislative privilege, along with
those who have not expressly asserted the privilege. See TLC Index at 1.
C. Any Legislative Privilege Concerning the Drafting of SB 14 Must Yield.
The State of Texas has also asserted a state legislative privilege over nearly the full range
of responsive documents in the possession of the Texas Legislative Council. See TLC Log at 1-8
(setting out consecutive bates ranges). The Attorney General does not dispute that these TLC
documents reflect “legislative acts” subject to the state legislative privilege recognized by this
Court. However the Supreme Court has held that this privilege is merely qualified, see United
States v. Gillock, 445 U.S. 360, 368-69 (1980), and numerous district courts have followed this
command to apply multifactor balancing tests. See Comm. for a Fair & Balanced Map v. Ill. State
Bd. of Elections, No. 11 C 5065, 2011 WL 4837508, at *7 (N.D. Ill. Oct. 12, 2011); Rodriguez v.
Pataki, 280 F. Supp. 2d 89, 100-01 (S.D.N.Y. 2003), aff’d, 293 F. Supp. 2d 302 (S.D.N.Y. 2003);
United States v. Irvin, 127 F.R.D. 169, 173 (C.D. Cal. 1989); Baldus v. Members of the Wis. Gov’t
Accountability Bd., No. 11-cv-562, 2011 WL 6122542, at *2 (E.D. Wis. Dec. 8, 2011) (three-judge
court). Moreover, any language in Arlington Heights concerning state legislative privilege is
limited to “[p]lacing a decisionmaker on the stand”; even this dicta does not require
“extraordinary circumstances” to require the production of otherwise discoverable documents.
See 429 U.S. at 268.
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For the reasons set out in the Attorney General’s May 21 motion to compel, any state
legislative privilege should yield in this extraordinary litigation. See Memorandum of Points and
Authorities in Support of the Attorney General’s Motion to Compel at 10-26 (Doc. 136-1).
However one category of documents in the possession of the Texas Legislative Council is
particularly probative of legislative purpose: drafting files concerning the bill itself. See TLC
Index at 1-2. As Texas legislators and staff have explained, legislators often provide the purpose
and rough contours of legislative proposals to the Legislative Council, which then provides
technical bill-drafting support. See Beuck Dep. at 50:11-23, May 14, 2012 (Doc. 136-3); Harless
Dep. at 61:10-13, May 15, 2012 (Doc. 136-5). Thus instructions to the Texas Legislative
Council and related inquiries are highly probative of the purpose of legislation, rather than
legislators’ mental impressions. With respect to this limited universe of documents, the factors
used to assess a qualified privilege overwhelming favor disclosure.
IV. CONCLUSION
For the reasons set out above, this Court should grant the Attorney General’s motion to
compel the production of documents and enter the proposed order attached to the instant motion.
Case 1:12-cv-00128-RMC-DST-RLW Document 152-1 Filed 05/25/12 Page 13 of 14
14
Date: May 25, 2012 Respectfully submitted, RONALD C. MACHEN, JR. THOMAS E. PEREZ United States Attorney Assistant Attorney General District of Columbia Civil Rights Division
/s/ Daniel J. Freeman T. CHRISTIAN HERREN, JR. MEREDITH BELL-PLATTS ELIZABETH S. WESTFALL BRUCE I. GEAR JENNIFER L. MARANZANO RISA BERKOWER DANIEL J. FREEMAN Attorneys Voting Section, Civil Rights Division U.S. Department of Justice 950 Pennsylvania Avenue, N.W. Washington, D.C. 20530
Case 1:12-cv-00128-RMC-DST-RLW Document 152-1 Filed 05/25/12 Page 14 of 14
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA
STATE OF TEXAS, Plaintiff, v. ERIC H. HOLDER, JR., in his official capacity as Attorney General of the United States, Defendant. ERIC KENNIE, et al., Defendant-Intervenors, TEXAS STATE CONFERENCE OF NAACP BRANCHES, et al., Defendant-Intervenors, TEXAS LEAGUE OF YOUNG VOTERS EDUCATION FUND, et al., Defendant-Intervenors. TEXAS LEGISLATIVE BLACK CAUCUS, et al., Defendant-Intervenors, VICTORIA RODRIGUEZ, et al., Defendant-Intervenors.
) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )
CASE NO. 1:12-CV-00128 (RMC-DST-RLW) Three-Judge Court
[PROPOSED] ORDER COMPELLING THE
PRODUCTION OF DOCUMENTS
Upon consideration of the Attorney General’s motion to compel the production of
testimony and documents (Doc. __), the State of Texas’s response thereto (Doc. ___), and the
Case 1:12-cv-00128-RMC-DST-RLW Document 152-2 Filed 05/25/12 Page 1 of 2
Attorney General’s reply in further support (Doc. __), it is hereby ORDERED that:
1. The Attorney General’s motion to compel is GRANTED.
2. The State of Texas shall produce all relevant documents in the possession of the Texas
Legislative Council within two days of the date of this order.
3. The State of Texas shall produce within two days of the date of this order, all relevant
documents in the possession of the Office of the Governor not subject to a valid assertion
of the attorney-client privilege, as set out in Exhibit 3 to Attorney General’s Motion to
Compel (Doc. __-__).
SO ORDERED. Date: June ____, 2012
___________________________ DAVID S. TATEL United States Circuit Judge ___________________________ ROSEMARY M. COLLYER United States District Judge ___________________________ ROBERT L. WILKINS United States District Judge
Case 1:12-cv-00128-RMC-DST-RLW Document 152-2 Filed 05/25/12 Page 2 of 2
State of Texas v. Eric Holder, Jr., Attorney General of the United States Case No. 1:12-cv-00128
United States District Court for the District of Columbia
REVISED PRIVILEGE LOG May 23, 2012
Beginning Document
End Document Recipient Sender/Author Issues Attynotes Date Sources
TX_00034902
TX_00034902
Governor Rick Perry
Representative Betty Brown
Legislative Privilege
Letter from State Representative Betty Brown regarding actions the Governor could take to advance the legislative enactment of a voter ID law. 6/18/2009
GOVERNOR PART 2
TX_00037744
TX_00037744
Governor Rick Perry
Rep. Doug Miller
Legislative Privilege
Letter from State representative Doug Miller to Governor Perry regarding actions the Governor could take to advance the legislative enactment of a voter ID law. 6/26/2009
GOVERNOR PART 2
TX_00038291
TX_00038291
Beverley Wooley Rick Perry
Legislative Privilege
Letter from Representative Beverley Wooley to Governor Rick Perry regarding actions that Governor Perry could take to advance the enactment of the 2009 voter ID bill. 6/15/2009
GOVERNOR PART 2
TX_00057287
TX_00057288
Governor Perry Greg Davidson
DNP - ATTY CLIENT;DELIBERATIVE PROCESS
Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 82nd Legislature. This document consists of 5/18/2011
GOVERNOR PART 3
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 1 of 196
1
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 1 of 196
PRIVILEGE
an in-depth analysis of SB 14. The document contains the advice, opinion, and recommendations of the author regarding legislation addressing economic development. The document was created to assist the Governor and his staff in deciding whether to support or oppose SB14. The Governor personally reviewed this document. Ultimately, the document was used to advise the Governor on whether to sign or veto SB 14. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor taff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00057289
TX_00057289 Jeff Boyd David Morales
DNP - ATTY CLIENT
Confidential e-mail from Governor's General Counsel to Governor's Chief of Staff sent for purposes of providing legal advice regarding SB 14 preclearance. 9/23/2011
GOVERNOR PART 3
TX_00057290
TX_00057290 Jeff Boyd David Morales
DNP - ATTY CLIENT
Attachment to above confidential attorney-client copmmunication (TX_00057289) sent for purposes of providing legal advice regardign SB 14 preclearance 9/23/2011
GOVERNOR PART 3
TX_00057 TX_00057 Jeff Boyd David Morales DNP - Attachment to above confidential 9/23/2011 GOVERN
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 2 of 196
2
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 2 of 196
291 293 ATTY CLIENT
attorney-client copmmunication (TX_00057289) sent for purposes of providing legal advice regardign SB 14 preclearance
OR PART 3
TX_00057294
TX_00057308
General Counsel~Budget Planning and Policy~Executive
General Counsel's Office
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 79th Legislature.~~This document consists of bill summaries and bill tracking of bills from the 79th legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the 00/00/2005
GOVERNOR PART 3
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 3 of 196
3
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 3 of 196
document cannot be produced in a redacted form without disclosing privileged information.
TX_00057309
TX_00057309
Coby Shorter~Jimmy Blacklock~Daniel Hodge~Ken Armbrister Jeff Boyd
DNP - ATTY CLIENT
Confidential e-mail from Governor's Chief of Staff to Secretary of State Director, OAG Attorneys, and Governor's staff sent for purposes of seeking legal advice regarding SB 14 preclearance submission 1/12/2012
GOVERNOR PART 3
TX_00057310
TX_00057319
Coby Shorter~Jimmy Blacklock~Daniel Hodge~Ken Armbrister Jeff Boyd
DNP - ATTY CLIENT
Attachment to above confidential attorney-client communication (TX_00057309) sent for purpose of seeking legal advice regarding SB 14 preclearance submission 1/12/2012
GOVERNOR PART 3
TX_00057320
TX_00057320
Jeff Boyd~Blaine Brunsen Daniel Hodge
DNP - ATTY CLIENT
Confidential communications from OAG First Assistant Attorney General to Governor Chief of Staff and Lt. Governor Chief of Staff sent for the purposes of providing legal advice regarding Voter ID 12/23/2011
GOVERNOR PART 3
TX_00057321
TX_00057321
Press Office~Jeff Boyd~Matthew Thompson~Konathan Hurst~Ken Armbrister~Mike Allison Castle
DNP - DELIBERATIVE PROCESS PRIVILEGE;DNP - ATTY CLIENT
Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 82nd Legislature.~~This document transmits a draft press release regarding bills from the 82nd legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding 8/31/2011
GOVERNOR PART 3
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 4 of 196
4
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 4 of 196
Morrissey certain legislation. Jeff Boyd is an attorney recipient of the document. The document was created to assist the Governor in formulating a policy announcement on legislation from the 82nd legislature. Ultimately, the document was used to advise the Governor on his decision on which policy positions the Governor should take. The document is a draft and was created prior to a final decision by the Governor on a policy statement. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00057322
TX_00057323
Press Office~Jeff Boyd~Matthew Thompson~Konathan Hurst~Ken Armbrister~Mike Morrissey Allison Castle
DNP - DELIBERATIVE PROCESS PRIVILEGE;DNP - ATTY CLIENT
Draft press release attachment to above privileged communication (TX_00057322) and privileged for the same reasons as the email to which it was attached. 8/31/2011
GOVERNOR PART 3
TX_00057324
TX_00057324
Jeff Boyd, Marty Brandy Colin Parish
DNP - ATTY CLIENT
Confidential communications between Governor's Office Attorneys and staff sent for the purpose of seeking or 5/6/2011
GOVERNOR PART 3
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 5 of 196
5
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 5 of 196
providing legal advice regarding Voter ID
TX_00057325
TX_00057356
Jeff Boyd, David Morales, Stacy Napier,~David, Schenck,~Jimmy Blacklock, Jonathan Mitchell,~Michael Schofield, Daniel Hodge,Ken Armbrister, Sarah Floerke, David Eichler, Ray Sullivan,~Brandy Marty, Mike Vitris,~Press Office, EBM_Cooridnators, Senior Staff, BPP 4th, General Counsel,
Daniel Hodge, David Morales,~Jeff Boyd,~ Stacy Napier~Colin Parrish,~BPP Advisors,~GC Lawyers, Gregg Davidson,
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Confidential communication between Governor Office Attorneys and Staff sent for purposes of seeking or providing legal advice regarding Voter ID.~~This document contains and solicits legal advice on the constitutionality of Section 5. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor in formulating a policy on bills in 82nd legislature that might trigger a preclearance obligation under Section 5. Ultimately, the document was used to advise the Governor on whether to support or oppose certain legislation. The document was created prior to a final decision by the Governor whether to support or oppose legislation that might require preclearance. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information. 3/21/2011
GOVERNOR PART 3
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 6 of 196
6
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 6 of 196
ATLAS Analysts, Legislative, Blake Bell, Logan Jack
TX_00057357
TX_00057358
Jonathan Hurst~Press Office~Jeff Boyd~Ken Armbrister~Mike Morrissey Steffany Duke
DNP - DELIBERATIVE PROCESS PRIVILEGE;DNP - ATTY CLIENT
Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 82nd Legislature.~~This document transmits a draft press release regarding bills from the 82nd legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. Jeff Boyd is an attorney recipient of the document. The document was created to assist the Governor in formulating a policy announcement on legislation from the 82nd legislature. Ultimately, the document was used to advise the Governor on his decision on which policy positions the Governor should take. The document is a draft and was created prior to a final decision by the Governoron a policy statement. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the 8/30/2011
GOVERNOR PART 3
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 7 of 196
7
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 7 of 196
public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00057359
TX_00057360
Jonathan Hurst~Press Office~Jeff Boyd~Ken Armbrister~Mike Morrissey Steffany Duke
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Draft press release attachment to above confidential attorney-client, deliberative process privileged communication (TX_00057357), and privileged for the same reasons. 8/31/2011
GOVERNOR PART 3
TX_00057361
TX_00057362
Lucy Nashed~Batherine Frazier~Jeff Boyd~Matthew Thompson~Jonathan Hurst~Press Office~Ken Armbrister~Mike Morrissey~Kethy Walt Steffany Duke
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 82nd Legislature.~~This document transmits a draft press release regarding bills from the 82nd legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. Jeff Boyd is an attorney recipient of the document. The document was created to assist the Governor in formulating a policy announcement on legislation from the 82nd legislature. Ultimately, the document was used to advise the Governor on his decision on which policy positions the Governor should take. The document is a draft and was created prior to a final decision by the Governoron a policy statement. As such, the document does not memorialize or 8/31/2011
GOVERNOR PART 3
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 8 of 196
8
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 8 of 196
evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00057363
TX_00057364
Lucy Nashed~Batherine Frazier~Jeff Boyd~Matthew Thompson~Jonathan Hurst~Press Office~Ken Armbrister~Mike Morrissey~Kethy Walt Steffany Duke
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Draft press release attachment to above attorney-client, deliberative process privileged communication (TX_00057362) and privileged for the same reasons as the email attaching it. 8/31/2011
GOVERNOR PART 3
TX_00057365
TX_00057366
Press Office~Jonathan hurst~Jeff Boyd~Ken Armbrister~Mike Morrissey Steffany Duke
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 82nd Legislature.~~This document transmits a draft press release regarding bills from the 82nd legislative session that were deemed important by the Governor's policy advisers. The document contains 8/30/2011
GOVERNOR PART 3
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 9 of 196
9
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 9 of 196
the advice, opinion, and recommendations of the author regarding certain legislation. Jeff Boyd is an attorney recipient of the document. The document was created to assist the Governor in formulating a policy announcement on legislation from the 82nd legislature. Ultimately, the document was used to advise the Governor on his decision on which policy positions the Governor should take. The document is a draft and was created prior to a final decision by the Governoron a policy statement. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00057367
TX_00057368
Press Office~Jonathan hurst~Jeff Boyd~Ken Armbrister~Mike Morrissey Steffany Duke
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Draft press release attachment to above confidential attorney-client, deliberative process privileged document (TX_00057365) and privileged for the same reasons as the email to which it is attached. 8/30/2011
GOVERNOR PART 3
TX_00057369
TX_00057414
Lisa Ried, Jeff Boyd, ~Press Offfice,
Andrew Barlow
DNP - ATTY CLIENT;DNP -
Confidential communication between Governor Office Attorneys and Staff sent for purposes of seeking or providing legal advice regarding Voter ID and numerous 2/7/2011
GOVERNOR PART 3
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 10 of 196
10
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 10 of 196
Ray Sullivan, Rob Johnson, Marty Brandy, Ken Armbrister, Mike Morrissey
DELIBERATIVE PROCESS PRIVILEGE
other laws and policy initiatives.~~This document transmits a draft State of the State" speech discussing numerous issues that were deemed important by the Governor's policy advisers, including Voter ID. The document contains the advice, opinion, and recommendations of the author regarding numerous pieces of legislation and various policy statements. Jeff Boyd is an attorney recipient of the document. The document was created to assist the Governor in formulating a policy announcement on legislation from the 82nd legislature. Ultimately, the document was used to advise the Governor on his decision on which policy positions the Governor should take. The document is a draft and was created prior to a final decision by the Governor on which policy statement he would publicly adopt. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information."
TX_00057415
TX_00057415
Allison Castle~Stephanie Duke~Jonathan Hurst~Kathy Walt Jeff Boyd
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS
Confidential communication between Governor Office Attorneys and Staff sent for purposes of seeking or providing legal advice regarding Voter ID and several other bills from the 82nd legislative session.~~This document edits a draft press release regarding bills from the 8/30/2011
GOVERNOR PART 3
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 11 of 196
11
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 11 of 196
PRIVILEGE
82nd legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. Jeff Boyd is an attorney recipient of the document. The document was created to assist the Governor in formulating a policy announcement on legislation from the 82nd legislature. Ultimately, the document was used to advise the Governor on his decision on which policy positions the Governor should take. The document is a draft and was created prior to a final decision by the Governoro n a policy statement. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00057416
TX_00057417
Allison Castle~Stephanie Duke~Jonathan Hurst~Kathy Walt Jeff Boyd
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Attachment to above confidential attorney-client, deliberative process privileged document (TX_00057415) and privileged for the same reasons as the email to which it is attached. 8/30/2011
GOVERNOR PART 3
TX_00057418
TX_00057450 Jeff Boyd Colin Parrish
DNP - DELIBERA
Confidential email communication and attachments involving Governor's 5/6/2011
GOVERNOR PART
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 12 of 196
12
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 12 of 196
TIVE PROCESS PRIVILEGE;DNP - ATTY CLIENT
General Counsel and Governor's Staff sent for purposes of providing legal advice regarding SB 14.~~This document transmits committee reports and other materials on SB 14 that were deemed important by the Governor's policy and advisers. The document reflects the advice, opinion, and recommendations of the author regarding certain legislation. Jeff Boyd is an attorney recipient of the document. The document was created to assist the Governor in deciding whether to support or oppose voter ID. Ultimately, the document was used to advise the Governor on his decision on which policy positions the Governor should take. The document was created prior to a final decision by the Governoron a policy statement. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
3
TX_00057451
TX_00057455
Jeff Boyd, Brandy Marty, Colin Parish Amando Saenz
Colin Parrish~Amando Saenz
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of giving or receiving legal advice regarding SB 14.~~This document is an email string among Governor Staff and Governor Counsel sent for the purpose of collecting information about SB 14. The document contains the advice, opinion, 3/30/2011
GOVERNOR PART 3
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 13 of 196
13
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 13 of 196
and recommendations of the author regarding whom the Governor should contact and consult regarding SB 14. Jeff Boyd is an attorney recipient and author of several emails in the email string. The document was created to assist the Governor in deciding whether to veto or sign SB 14. Ultimately, the document was used to advise the Governor on his decision on whether to veto or sign SB 14. The document was created prior to a final decision by the Governor on whether to sign or veto SB 14. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00057456
TX_00057475
Travis Richmond Jeff Boyd John Sepehri AnnMcGeehan Erik Wilson Paul Miles Elizabeth Winn
John Sepehri~Elizabeth Winn
DNP - ATTY CLIENT
Confidential communication between Governor Office Attorneys and SOS General Counsel sent for purposes of seeking or providing legal advice regarding SB 14 preclearance submission 7/22/2011
GOVERNOR PART 3
TX_00057476
TX_00057511
Travis Richmond Jeff Boyd
John Sepehri~Ann McGeehan
DNP - ATTY CLIENT
Confidential communication between Governor Office Attorneys, SOS General Counsel, and OAG Attorneys sent for 7/26/2011
GOVERNOR PART 3
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 14 of 196
14
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John Sepehri Erik Wilson Paul Miles Elizabeth Winn Jay Dyer~Jimmy Blacklock David Schenck Stacy Napier Reed Clay
purposes of seeking or providing legal advice regarding SB 14 preclearance submission
TX_00057512
TX_00057518
Jeff Boyd ~David Morales
Jay Dyer~David Morales
DNP - ATTY CLIENT
Confidential communication between Governor Office Attorneys and Staff sent for purposes of seeking or providing legal advice regarding Voter ID, containing advice, opinions, and deliberations that precede a final decision relating to voter ID implementation 9/23/2011
GOVERNOR PART 3
TX_00057519
TX_00057537
Jeff Boyd~Travis Richmondf~Jay Dyer~John Sepehri
John Sepehri~Jimmy Blacklock
DNP - ATTY CLIENT
Confidential communication among OAG Attorneys, SOS General Counsel, Governor Office Attorneys and Staff sent for purposes of seeking or providing legal advice regarding Voter ID. 7/20/2011
GOVERNOR PART 3
TX_00057538
TX_00057539 Jeff Boyd Colin Parrish
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS
Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of giving or receiving legal advice regarding SB 14.~~This document is an email string among Governor Staff and Governor Counsel sent for the purpose of 5/13/2011
GOVERNOR PART 3
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 15 of 196
15
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 15 of 196
PRIVILEGE
collecting information about SB 14. The document contains the advice, opinion, and recommendations of the author regarding whom the Governor should contact and consult regarding SB 14. Jeff Boyd is an attorney recipient of emails in the email string. The document was created to assist the Governor in deciding whether to veto or sign SB 14. Ultimately, the document was used to advise the Governor on his decision on whether to veto or sign SB 14. The document was created prior to a final decision by the Governor on whether to sign or veto SB 14. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00057540
TX_00057546 Jeff Boyd Lisa Reid
DNP - ATTY CLIENT
Confidential communication between Governor Office Attorneys and Staff sent for purposes of seeking or providing legal advice regarding Voter ID 9/2/2011
GOVERNOR PART 3
TX_00057547
TX_00057562
Ann McGeehan,~Elizabeth Winn~Erik Wilson~Esperanza Andrade~ John Sepehri
DNP - ATTY CLIENT
Confidential communications between Governor Office Attorneys and Staff sent for purposes of seeking or providing legal advice. 7/22/2011
GOVERNOR PART 3
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 16 of 196
16
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Coby Shorter~Jeff Boyd~Travis Richmond
TX_00057563
TX_00057564 Jeff Boyd Lisa Ried
DNP - ATTY CLIENT
Confidential communication between Governor Office Attorney and Staff sent for purposes of seeking or providing legal advice regarding Voter ID 5/6/2011
GOVERNOR PART 3
TX_00057565
TX_00057566
Lucy Nashed~Jeff Boyd~Mary Anne Wiley~Kathy Wall~Josh Havens~Matthew Thompson~Ken Armbrister~Jonathan Hurst~Steffany Duke Allison Castle
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of giving or receiving legal advice regarding SB 14.~~This document is an email string among Governor Staff and Governor Counsel sent for the purpose of responding to media inquiries about SB 14. The document contains the advice, opinion, and recommendations of the author regarding the public policy positions that the Governor would adopt on SB 14. Jeff Boyd is an attorney recipient. The document was created to assist the Governor in deciding whether which public positions, if any, he would take on SB 14. Ultimately, the document was used to advise the Governor on his decision on policy positions relating to SB 14. The document was created prior to a final decision by the Governor on which public policy positions he should take as to SB 14. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. 9/14/2011
GOVERNOR PART 3
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17
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The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00057567
TX_00057568
Steffany Duke~Press Office~Jeff Boyd~Ken Armbrister~Mike Morrissey
Jonathan Hurst
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Confidential communication between Governor Office Attorneys and Staff sent for purposes of seeking or providing legal advice regarding Voter ID and several other bills from the 82nd legislative session.~~This document edits a draft press release regarding bills from the 82nd legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. Jeff Boyd is an attorney recipient of the document. The document was created to assist the Governor in formulating a policy announcement on legislation from the 82nd legislature. Ultimately, the document was used to advise the Governor on his decision on which policy positions the Governor should take. The document is a draft and was created prior to a final decision by the Governoro n a policy statement. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information. 8/30/2011
GOVERNOR PART 3
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18
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TX_00057569
TX_00057570
Jonathan Hurst~Press Office~Jeff Boyd~Ken Armbrister~Mike Morrissey Steffany Duke
DNP - ATTY CLIENT;DNP - WORK PRODUCT
Confidential communications between Governor Office Attorneys and Staff sent for purposes of seeking or providing legal advice regarding Voter ID, containing advice, opinions, and deliberations that precede a final decision relating to voter ID implementation 8/31/2011
GOVERNOR PART 3
TX_00057571
TX_00057572
Steffany Duke~Lucy Nashed~Catherine Frazier~Jeff Boyd~Jonathan Hurst~Press Office~Ken Armbrister~Mike Morrissey~Kathy Walt
Matthew Thompson
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Confidential communication between Governor Office Attorneys and Staff sent for purposes of seeking or providing legal advice regarding Voter ID and several other bills from the 82nd legislative session.~~This document edits a draft press release regarding bills from the 82nd legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. Jeff Boyd is an attorney recipient of the document. The document was created to assist the Governor in formulating a policy announcement on legislation from the 82nd legislature. Ultimately, the document was used to advise the Governor on his decision on which policy positions the Governor should take. The document is a draft and was created prior to a final decision by the Governoro n a policy statement. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor 8/31/2011
GOVERNOR PART 3
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19
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staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00057573
TX_00057574
Steffany Duke~Lucy Nashed~Catherine Frazier~Jeff Boyd~Jonathan Hurst~Press Office~Ken Armbrister~Mike Morrissey~Kathy Walt
Matthew Thompson
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Draft press release attachment to above confidential attorney-client, deliberative process privileged document (TX_00057571) and privileged for the same reasons as the email to which it is attached. 8/31/2011
GOVERNOR PART 3
TX_00057575
TX_00057577
Jeff Boyd~Steffany Duke~Matthew Thompson~Jonathan Hurst~Press Office~Ken Armbrister~Mike
Catherine Frazier
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Confidential communication between Governor Office Attorneys and Staff sent for purposes of seeking or providing legal advice regarding Voter ID and several other bills from the 82nd legislative session.~~This document edits a draft press release regarding bills from the 82nd legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. Jeff Boyd is an attorney recipient of the document. The 8/31/2011
GOVERNOR PART 3
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20
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Morrissey~Kathy Walt
document was created to assist the Governor in formulating a policy announcement on legislation from the 82nd legislature. Ultimately, the document was used to advise the Governor on his decision on which policy positions the Governor should take. The document is a draft and was created prior to a final decision by the Governoro n a policy statement. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00057578
TX_00057579
Jeff Boyd~Steffany Duke~Matthew Thompson~Jonathan Hurst~Press Office~Ken Armbrister~Mike Morrissey~Kathy Walt
Catherine Frazier
DNP - DELIBERATIVE PROCESS PRIVILEGE
Draft press release attachment to above confidential attorney-client, deliberative process privileged document (TX_00057575) and privileged for the same reasons as the email to which it is attached. 8/31/2011
GOVERNOR PART 3
TX_00057 TX_00057 Catherine Lucy Nached DNP - Confidential communication between 8/31/2011 GOVERN
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 21 of 196
21
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 21 of 196
580 582 Frazier~Jeff Boyd~Steffany Duke~Matthew Thompson~Jonathan Hurst~Press Office~Ken Armbrister~Mike Morrisey~Kathy Walt
ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Governor Office Attorneys and Staff sent for purposes of seeking or providing legal advice regarding Voter ID and several other bills from the 82nd legislative session.~~This document edits a draft press release regarding bills from the 82nd legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. Jeff Boyd is an attorney recipient of the document. The document was created to assist the Governor in formulating a policy announcement on legislation from the 82nd legislature. Ultimately, the document was used to advise the Governor on his decision on which policy positions the Governor should take. The document is a draft and was created prior to a final decision by the Governoro n a policy statement. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
OR PART 3
TX_00057583
TX_00057584
Catherine Frazier~Jeff Boyd~Steffany Lucy Nached
DNP - DELIBERATIVE PROCESS PRIVILEG
Draft press release attachment to above confidential attorney-client, deliberative process privileged document (TX_00057580) and privileged for the same reason as the email to which it is 8/31/2011
GOVERNOR PART 3
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 22 of 196
22
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Duke~Matthew Thompson~Jonathan Hurst~Press Office~Ken Armbrister~Mike Morrisey~Kathy Walt
E;DNP - ATTY CLIENT
attached.
TX_00057585
TX_00057587
Steffany Duke~Matthew Thompson~Jonathan Hurst~Press Office~Ken Armbrister~Mike Morrissey Jeff Boyd
DNP - DELIBERATIVE PROCESS PRIVILEGE;DNP - ATTY CLIENT
Confidential communication between Governor Office Attorneys and Staff sent for purposes of seeking or providing legal advice regarding Voter ID and several other bills from the 82nd legislative session.~~This document edits a draft press release regarding bills from the 82nd legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. Jeff Boyd is an attorney author of the document. The document was created to assist the Governor in formulating a policy announcement on legislation from the 82nd legislature. Ultimately, the document was used to advise the Governor on his decision on which policy positions the Governor should take. The document is a draft and was created prior to a final decision by the Governor on a policy statement. As such, the 8/31/2011
GOVERNOR PART 3
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23
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document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00057588
TX_00057589
Steffany Duke~Matthew Thompson~Jonathan Hurst~Press Office~Ken Armbrister~Mike Morrissey Jeff Boyd
DNP - DELIBERATIVE PROCESS PRIVILEGE;DNP - ATTY CLIENT
Draft press release attachment to above confidential attorney-client, deliberative process privileged documents (TX_00057585) and privileged for the same reasons as the email to which it was originally attached. 8/31/2011
GOVERNOR PART 3
TX_00057590
TX_00057591
Matthew Thompson~Steffany Duke~Press Office~Jeff Boyd~Ken Armbrister~Mike Morrissey
Jonathan Hurst
DNP - DELIBERATIVE PROCESS PRIVILEGE;DNP - ATTY CLIENT
Confidential communication between Governor Office Attorneys and Staff sent for purposes of seeking or providing legal advice regarding Voter ID and several other bills from the 82nd legislative session.~~This document edits a draft press release regarding bills from the 82nd legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. Jeff Boyd is an attorney recipient of the document. The document was created to assist the 8/30/2011
GOVERNOR PART 3
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 24 of 196
24
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Governor in formulating a policy announcement on legislation from the 82nd legislature. Ultimately, the document was used to advise the Governor on his decision on which policy positions the Governor should take. The document is a draft and was created prior to a final decision by the Governoro n a policy statement. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00057592
TX_00057593
Matthew Thompson~Jonathan Hurst~Press Office~Jeff Boyd~Ken Armbrister~Mike Morrissey Steffany Duke
DNP - DELIBERATIVE PROCESS PRIVILEGE;DNP - ATTY CLIENT
Confidential communication between Governor Office Attorneys and Staff sent for purposes of seeking or providing legal advice regarding Voter ID and several other bills from the 82nd legislative session.~~This document edits a draft press release regarding bills from the 82nd legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. Jeff Boyd is an attorney recipient of the document. The document was created to assist the Governor in formulating a policy announcement on legislation from the 82nd legislature. Ultimately, the document was used to advise the 8/30/2011
GOVERNOR PART 3
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 25 of 196
25
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Governor on his decision on which policy positions the Governor should take. The document is a draft and was created prior to a final decision by the Governoro n a policy statement. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00057594
TX_00057595
Jonathan Hurst~Steffany Duke~Press Office~Jeff Boyd~Ken Armbrister
Matthew Thompson
DNP - DELIBERATIVE PROCESS PRIVILEGE;DNP - ATTY CLIENT
Confidential communication between Governor Office Attorneys and Staff sent for purposes of seeking or providing legal advice regarding Voter ID and several other bills from the 82nd legislative session.~~This document edits a draft press release regarding bills from the 82nd legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. Jeff Boyd is an attorney recipient of the document. The document was created to assist the Governor in formulating a policy announcement on legislation from the 82nd legislature. Ultimately, the document was used to advise the Governor on his decision on which policy positions the Governor should take. The document is a draft and was created prior to a final decision by the Governoro 8/30/2011
GOVERNOR PART 3
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 26 of 196
26
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 26 of 196
n a policy statement. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00057596
TX_00057597
Steffany Duke~Press Office~Jeff Boyd~Ken Armbrister~Mike Morrissey
Jonathan Hurst
DNP - DELIBERATIVE PROCESS PRIVILEGE;DNP - ATTY CLIENT
Confidential communication between Governor Office Attorneys and Staff sent for purposes of seeking or providing legal advice regarding Voter ID and several other bills from the 82nd legislative session.~~This document edits a draft press release regarding bills from the 82nd legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. Jeff Boyd is an attorney recipient of the document. The document was created to assist the Governor in formulating a policy announcement on legislation from the 82nd legislature. Ultimately, the document was used to advise the Governor on his decision on which policy positions the Governor should take. The document is a draft and was created prior to a final decision by the Governoro n a policy statement. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed 8/30/2011
GOVERNOR PART 3
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 27 of 196
27
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 27 of 196
and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00057598
TX_00057599
Lucy Nashed~Catherine Frazier~Jeff Boyd~Matthew Thompson~Jonathan Hurst~Press Office~Ken Armbrister~Mike Morrissey~Kathy Walt Steffany Duke
DNP - DELIBERATIVE PROCESS PRIVILEGE;DNP - ATTY CLIENT
Confidential communication between Governor Office Attorneys and Staff sent for purposes of seeking or providing legal advice regarding Voter ID and several other bills from the 82nd legislative session.~~This document edits a draft press release regarding bills from the 82nd legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. Jeff Boyd is an attorney recipient of the document. The document was created to assist the Governor in formulating a policy announcement on legislation from the 82nd legislature. Ultimately, the document was used to advise the Governor on his decision on which policy positions the Governor should take. The document is a draft and was created prior to a final decision by the Governoro n a policy statement. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the 8/31/2011
GOVERNOR PART 3
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 28 of 196
28
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public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00057600
TX_00057601
Lucy Nashed~Catherine Frazier~Jeff Boyd~Matthew Thompson~Jonathan Hurst~Press Office~Ken Armbrister~Mike Morrissey~Kathy Walt Steffany Duke
DNP - DELIBERATIVE PROCESS PRIVILEGE;DNP - ATTY CLIENT
Draft press release attachment to above confidential attorney-client, deliberative process privileged documents (TX_00057598) and privileged for the same reasons as the original email to which it is attached. 8/31/2011
GOVERNOR PART 3
TX_00057602
TX_00057603
Allison Castle~Lucy Nashed~Mary Anne Wiley~Kathy Walt~Josh Havens~Matthew Thompson~Ken Armbrister~Jonat Jeff Boyd
DNP - DELIBERATIVE PROCESS PRIVILEGE;DNP - ATTY CLIENT
Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of giving or receiving legal advice regarding SB 14.~~This document is an email string among Governor Staff and Governor Counsel sent for the purpose of responding to media inquiries about SB 14. The document contains the advice, opinion, and recommendations of the author regarding the public policy positions that the Governor would adopt on SB 14. Jeff Boyd is an attorney author and recipient of emails in this email string. The document was created to assist the Governor in deciding 9/14/2011
GOVERNOR PART 3
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 29 of 196
29
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hen Hurst~Steffany Duke
whether which public positions, if any, he would take on SB 14. Ultimately, the document was used to advise the Governor on his decision on policy positions relating to SB 14. The document was created prior to a final decision by the Governor on which public policy positions he should take as to SB 14. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00057604
TX_00057605
Allison Castle~Lucy Nashed~Mary Anne Wiley~Kathy Walt~Josh Havens~Matthew Thompson~Ken Armbrister~Jonathen Hurst~Steffany Duke
Jonathan Hurst~Allison Castle
DNP - DELIBERATIVE PROCESS PRIVILEGE;DNP - ATTY CLIENT
Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of giving or receiving legal advice regarding SB 14.~~This document is an email string among Governor Staff and Governor Counsel sent for the purpose of responding to media inquiries about SB 14. The document contains the advice, opinion, and recommendations of the author regarding the public policy positions that the Governor would adopt on SB 14. Jeff Boyd is an attorney recipient of emails in the email string. The document was created to assist the Governor in deciding whether which public positions, if any, he would take on SB 14. Ultimately, the document was used to advise the Governor on his decision on policy positions relating to SB 9/14/2011
GOVERNOR PART 3
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 30 of 196
30
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14. The document was created prior to a final decision by the Governor on which public policy positions he should take as to SB 14. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00057606
TX_00057607
Becky Dean~Lucy Nashed~Allison Castle~Jeff Boyd~Press Office~Mary Anne Wiley Steffany Duke
DNP - DELIBERATIVE PROCESS PRIVILEGE;DNP - ATTY CLIENT
Confidential communication between Governor Office Attorneys and Staff sent for purposes of seeking or providing legal advice regarding Voter ID and several other bills from the 82nd legislative session.~~This document edits a draft press release regarding bills from the 82nd legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. Jeff Boyd is an attorney recipient of the document. The document was created to assist the Governor in formulating a policy announcement on legislation from the 82nd legislature. Ultimately, the document was used to advise the Governor on his decision on which policy positions the Governor should take. The document is a draft and was created prior to a final decision by the Governoro n a policy statement. As such, the document does not memorialize or 8/31/2011
GOVERNOR PART 3
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 31 of 196
31
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 31 of 196
evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00057608
TX_00057609
Becky Dean~Lucy Nashed~Allison Castle~Jeff Boyd~Press Office~Mary Anne Wiley Steffany Duke
DNP - DELIBERATIVE PROCESS PRIVILEGE;DNP - ATTY CLIENT
Attachment to above confidential attorney-client, delibertaive process privileged document (TX_00057606) and privileged for the same reasons as the email to which it is attached. 8/31/2011
GOVERNOR PART 3
TX_00057610
TX_00057626
Colin Parrish~Brandy Marty
Jeff Boyd~Colin Parrish
DNP - DELIBERATIVE PROCESS PRIVILEGE;DNP - ATTY CLIENT
Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of giving or receiving legal advice regarding SB 14.~~This document is an email string among Governor Staff and Governor Counsel sent for the purpose of collecting information about SB 14. The document contains the advice, opinion, and recommendations of the author regarding whom the Governor should contact and consult regarding SB 14. Jeff Boyd is an attorney recipient and author of emails in the email string. The document was created to assist the Governor in deciding whether to veto or sign SB 14. Ultimately, the document 3/29/2011
GOVERNOR PART 3
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 32 of 196
32
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 32 of 196
was used to advise the Governor on his decision on whether to veto or sign SB 14. The document was created prior to a final decision by the Governor on whether to sign or veto SB 14. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00057627
TX_00057644
Jeff Boyd ~Michael Schofield~Rep Anchia~Deirdre Delisi
Michael Schoenfiled~Jeff Boyd~Rep. Anchia
DNP - DELIBERATIVE PROCESS PRIVILEGE;DNP - ATTY CLIENT;DNP - LEGISLATIVE PRIVILEGE
Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of giving or receiving legal advice regarding SB 14.~~This document is an email string among Governor Staff and Governor Counsel sent for the purpose of collecting information about SB 14. The document contains the advice, opinion, and recommendations of the author regarding whom the Governor should contact and consult regarding SB 14. Jeff Boyd is an attorney recipient of emails in the email string. The document was created to assist the Governor in deciding whether to veto or sign SB 14. Ultimately, the document was used to advise the Governor on his decision on whether to veto or sign SB 14. The document was created prior to a final decision by the Governor on whether to sign or veto SB 14. As such, the document does not memorialize or 5/6/2011
GOVERNOR PART 3
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 33 of 196
33
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evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00057645
TX_00057678
Collin Parrish~Michael Schofield~Brandy Marty Jeff Boyd
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of giving or receiving legal advice regarding SB 14.~~This document is an email string among Governor Staff and Governor Counsel sent for the purpose of collecting information about SB 14. The document contains the advice, opinion, and recommendations of the author regarding whom the Governor should contact and consult regarding SB 14. Jeff Boyd is an attorney author and recipient of emails in the email string. The document was created to assist the Governor in deciding whether to veto or sign SB 14. Ultimately, the document was used to advise the Governor on his decision on whether to veto or sign SB 14. The document was created prior to a final decision by the Governor on whether to sign or veto SB 14. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the 4/16/2011
GOVERNOR PART 3
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 34 of 196
34
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 34 of 196
public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00057679
TX_00057695
John Sepehri~Keff Boyd
Travis Richmond
DNP - ATTY CLIENT
Confidential communications between Governor Office Attorneys and SOS General Counsel sent for purposes of seeking or providing legal advice regarding SB 14 preclearance submission 7/25/2011
GOVERNOR PART 3
TX_00057696
TX_00057698
Katherine Cesinger~Michael Schofield Jeff Boyd
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of giving or receiving legal advice regarding SB 14.~~This document is an email string among Governor Staff and Governor Counsel sent for the purpose of discussing preclearance of SB 14. The document contains the advice, opinion, and recommendations of the author regarding the Governor's role, if any, in the preclearance of SB 14. Jeff Boyd is an attorney author and recipient of emails in the email string. The document was created to assist the Governor in deciding his post-enactment role in the preclearance of SB 14. Ultimately, the document was used to advise the Governor on his decision on his post-enactment role in the preclearance of SB 14. The document was created prior to a final decision by the Governor on what role he would play in the preclearance of SB 14. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The 6/7/2011
GOVERNOR PART 3
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 35 of 196
35
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 35 of 196
document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00057699
TX_00057718
John Sepehri~Jeff Boyd
Travis Richmond
DNP - ATTY CLIENT
Confidential comunication between Governor's Office Attorneys and SOS General Counsel sent for purposes of providing or seeking legal advice regarding SB 14 preclearance submission 7/21/2011
GOVERNOR PART 3
TX_00057719
TX_00057743
Travis Richmond~Jeff Boyd John Sepehri
DNP - ATTY CLIENT
Confidential comunication between Governor's Office Attorneys and SOS General Counsel sent for purposes of providing or seeking legal advice regarding SB 14 preclearance submission 7/20/2011
GOVERNOR PART 3
TX_00057744
TX_00057746
Travis Richmond~Jeff Boyd John Sepehri
DNP - ATTY CLIENT
Confidential comunication between Governor's Office Attorneys and SOS General Counsel sent for purposes of providing or seeking legal advice regarding SB 14 preclearance submission 7/20/2011
GOVERNOR PART 3
TX_00057747
TX_00057753
Colin Parrish~Brandy Marty Jeff Boyd
DNP - ATTY CLIENT
Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of giving or receiving legal advice regarding SB 14.~~This document is an email string among Governor Staff and Governor Counsel sent for the purpose of collecting information about the fiscal impact of SB 14. The document contains the advice, opinion, and recommendations of the author regarding the fiscal impact of SB 14. Jeff Boyd is an attorney recipient and author of emails in the email string. The document was created to assist the Governor in making a final policy determination on whether the fiscal impact of SB 14 has constitutional or other legal implications. 5/6/2011
GOVERNOR PART 3
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 36 of 196
36
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 36 of 196
TX_00057754
TX_00057755 Jeff Boyd
Travis Richmond
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Confidential communication from Governor's General Counsel attorneys sent for purposes of giving or receiving legal advice regarding SB 14.~~This document is an email string among Governor's Counsel attorneys opining on the legality and constitutionality of SB 14. The document contains the advice, opinion, and recommendations of the author regarding the legality and constitutionality of SB 14. Jeff Boyd is an attorney recipient and author of emails in string. The document was created to assist the Governor in deciding whether to veto or sign SB 14. Ultimately, the document was used to advise the Governor on his decision on whether to veto or sign SB 14. The document was created prior to a final decision by the Governor on whether to sign or veto SB 14. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information. 1/28/2011
GOVERNOR PART 3
TX_00057756
TX_00057759
Allison Castle~Lucy Nashed~Mary Anne Wiley~Ka Jeff Boyd
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS
Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of giving or receiving legal advice regarding SB 14.~~This document is an email string among Governor Staff and Governor Counsel sent for the purpose of 9/14/2011
GOVERNOR PART 3
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 37 of 196
37
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 37 of 196
thy Walt~Josh Havens~Matthew thompson~Ken Armbrister~Konathan Hurst
PRIVILEGE
responding to media inquiries about SB 14. The document contains the advice, opinion, and recommendations of the author regarding the public policy positions that the Governor would adopt on SB 14. Jeff Boyd is an attorney recipient. The document was created to assist the Governor in deciding whether which public positions, if any, he would take on SB 14. Ultimately, the document was used to advise the Governor on his decision on policy positions relating to SB 14. The document was created prior to a final decision by the Governor on which public policy positions he should take as to SB 14. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00057760
TX_00057779
Jimmy Blacklock~Jay Dyer~Stacey Napier~Devid Schenck~Reed Clay~Jeff Boyd~Travis Richmond John Sepehri
DNP - ATTY CLIENT
Confidential e-mail from SOS General Counsel to OAG Attorneys and Governor's Office Attorneys sent for purpose of providing or seeking legal advice regarding SB 14 preclearance submission 7/21/2011
GOVERNOR PART 3
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 38 of 196
38
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 38 of 196
~Ann McGeehan~Elizabeth Winn
TX_00057780
TX_00057781 Jeff Boyd Ray Sullivan
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of giving or receiving legal advice regarding SB 14.~~This document is an email string among Governor Staff and Governor Counsel sent for the purpose of discussing preclearance of SB 14 and relating legal advice from the Office of the Attorney General. The document contains the advice, opinion, and recommendations of the author regarding the Governor's role, if any, in the preclearance of SB 14. Jeff Boyd is an attorney author and recipient of emails in the email string. The document was created to assist the Governor in deciding his post-enactment role in the preclearance of SB 14. Ultimately, the document was used to advise the Governor on his decision on his post-enactment role in the preclearance of SB 14. The document was created prior to a final decision by the Governor on what role he would play in the preclearance of SB 14. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without 7/14/2011
GOVERNOR PART 3
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 39 of 196
39
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 39 of 196
disclosing privileged information.
TX_00057782
TX_00057803
Jimmy Blacklock~Jeff Boyd~Travis Richmond~David Schenck~Jay Dyer John Sepehri
DNP - ATTY CLIENT
Confidential communication between SOS General Counsel, OAG Attorneys, and Governor's Office Attorneys sent for purposes of seeking or providing legal advice regarding SB 14 preclearance submission 7/20/2011
GOVERNOR PART 3
TX_00057804
TX_00057806
Daniel Hodge~Reed Clay Jeff Boyd
DNP - ATTY CLIENT
Confidential communication between Governor's Office Attorney and OAG Attorneys sent for purpose of providing or seeking legal advice regarding SB 14 preclearance 7/11/2011
GOVERNOR PART 3
TX_00057807
TX_00057999
Press Office~Jonathan Hurst~Jeff Boyd~Ken Armbrister~Mike Morrissey Steffany Duke
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 82nd Legislature.~~This document transmits a draft press release regarding bills from the 82nd legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. Jeff Boyd is an attorney recipient of the document. The document was created to assist the Governor in formulating a policy announcement on legislation from the 82nd legislature. Ultimately, the document was used to advise the Governor on his decision on which policy positions the Governor should take. The document is a draft and was created prior to a final decision by the 8/30/2011
GOVERNOR PART 3
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 40 of 196
40
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 40 of 196
Governoron a policy statement. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00058000
TX_00058000 Jeff Boyd
Travis Richmond
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Confidential communication from Governor's General Counsel attorneys sent for purposes of giving or receiving legal advice regarding SB 14.~~This document is an email string among Governor's Counsel attorneys opining on the legality and constitutionality of SB 14. The document contains the advice, opinion, and recommendations of the author regarding the legality and constitutionality of SB 14. Jeff Boyd is an attorney recipient and author of emails in string. The document was created to assist the Governor in deciding whether to veto or sign SB 14. Ultimately, the document was used to advise the Governor on his decision on whether to veto or sign SB 14. The document was created prior to a final decision by the Governor on whether to sign or veto SB 14. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The 1/27/2011
GOVERNOR PART 3
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 41 of 196
41
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 41 of 196
document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00058001
TX_00058036
Executive~Budget, Planning, and Policy Press Office
DNP - DELIBERATIVE PROCESS PRIVILEGE
This document transmits a draft State of the State" speech discussing numerous issues that were deemed important by the Governor's policy advisers, including Voter ID. The document contains the advice, opinion, and recommendations of the author regarding numerous pieces of legislation and various policy statements. Jeff Boyd is an attorney recipient of the document. The document was created to assist the Governor in formulating a policy announcement on legislation from the 82nd legislature. Ultimately, the document was used to advise the Governor on his decision on which policy positions the Governor should take. The document is a draft and was created prior to a final decision by the Governor on which policy statement he would publicly adopt. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information." 2/8/2011
GOVERNOR PART 3
TX_00058037
TX_00058038
General Counsel~Press Office~Ex Press Office
DNP - DELIBERATIVE PROCESS
This document is a draft press release explaining the Governor's policies behind signing SB 14. The document contains the advice, opinion, and 5/27/2011
GOVERNOR PART 3
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 42 of 196
42
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 42 of 196
ecutive PRIVILEGE
recommendations of the author regarding certain SB 14. The document was created to assist the Governor in formulating a policy announcement on legislation from the 82nd legislature. Ultimately, the document was used to advise the Governor on his decision on which policy positions the Governor should take. The document is a draft and was created prior to a final decision by the Governor on a policy statement. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00058039
TX_00058069
Budget, Planning, and Policy~Executive~General Counsel~Legislative
Governor's Legislative Division
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
This document was created to assist the Office of the Governor employee in providing analyses, opinions, and recommendations to Office of the Governor policy-making staff. The content of the document reveals analyses, opinions, and recommendations that were ultimately communicated to Office of the Governor policy-making staff. The analyses, opinions, and recommendations contain legal and policy advice. The document was created prior to an ultimate decision by the Governor on whether to sign or veto bills pending in the House. It cannot be redacted in a manner that would preclude the disclosure of privileged information. It 5/8/2007
GOVERNOR PART 3
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 43 of 196
43
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 43 of 196
also does not memorialize or evidence the Office of the Governor's final decision on the matters identified in the document. It was not shared with the public.
TX_00058070
TX_00058143
Budget, Planning, and Policy~Executive~General Counsel~Legislative
Michael Schofield
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice bills from the 81st Legislature.~~This document consists of bill summaries and bill tracking of bills from the 81st legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor taff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a 8/13/2008
GOVERNOR PART 3
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 44 of 196
44
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 44 of 196
redacted form without disclosing privileged information.
TX_00058144
TX_00058150
Budget, Planning, and Policy~Executive~General Counsel~Legislative
DNP - DELIBERATIVE PROCESS PRIVILEGE
This document was created to assist the Office of the Governor employee in providing analyses, opinions, and recommendations to Office of the Governor policy-making staff. The content of the document reveals analyses, opinions, and recommendations that were ultimately communicated to Office of the Governor policy-making staff. The document was created prior to an ultimate decision by the Governor on whether to sign or veto bills pending in the House. It cannot be redacted in a manner that would preclude the disclosure of privileged information. It also does not memorialize or evidence the Office of the Governor's final decision on the matters identified in the document. It was not shared with the public. 00/00/2009
GOVERNOR PART 3
TX_00058151
TX_00058234
Budget, Planning, and Policy~Executive~General Counsel~Legislative
Michael Schofield
DNP - DELIBERATIVE PROCESS PRIVILEGE
This document consists of bill summaries and bill tracking of bills from the 81st legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the 00/00/2009
GOVERNOR PART 3
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 45 of 196
45
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 45 of 196
document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00058235
TX_00058298
Budget, Planning, and Policy~Executive~General Counsel~Legislative
Michael Schofield
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice bills from the 82nd Legislature.~~This document consists of bill summaries and bill tracking of bills from the 82nd legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of 8/13/2008
GOVERNOR PART 3
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 46 of 196
46
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 46 of 196
the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00058299
TX_00058304
DNP - DELIBERATIVE PROCESS PRIVILEGE
This document was created to assist the Office of the Governor employee in providing analyses, opinions, and recommendations to Office of the Governor policy-making staff. The content of the document reveals analyses, opinions, and recommendations that were ultimately communicated to Office of the Governor policy-making staff. The document was created prior to an ultimate decision by the Governor on whether to sign or veto bills pending in the House. It cannot be redacted in a manner that would preclude the disclosure of privileged information. It also does not memorialize or evidence the Office of the Governor's final decision on the matters identified in the document. It was not shared with the public. 00/00/2011
GOVERNOR PART 3
TX_00058305
TX_00058308
Michael Schofield Legislative
DNP - DELIBERATIVE PROCESS PRIVILEGE
This document consists of bill summaries, bill tracking, and recommendations for bills from the 82nd legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of 00/00/2011
GOVERNOR PART 3
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 47 of 196
47
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 47 of 196
the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00058309
TX_00058310
DNP - DELIBERATIVE PROCESS PRIVILEGE
This document consists of a policy outline on the features that a Texas Voter ID bill should have if the legislature were to consider such a bill. The document contains the advice, opinion, and recommendations of the author regarding Voter ID. The document was created to assist the Governor and his staff in deciding whether to support or oppose Voter ID legislation. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created 00/00/2010
GOVERNOR PART 3
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 48 of 196
48
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 48 of 196
prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. This document reflects analyses, opinions, and recommendations that were ultimately communicated to Office of the Governor policy-making staff. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00058311
TX_00058330
DNP - DELIBERATIVE PROCESS PRIVILEGE
This document consists of bill summaries, bill tracking, and recommendations for bills from the 82nd legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied 00/00/2009
GOVERNOR PART 3
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 49 of 196
49
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 49 of 196
upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00058331
TX_00058332
Budget, Planning, and Policy~Executive~General Counsel~Legislative
Michael Schofield
DNP - DELIBERATIVE PROCESS PRIVILEGE
This document consists of bill analyses of a Voter ID bill. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation. Ultimately, the document was used to advise the Governor on his decision whether to support or oppose a bill. The document was created prior to a final decision by the Governor whether to support or oppose the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information. 00/00/2007
GOVERNOR PART 3
TX_00058334
TX_00058336
Ryan Brannan
Jonathan Hurst
DNP - DELIBERATIVE
Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of 3/22/2012
GOVERNOR PART 3
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 50 of 196
50
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 50 of 196
PROCESS PRIVILEGE;DNP - ATTY CLIENT;DNP - WORK PRODUCT
giving or receiving legal advice regarding SB 14.~~This document is an email string among Governor Staff and Governor Counsel sent for the purpose of responding to media inquiries about SB 14. The document contains the advice, opinion, and recommendations of the author regarding the public policy positions that the Governor would adopt on SB 14. Jeff Boyd is an attorney author and recipient of emails in this email string. The document was created to assist the Governor in deciding whether which public positions, if any, he would take on SB 14. Ultimately, the document was used to advise the Governor on his decision on policy positions relating to SB 14. The document was created prior to a final decision by the Governor on which public policy positions he should take as to SB 14. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00058337
TX_00058342
DNP - DELIBERATIVE PROCESS PRIVILEGE
This document is a copy of DOJ preclearance rejection letter sent to the Texas SOS with handwritten notes.~The document contains the advice, opinion, and recommendations of the author regarding the what the Governor's legal and policy positions should be on 3/12/2012
GOVERNOR PART 3
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 51 of 196
51
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 51 of 196
preclearance of SB 14. The document was created to assist the Governor in deciding what the Governor's legal and policy positions should be on preclearance of SB 14. Ultimately, the document was used to advise the Governor on his decision on what the Governor's legal and policy positions should be on preclearance of SB 14. The document was created prior to a final decision by the Governor on what role he would play in the preclearance of SB 14. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00058343
TX_00058343
Budget, Planning, and Policy~Executive~General Counsel Ryan Brannan
DNP - DELIBERATIVE PROCESS PRIVILEGE
This document contains handwritten notes on the preclearance of SB 14.~The document contains the advice, opinion, and recommendations of the author regarding the what the Governor's legal and policy positions should be on preclearance of SB 14. The document was created to assist the Governor in deciding what the Governor's legal and policy positions should be on preclearance of SB 14. Ultimately, the document was used to advise the Governor on his decision on what the Governor's legal and policy positions should be on preclearance of SB 14. The document was created prior to a final 00/00/2011
GOVERNOR PART 3
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 52 of 196
52
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 52 of 196
decision by the Governor on what role he would play in the preclearance of SB 14. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. It was stored in files available to internal Governor staff, but it document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00058344
TX_00058345 Executive
Ray Sullivan (Executive)
DNP - DELIBERATIVE PROCESS PRIVILEGE
This document is a draft constituent communication to a prominent business leader.~The document contains the advice, opinion, and recommendations of the author regarding the what the Governor's public stated policy positions should be on Voter ID. The document was created to assist the Governor in deciding public stated policy positions should be on Voter ID. Ultimately, the document was used to advise the Governor on his decision on public stated policy positions should be on Voter ID. The document was created prior to a final decision by the Governor on public stated policy positions should be on Voter ID. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. It was stored in files available to internal Governor staff, but it document was not 00/00/2011
GOVERNOR PART 3
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 53 of 196
53
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 53 of 196
shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00058346
TX_00058352
Communication Division.
Ashton Morgan (Communication Division)
DNP - DELIBERATIVE PROCESS PRIVILEGE
This document is a legislative communication plan prepared by the Governor's staff on a variety of topics.~The document contains the advice, opinion, and recommendations of the author regarding the what the Governor's public stated policy positions should be on a variety of policies. The document was created to assist the Governor in deciding public stated policy positions should be on a variety of policies. Ultimately, the document was used to advise the Governor on his decision on public stated policy positions should be on a variety of issues and other policies as well as whether he should sign or veto certain bills. The document was created prior to a final decision by the Governor on public stated policy positions on a variety of issues. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. It was stored in files available to internal Governor staff, but it document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
GOVERNOR PART 3
TX_00058353
TX_00058377
Budget, Planning,
Governor's Legislative
DNP - ATTY
Confidential communication from Governor's General Counsel to 4/6/2009
GOVERNOR PART
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 54 of 196
54
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 54 of 196
and Policy~General Counsel
Division CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 81st Legislature.~~This document consists of bill summaries, bill tracking, and recommendations for bills from the 81st legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
3
TX_00058378
TX_00058405
Budget, Planning, and
Governor's Legislative Division
DNP - DELIBERATIVE
Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of 4/7/2009
GOVERNOR PART 3
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 55 of 196
55
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 55 of 196
Policy~General Counsel
PROCESS PRIVILEGE
providing legal advice regarding engrossed bills from the 81st Legislature.~~This document consists of bill summaries, bill tracking, and recommendations for bills from the 81st legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00058406
TX_00058545
Executive~Budget, Planning, and
Governor's Legislative Division
DNP - ATTY CLIENT;DNP -
Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding 3/5/2009
GOVERNOR PART 3
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56
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Policy~General Counsel~Legislative Counsel
DELIBERATIVE PROCESS PRIVILEGE
engrossed bills from the 81st Legislature.~~This document consists of bill summaries, bill tracking, and recommendations for bills from the 81st legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00058546
TX_00058783
Executive~Budget, Planning, and Policy~Ge
Governor's Legislative Division
DNP - ATTY CLIENT;DNP - DELIBERA
Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 81st 4/6/2009
GOVERNOR PART 3
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57
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neral Counsel~Legislative Counsel
TIVE PROCESS PRIVILEGE
Legislature.~~This document consists of bill summaries, bill tracking, and recommendations for bills from the 81st legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00058784
TX_00058791
Governor's Communications/Scheduling Division.
Governor's Communications/Scheduling Division.
DNP - DELIBERATIVE PROCESS PRIVILEGE
This document contains a list of persons and organizations from whom the Governor solicited , or to whom the Governor provided, information regarding a variety of bills pending before the 82nd Legislature. It reflects
GOVERNOR PART 3
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the Office of the Governor's internal deliberations regarding which individuals and groups can contribute policy advice on a variety of issues, including Voter ID. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was made prior to a final decision on whether to sign or veto the legislation identified in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00058792
TX_00058811
Executive~Budget, Planning, and Policy~General Counsel~Legislative Counsel
Governor's Budget, Planning, and Policy Division
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 82nd Legislature.~~This document consists of bill summaries, bill tracking, and recommendations for bills from the 82nd legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the 02/00/2011
GOVERNOR PART 3
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59
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Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00058812
TX_00058829
Executive~Budget, Planning, and Policy~General Counsel~Legislative Counsel
Governor's Budget, Planning, and Policy Division
DNP - DELIBERATIVE PROCESS PRIVILEGE;DNP - ATTY CLIENT
Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 82nd Legislature.~~This document consists of bill summaries, bill tracking, and recommendations for bills from the 82nd legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding 1/24/2011
GOVERNOR PART 3
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60
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whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00058830
TX_00059449
Executive~Budget, Planning, and Policy~General Counsel~Legislative Counsel
Governor's Legislative Division
DNP - DELIBERATIVE PROCESS PRIVILEGE;DNP - ATTY CLIENT
Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 82nd Legislature.~~This document consists of bill summaries, bill tracking, and recommendations for bills from the 82nd legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the 2/18/2009
GOVERNOR PART 3
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61
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legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00059450
TX_00059703
Executive~Budget, Planning, and Policy~General Counsel~Legislative Counsel
Governor's Legislative Division
DNP - DELIBERATIVE PROCESS PRIVILEGE;DNP - ATTY CLIENT
Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 82nd Legislature.~~This document consists of bill summaries, bill tracking, and recommendations for bills from the 82nd legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. 00/00/2011
GOVERNOR PART 3
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Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00059714
TX_00059716
Legislative Division Jordan Root
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 82nd Legislature.~~This document consists of bill summaries, bill tracking, and recommendations for bills from the 82nd legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to 00/00/2011
GOVERNOR PART 3
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advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00059717
TX_00059956
Executive~Budget, Planning, and Policy~General Counsel~Legislative Counsel
Governor's Legislative Division
DNP - DELIBERATIVE PROCESS PRIVILEGE;DNP - ATTY CLIENT
Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 82nd Legislature.~~This document consists of bill summaries, bill tracking, and recommendations for bills from the 82nd legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision 00/00/2011
GOVERNOR PART 3
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64
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whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00059957
TX_00060257
Executive~Budget, Planning, and Policy~General Counsel~Legislative Counsel
Governor's Legislative Division
DNP - DELIBERATIVE PROCESS PRIVILEGE;DNP - ATTY CLIENT
Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 82nd Legislature.~~This document consists of bill summaries, bill tracking, and recommendations for bills from the 82nd legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The 00/00/2011
GOVERNOR PART 3
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document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00060258
TX_00060258
Kimberly Snyder~Kristy French~Ray Sullivan~Clint Harp~Ken Armbrister~David Eichler~Sarah Floerke Sarah Floerke
DNP - DELIBERATIVE PROCESS PRIVILEGE;DNP - ATTY CLIENT
Confidential e-mail between Governor's Office Attorneys and Staff sent for purposes of seeking or providing legal advice regarding Voter ID and numerous other items.~~This email consists of bill tracking and summaries regarding the procedural posture of pending bills from the 81st legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to 3/22/2011
GOVERNOR PART 3
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veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor taff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00060259
TX_00060559
Executive~Budget, Planning, and Policy~General Counsel~Legislative Counsel
Governor's Legislative Staff
DNP - DELIBERATIVE PROCESS PRIVILEGE;DNP - ATTY CLIENT
Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 82nd Legislature.~~This document consists of bill summaries, bill tracking, and recommendations for bills from the 82nd legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the 00/00/2011
GOVERNOR PART 3
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document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00060560
TX_00060560 Executive
Executive~Budget, Planning, and Policy Division
DNP - DELIBERATIVE PROCESS PRIVILEGE
This document consists of bill tracking and summaries regarding the procedural posture of pending bills from the 81st legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff.
GOVERNOR PART 3
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The document was reviewed and relied upon by Office of the Governor taff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00060561
TX_00060561
DNP - DELIBERATIVE PROCESS PRIVILEGE
This document was created to assist the Office of the Governor employee in providing analyses, opinions, and recommendations to Office of the Governor policy-making staff. The content of the document reveals analyses, opinions, and recommendations that were ultimately communicated to Office of the Governor policy-making staff. The document was created prior to an ultimate decision by the Governor on whether to sign or veto bills pending in the House. It cannot be redacted in a manner that would preclude the disclosure of privileged information. It also does not memorialize or evidence the Office of the Governor's final decision on the matters identified in the document. It was not shared with the public.
GOVERNOR PART 3
TX_00060562
TX_00060563
Governor's Staff
Governor's Budget, Planning, and Policy Division
DNP - DELIBERATIVE PROCESS PRIVILEGE
This document consists of a list of Governor policy priorities. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation affecting the policy priorities identified. Ultimately, the document was used to advise the Governor on his decision whether to veto
GOVERNOR PART 3
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or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor taff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00060564
TX_00060565
Governor's Budget, Planning, and Policy Division Greg Stein
DNP - DELIBERATIVE PROCESS PRIVILEGE
This document consists of a list of Governor policy priorities. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation affecting the policy priorities identified. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor taff as part of the Office of the Governor's decision-making process. The document 2/3/2009
GOVERNOR PART 3
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was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00060566
TX_00060566
Executive~Budget, Planning, and Policy~General Counsel~Legislative Counsel
Governor's Budget, Planning, and Policy Division
DNP - DELIBERATIVE PROCESS PRIVILEGE
This document consists of bill analyses for HB 2194. The document contains a summary of the bill as well as advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
GOVERNOR PART 3
TX_00060567
TX_00060569
Executive~Budget, Planning, and Policy~General
Governor's Budget, Planning, and Policy Division
DNP - DELIBERATIVE PROCESS PRIVILEGE
This document consists of bill analyses for HB 16. The document contains a summary of the bill as well as advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the 12/21/2010
GOVERNOR PART 3
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Counsel~Legislative Counsel
Governor and his staff in deciding whether to support or oppose the legislation. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00060570
TX_00060571
Executive~Budget, Planning, and Policy~General Counsel~Legislative Counsel
Governor's Budget, Planning, and Policy Division
DNP - DELIBERATIVE PROCESS PRIVILEGE
This document consists of bill analyses for HB 101. The document contains a summary of the bill as well as advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of
GOVERNOR PART 3
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the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00060572
TX_00060573
Executive~Budget, Planning, and Policy~General Counsel~Legislative Counsel
Governor's Budget, Planning, and Policy Division
DNP - DELIBERATIVE PROCESS PRIVILEGE
This document consists of bill analyses for HB 112. The document contains a summary of the bill as well as advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a 12/21/2010
GOVERNOR PART 3
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redacted form without disclosing privileged information.
TX_00060574
TX_00060577
Executive~Budget, Planning, and Policy~General Counsel~Legislative Counsel
Governor's Budget, Planning, and Policy Division
DNP - DELIBERATIVE PROCESS PRIVILEGE
This document consists of bill analyses for HB 125. The document contains a summary of the bill as well as advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
GOVERNOR PART 3
TX_00060578
TX_00060579
Executive~Budget, Planning, and Policy~General Counsel~Legislativ
Governor's Budget, Planning, and Policy Division
DNP - DELIBERATIVE PROCESS PRIVILEGE
This document consists of bill analyses for HB 186. The document contains a summary of the bill as well as advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the 12/21/2010
GOVERNOR PART 3
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e Counsel legislation. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00060580
TX_00060582
Executive~Budget, Planning, and Policy~General Counsel~Legislative Counsel
Governor's Budget, Planning, and Policy Division
DNP - DELIBERATIVE PROCESS PRIVILEGE
This document consists of bill analyses for HB 218. The document contains a summary of the bill as well as advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared 2/22/2007
GOVERNOR PART 3
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75
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internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00060583
TX_00060583
DNP - DELIBERATIVE PROCESS PRIVILEGE
This document was created to assist the Office of the Governor employee in providing analyses, opinions, and recommendations to Office of the Governor policy-making staff. The content of the document reveals analyses, opinions, and recommendations that were ultimately communicated to Office of the Governor policy-making staff. The document was created prior to an ultimate decision by the Governor on whether to sign or veto bills pending in the House. It cannot be redacted in a manner that would preclude the disclosure of privileged information. It also does not memorialize or evidence the Office of the Governor's final decision on the matters identified in the document. It was not shared with the public.
GOVERNOR PART 3
TX_00060584
TX_00060585
Executive~Budget, Planning, and Policy~General Counsel~Legislative Counsel
Governor's Budget, Planning, and Policy Division
DNP - DELIBERATIVE PROCESS PRIVILEGE
This document consists of bill analyses for HB 373. The document contains a summary of the bill as well as advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation. Ultimately, the document
GOVERNOR PART 3
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76
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was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00060586
TX_00060587
Executive~Budget, Planning, and Policy~General Counsel~Legislative Counsel
Governor's Budget, Planning, and Policy Division
DNP - DELIBERATIVE PROCESS PRIVILEGE
This document consists of bill analyses for HB 401. The document contains a summary of the bill as well as advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive 12/21/2010
GOVERNOR PART 3
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77
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and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00060588
TX_00060589
Executive~Budget, Planning, and Policy~General Counsel~Legislative Counsel
Governor's Budget, Planning, and Policy Division
DNP - DELIBERATIVE PROCESS PRIVILEGE
This document consists of bill analyses for HB 539. The document contains a summary of the bill as well as advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information. 1/7/2011
GOVERNOR PART 3
TX_00060 TX_00060 Executive Governor's DNP - This document consists of bill analyses 3/7/2005 GOVERN
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78
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 78 of 196
590 591 ~Budget, Planning, and Policy~General Counsel~Legislative Counsel
Budget, Planning, and Policy Division
DELIBERATIVE PROCESS PRIVILEGE
for a 2005 Voter ID bill. The document contains a summary of the bill as well as advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
OR PART 3
TX_00060592
TX_00060593
Executive~Budget, Planning, and Policy~General Counsel~Legislative Counsel
Governor's Budget, Planning, and Policy Division
DNP - DELIBERATIVE PROCESS PRIVILEGE
This document consists of bill analyses for a HB 1726 bill. The document contains a summary of the bill as well as advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill.
GOVERNOR PART 3
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79
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The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00060594
TX_00060595
Executive~Budget, Planning, and Policy~General Counsel~Legislative Counsel
Governor's Budget, Planning, and Policy Division
DNP - DELIBERATIVE PROCESS PRIVILEGE
This document consists of bill analyses for a HB 1882 bill. The document contains a summary of the bill as well as advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied
GOVERNOR PART 3
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80
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upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00060596
TX_00060598
Executive~Budget, Planning, and Policy~General Counsel~Legislative Counsel
Governor's Budget, Planning, and Policy Division
DNP - DELIBERATIVE PROCESS PRIVILEGE
This document consists of bill analyses for HB 2194. The document contains a summary of the bill as well as advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information. 4/17/2011
GOVERNOR PART 3
TX_00060599
TX_00060600
Executive~Budget, Planning,
Governor's Budget, Planning, and
DNP - DELIBERATIVE
This document consists of bill analyses for HB 3556. The document contains a summary of the bill as well as advice,
GOVERNOR PART 3
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 81 of 196
81
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 81 of 196
and Policy~General Counsel~Legislative Counsel
Policy Division PROCESS PRIVILEGE
opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00060601
TX_00060602
Executive~Budget, Planning, and Policy~General Counsel~Legislative Counsel
Governor's Budget, Planning, and Policy Division
DNP - DELIBERATIVE PROCESS PRIVILEGE
This document consists of bill analyses for HB 3901 The document contains a summary of the bill as well as advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to
GOVERNOR PART 3
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veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00060603
TX_00060604
Executive~Budget, Planning, and Policy~General Counsel~Legislative Counsel
Governor's Budget, Planning, and Policy Division
DNP - DELIBERATIVE PROCESS PRIVILEGE
This document consists of bill analyses for HB 3902 The document contains a summary of the bill as well as advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's
GOVERNOR PART 3
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83
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decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00060605
TX_00060606
Executive~Budget, Planning, and Policy~General Counsel~Legislative Counsel
Governor's Budget, Planning, and Policy Division
DNP - DELIBERATIVE PROCESS PRIVILEGE
This document consists of bill analyses for HB 3948 The document contains a summary of the bill as well as advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
GOVERNOR PART 3
TX_00060607
TX_00060608
Executive~Budget, Planning, and Policy~Ge
Governor's Budget, Planning, and Policy Division
DNP - DELIBERATIVE PROCESS PRIVILEG
This document consists of bill analyses for HB 1351 The document contains a summary of the bill as well as advice, opinion, and recommendations of the author regarding certain legislation. The
GOVERNOR PART 3
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84
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neral Counsel~Legislative Counsel
E document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00060609
TX_00060609 Executive
Ray Sullivan (Executive)
DNP - DELIBERATIVE PROCESS PRIVILEGE
This document is a draft constituent communication to a prominent business leader.~The document contains the advice, opinion, and recommendations of the author regarding the what the Governor's public stated policy positions should be on Voter ID. The document was created to assist the Governor in deciding public stated policy positions should be on Voter ID. Ultimately, the document was used to advise the Governor on his decision on public stated policy positions should be on Voter ID. The document was created prior to a final decision by the Governor on public
GOVERNOR PART 3
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85
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stated policy positions should be on Voter ID. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00060618
TX_00060640
Governor's Staff
Governor's Budget, Planning, and Policy Division
GOV - Deliberative Process Privilege
Confidential communications between Governor Staff containing advice, opinions, and deliberations that precede a final decision relating to voter ID and other policies.
GOVERNOR PART 3
TX_00060641
TX_00060686
Executive~Budget, Planning, and Policy~General Counsel~Legislative Counsel
Governor's Legislative Division
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 80th Legislature.~~This document consists of bill summaries, bill tracking, and recommendations for bills from the 80th legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision
GOVERNOR PART 3
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86
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whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00060687
TX_00060706
Executive~Budget, Planning, and Policy~General Counsel~Legislative Counsel
Governor's Legislative Division
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 80th Legislature.~~This document consists of bill summaries, bill tracking, and recommendations for bills from the 80th legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The
GOVERNOR PART 3
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87
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document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00060707
TX_00060814
Executive~Budget, Planning, and Policy~General Counsel~Legislative Counsel
Governor's Legislative Division
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 80th Legislature.~~This document consists of bill summaries, bill tracking, and recommendations for bills from the 80th legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final
GOVERNOR PART 3
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88
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decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00060815
TX_00060932
Executive~Budget, Planning, and Policy~General Counsel~Legislative Counsel
Governor's Legislative Division
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 80th Legislature.~~This document consists of bill summaries, bill tracking, and recommendations for bills from the 80th legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto
GOVERNOR PART 3
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89
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or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00060933
TX_00061396
Executive~Budget, Planning, and Policy~General Counsel~Legislative Counsel
Governor's Legislative Division
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 81st Legislature.~~This document consists of bill summaries, bill tracking, and recommendations for bills from the 81st legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the
GOVERNOR PART 3
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90
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document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00061397
TX_00062024
Executive~Budget, Planning, and Policy~General Counsel~Legislative Counsel
Governor's Legislative Division
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 81st Legislature.~~This document consists of bill summaries, bill tracking, and recommendations for bills from the 81st legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does
GOVERNOR PART 3
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91
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 91 of 196
not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00062025
TX_00062984
Executive~Budget, Planning, and Policy~General Counsel~Legislative Counsel
Governor's Legislative Division
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 81st Legislature.~~This document consists of bill summaries, bill tracking, and recommendations for bills from the 81st legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of
GOVERNOR PART 3
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92
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the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00062985
TX_00064428
Executive~Budget, Planning, and Policy~General Counsel~Legislative Counsel
Governor's Legislative Division
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 81st Legislature.~~This document consists of bill summaries, bill tracking, and recommendations for bills from the 81st legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The
GOVERNOR PART 3
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93
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document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00064429
TX_00065892
Executive~Budget, Planning, and Policy~General Counsel~Legislative Counsel
Governor's Legislative Division
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 81st Legislature.~~This document consists of bill summaries, bill tracking, and recommendations for bills from the 81st legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared
GOVERNOR PART 3
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94
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internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00065893
TX_00067976
Executive~Budget, Planning, and Policy~General Counsel~Legislative Counsel
Governor's Legislative Division
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 81st Legislature.~~This document consists of bill summaries, bill tracking, and recommendations for bills from the 81st legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive
GOVERNOR PART 3
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95
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and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00067977
TX_00069906
Executive~Budget, Planning, and Policy~General Counsel~Legislative Counsel
Governor's Legislative Division
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 81st Legislature.~~This document consists of bill summaries, bill tracking, and recommendations for bills from the 81st legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff.
GOVERNOR PART 3
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96
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The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00069907
TX_00071582
Executive~Budget, Planning, and Policy~General Counsel~Legislative Counsel
Governor's Legislative Division
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 81st Legislature.~~This document consists of bill summaries, bill tracking, and recommendations for bills from the 81st legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied
GOVERNOR PART 3
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97
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upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00071583
TX_00073582
Executive~Budget, Planning, and Policy~General Counsel~Legislative Counsel
Governor's Legislative Division
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 81st Legislature.~~This document consists of bill summaries, bill tracking, and recommendations for bills from the 81st legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as
GOVERNOR PART 3
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98
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part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00073583
TX_00073584
Mark Miner,~Ken Armbrister,~Steve McGraw,~Mary Katherine, Stout~Jim Harrison,~Kyle Mitchell, Brandy Marty,~David Eichler,~Allison Castle, RuthAnn Nicholson
Amanda Arriaga
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
This document consists a list of studies that the Governor's policy advisers deemed important on the policy issues of immigration/border issues. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation affecting the policy priorities identified. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor taff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
GOVERNOR PART 3
TX_00073 TX_00073 Executive Governor's DNP - Confidential communication from GOVERN
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99
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 99 of 196
585 604 ~Budget, Planning, and Policy~General Counsel~Legislative Counsel
Legislative Division
ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 81st Legislature.~~This document consists of bill summaries, bill tracking, and recommendations for bills from the 81st legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
OR PART 3
TX_00073605
TX_00073613
Executive~Budget,
Governor's Legislative
DNP - DELIBERA
This document consists of a list of Governor legislative priorities for the 5/24/2011
GOVERNOR PART
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100
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Planning, and Policy~General Counsel~Legislative Counsel
Division TIVE PROCESS PRIVILEGE
82nd Legislature and the procedural posture of bills addressing these priorities. The document was prepared by the Governor's staff. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation affecting the policy priorities identified. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor taff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
3
TX_00073614
TX_00073627
Executive~Budget, Planning, and Policy~General Counsel~Legislativ
Governor's Legislative Division
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEG
Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 81st Legislature.~~This document consists of bill summaries, bill tracking, and recommendations for bills from the 81st
GOVERNOR PART 3
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101
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e E legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00073628
TX_00073633
Executive~Budget, Planning, and Policy~General Counsel~Legislative
Governor's Budget, Planning, and Policy Division
DNP - DELIBERATIVE PROCESS PRIVILEGE
This document consists of a list of Governor policy priorities on border security entitled Priority Issues: Texas Border Security Plan." The document contains the advice, opinion, and recommendations of the author regarding legislation addressing the border security priorities identified in the document. The document was created to assist the
GOVERNOR PART 3
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102
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Governor and his staff in deciding whether to support or oppose the legislation affecting the policy priorities identified. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor taff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information."
TX_00073634
TX_00073707
Executive~Budget, Planning, and Policy
Governor's Budget, Planning, and Policy Division & Communications Division
DNP - DELIBERATIVE PROCESS PRIVILEGE
This document consists of a list of Governor policy priorities on economic development entitled Economic Development and Job Creation" The document contains the advice, opinion, and recommendations of the author regarding legislation addressing economic development. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation affecting the policy priorities identified. Ultimately, the document was used to advise the Governor on which publicly stated policy positions he would take on economic
GOVERNOR PART 3
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103
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development issues. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor taff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information."
TX_00073708
TX_00073708
DNP - DELIBERATIVE PROCESS PRIVILEGE
This email consists of a discussion on the public policy positions that the Governor should take on DOJ's denial of administrative preclearance of SB 14. The document contains the advice, opinion, and recommendations of the author regarding legislation addressing economic development. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation affecting the policy priorities identified. Ultimately, the document was used to advise the Governor on which publicly stated policy positions he would take on economic development issues. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's 3/12/2012
GOVERNOR PART 3
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final policy. The document was reviewed and relied upon by Office of the Governor taff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00073709
TX_00073709
Executive~Budget, Planning, and Policy~General Counsel~Legislative
Governor's Budget, Planning, and Policy Division
DNP - DELIBERATIVE PROCESS PRIVILEGE
This document consists of an in-depth analysis of SB 14. The document contains the advice, opinion, and recommendations of the author regarding legislation addressing economic development. The document was created to assist the Governor and his staff in deciding whether to support or oppose SB14. Ultimately, the document was used to advise the Governor on whether to sign or veto SB 14. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor taff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
GOVERNOR PART 3
TX_00073710
TX_00073712
Executive~Budget, Planning,
Governor's Budget, Planning, and
DNP - DELIBERATIVE
This document consists of bill analyses for a Voter ID Bill. The document contains a summary of the bill as well as 1/14/2011
GOVERNOR PART 3
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 105 of 196
105
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 105 of 196
and Policy~General Counsel~Legislative
Policy Division PROCESS PRIVILEGE
advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00073716
TX_00073717
Executive~Budget, Planning, and Policy~General Counsel~Legislative
Governor's Budget, Planning, and Policy Division
DNP - DELIBERATIVE PROCESS PRIVILEGE
This document consists of bill analyses for SB 14. The document contains a summary of the bill as well as advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to 1/14/2011
GOVERNOR PART 3
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106
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veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00073718
TX_00073722
Executive~Budget, Planning, and Policy~General Counsel~Legislative
Governor's Budget, Planning, and Policy Division
DNP - DELIBERATIVE PROCESS PRIVILEGE
This document consists of amendment analyses and tracking as well as recommendations for SB 14. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied 3/21/2011
GOVERNOR PART 3
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107
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upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00073742
TX_00073744
Executive~Budget, Planning, and Policy~General Counsel~Legislative
Governor's Budget, Planning, and Policy Division
DNP - DELIBERATIVE PROCESS PRIVILEGE
This document consists of bill analyses for SB 178 The document contains a summary of the bill as well as advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
GOVERNOR PART 3
TX_00073764
TX_00073766
Executive~Budget, Planning,
Governor's Budget, Planning, and
DNP - DELIBERATIVE
This document consists of bill analyses for a voter ID bill. The document contains a summary of the bill as well as
GOVERNOR PART 3
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 108 of 196
108
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 108 of 196
and Policy~General Counsel~Legislative
Policy Division PROCESS PRIVILEGE
advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00073767
TX_00073769
Executive~Budget, Planning, and Policy~General Counsel~Legislative
Governor's Budget, Planning, and Policy Division
DNP - DELIBERATIVE PROCESS PRIVILEGE
This document consists of bill analyses for a voter ID bill. The document contains a summary of the bill as well as advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to
GOVERNOR PART 3
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veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00073770
TX_00073773
Executive~Budget, Planning, and Policy~General Counsel~Legislative
Governor's Budget, Planning, and Policy Division
DNP - DELIBERATIVE PROCESS PRIVILEGE
This document consists of bill analyses for a voter ID bill. The document contains a summary of the bill as well as advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's
GOVERNOR PART 3
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110
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decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00073774
TX_00073775
DNP - DELIBERATIVE PROCESS PRIVILEGE
This document was created to assist the Office of the Governor employee in providing analyses, opinions, and recommendations to Office of the Governor policy-making staff. The content of the document reveals analyses, opinions, and recommendations that were ultimately communicated to Office of the Governor policy-making staff. The document was created prior to an ultimate decision by the Governor on whether to sign or veto bills pending in the House. It cannot be redacted in a manner that would preclude the disclosure of privileged information. It also does not memorialize or evidence the Office of the Governor's final decision on the matters identified in the document. It was not shared with the public.
GOVERNOR PART 3
TX_00073776
TX_00073777
DNP - DELIBERATIVE PROCESS PRIVILEGE
This document consists of a bill comparison for two voter ID bills--SB 362 and HB125. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's
GOVERNOR PART 3
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111
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final policy. The content of this document was ultimately communicated to the Governor's policy-making staff. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00073796
TX_00073799
Executive~Budget, Planning, and Policy~General Counsel~Legislative
Governor's Budget, Planning, and Policy Division
DNP - DELIBERATIVE PROCESS PRIVILEGE
This document consists of bill analyses for SB 1647. The document contains a summary of the bill as well as advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing
GOVERNOR PART 3
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112
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privileged information.
TX_00073800
TX_00073860
Executive~Budget, Planning, and Policy~General Counsel~Legislative
Governor's Legislative Division
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 80th Legislature.~~This document consists of bill summaries, bill tracking, and recommendations for bills from the 80th legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
GOVERNOR PART 3
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113
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TX_00073861
TX_00073866
Executive~Budget, Planning, and Policy~General Counsel~Legislative
Governor's Legislative Division
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 80th Legislature.~~This document consists of bill summaries, bill tracking, and recommendations for bills from the 80th legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
GOVERNOR PART 3
TX_00073 TX_00073 Executive Governor's DNP - Confidential communication from GOVERN
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867 878 ~Budget, Planning, and Policy~General Counsel~Legislative
Legislative Division
ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 80th Legislature.~~This document consists of bill summaries, bill tracking, and recommendations for bills from the 80th legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
OR PART 3
TX_00073879
TX_00074003
Executive~Budget,
Governor's Legislative
DNP - ATTY
Confidential communication from Governor's General Counsel to
GOVERNOR PART
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Planning, and Policy~General Counsel~Legislative
Division CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 80th Legislature.~~This document consists of bill summaries, bill tracking, and recommendations for bills from the 80th legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
3
TX_00074010
TX_00074011
Michael Schofield
Budget, Planning, and Policy
DNP - DELIBERATIVE
This document consists of document describing how SB 14 will work. The document contains advice, opinion, and
GOVERNOR PART 3
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PROCESS PRIVILEGE
recommendations of the author regarding SB 14. The document was created to assist the Governor and his staff in deciding the public policy position that the Governor would take on SB 14. Ultimately, the document was used to advise the Governor on his decision the public policy position his office would take on SB 14. The document was created prior to a final decision by the Governor on the public policy grounds supporting SB 14. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00074012
TX_00074012
Press Office,~Brandy Marty,~Jeff Boyd
Catherine Frazier
DNP - DELIBERATIVE PROCESS PRIVILEGE
This email consists of a discussion on the public policy positions that the Governor should take on DOJ's denial of administrative preclearance of SB 14. The document contains the advice, opinion, and recommendations of the author regarding legislation addressing potential responses to the decision to deny preclearance of SB 14. The document was created to assist the Governor and his staff in deciding the proper policy response to denial of preclearance. Ultimately, the document 3/12/2012
GOVERNOR PART 3
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was used to advise the Governor on which publicly stated policy positions he would take on the denial of preclearance. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00074031
TX_00074046
GCPD (Governor's Committee on People with Disabilities) Mail Drop
GCPD Mail Drop
DNP - DELIBERATIVE PROCESS PRIVILEGE
This document consists of bill summaries, bill tracking, and recommendations for bills from the 82nd legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied 1/21/2011
GOVERNOR PART 3
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upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00074047
TX_00074071
GCPD Mail Drop
Angela English
DNP - DELIBERATIVE PROCESS PRIVILEGE
This document consists of bill summaries, bill tracking, and recommendations for bills from the 82nd legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing 1/28/2011
GOVERNOR PART 3
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privileged information.
TX_00074072
TX_00074113
GCPD Mail Drop
Angela English
DNP - DELIBERATIVE PROCESS PRIVILEGE
This document consists of bill summaries, bill tracking, and recommendations for bills from the 82nd legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information. 2/25/2011
GOVERNOR PART 3
TX_00074114
TX_00074136
GCPD Mail Drop
GCPD Mail Drop
DNP - DELIBERATIVE PROCESS PRIVILEG
This document consists of bill summaries, bill tracking, and recommendations for bills from the 82nd legislative session that were deemed important by the Governor's policy 2/18/2011
GOVERNOR PART 3
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E advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00074137
TX_00074149
Tammy Tatom
GCPD Mail Drop
DNP - DELIBERATIVE PROCESS PRIVILEGE
This document consists of bill summaries, bill tracking, and recommendations for bills from the 82nd legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the 6/20/2011
GOVERNOR PART 3
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legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00074150
TX_00074175
Tammy Tatom
GCPD Mail Drop
DNP - DELIBERATIVE PROCESS PRIVILEGE
This document consists of bill summaries, bill tracking, and recommendations for bills from the 82nd legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto 5/27/2011
GOVERNOR PART 3
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or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00074176
TX_00074225
GCPD Mail Drop
GCPD Mail Drop
DNP - DELIBERATIVE PROCESS PRIVILEGE
This document consists of bill summaries, bill tracking, and recommendations for bills from the 82nd legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive 5/20/2011
GOVERNOR PART 3
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and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00074226
TX_00074227
Executive~Communications Division
Communications Division
DNP - DELIBERATIVE PROCESS PRIVILEGE
This document is a draft press release explaining the Governor's policies behind signing SB 14. The document contains the advice, opinion, and recommendations of the author regarding certain SB 14. The document was created to assist the Governor in formulating a policy announcement on legislation from the 82nd legislature. Ultimately, the document was used to advise the Governor on his decision on which policy positions the Governor should take. The document is a draft and was created prior to a final decision by the Governor on a policy statement. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information. 5/27/2011
GOVERNOR PART 3
TX_00074 TX_00074 GCPD GCPD DNP - This document is a draft press release 11/28/2011 GOVERN
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228 234 DELIBERATIVE PROCESS PRIVILEGE
explaining the Governor's policies relating to disabled Texans. The document contains the advice, opinion, and recommendations of the author regarding the Governor's policy priorities for disabled Texans. The document was created to assist the Governor in formulating a policy announcement on legislation from the 82nd legislature. Ultimately, the document was used to advise the Governor on his decision on which policy positions the Governor should take. The document is a draft and was created prior to a final decision by the Governor on a policy statement. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
OR PART 3
TX_00074235
TX_00074235
Communications Division Josh Havens
DNP - DELIBERATIVE PROCESS PRIVILEGE
This email consists of a discussion on the public policy positions that the Governor should take on the administrative preclearance of SB 14. The document contains the advice, opinion, and recommendations of the author regarding legislation addressing potential responses to administrative preclearance of SB 14. The document was created to assist the Governor and his staff in 9/22/2011
GOVERNOR PART 3
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deciding the proper policy seeking administrative preclearance. Ultimately, the document was used to advise the Governor on which publicly stated policy positions he would take on administrative preclearance. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00074236
TX_00074236
DNP - DELIBERATIVE PROCESS PRIVILEGE
This document is a draft constituent communication to a prominent business leader.~The document contains the advice, opinion, and recommendations of the author regarding the what the Governor's public stated policy positions should be on Voter ID. The document was created to assist the Governor in deciding public stated policy positions should be on Voter ID. Ultimately, the document was used to advise the Governor on his decision on public stated policy positions should be on Voter ID. The document was created prior to a final decision by the Governor on public stated policy positions should be on Voter ID. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office. The document was reviewed and relied 3/21/2011
GOVERNOR PART 3
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upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00074237
TX_00074237
Matthew Thompson~Allison Castle~Josh Havens Lucy Nashed
DNP - DELIBERATIVE PROCESS PRIVILEGE
This email consists of a discussion on the public policy positions that the Governor should take on the administrative preclearance of SB 14. The document contains the advice, opinion, and recommendations of the author regarding the administrative preclearance of SB 14.. The document was created to assist the Governor and his staff in deciding the proper policy seeking administrative preclearance. Ultimately, the document was used to advise the Governor on which publicly stated policy positions he would take on administrative preclearance. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information. 9/14/2011
GOVERNOR PART 3
TX_00074238
TX_00074238
Allison Castle~Lucy Nashed~Josh Havens
Matthew Thompson
DNP - DELIBERATIVE PROCESS PRIVILEGE
This email consists of a discussion on the public policy positions that the Governor should take on the administrative preclearance of SB 14. The document contains the advice, opinion, and recommendations of the author regarding 9/14/2011
GOVERNOR PART 3
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the administrative preclearance of SB 14.. The document was created to assist the Governor and his staff in deciding the proper policy seeking administrative preclearance. Ultimately, the document was used to advise the Governor on which publicly stated policy positions he would take on administrative preclearance. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00074239
TX_00074242
Jeff Boyd,~Press Office
Kalese Hammonds
DNP - DELIBERATIVE PROCESS PRIVILEGE
This is a draft press release on school finance lawsuits. The document contains the advice, opinion, and recommendations of the author regarding school finance lawsuits. The document was created to assist the Governor and his staff in deciding the proper policy on school finance lawsuits. Ultimately, the document was used to advise the Governor on which publicly stated policy positions he would take on school finance lawsuits. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be
GOVERNOR PART 3
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produced in a redacted form without disclosing privileged information.
TX_00074243
TX_00074705
Budget, Planning, and Policy Division,~General Counsel
Legislative~Division
DNP - DELIBERATIVE PROCESS PRIVILEGE
This document consists of bill summaries, bill tracking, and recommendations for bills from the 80th legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information. 5/5/2009
GOVERNOR PART 3"|"|"|"|"|"|463"
TX_00074706
TX_00075089
Budget, Planning, and Policy
Legislative~Division
DNP - DELIBERATIVE PROCESS
This document consists of bill summaries, bill tracking, and recommendations for bills from the 80th legislative session that were deemed
GOVERNOR PART 3"|"|"|"|"|"|384"
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Division,~General Counsel
PRIVILEGE
important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00075090
TX_00075153
Julie Johnson Pat Pound
DNP - DELIBERATIVE PROCESS PRIVILEGE
This document consists of bill summaries, bill tracking, and recommendations for bills from the 80th legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding
GOVERNOR PART 3"|"|"|"|"|"|64"
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whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00089058
TX_00089059 Jeff Boyd Ray Sullivan
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
This email discusses a new SEC investment adviser rule and the preclearance obligations related to eliminating elected offices. The document contains the advice, opinion, and recommendations of the author regarding the new SEC rule and the elimination of elected offices. The document was created to assist the Governor and his staff in deciding whether to support or oppose legislation relating to the elimination of elected offices. The emails also discuss the effect of the SEC rule on the appointee process. Ultimately, the document was used to advise the Governor on his decision on 3/24/2011
OOG STAFF ELECTRONIC RECORDS
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legislation and the appointee process. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document and how to proceed on appointing political appointees. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.~~The email also forwards legal advice from the office of the attorney general sent for the purpose of giving or receiving legal advice on preclearance obligations relating to the the elimination of elected offices. Jeff Boyd is also an attorney-recipient of the document.
TX_00089060
TX_00089061
David Zimmerman Jeff Boyd
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
This email discusses a new SEC investment adviser rule and the preclearance obligations related to eliminating elected offices. The document contains the advice, opinion, and recommendations of the author regarding the new SEC rule and the elimination of elected offices. The document was created to assist the Governor and his staff in deciding whether to support or oppose legislation relating to the elimination of elected offices. The emails also discuss the effect of the SEC rule on the appointee process. Ultimately, the document was used to 3/24/2011
OOG STAFF ELECTRONIC RECORDS
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advise the Governor on his decision on legislation and the appointee process. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.~~The email also forwards legal advice from the office of the attorney general sent for the purpose of giving or receiving legal advice on preclearance obligations relating to the the elimination of elected offices. Jeff Boyd is also an attorney-author of the document.
TX_00089062
TX_00089063
Ray Sullivan Jeff Boyd
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
This email discusses a new SEC investment adviser rule and the preclearance obligations related to eliminating elected offices. The document contains the advice, opinion, and recommendations of the author regarding the new SEC rule and the elimination of elected offices. The document was created to assist the Governor and his staff in deciding whether to support or oppose legislation relating to the elimination of elected offices. The emails also discuss the effect of the SEC rule on the appointee process. Ultimately, the document was used to 3/24/2011
OOG STAFF ELECTRONIC RECORDS
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advise the Governor on his decision on legislation and the appointee process. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.~~The email also forwards legal advice from the office of the attorney general sent for the purpose of giving or receiving legal advice on preclearance obligations relating to the the elimination of elected offices. Jeff Boyd is also an attorney-author of the document.
TX_00089064
TX_00089066
Collin Parish~Brandy Marty Jeff Boyd
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
This email discusses a request for information relating to SB 14 from Representative Anchia's office to an executive agency that reports to the Governor--TxDOT. The document contains the advice, opinion, and recommendations of the author regarding potential responses to Representative Anchia's request. The document was created to assist the Governor and his staff in deciding how to respond to Representative Anchia's request. Ultimately, the document was used to advise the Governor's Office on the proper response to Representative 3/29/2011
OOG STAFF ELECTRONIC RECORDS
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134
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 134 of 196
Anchia's request. The document was created prior to a final decision by the Governor on how to respond. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.~~The email also contains legal advice from Governor's General Counsel attorneys to the Governor's staff sent for the purpose of giving or receiving legal advice on SB 14 and DPS statistics relating to the bill.
TX_00089067
TX_00089067
Jeff Boyd~Brandy Marty Colin Parrish
DNP - DELIBERATIVE PROCESS PRIVILEGE
This email transmits information collected from DPS and relating to SB 14. The document reflects the information that the Governor's office considered pertinent in its review of SB 14. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. 3/30/2011
OOG STAFF ELECTRONIC RECORDS
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 135 of 196
135
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 135 of 196
The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00089068
TX_00089068
Amadeo Saenz James Bass
DNP - DELIBERATIVE PROCESS PRIVILEGE
This email transmits information collected from DPS and relating to SB 14. The document reflects the information that the Governor's office considered pertinent in its review of SB 14. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information. 3/29/2011
OOG STAFF ELECTRONIC RECORDS
TX_00089069
TX_00089069
Amadeo Saenz James Bass
DNP - DELIBERA
Charts attached to document TX_00089068 and privileged for the same 3/29/2011
OOG STAFF
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 136 of 196
136
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 136 of 196
TIVE PROCESS PRIVILEGE
reasons as the email to which the charts are attached.
ELECTRONIC RECORDS
TX_00089070
TX_00089070
Amadeo Saenz James Bass
DNP - DELIBERATIVE PROCESS PRIVILEGE
Charts attached to document TX_00089068 and privileged for the same reasons as the email to which the charts are attached. 3/29/2011
OOG STAFF ELECTRONIC RECORDS
TX_00089072
TX_00089075
Collin Parrish~Michael Schofield,~Brandy Marty Jeff Boyd
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
This email discusses a free election IDs in SB 14. The document contains the advice, opinion, and recommendations of the author regarding the free election IDs. The document was created to assist the Governor and his staff in deciding whether to support or oppose SB 14. Ultimately, the document was used to advise the Governor on his decision to sign or veto SB 14. The document was created prior to a final decision by the Governor whether to veto or sign Sb 14. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.~~The email also relates legal advice from the office of the attorney general sent for the purpose of giving or receiving legal advice on free election IDs. Jeff Boyd is also an attorney-author of the document. 4/15/2011
OOG STAFF ELECTRONIC RECORDS
TX_00089 TX_00089 Brandy Chip Roy DNP - This email fo discusses Section 5 in the 6/1/2011 OOG
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137
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 137 of 196
076 078 Marty,~Travis Richmond,~Jeff Boyd
ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
context of redistricting. The document contains reflections of the author regarding the free election IDs. The document was created to assist the Governor and his staff in deciding on a final policy position regarding preclearance litigation. Ultimately, the document was used to advise the Governor on his final policy decisions on preclearance. The document was created prior to a final decision on the Governor's public position on preclearance . As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.~~The email also relates a request for attorney review of applicable Section 5 standards. Jeff Boyd and Travis Richmond are also attorney recipients of the document.
STAFF ELECTRONIC RECORDS
TX_00089079
TX_00089079 Jeff Boyd John Sepehri
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
This email transmits and discusses a draft administrative preclearance submission prepared by attorneys in the Secretay of State office--an executive agency of the State. The document contains reflections of the author regarding the preclearance. The document was created to assist the Governor and his staff in deciding on a final policy position regarding preclearance. Ultimately, the document was used to advise the Governor on his 7/19/2011
OOG STAFF ELECTRONIC RECORDS
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 138 of 196
138
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 138 of 196
final policy decisions on preclearance. The document was created prior to a final decision on the Governor's public position on preclearance . As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.~~The email also relates legal advice on administrative preclearance from a Secretary of State attorney to other executive attorneys. Attorney John Sepehri is the attorney author and Jeff Boyd is the attorney recipient.
TX_00089080
TX_00089095 Jeff Boyd John Sepehri
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Draft preclearance submission attachment to TX-00089079 and privileged for the same reasons as the email to which it is attached. 7/19/2011
OOG STAFF ELECTRONIC RECORDS
TX_00089096
TX_00089097
Jimmy Blacklock, Jeff Boyd, Travis Richmond, David Schenck, Jay Dyer, John Sepehri
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
This email discusses a draft administrative preclearance submission prepared by attorneys in the Secretay of State office--an executive agency of the State. The document contains reflections of the author regarding the preclearance. The document was created to assist the Governor and his staff in deciding on a final policy position regarding 7/20/2011
OOG STAFF ELECTRONIC RECORDS
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 139 of 196
139
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 139 of 196
Stacey Napier
preclearance. Ultimately, the document was used to advise the Governor on his final policy decisions on preclearance. The document was created prior to a final decision on the Governor's public position on preclearance . As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.~~The email also relates legal advice on administrative preclearance from Secretary of State, Attorney General, and Office of the Governor attorneys. Attorney John Sepehri is the attorney author and attorneys from the Governor's Office and Office of the Attorney General are recipients.
TX_00089098
TX_00089098
Jeff Boyd~Travis Richmond John Sepehri
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
This email transmits and discusses a draft administrative preclearance submission prepared by attorneys in the Secretay of State office--an executive agency of the State. The document contains reflections of the author regarding the preclearance. The document was created to assist the Governor and his staff in deciding on a final policy position regarding preclearance. Ultimately, the document was used to advise the Governor on his final policy decisions on preclearance. The document was created prior to a 7/20/2011
OOG STAFF ELECTRONIC RECORDS
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 140 of 196
140
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 140 of 196
final decision on the Governor's public position on preclearance . As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.~~The email also relates legal advice on administrative preclearance from Secretary of State and Attorney General attorneys. Attorney John Sepehri is the attorney author and attorneys from the Governor's Office are recipients.
TX_00089099
TX_00089113
Jeff Boyd~Travis Richmond John Sepehri
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Attachment to TX-00089098 and privileged for the same reasons as the email to which it is attached. 7/20/2011
OOG STAFF ELECTRONIC RECORDS
TX_00089114
TX_00089114
Jimmy Blacklock,~Jay Dyer, Stacey Napier, David Schenck, Reed Clay, Jeff Boyd, John Sepehri
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
This email discusses a draft administrative preclearance submission prepared by attorneys in the Secretay of State office--an executive agency of the State. The document contains reflections of the author regarding preclearance. The document was created to assist the Governor and his staff in deciding on a final policy position regarding preclearance. Ultimately, the document was used to advise the Governor on his 7/21/2011
OOG STAFF ELECTRONIC RECORDS
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 141 of 196
141
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 141 of 196
Travis Richmond, Ann McGeehan, Elizabeth Winn
final policy decisions on preclearance. The document was created prior to a final decision on the Governor's public position on preclearance . As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.~~The email also relates legal advice on administrative preclearance from Secretary of State, Attorney General, and Office of the Governor attorneys. Attorney John Sepehri is the attorney author and attorneys from the Governor's Office, Secretary of State, and Office of the Attorney General are recipients.
TX_00089115
TX_00089129
Jimmy Blacklock,~Jay Dyer, Stacey Napier, David Schenck, Reed Clay, Jeff Boyd, Travis Richmond, Ann McGeehan, John Sepehri
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Draft preclearance submission attachment to TX-00089115 and privileged for the same reasons as the email to which it is attached. 7/21/2011
OOG STAFF ELECTRONIC RECORDS
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 142 of 196
142
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 142 of 196
Elizabeth Winn
TX_00089130
TX_00089130
John Sepehri,~Jeff Boyd
Travis Richmond
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
This email discusses a draft administrative preclearance submission prepared by attorneys in the Secretay of State office--an executive agency of the State. The document contains reflections of the author regarding preclearance. The document was created to assist the Governor and his staff in deciding on a final policy position regarding preclearance. Ultimately, the document was used to advise the Governor on his final policy decisions on preclearance. The document was created prior to a final decision on the Governor's public position on preclearance . As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.~~The email also relates legal advice on administrative preclearance from Secretary of State, Attorney General, and Office of the Governor attorneys. Attorney Travis Richmond is the attorney author and attorneys from the Governor's Office and Secretary of State are recipients. 7/21/2011
OOG STAFF ELECTRONIC RECORDS
TX_00089131
TX_00089145
John Sepehri,~Jeff Boyd
Travis Richmond
DNP - ATTY CLIENT;D
Draft preclearance submission attachment to TX-00089131 and privileged for the same reasons as the 7/21/2011
OOG STAFF ELECTRO
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 143 of 196
143
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 143 of 196
NP - DELIBERATIVE PROCESS PRIVILEGE
email to which it is attached. NIC RECORDS
TX_00089146
TX_00089146
Ann McGeehan, Elizabeth Winn, Erik Wilson, Esperanza Andrade, Coby Shorter, Jeff Boyd, Travis Richmond John Sepehri
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
This email discusses a draft administrative preclearance submission prepared by attorneys in the Secretay of State office--an executive agency of the State. The document contains reflections of the author regarding preclearance. The document was created to assist the Governor and his staff in deciding on a final policy position regarding preclearance. Ultimately, the document was used to advise the Governor on his final policy decisions on preclearance. The document was created prior to a final decision on the Governor's public position on preclearance . As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.~~The email also relates legal advice on administrative preclearance from Secretary of State, Attorney General, and Office of the Governor attorneys. Attorney John Sepehri is the attorney author and attorneys and staff from the Governor's Office and Secretary of State 7/22/2011
OOG STAFF ELECTRONIC RECORDS
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 144 of 196
144
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 144 of 196
are recipients.
TX_00089147
TX_00089161
Ann McGeehan, Elizabeth Winn, Erik Wilson, Esperanza Andrade, Coby Shorter, Jeff Boyd, Travis Richmond John Sepehri
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Draft preclearance submission attachment to TX-00089146 and privileged for the same reasons as the email to which it is attached. 7/22/2011
OOG STAFF ELECTRONIC RECORDS
TX_00089162
TX_00089166
Travis Richmond,~Jeff Boyd John Sepehri
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
This email discusses a draft administrative preclearance submission prepared by attorneys in the Secretay of State office--an executive agency of the State. The document contains reflections of the author regarding preclearance. The document was created to assist the Governor and his staff in deciding on a final policy position regarding preclearance. Ultimately, the document was used to advise the Governor on his final policy decisions on preclearance. The document was created prior to a final decision on the Governor's public position on preclearance . As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the 7/22/2011
OOG STAFF ELECTRONIC RECORDS
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 145 of 196
145
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 145 of 196
public, and the document cannot be produced in a redacted form without disclosing privileged information.~~The email also relates legal advice on administrative preclearance from Secretary of State, Attorney General, and Office of the Governor attorneys. Attorney John Sepehri is the attorney author and attorneys from the Governor's Office are recipients.
TX_00089167
TX_00089181
Travis Richmond,~Jeff Boyd John Sepehri
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Draft preclearance submission attachment to TX-00089166 and privileged for the same reasons as the email to which it is attached. 7/22/2011
OOG STAFF ELECTRONIC RECORDS
TX_00089182
TX_00089187
John Sepehri,~Jeff Boyd
Travis Richmond
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
This email discusses a draft administrative preclearance submission prepared by attorneys in the Secretay of State office--an executive agency of the State. The document contains reflections of the author regarding preclearance. The document was created to assist the Governor and his staff in deciding on a final policy position regarding preclearance. Ultimately, the document was used to advise the Governor on his final policy decisions on preclearance. The document was created prior to a final decision on the Governor's public position on preclearance . As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor 7/25/2011
OOG STAFF ELECTRONIC RECORDS
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 146 of 196
146
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 146 of 196
Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.~~The email also relates legal advice on administrative preclearance from Secretary of State, Attorney General, and Office of the Governor attorneys. Attorney Travis Richmond is the attorney author and attorneys from the Governor's Office and Secretary of State are recipients.
TX_00089188
TX_00089189
Travis Richmond,~Jeff Boyd,~Jimmy Blacklock,~Jay Dyer,~Stacey Napier,~David Schenck,~Reed Clay John Sepehri
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
This email discusses the final administrative preclearance submission prepared by attorneys in the Secretay of State office--an executive agency of the State. The document contains reflections of the author regarding preclearance. The document was created to assist the Governor and his staff in deciding on a final policy position regarding preclearance. Ultimately, the document was used to advise the Governor on his final policy decisions on preclearance. The document was created after a final decision, but contains numerous pre-decision deliberations throughout the email string on preclearance . As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be 7/26/2011
OOG STAFF ELECTRONIC RECORDS
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 147 of 196
147
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 147 of 196
produced in a redacted form without disclosing privileged information.~~The email also relates legal advice on administrative preclearance from Secretary of State, Attorney General, and Office of the Governor attorneys. Attorney John Sepehri is the attorney author and attorneys from the Governor's Office, Office of the Attorney General, and Secretary of State are recipients.
TX_00089224
TX_00089225
Jeff Boyd,~Denise Davis,~Blaine Brunson Daniel Hodge
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
This email discusses the constitutionality of Section 5. The document contains reflections of the author regarding Section 5's constitutionality. The document was created to assist the Governor and his staff in deciding on a final policy position regarding preclearance. Ultimately, the document was used to advise the Governor on his final policy decisions on preclearance. The document was created prior to a final decision on the Governor's public position on preclearance . As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.~~The email also relates legal advice on the constitutionality of Section 5. Attorney Daniel Hodge from the Attorney General's Office is the author. 8/26/2011
OOG STAFF ELECTRONIC RECORDS
TX_00089 TX_00089 Jeff Boyd John Sepehri DNP - This email discusses the administrative 8/29/2011 OOG
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 148 of 196
148
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 148 of 196
226 227 ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
preclearance process. The document contains reflections of the author regarding Section 5's constitutionality. The document was created to assist the Governor and his staff in deciding on a final policy position regarding preclearance. Ultimately, the document was used to advise the Governor on his final policy decisions on preclearance. The document was created prior to a final decision on the Governor's public position on preclearance . As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.~~The email also relates legal advice on administrative preclearance. Attorney John Sepehri from the Secretary of State's office is the author and Jeff Boyd is the recipient.
STAFF ELECTRONIC RECORDS
TX_00089229
TX_00089229
Jay Dyer,~John Sepehri,~Richard Parsons
Ann McGeehan
DNP - ATTY CLIENT
This document is an email sent for the purpose of giving or seeking legal advice on the progress of the administrative preclearance process. Attorney Ann McGeehan of the Secretary of State's office is the author of the email and attorneys Jay Dyer and John Sepehri of the Office of the Attorney General and Secretary of State's office are among the recipients. 9/23/2011
OOG STAFF ELECTRONIC RECORDS
TX_00089 TX_00089 David Daniel Hodge DNP - This document is an email sent for the 11/8/2011 OOG
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 149 of 196
149
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 149 of 196
233 233 Morales, Jeff Boyd, Doug Davis, Denise Davis, Blaine Brunson.
ATTY CLIENT
purpose of giving or seeking legal advice on the progress of the administrative preclearance process. Attorney Daniel Hodge of the Attorney General is the author of the email.
STAFF ELECTRONIC RECORDS
TX_00089234
TX_00089235
Coby Shorter,~Kathy Walt Jeff Boyd
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
This email discusses the MOVE Act requirements. The document contains opinions, advice, and reflections of the author regarding MOVE Act requirements. The document was created to assist the Governor and his staff in deciding on actions it must take to facilitate MOVE act compliance. Ultimately, the document was used to advise the Governor on his final policy decisions on MOVE Act Compliance. The document was created prior to a final decision on MOVE Act Compliance . As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.~~The email also relates legal advice on Move Act Compliance. Attorney Jeff Boyd to Coby Shorter and Kathy Walt. 12/2/2011
OOG STAFF ELECTRONIC RECORDS
TX_00089236
TX_00089238 Jeff Boyd
Blaine Brunson
DNP - ATTY CLIENT;DNP -
This email discusses the Texas primaries. The document contains opinions, advice, and reflections of the author regarding bifurcated primaries. 12/13/2011
OOG STAFF ELECTRONIC
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 150 of 196
150
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 150 of 196
DELIBERATIVE PROCESS PRIVILEGE
The document was created to assist the Governor and his staff in deciding its position on bifurcated primaries. Ultimately, the document was used to advise the Governor on his final policy decisions on bifurcated primaries The document was created prior to a final decision on bifurcated primaries . As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.~~The email also relates legal advice on bifurcated primaries. Blaine Brunson is the author and attorney Jeff Boyd is the recipient.
RECORDS
TX_00089239
TX_00089239
Jeff Boyd,~Blaine Brunson, Daniel Hodge
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
This email discusses the administrative preclearance process. The document contains reflections of the author regarding Section 5's constitutionality. The document was created to assist the Governor and his staff in deciding on a final policy position regarding preclearance. Ultimately, the document was used to advise the Governor on his final policy decisions on preclearance. The document was created prior to a final decision on the Governor's public position on preclearance . As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed 12/23/2011
OOG STAFF ELECTRONIC RECORDS
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 151 of 196
151
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 151 of 196
and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.~~The email also relates legal advice on administrative preclearance. Attorney Daniel Hodge is the author of the email
TX_00089240
TX_00089240
Coby Shorter, Jimmy Blacklock, Daniel Hodge, Ken Armbrister Jeff Boyd
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
This email discusses the administrative preclearance process. The document contains reflections of the author regarding Section 5's constitutionality. The document was created to assist the Governor and his staff in deciding on a final policy position regarding preclearance. Ultimately, the document was used to advise the Governor on his final policy decisions on preclearance. The document was created prior to a final decision on the Governor's public position on preclearance . As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.~~The email also relates legal advice on administrative preclearance. Attorney Jeff Boyd is the author of the email 1/12/2012
OOG STAFF ELECTRONIC RECORDS
TX_00089241
TX_00089250
DNP - ATTY
Attachment to TX_0089240 containing edits to an email responsive to a DOJ 1/12/2012
OOG STAFF
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 152 of 196
152
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 152 of 196
CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
request for information and privileged for the same reasons as the email to which it is attached.
ELECTRONIC RECORDS
TX_00089251
TX_00089252
OOG Press Office; Jonathan Hurst; Jeff Boyd; Ken Armbrister; Mike Morrissey Steffany Duke
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Confidential e-mail communication between OOG Press staff and OOG Chief of Staff and Attorney Jeff Boyd sent for the purposes of seeking legal advice regarding legislative summaries and effective dates.~~This document consists of an e-mail communication between OOG Press Assistant Steffany Duke and OOG Executives and Press Office staff regarding the drafting of a press statement summarizing legislation going into effect from the 82nd legislature that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding suggested edits to the Press Release. The document was created to assist the Governor and his staff in formulating a Press Release summarizing important legislation passed during the 82nd legislature. Ultimately, the document was used to advise the Governor's Press Office in formulating a final press release summarizing important legislation passed during the 82nd legislature and the effective dates of each. The document was created prior to creation and issuance of a final press release issued by the Governor's Office. As such,
OOG STAFF ELECTRONIC RECORDS
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 153 of 196
153
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 153 of 196
the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00089253
TX_00089254
OOG Press Office; Jonathan Hurst; Jeff Boyd; Ken Armbrister; Mike Morrissey Steffany Duke
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Attachment to above confidential attorne-client e-mail communication (TX_00089251) sent for the purposes of seeking legal advice legislative summaries and effective dates.~~This document consists of a draft press release prepared by OOG Press Assistant Steffany Duke summarizing notable legislation passed during 82nd legislature that was deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding the format and substance of the Press Statement. The document was created to assist the Governor and his staff in formulating a Press Release summarizing important legislation passed during the 82nd legislature. Ultimately, the document was used to advise the Governor's Press Office in formulating a final press release summarizing important legislation passed during the 82nd legislature and the effective dates of each. The
OOG STAFF ELECTRONIC RECORDS
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 154 of 196
154
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 154 of 196
document was created prior to creation and issuance of a final press release issued by the Governor's Office. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00089255
TX_00089256
Steffany Duke; OOG Office staff; Jeff Boyd; Ken Armbrister; Mike Morrissey
Jonathan Hurst
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Confidential e-mail communication between OOG Director and OOG Chief of Staff and Attorney Jeff Boyd sent for purposes of seeking legal advice regarding legislative summaries and effective dates.~~This document consists of e-mail communications between OOG Director Jonathan Hurst and OOG Executives and Press Office staff regarding edits to a draft Press Release summarizing legislation passed during the 82nd legislature that was deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding suggested edits to the Press Release. The document was created to assist the Governor and his staff in formulating a Press Release summarizing important legislation passed during the 82nd legislature. Ultimately, the document was used to
OOG STAFF ELECTRONIC RECORDS
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 155 of 196
155
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 155 of 196
advise the Governor's Press Office in formulating a final press release summarizing important legislation passed during the 82nd legislature and the effective dates of each. The document was created prior to creation and issuance of a final Press Release from the Governor's Office regarding the legislation addressed in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00089257
TX_00089258
Jonathan Hurst; Steffany Duke; OOG Press Office; Jeff Boyd; Ken Armbrister; Mike Morrissey
Matthew Thompson
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Confidential e-mail communication between OOG Speechwriter and OOG Chief of Staff and Attorney Jeff Boyd sent for the purposes of seeking legal advice regarding implementation of SB 14.~~This document consists of an e-mail communication between OOG Speechwriter Matthew thompson and OOG Chief of Staff, Executives and Press Office staff regarding the drafting of a Press Release summarizing legislation going into effect from the 82nd legislature that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author
OOG STAFF ELECTRONIC RECORDS
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 156 of 196
156
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 156 of 196
regarding suggested edits to the Press Release and the legislation summarized therein. The document was created to assist the Governor and his staff in formulating a Press Release summarizing important legislation passed during the 82nd legislature. Ultimately, the document was used to advise the Governor's Press Office in formulating a final press release summarizing important legislation passed during the 82nd legislature and the effective dates of each. The document was created prior to creation and issuance of a final press release issued by the Governor's Office. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00089259
TX_00089261
Matthew Thompson; Jonathan Jurst; OOG Press Office; Jeff Boyd; Steffany Duke
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Confidential e-mail communication between OOG Press staff and OOG Chief of Staff and Attorney Jeff Boyd sent for the purposes of seeking legal advice regarding implementation of SB 14.~~This document consists of an e-mail communication between OOG Press staff Steffany Duke and OOG Chief of Staff, Executives and Press Office staff
OOG STAFF ELECTRONIC RECORDS
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 157 of 196
157
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 157 of 196
Ken Armbrister; Mike Morrissey
regarding the drafting of a Press Release summarizing legislation going into effect from the 82nd legislature that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding suggested edits to the Press Release and the legislation summarized therein. The document was created to assist the Governor and his staff in formulating a Press Release summarizing important legislation passed during the 82nd legislature. Ultimately, the document was used to advise the Governor's Press Office in formulating a final press release summarizing important legislation passed during the 82nd legislature and the effective dates of each. The document was created prior to creation and issuance of a final press release issued by the Governor's Office. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00089262
TX_00089264
Matthew Thompson;
Jonathan Hurst
DNP - ATTY CLIENT;D
Confidential e-mail communication between OOG Director of Budget, Planning and Policy Jonathan Hurst and
OOG STAFF ELECTRO
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 158 of 196
158
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 158 of 196
Steffany Duke; OOG Press Office; Jeff Boyd; Ken Armbrister; Mike Morrissey
NP - DELIBERATIVE PROCESS PRIVILEGE
OOG Chief of Staff and Attorney Jeff Boyd sent for the purposes of seeking legal advice regarding the implementation of SB 14.~~This document consists of an e-mail communication between OOG Director Jonathan Hurst and OOG Chief of Staff, Executives and Press Office staff regarding the drafting of a Press Release summarizing legislation going into effect from the 82nd legislature that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding suggested edits to the Press Release and the legislation summarized therein. The document was created to assist the Governor and his staff in formulating a Press Release summarizing important legislation passed during the 82nd legislature. Ultimately, the document was used to advise the Governor's Press Office in formulating a final press release summarizing important legislation passed during the 82nd legislature and the effective dates of each. The document was created prior to creation and issuance of a final press release issued by the Governor's Office. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the
NIC RECORDS
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 159 of 196
159
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 159 of 196
Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00089265
TX_00089266
Jonathan Hurst; OOG Press Office; Jeff Boyd; Ken Armbrister; Mike Morrissey Steffany Duke
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Confidential e-mail communication between OOG Press Office staffer Steffany Duke and OOG Chief of Staff and Attorney Jeff Boyd sent for the purposes of seeking legal advice regarding legislative summaries and effective dates.~~This document consists of an e-mail communication between OOG Press staff and OOG Chief of Staff, Executives and Press Office staff regarding the drafting of a Press Release summarizing legislation going into effect from the 82nd legislature that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding suggested edits to the Press Release and the legislation summarized therein. The document was created to assist the Governor and his staff in formulating a Press Release summarizing important legislation passed during the 82nd legislature. Ultimately, the document was used to advise the Governor's Press Office in formulating a final press release summarizing important legislation passed during the 82nd legislature and the effective dates of each. The document was created prior to creation and issuance of a final press release issued by the Governor's Office. As such, the document does not memorialize or
OOG STAFF ELECTRONIC RECORDS
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 160 of 196
160
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 160 of 196
evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00089267
TX_00089268
Jonathan Hurst; OOG Press Office; Jeff Boyd; Ken Armbrister; Mike Morrissey Steffany Duke
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Attachment to above confidential attorney-client communication (TX_00089265) between OOG Press Staff and OOG CHief of Staff and Attorney Jeff Boyd sent for the purposes of seeking legal advice regarding legislative summaries and effective dates.~~This document consists of a draft Press Release prepared by OOG Press Office staffer Steffany Duke summarizing legislation passed during 82nd legislature that was deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding suggested edits to the Press Release and the legislation summarized therein. The document was created to assist the Governor and his staff in formulating a Press Release summarizing important legislation passed during the 82nd legislature. Ultimately, the document was used to advise the Governor's Press Office in formulating a final press release summarizing important legislation
OOG STAFF ELECTRONIC RECORDS
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 161 of 196
161
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 161 of 196
passed during the 82nd legislature and the effective dates of each. The document was created prior to creation and issuance of a final press release issued by the Governor's Office. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00089269
TX_00089270
Steffany Duke; OOG Press Office; Jeff Boyd; Ken Armbrister; Mike Morrissey
Jonathan Hurst
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Confidential e-mail communication between OOG Director of Budget, Planning and Policy Jonathan Hurst and OOG Chief of Staff and Attorney Jeff Boyd sent for the purposes of seeking legal advice regarding legislative summaries and effective dates.~~This document consists of an e-mail communication between OOG Director Jonathan Hurst and OOG Chief of Staff, Executives and Press Office staff regarding the drafting of a Press Release summarizing legislation going into effect from the 82nd legislature that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding suggested edits to the Press Release and the legislation summarized therein. The
OOG STAFF ELECTRONIC RECORDS
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 162 of 196
162
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 162 of 196
document was created to assist the Governor and his staff in formulating a Press Release summarizing important legislation passed during the 82nd legislature. Ultimately, the document was used to advise the Governor's Press Office in formulating a final press release summarizing important legislation passed during the 82nd legislature and the effective dates of each. The document was created prior to creation and issuance of a final press release issued by the Governor's Office. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00089271
TX_00089271
Allison Castle; Stephanie Duke; Jonathan Hurst; Kathy Walt Jeff Boyd
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Confidential e-mail communication from OOG Chief of Staff and Attorney Jeff Boyd to OOG Executives and Press Office Staff sent for the purposes of providing legal advice regarding legislative summaries and effective dates.~~This document consists of an e-mail communication between OOG Chief of Staff Jeff Boyd and OOG Executives and Press Office staff regarding the drafting of a Press Release summarizing legislation going into effect from the 82nd
OOG STAFF ELECTRONIC RECORDS
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 163 of 196
163
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 163 of 196
legislature that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding suggested edits to the Press Release and the legislation summarized therein. The document was created to assist the Governor and his staff in formulating a Press Release summarizing important legislation passed during the 82nd legislature. Ultimately, the document was used to advise the Governor's Press Office in formulating a final press release summarizing important legislation passed during the 82nd legislature and the effective dates of each. The document was created prior to creation and issuance of a final press release issued by the Governor's Office. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00089272
TX_00089273
Allison Castle; Stephanie Duke; Jonathan Jeff Boyd
DNP - ATTY CLIENT;DNP - DELIBERA
Attachment to above confidential attorney-client communication (TX_00089271) between OOG Chief of Staff and Attorney Jeff Boyd and OOG Executives and Press Office staff sent for
OOG STAFF ELECTRONIC RECORDS
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 164 of 196
164
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 164 of 196
Hurst; Kathy Walt
TIVE PROCESS PRIVILEGE
the purposes of seeking legal advice regarding legislative summaries and effective dates.~~This document consists of a draft Press Release prepared by OOG Press Office staffer Steffany Duke summarizing legislation passed during 82nd legislature that was deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding suggested edits to the Press Release and the legislation summarized therein. The document was created to assist the Governor and his staff in formulating a Press Release summarizing important legislation passed during the 82nd legislature. Ultimately, the document was used to advise the Governor's Press Office in formulating a final press release summarizing important legislation passed during the 82nd legislature and the effective dates of each. The document was created prior to creation and issuance of a final press release issued by the Governor's Office. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 165 of 196
165
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 165 of 196
disclosing privileged information.
TX_00089274
TX_00089276
Steffany Duke; Matthew Thompson; Jonathan Hurst; OOG Press Office; Ken Armbrister; Mike Morrissey; Kathy Walt Jeff Boyd
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Confidential e-mail communication from OOG Chief of Staff and Attorney Jeff Boyd to OOG Executives and Press Office Staff sent for the purposes of providing legal advice regarding legislative summaries and effective dates.~~This document consists of an e-mail communication between OOG Chief of Staff Jeff Boyd and OOG Executives and Press Office staff regarding the drafting of a Press Release summarizing legislation going into effect from the 82nd legislature that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding suggested edits to the Press Release and the legislation summarized therein. The document was created to assist the Governor and his staff in formulating a Press Release summarizing important legislation passed during the 82nd legislature. Ultimately, the document was used to advise the Governor's Press Office in formulating a final press release summarizing important legislation passed during the 82nd legislature and the effective dates of each. The document was created prior to creation and issuance of a final press release issued by the Governor's Office. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the
OOG STAFF ELECTRONIC RECORDS
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 166 of 196
166
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 166 of 196
Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00089277
TX_00089278
Steffany Duke; Matthew Thompson; Jonathan Hurst; OOG Press Office; Ken Armbrister; Mike Morrissey; Kathy Walt Jeff Boyd
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Attachment to above confidential attorney-client communication (TX_00089274) from OOG Chief of Staff and Attorney Jeff Boyd to OOG Executives and Pres Office staff sent for the purposes of providing legal advice regarding legislative summaries and effective dates.~~This document consists of a draft Press Release prepared by OOG Chief of Staff Jeff Boyd summarizing legislation passed during 82nd legislature that was deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding suggested edits to the Press Release and the legislation summarized therein. The document was created to assist the Governor and his staff in formulating a Press Release summarizing important legislation passed during the 82nd legislature. Ultimately, the document was used to advise the Governor's Press Office in formulating a final press release summarizing important legislation passed during the 82nd legislature and the effective dates of each. The document was created prior to creation and issuance of a final press release
OOG STAFF ELECTRONIC RECORDS
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 167 of 196
167
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 167 of 196
issued by the Governor's Office. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00089279
TX_00089280
Jonathan Hurst; OOG Press Office; Jeff Boyd; Ken Armbrister; Mike Morrissey Steffany Duke
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Confidential e-mail communication between OOG Press Office staff Steffany Duke and OOG Chief of Staff and Attorney Jeff Boyd sent for the purposes of seeking legal advice regarding legislative summaries and effective dates.~~This document consists of an e-mail communication between OOG Press Office Staffer Steffany Duke and OOG Chief of Staff, Executives and Press Office staff regarding the drafting of a Press Release summarizing legislation going into effect from the 82nd legislature that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding suggested edits to the Press Release and the legislation summarized therein. The document was created to assist the Governor and his staff in formulating a Press Release summarizing important legislation passed during the 82nd legislature.
OOG STAFF ELECTRONIC RECORDS
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 168 of 196
168
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 168 of 196
Ultimately, the document was used to advise the Governor's Press Office in formulating a final press release summarizing important legislation passed during the 82nd legislature and the effective dates of each. The document was created prior to creation and issuance of a final press release issued by the Governor's Office. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00089281
TX_00089283
Jeff Boyd; Steffany Duke; Matthew Thompson; Jonathan Hurst; OOG Press Office; Ken Armbrister; Mike Morrissey; Kathy
Catherine Frazier
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Confidential e-mail communication between OOG Press Secretary Catherine Frazier and OOG Chief of Staff and Attorney Jeff Boyd sent for the purposes of seeking legal advice regarding legislative summaries and effective dates.~~This document consists of an e-mail communication between OOG Press Secretary Catherine Frazier and OOG Chief of Staff, Executives and Press Office staff regarding the drafting of a Press Release summarizing legislation going into effect from the 82nd legislature that were deemed important by the Governor's policy advisers. The document contains the advice, opinion,
OOG STAFF ELECTRONIC RECORDS
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 169 of 196
169
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 169 of 196
Walt and recommendations of the author regarding suggested edits to the Press Release and the legislation summarized therein. The document was created to assist the Governor and his staff in formulating a Press Release summarizing important legislation passed during the 82nd legislature. Ultimately, the document was used to advise the Governor's Press Office in formulating a final press release summarizing important legislation passed during the 82nd legislature and the effective dates of each. The document was created prior to creation and issuance of a final press release issued by the Governor's Office. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00089284
TX_00089285
Jeff Boyd; Steffany Duke; Matthew Thompson; Jonathan Hurst;
Catherine Frazier
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEG
Attachment to above confidential attorney-client communication (TX_00089281) from by OOG Press Secretary Catherine Frazier to OOG Chief of Staff and Attorney Jeff Boyd sent for the purposes of seeking legal advice regarding legislative summaries and effective dates.~~This document
OOG STAFF ELECTRONIC RECORDS
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 170 of 196
170
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 170 of 196
OOG Press Office; Ken Armbrister; Mike Morrissey; Kathy Walt
E consists of a draft Press Release prepared by OOG Press Secretary Catherine Frazier summarizing legislation passed during 82nd legislature that was deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding suggested edits to the Press Release and the legislation summarized therein. The document was created to assist the Governor and his staff in formulating a Press Release summarizing important legislation passed during the 82nd legislature. Ultimately, the document was used to advise the Governor's Press Office in formulating a final press release summarizing important legislation passed during the 82nd legislature and the effective dates of each. The document was created prior to creation and issuance of a final press release issued by the Governor's Office. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00089286
TX_00089288
Catherine Frazier; Lucy Nashed
DNP - ATTY
Confidential e-mail communication between OOG Deputy Press Secretary
OOG STAFF
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 171 of 196
171
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 171 of 196
Jeff Boyd; Steffany Duke; Matthew Thompson; Jonathan Hurst; OOG Press Office; Kem Arbrister; Mike Morrissey; Kathy Walt
CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Lucy Nashed and OOG Chief of Staff and Attorney Jeff Boyd sent for the purposes of seeking legal advice regarding legislative summaries and effective dates.~~This document consists of an e-mail communication between OOG Deputy Press Secretary Lucy Nashed and OOG Chief of Staff, Executives and Press Office staff regarding the drafting of a Press Release summarizing legislation going into effect from the 82nd legislature that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding suggested edits to the Press Release and the legislation summarized therein. The document was created to assist the Governor and his staff in formulating a Press Release summarizing important legislation passed during the 82nd legislature. Ultimately, the document was used to advise the Governor's Press Office in formulating a final press release summarizing important legislation passed during the 82nd legislature and the effective dates of each. The document was created prior to creation and issuance of a final press release issued by the Governor's Office. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the
ELECTRONIC RECORDS
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172
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Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00089289
TX_00089290
Catherine Frazier; Jeff Boyd; Steffany Duke; Matthew Thompson; Jonathan Hurst; OOG Press Office; Kem Arbrister; Mike Morrissey; Kathy Walt Lucy Nashed
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Attachment to above confidential attorney-client communication (TX_00089286) between OOG Deputy Press Secretary Lucy Nashed and OOG Chief of Staff and Attorney Jeff Boyd sent for the purposes of seeking legal advice regarding legislative summaries and effective dates.~~This document consists of a draft Press Release prepared by OOG Deputy Press Secretary Lucy Nashed summarizing legislation passed during 82nd legislature that was deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding suggested edits to the Press Release and the legislation summarized therein. The document was created to assist the Governor and his staff in formulating a Press Release summarizing important legislation passed during the 82nd legislature. Ultimately, the document was used to advise the Governor's Press Office in formulating a final press release summarizing important legislation passed during the 82nd legislature and the effective dates of each. The document was created prior to creation and issuance of a final press release issued by the Governor's Office. As such, the document does not memorialize
OOG STAFF ELECTRONIC RECORDS
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 173 of 196
173
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or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00089291
TX_00089292
Lucy Nashed; Catherine Frazier; Jeff Boyd; Matthew Thompson; Jonathan Hurst; OOG Press Office, Ken Armbrister; Mike Morrissey; Kathy Walt Steffany Duke
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Confidential e-mail communication between OOG Press Office staff Steffany Duke and OOG Chief of Staff and Attorney Jeff Boyd sent for the purposes of seeking legal advice regarding legislative summaries and effective dates.~~This document consists of an e-mail communication between OOG Press Office Staffer Steffany Duke and OOG Chief of Staff, Executives and Press Office staff regarding the drafting of a Press Release summarizing legislation going into effect from the 82nd legislature that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding suggested edits to the Press Release and the legislation summarized therein. The document was created to assist the Governor and his staff in formulating a Press Release summarizing important legislation passed during the 82nd legislature. Ultimately, the document was used to advise the Governor's Press Office in
OOG STAFF ELECTRONIC RECORDS
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 174 of 196
174
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 174 of 196
formulating a final press release summarizing important legislation passed during the 82nd legislature and the effective dates of each. The document was created prior to creation and issuance of a final press release issued by the Governor's Office. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00089293
TX_00089294
Lucy Nashed; Catherine Frazier; Jeff Boyd; Matthew Thompson; Jonathan Hurst; OOG Press Office, Ken Armbrister; Mike Morrissey; Kathy
Stephany Duke
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Attachment to above confidential attorney-client communication (TX_00089291) between OOG Press Staffer Steffany Duke and OOG Chief of Staff and Attorney Jeff Boyd sent for the purposes of seeking legal advice regarding legislative summaries and effective dates.~~This document consists of a draft Press Release prepared by OOG Press Office staffer Steffany Duke summarizing legislation passed during 82nd legislature that was deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding suggested edits to the Press Release and the legislation summarized therein. The document was
OOG STAFF ELECTRONIC RECORDS
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 175 of 196
175
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 175 of 196
Walt created to assist the Governor and his staff in formulating a Press Release summarizing important legislation passed during the 82nd legislature. Ultimately, the document was used to advise the Governor's Press Office in formulating a final press release summarizing important legislation passed during the 82nd legislature and the effective dates of each. The document was created prior to creation and issuance of a final press release issued by the Governor's Office. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00089295
TX_00089296
Lucy Nashed; Catherine Frazier; Jeff Boyd; Matthew Thompson; Jonathan Hurst; OOG Press Steffany Duke
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Confidential e-mail communication between OOG Press Office staff Steffany Duke and OOG Chief of Staff and Attorney Jeff Boyd sent for the purposes of seeking legal advice regarding legislative summaries and effective dates.~~This document consists of an e-mail communication between OOG Press Office Staffer Steffany Duke and OOG Chief of Staff, Executives and Press Office staff regarding the drafting of a Press Release summarizing legislation
OOG STAFF ELECTRONIC RECORDS
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 176 of 196
176
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 176 of 196
Office; Ken Armbrister; Mike Morrissey; Kathy Walt
going into effect from the 82nd legislature that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding suggested edits to the Press Release and the legislation summarized therein. The document was created to assist the Governor and his staff in formulating a Press Release summarizing important legislation passed during the 82nd legislature. Ultimately, the document was used to advise the Governor's Press Office in formulating a final press release summarizing important legislation passed during the 82nd legislature and the effective dates of each. The document was created prior to creation and issuance of a final press release issued by the Governor's Office. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00089297
TX_00089298
Lucy Nashed; Catherine Frazier; Steffany Duke
DNP - ATTY CLIENT;DNP -
Attachment to above confidential attorney-client communication (TX_00089295) from by OOG Chief of Staff and Attorney Jeff Boyd to OOG
OOG STAFF ELECTRONIC
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177
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 177 of 196
Jeff Boyd; Matthew Thompson; Jonathan Hurst; OOG Press Office; Ken Armbrister; Mike Morrissey; Kathy Walt
DELIBERATIVE PROCESS PRIVILEGE
Executives and Pres Office staff sent for the purposes of providing legal advice regarding legislative summaries and effective dates.~~This document consists of a draft Press Release prepared by OOG Chief of Staff Jeff Boyd summarizing legislation passed during 82nd legislature that was deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding suggested edits to the Press Release and the legislation summarized therein. The document was created to assist the Governor and his staff in formulating a Press Release summarizing important legislation passed during the 82nd legislature. Ultimately, the document was used to advise the Governor's Press Office in formulating a final press release summarizing important legislation passed during the 82nd legislature and the effective dates of each. The document was created prior to creation and issuance of a final press release issued by the Governor's Office. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be
RECORDS
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178
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produced in a redacted form without disclosing privileged information.
TX_00089299
TX_00089300
Steffany Duke; Lucy Nashed; Catherine Frazier; Jeff Boyd; Jonathan Hurst; OOG Press Office; Ken Armbrister; Mike Morrissey; Kathy Walt
Matthew Thompson
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Confidential e-mail communication between OOG Speechwriter Matthew Thompson and OOG Chief of Staff and Attorney Jeff Boyd sent for the purposes of seeking legal advice regarding legislative summaries and effective dates.~~This document consists of e-mail communications between OOG Speechwriter Matthew Thompson and OOG Press Office staff, OOG Director of Comunications, and OOG Deputy Press Secretaries regarding the drafting of a press statement summarizing legislation passed during the 82nd legislature that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding suggested edits to the Press Statement. The document was created to assist the Governor and his staff in formulating a public statement regarding legislative accomplishments from the 82nd legislature. Ultimately, the document was used to advise the Governor's Press Office in formulating a final press statement. The document was created prior to creation and issuance of a final press release issued by the Governor's Office regarding the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the
OOG STAFF ELECTRONIC RECORDS
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 179 of 196
179
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 179 of 196
Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00089301
TX_00089302
Steffany Duke; Lucy Nashed; Catherine Frazier; Jeff Boyd; Jonathan Hurst; OOG Press Office; Ken Armbrister; Mike Morrissey; Kathy Walt
Matthew Thompson
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Attachment to above confidential attorney-client communication (TX_00089290) between OOG Speeachwriter Matthew Thompson and OOG Chief of Staff and Attorney Jeff Boyd sent for the purposes of seeking legal advice regarding legislative summaries and effective dates.~~This document consists of a draft Press Release prepared by OOG Speechwriter Matthew Thompson summarizing legislation passed during 82nd legislature that was deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding suggested edits to the Press Release and the legislation summarized therein. The document was created to assist the Governor and his staff in formulating a Press Release summarizing important legislation passed during the 82nd legislature. Ultimately, the document was used to advise the Governor's Press Office in formulating a final press release summarizing important legislation passed during the 82nd legislature and the effective dates of each. The document was created prior to creation
OOG STAFF ELECTRONIC RECORDS
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 180 of 196
180
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 180 of 196
and issuance of a final press release issued by the Governor's Office. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00089303
TX_00089303
OOG Press Office; Jeff Boyd; Matthew Thompson; Jonathan Hurst; Ken Armbrister; Mike Morrissey Allison Castle
DNP - DELIBERATIVE PROCESS PRIVILEGE
Confidential e-mail communication between OOG Director of Communciations Allison Castle and OOG Chief of Staff and Attorney Jeff Boyd sent for the purposes of seeking legal advice regarding legislative summaries and effective dates.~~This document consists of e-mail communications between OOG Director of Comunications Allison Castle and OOG Executives and Press Office staff regarding the drafting of a Press Release summarizing legislation passed during the 82nd legislature that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding suggested edits to the Press Release. The document was created to assist the Governor and his staff in formulating a public statement regarding legislative accomplishments from the 82nd legislature. Ultimately, the
OOG STAFF ELECTRONIC RECORDS
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 181 of 196
181
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document was used to advise the Governor's Press Office in formulating a final press statement. The document was created prior to creation and issuance of a final press release issued by the Governor's Office regarding the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00089304
TX_00089305
OOG Press Office; Jeff Boyd; Matthew Thompson; Jonathan Hurst; Ken Armbrister; Mike Morrissey Allison Castle
DNP - DELIBERATIVE PROCESS PRIVILEGE
Attachment to above confidential attorney-client communication (TX_00089274) from by OOG Chief of Staff and Attorney Jeff Boyd to OOG Executives and Pres Office staff sent for the purposes of providing legal advice regarding legislative summaries and effective dates.~~This document consists of a draft Press Release prepared by OOG Chief of Staff Jeff Boyd summarizing legislation passed during 82nd legislature that was deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding suggested edits to the Press Release and the legislation summarized therein. The document was
OOG STAFF ELECTRONIC RECORDS
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182
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created to assist the Governor and his staff in formulating a Press Release summarizing important legislation passed during the 82nd legislature. Ultimately, the document was used to advise the Governor's Press Office in formulating a final press release summarizing important legislation passed during the 82nd legislature and the effective dates of each. The document was created prior to creation and issuance of a final press release issued by the Governor's Office. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00089306
TX_00089307
Becky Dean;~Lucy Nashed;~Allison Castle;~Jeff Boyd;~Governor's Press Office;~Mary Anne Steffany Duke
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
This document consists of e-mail communications between OOG Press Office staff and Deputy Press Secretaries regarding the preparation of a press release summarizing legislation passed during the 82nd legislature that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his
OOG STAFF ELECTRONIC RECORDS
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 183 of 196
183
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 183 of 196
Wiley staff in formulating a public statement regarding legislative accomplishments from the 82nd legislature. Ultimately, the document was used to advise the Governor's Press Secretaries in formulating a final press statement. The document was created prior to creation and issuance of a final press release issued by the Governor's Office regarding the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00089308
TX_00089309
Becky Dean;~Lucy Nashed;~Allison Castle;~Jeff Boyd;~Governor's Press Office;~Mary Anne Wiley Steffany Duke
DNP - DELIBERATIVE PROCESS PRIVILEGE
Attachment to above confidential e-mail communication (TX_00089306) between OOG Press Staff and OOG Chief of Staff and Attorney Jeff Boyd sent for the purposes of seeking legal advice regarding legsilative summaries and effective dates.~~This document consists of a draft press release prepared by OOG Press Assistant Steffany Duke regarding legislation passed during 82nd legislature that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The
OOG STAFF ELECTRONIC RECORDS
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 184 of 196
184
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 184 of 196
document was created to assist the Governor and his staff in formulating a public statement regarding legislative accomplishments from the 82nd legislature. Ultimately, the document was used to advise the Governor's Press Secretaries in formulating a final press statement. The document was created prior to creation and issuance of a final press release issued by the Governor's Office regarding the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00089310
TX_00089310
Allison Castle; Lucy Nashed; Josh Havens
Matthew Thompson
DNP - DELIBERATIVE PROCESS PRIVILEGE
This document consists of e-mail communications between OOG Deputy Press Secretaries and OOG Press staff regarding media requests for a comment by the Governor on letters submitted to DOJ opposing the preclearance of SB 14 that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain media responses by the Governor. The document was created to assist the Governor and his staff in
OOG STAFF ELECTRONIC RECORDS
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 185 of 196
185
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 185 of 196
deciding whether to issue a press statement in response to the media inquery. Ultimately, the document was used to advise the Governor on his decision to issue a press statement responding to SB 14 preclearance opposition. The document was created prior to a final decision by the Governor whether to issue a press statement responding to the request for commentary at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00089311
TX_00089312
Matthew Thompson;~Allison Castle; Josh Havens Lucy Nashed
DNP - DELIBERATIVE PROCESS PRIVILEGE
This document consists of e-mail communications between OOG Deputy Press Secretaries and OOG Press staff regarding media requests for comments from the Governor on letters submitted to DOJ opposing the preclearance of SB 14 that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain media responses by the Governor. The document was created to assist the Governor and his staff in deciding whether to issue a press
OOG STAFF ELECTRONIC RECORDS
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 186 of 196
186
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 186 of 196
statement in response to the media inquery. Ultimately, the document was used to advise the Governor on his decision to issue a press statement responding to SB 14 preclearance opposition. The document was created prior to a final decision by the Governor whether to issue a press statement responding to the request for commentary at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00089313
TX_00089314
Lucy Nashed; Jeff Boyd; Mary Anne Wiley; Kathy Walt; Josh Havens; Matthew Thompson; Ken Armbrister; Allison Castle
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Confidential, internal e-mail communication from OOG Deputy Press Secreatry to The Governor's Chief of Staff and Attorney Jeff Boyd and Deputy General Counsel sent for the purposes of requesting legal advice regarding challenges to SB 14 preclearance. ~~This document consists of e-mail communications from the OOG Deputy Press Secretary to the Governor's Chief of Staff, Deputy General Counsel, and the OOG Press Office and Communication staff regarding a potential response to media attacks on Voter ID that were deemed important by
OOG STAFF ELECTRONIC RECORDS
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 187 of 196
187
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 187 of 196
Jonathan Hurst; Steffany Duke
the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding SB 14. The document was created to assist the Governor and his staff in deciding whether to issue a press statement responding to the media attacks. Ultimately, the document was used to advise the Governor on his decision to issue a press statement. The document was created prior to a final decision by the Governor whether to issue a press statement regarding the media attacks at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00089315
TX_00089316
Allison Castle
Jonathan Hurst
DNP - DELIBERATIVE PROCESS PRIVILEGE
This document consists of e-mail communications from the OOG Director or Budget, Planning and Policy Honathen Hurst to OOG Deputy Press Secretary Allison Castle regarding a potential response to statements submitted to the DOJ opposing preclearance of SB 14. The document contains the advice, opinion, and recommendations of the author regarding an appropriate media response. The
OOG STAFF ELECTRONIC RECORDS
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 188 of 196
188
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 188 of 196
document was created to assist the Governor and his staff in deciding whether to issue a press statement responding to statements in opposition of SB 14 preclearance. Ultimately, the document was used to advise the Governor on his decision to issue a press statement. The document was created prior to a final decision by the Governor whether to issue a press statement regarding the statements in opposition to SB 14 at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00089317
TX_00089317
Allison Castle Lucy Nashed
DNP - DELIBERATIVE PROCESS PRIVILEGE
This document consists of an e-mail communication between the Governor's Deputy Press Secretary and the Governor's Director of Communications regarding potentnail responses to media commentary attacking SB 14 that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain media responses. The document was created to assist the Governor and his staff in deciding whether to issue a
OOG STAFF ELECTRONIC RECORDS
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 189 of 196
189
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 189 of 196
press statement in response to the media attacks on SB 14. Ultimately, the document was used to advise the Governor on his decision to issue a press statement responding to media commentary. The document was created prior to a final decision by the Governor whether to issue a press statement responding to the attacks on SB 14 at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00089318
TX_00089319
Allison Castle; Lucy Nached; Mary Anne Wiley; Kathy Walt; Josh Havens; Matthew Thompson; Ken Armbrist Jeff Boyd
DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE
Confidential, internal e-mail communication from OOG Chief of Staff and Attorney Jeff Boyd to OOG staff and policy advisors sent for the purposes of providing legal advice regarding the application of SB 14. ~~This document consists of e-mail communications between the Governor's Chief of Staff, Deputy General Counsel, Deputy Press Secretary, and OOG Press Division staff regarding media responses to media commentary about Voter ID that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and
OOG STAFF ELECTRONIC RECORDS
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 190 of 196
190
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 190 of 196
er; Jonathan Hurst; Steffany Duke
recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to issue a press statement in response to the media commentary. Ultimately, the document was used to advise the Governor on his decision to issue a press statement responding to attacks on SB 14. The document was created prior to a final decision by the Governor whether to issue a press statement regarding the media commentary at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00089320
TX_00089320
OOG Press Office Josh Havens
DNP - DELIBERATIVE PROCESS PRIVILEGE
This document consists of e-mail communications between the Governor's Deputy Press Secretary and the OOG Press Division regarding media responses to media inqueries about the Governor's expectations regarding the DOJ's potential preclearance determination for SB 14 that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and
OOG STAFF ELECTRONIC RECORDS
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 191 of 196
191
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 191 of 196
recommendations of the author regarding certain media responses. The document was created to assist the Governor and his staff in deciding whether to issue a press statement in response to the media inquery. Ultimately, the document was used to advise the Governor on his decision to issue a press statement refusing to comment until a preclearance determination has been made. The document was created prior to a final decision by the Governor whether to issue a press statement responding to the media inquery at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00089321
TX_00089321
OOG Press Office;~Brandy Marty;~Jeff Boyd
Catherine Frazier
DNP - DELIBERATIVE PROCESS PRIVILEGE
This document consists of e-mail communications between the Governor's Chief of Staff and Deputy Chief of Staff, Press Secretary, and the OOG Press Division regarding media responses to DOJ's denial of preclearance for SB 14 that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The
OOG STAFF ELECTRONIC RECORDS
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 192 of 196
192
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 192 of 196
document was created to assist the Governor and his staff in deciding whether to issue a press statement in response to the denial of preclearance. Ultimately, the document was used to advise the Governor on his decision to issue a press statement condemning the DOJ's actions. The document was created prior to a final decision by the Governor whether to issue a press statement regarding the DOJ's preclearance determination at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00089322
TX_00089322
Catherine Frazier;~OOG Press Office;~Brendy Marty;~Jeff Boyd
Catherine Frazier
DNP - DELIBERATIVE PROCESS PRIVILEGE
This document consists of e-mail communications between the Governor's Chief of Staff and Deputy Chief of Staff, Press Secretary, and the OOG Press Division regarding media responses to DOJ's denial of preclearance for SB 14 that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the
OOG STAFF ELECTRONIC RECORDS
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 193 of 196
193
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 193 of 196
Governor and his staff in deciding whether to issue a press statement in response to the denial of preclearance. Ultimately, the document was used to advise the Governor on his decision to issue a press statement condemning the DOJ's actions. The document was created prior to a final decision by the Governor whether to issue a press statement regarding the DOJ's preclearance determination at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00089323
TX_00089324
Governor's Office Press Division; Governor's Office Budget, Panning and Policy Division staff; and Governor' Dan Wilmot
DNP - DELIBERATIVE PROCESS PRIVILEGE
This document consists of e-mail communications between OOG policy advisors and staff regarding media responses to the debate over federal health care funding in Texas that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain media articles. The document was created to assist the Governor and his staff in deciding whether to issue a response to the media article at issue in
OOG STAFF ELECTRONIC RECORDS
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 194 of 196
194
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 194 of 196
s Office Federal Relations Division staff
the document. Ultimately, the document was used to advise the Governor on his decision whether to release a press statement on the issue. The document was created prior to a final decision by the Governor whether to issue a statement to the press clarifying the facts regarding federal health care funding at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
TX_00089325
TX_00089327
Governor's Office Press Division Lucy Nashed
DNP - DELIBERATIVE PROCESS PRIVILEGE
This document consists of e-mail communications between OOG staff regarding media responses to ongoing political debates concerning federal health care funding and state Voter ID and redistricting lawsuits that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his
OOG STAFF ELECTRONIC RECORDS
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 195 of 196
195
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 195 of 196
decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.
Case 1:12-cv-00128-RMC-DST-RLW Document 139-1 Filed 05/23/12 Page 196 of 196
196
Case 1:12-cv-00128-RMC-DST-RLW Document 152-3 Filed 05/25/12 Page 196 of 196
1
State of Texas v. Eric Holder, Jr., Attorney General of the United States
Case No. 1:12-cv-00128
United States District Court for the District of Columbia
TEXAS LEGISLATIVE COUNCIL
SECOND REVISED PRIVILEGE LOG
May 23, 2012
Beginning Beginning Beginning Beginning Doc. NumberDoc. NumberDoc. NumberDoc. Number
End Doc. End Doc. End Doc. End Doc. NumberNumberNumberNumber
Basis for Basis for Basis for Basis for WithholdingWithholdingWithholdingWithholding DescriptionDescriptionDescriptionDescription DateDateDateDate SourcesSourcesSourcesSources
Sender / Sender / Sender / Sender / AuthorAuthorAuthorAuthor RecipientRecipientRecipientRecipient
TX_00041842 TX_00041845
Attorney-Client Privilege; Legislative Privilege
Document responsive to a public information law request that was provided to the council in order to obtain legal advice regarding the request. Reflects legislator thoughts, opinions, or mental impressions on Voter ID. 11/29/2011
TLC (LEGAL DIVISION)
Colby Beuck (Atty.) (Rep. Harless)
Ross Giesinger (Atty.)
TX_00041846 TX_00041846
Attorney-Client Privilege; Legislative Privilege
Document responsive to a public information law request that was provided to the council in order to obtain legal advice regarding the request. Reflects legislator thoughts, opinions, or mental impressions on Voter ID. 11/29/2011
TLC (LEGAL DIVISION)
Colby Beuck (Atty.) (Rep. Harless)
Ross Giesinger (Atty.)
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 1 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 1 of 181
2
TX_00041847 TX_00041847
Attorney-Client Privilege; Legislative Privilege
Document responsive to a public information law request that was provided to the council in order to obtain legal advice regarding the request. Reflects legislator thoughts, opinions, or mental impressions on Voter ID. 11/29/2011
TLC (LEGAL DIVISION)
Colby Beuck (Atty.) (Rep. Harless)
Ross Giesinger (Atty.)
TX_00041848 TX_00041848
Attorney-Client Privilege; Legislative Privilege
Document responsive to a public information law request that was provided to the council in order to obtain legal advice regarding the request. Reflects legislator thoughts, opinions, or mental impressions on Voter ID. 11/29/2011
TLC (LEGAL DIVISION)
Colby Beuck (Atty.) (Rep. Harless)
Ross Giesinger (Atty.)
TX_00041849 TX_00041850
Attorney-Client Privilege; Legislative Privilege
Document responsive to a public information law request that was provided to the council in order to obtain legal advice regarding the request. Reflects legislator thoughts, opinions, or mental impressions on Voter ID. 11/29/2011
TLC (LEGAL DIVISION)
Colby Beuck (Atty.) (Rep. Harless)
Ross Giesinger (Atty.)
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 2 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 2 of 181
3
TX_00041851 TX_00041853
Attorney-Client Privilege; Legislative Privilege
Document responsive to a public information law request that was provided to the council in order to obtain legal advice regarding the request. Reflects legislator thoughts, opinions, or mental impressions on Voter ID. 11/29/2011
TLC (LEGAL DIVISION)
Colby Beuck (Atty.) (Rep. Harless)
Ross Giesinger (Atty.)
TX_00041854 TX_00041855
Attorney-Client Privilege; Legislative Privilege
Document responsive to a public information law request that was provided to the council in order to obtain legal advice regarding the request. Reflects legislator thoughts, opinions, or mental impressions on Voter ID. 11/29/2011
TLC (LEGAL DIVISION)
Colby Beuck (Atty.) (Rep. Harless)
Ross Giesinger (Atty.)
TX_00041856 TX_00041859
Attorney-Client Privilege; Legislative Privilege
Document responsive to a public information law request that was provided to the council in order to obtain legal advice regarding the request. Reflects legislator thoughts, opinions, or mental impressions on Voter ID. 11/29/2011
TLC (LEGAL DIVISION)
Colby Beuck (Atty.) (Rep. Harless)
Ross Giesinger (Atty.)
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 3 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 3 of 181
4
TX_00041860 TX_00041862
Attorney-Client Privilege; Legislative Privilege
Document responsive to a public information law request that was provided to the council in order to obtain legal advice regarding the request. Reflects legislator thoughts, opinions, or mental impressions on Voter ID. 11/29/2011
TLC (LEGAL DIVISION)
Colby Beuck (Atty.) (Rep. Harless)
Ross Giesinger (Atty.)
TX_00041863 TX_00041865
Attorney-Client Privilege; Legislative Privilege
Document responsive to a public information law request that was provided to the council in order to obtain legal advice regarding the request. Reflects legislator thoughts, opinions, or mental impressions on Voter ID. 11/29/2011
TLC (LEGAL DIVISION)
Colby Beuck (Atty.) (Rep. Harless)
Ross Giesinger (Atty.)
TX_00041866 TX_00041868
Attorney-Client Privilege; Legislative Privilege
Document responsive to a public information law request that was provided to the council in order to obtain legal advice regarding the request. Reflects legislator thoughts, opinions, or mental impressions on Voter ID. 11/29/2011
TLC (LEGAL DIVISION)
Colby Beuck (Atty.) (Rep. Harless)
Ross Giesinger (Atty.)
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 4 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 4 of 181
5
TX_00041869 TX_00041871
Attorney-Client Privilege; Legislative Privilege
Document responsive to a public information law request that was provided to the council in order to obtain legal advice regarding the request. Reflects legislator thoughts, opinions, or mental impressions on Voter ID. 11/29/2011
TLC (LEGAL DIVISION)
Colby Beuck (Atty.) (Rep. Harless)
Ross Giesinger (Atty.)
TX_00041872 TX_00041874
Attorney-Client Privilege; Legislative Privilege
Document responsive to a public information law request that was provided to the council in order to obtain legal advice regarding the request. Reflects legislator thoughts, opinions, or mental impressions on Voter ID. 11/29/2011
TLC (LEGAL DIVISION)
Colby Beuck (Atty.) (Rep. Harless)
Ross Giesinger (Atty.)
TX_00041875 TX_00041875
Attorney-Client Privilege; Legislative Privilege
Document responsive to a public information law request that was provided to the council in order to obtain legal advice regarding the request. Reflects legislator thoughts, opinions, or mental impressions on Voter ID. 11/29/2011
TLC (LEGAL DIVISION)
Colby Beuck (Atty.) (Rep. Harless)
Ross Giesinger (Atty.)
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 5 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 5 of 181
6
TX_00041876 TX_00041880
Attorney-Client Privilege; Legislative Privilege
Document responsive to a public information law request that was provided to the council in order to obtain legal advice regarding the request. Reflects legislator thoughts, opinions, or mental impressions on Voter ID. 11/29/2011
TLC (LEGAL DIVISION)
Colby Beuck (Atty.) (Rep. Harless)
Ross Giesinger (Atty.)
TX_00041881 TX_00041884
Attorney-Client Privilege; Legislative Privilege
Document responsive to a public information law request that was provided to the council in order to obtain legal advice regarding the request. Reflects legislator thoughts, opinions, or mental impressions on Voter ID. 11/29/2011
TLC (LEGAL DIVISION)
Colby Beuck (Atty.) (Rep. Harless)
Ross Giesinger (Atty.)
TX_00041885 TX_00041887
Attorney-Client Privilege; Legislative Privilege
Document responsive to a public information law request that was provided to the council in order to obtain legal advice regarding the request. Reflects legislator thoughts, opinions, or mental impressions on Voter ID. 11/29/2011
TLC (LEGAL DIVISION)
Colby Beuck (Atty.) (Rep. Harless)
Ross Giesinger (Atty.)
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 6 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 6 of 181
7
TX_00041888 TX_00041889
Attorney-Client Privilege; Legislative Privilege
Document responsive to a public information law request that was provided to the council in order to obtain legal advice regarding the request. Reflects legislator thoughts, opinions, or mental impressions on Voter ID. Reflects legislator thoughts, opinions, or mental impressions on Voter ID. 11/29/2011
TLC (LEGAL DIVISION)
Colby Beuck (Atty.) (Rep. Harless)
Ross Giesinger (Atty.)
TX_00041890 TX_00041894
Attorney-Client Privilege; Legislative Privilege
Document responsive to a public information law request that was provided to the council in order to obtain legal advice regarding the request. Reflects legislator thoughts, opinions, or mental impressions on Voter ID. 11/29/2011
TLC (LEGAL DIVISION)
Colby Beuck (Atty.) (Rep. Harless)
Ross Giesinger (Atty.)
TX_00041895 TX_00041896
Attorney-Client Privilege; Legislative Privilege
Document responsive to a public information law request that was provided to the council in order to obtain legal advice regarding the request. Reflects legislator thoughts, opinions, or mental impressions on Voter ID. 11/29/2011
TLC (LEGAL DIVISION)
Colby Beuck (Atty.) (Rep. Harless)
Ross Giesinger (Atty.)
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 7 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 7 of 181
8
TX_00041897 TX_00041947
Attorney-Client Privilege; Legislative Privilege
Document responsive to a public information law request that was provided to the council in order to obtain legal advice regarding the request. Reflects legislator thoughts, opinions, or mental impressions on Voter ID. 11/29/2011
TLC (LEGAL DIVISION)
Colby Beuck (Atty.) (Rep. Harless)
Ross Giesinger (Atty.)
TX_00041948 TX_00042058
Attorney-Client Privilege; Legislative Privilege
Document responsive to a public information law request that was provided to the council in order to obtain legal advice regarding the request. Reflects legislator thoughts, opinions, or mental impressions on Voter ID. 11/29/2011
TLC (LEGAL DIVISION)
Colby Beuck (Atty.) (Rep. Harless)
Ross Giesinger (Atty.)
TX_00042059 TX_00042059
Attorney-Client Privilege; Legislative Privilege
Document responsive to a public information law request that was provided to the council in order to obtain legal advice regarding the request. Reflects legislator thoughts, opinions, or mental impressions on Voter ID. 11/29/2011
TLC (LEGAL DIVISION)
Colby Beuck (Atty.) (Rep. Harless)
Ross Giesinger (Atty.)
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 8 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 8 of 181
9
TX_00042060 TX_00042111
Attorney-Client Privilege; Legislative Privilege
Document responsive to a public information law request that was provided to the council in order to obtain legal advice regarding the request. Reflects legislator thoughts, opinions, or mental impressions on Voter ID. 11/29/2011
TLC (LEGAL DIVISION)
Colby Beuck (Atty.) (Rep. Harless)
Ross Giesinger (Atty.)
TX_00042138 TX_00042138
Attorney-Client Privilege; Legislative Privilege
Confidential legal analysis of compliance with legislative rules and the Texas Constitution prepared by an attorney that was requested by and provided to legislative clients separately and independently.
(82nd Legislature)
TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Karina Davis (Senate Parliamentarian) & Chris Griesel (House Parliamentarian/Atty.)
TX_00042139 TX_00042141
Attorney-Client Privilege; Legislative Privilege
Notes re: telephone discussions seeking legal advice on legislative drafting. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
(82nd Legislature)
TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Sen. Lucio; Rep. Y. Davis; Rep. Harless (Rep. Y. Davis has waived privileges.)
TX_00042142 TX_00042142
Attorney-Client Privilege; Legislative Privilege
Notes re: telephone discussions seeking legal advice on legislative drafting. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
12/15/2010 (82nd
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Rep. Todd Smith
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 9 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 9 of 181
10
TX_00042143 TX_00042143
Attorney-Client Privilege; Legislative Privilege
Confidential legal analysis of compliance with legislative rules and the Texas Constitution prepared by an attorney that was requested by and provided to legislative clients separately and independently. (Part.)
5/5/2011 (82nd
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Karina Davis (Senate Parliamentarian) & Chris Griesel (House Parliamentarian/Atty.)
TX_00042144 TX_00042144
Attorney-Client Privilege; Legislative Privilege
Confidential legal analysis of compliance with legislative rules and the Texas Constitution prepared by an attorney that was requested by and provided to legislative clients separately and independently. (Part.)
5/5/2011 (82nd
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Karina Davis (Senate Parliamentarian) & Chris Griesel (House Parliamentarian/Atty.)
TX_00042145 TX_00042145
Attorney-Client Privilege; Legislative Privilege
Confidential communication among TLC attorneys containing legal research on Voter ID laws in other states.
3/11/2011 (82nd
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Anne Peters (Atty.)
TX_00042146 TX_00042146
Attorney-Client Privilege; Legislative Privilege
Confidential legal analysis of compliance with legislative rules and the Texas Constitution prepared by an attorney that was requested by and provided to legislative clients separately and independently. (Part.)
5/5/2011 (82nd
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Karina Davis (Senate Parliamentarian) & Chris Griesel (House Parliamentarian/Atty.)
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 10 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 10 of 181
11
TX_00042147 TX_00042147
Attorney-Client Privilege; Legislative Privilege
Confidential legal analysis of compliance with legislative rules and the Texas Constitution prepared by an attorney that was requested by and provided to legislative clients separately and independently. (Part.)
5/5/2011 (82nd
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Karina Davis (Senate Parliamentarian) & Chris Griesel (House Parliamentarian/Atty.)
TX_00042151 TX_00042154 Legislative Privilege
Drafting file for house committee-hearing stage analysis of SB 14 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill as required by house rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
2/25/2011 (82nd
Legislature)
TLC (RESEARCH DIVISION) Liz Morris Rep. Bonnen
TX_00042155 TX_00042161 Legislative Privilege
Drafting file for house committee-hearing stage analysis of SB 14 documenting information relating to the production of confidential proposed detailed analysis of the
2/25/2011 (82nd
Legislature)
TLC (RESEARCH DIVISION) Liz Morris Rep. Bonnen
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 11 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 11 of 181
12
subject matter and other content of a bill as required by house rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
TX_00042162 TX_00042168 Legislative Privilege
Drafting file for house committee-hearing stage analysis of SB 14 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill as required by house rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
2/23/2011 (82nd
Legislature)
TLC (RESEARCH DIVISION) Liz Morris Rep. Bonnen
TX_00042169 TX_00042175 Legislative Privilege
Drafting file for house committee-hearing stage analysis of SB 14 documenting information relating to the production of
2/25/2011 (82nd
Legislature)
TLC (RESEARCH DIVISION) Liz Morris Rep. Bonnen
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 12 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 12 of 181
13
confidential proposed detailed analysis of the subject matter and other content of a bill as required by house rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
TX_00042176 TX_00042182 Legislative Privilege
Drafting file for house committee-hearing stage analysis of SB 14 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill as required by house rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
2/23/2011 (82nd
Legislature)
TLC (RESEARCH DIVISION) Liz Morris Rep. Bonnen
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 13 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 13 of 181
14
TX_00042183 TX_00042189 Legislative Privilege
Drafting file for house committee-hearing stage analysis of SB 14 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill as required by house rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
2/25/2011 (82nd
Legislature)
TLC (RESEARCH DIVISION) Liz Morris Rep. Bonnen
TX_00042190 TX_00042193 Legislative Privilege
Drafting file for house committee-hearing stage analysis of SB 14 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill as required by house rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental
2/25/2011 (82nd
Legislature)
TLC (RESEARCH DIVISION) Liz Morris Rep. Bonnen
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 14 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 14 of 181
15
impressions on Voter ID.
TX_00042194 TX_00042200 Legislative Privilege
Drafting file for house committee-hearing stage analysis of SB 14 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill as required by house rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
2/23/2011 (82nd
Legislature)
TLC (RESEARCH DIVISION) Liz Morris Rep. Bonnen
TX_00042201 TX_00042204 Legislative Privilege
Drafting file for house committee-hearing stage analysis of SB 14 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill as required by house rules and that was requested by and
2/25/2011 (82nd
Legislature)
TLC (RESEARCH DIVISION) Liz Morris Rep. Bonnen
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 15 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 15 of 181
16
provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
TX_00042205 TX_00042205 Legislative Privilege
Drafting file for house committee-hearing stage analysis of SB 14 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill as required by house rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
2/23/2011 (82nd
Legislature)
TLC (RESEARCH DIVISION) Liz Morris Rep. Bonnen
TX_00042206 TX_00042210 Legislative Privilege
Drafting file for house second-reading stage analysis of SB 14 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill as required by house
3/15/2011 (82nd
Legislature)
TLC (RESEARCH DIVISION) Liz Morris Rep. Bonnen
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 16 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 16 of 181
17
rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
TX_00042211 TX_00042215 Legislative Privilege
Drafting file for house second-reading stage analysis of SB 14 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill as required by house rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
3/10/2011 (82nd
Legislature)
TLC (RESEARCH DIVISION) Liz Morris Rep. Bonnen
TX_00042216 TX_00042224 Legislative Privilege
Drafting file for house second-reading stage analysis of SB 14 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and
3/10/2011 (82nd
Legislature)
TLC (RESEARCH DIVISION) Liz Morris Rep. Bonnen
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 17 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 17 of 181
18
other content of a bill as required by house rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
TX_00042225 TX_00042234 Legislative Privilege
Drafting file for house second-reading stage analysis of SB 14 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill as required by house rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
3/21/2011 (82nd
Legislature)
TLC (RESEARCH DIVISION) Liz Morris Rep. Bonnen
TX_00042235 TX_00042242 Legislative Privilege
Drafting file for house second-reading stage analysis of SB 14 documenting information relating to the production of confidential proposed
3/15/2011 (82nd
Legislature)
TLC (RESEARCH DIVISION) Liz Morris Rep. Bonnen
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 18 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 18 of 181
19
detailed analysis of the subject matter and other content of a bill as required by house rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
TX_00042243 TX_00042247 Legislative Privilege
Drafting file for house second-reading stage analysis of SB 14 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill as required by house rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
3/15/2011 (82nd
Legislature)
TLC (RESEARCH DIVISION) Liz Morris Rep. Bonnen
TX_00042248 TX_00042252 Legislative Privilege
Drafting file for house second-reading stage analysis of SB 14 documenting information relating to
3/10/2011 (82nd
Legislature)
TLC (RESEARCH DIVISION) Liz Morris Rep. Bonnen
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 19 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 19 of 181
20
the production of confidential proposed detailed analysis of the subject matter and other content of a bill as required by house rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
TX_00042253 TX_00042257 Legislative Privilege
Drafting file for house second-reading stage analysis of SB 14 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill as required by house rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
3/15/2011 (82nd
Legislature)
TLC (RESEARCH DIVISION) Liz Morris Rep. Bonnen
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 20 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 20 of 181
21
TX_00042258 TX_00042262 Legislative Privilege
Drafting file for house second-reading stage analysis of SB 14 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill as required by house rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
3/21/2011 (82nd
Legislature)
TLC (RESEARCH DIVISION) Liz Morris Rep. Bonnen
TX_00042263 TX_00042267 Legislative Privilege
Drafting file for house second-reading stage analysis of SB 14 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill as required by house rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental
3/21/2011 (82nd
Legislature)
TLC (RESEARCH DIVISION) Liz Morris Rep. Bonnen
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 21 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 21 of 181
22
impressions on Voter ID.
TX_00042268 TX_00042272 Legislative Privilege
Drafting file for house second-reading stage analysis of SB 14 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill as required by house rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
3/21/2011 (82nd
Legislature)
TLC (RESEARCH DIVISION) Liz Morris Rep. Bonnen
TX_00042273 TX_00042277 Legislative Privilege
Drafting file for house second-reading stage analysis of SB 14 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill as required by house rules and that was requested by and provided to the
3/10/2011 (82nd
Legislature)
TLC (RESEARCH DIVISION) Liz Morris Rep. Bonnen
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 22 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 22 of 181
23
legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
TX_00042278 TX_00042281 Legislative Privilege
Drafting file for house second-reading stage analysis of SB 14 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill as required by house rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
(82nd Legislature)
TLC (RESEARCH DIVISION) Liz Morris Rep. Bonnen
TX_00042282 TX_00042286 Legislative Privilege
Drafting file for house second-reading stage analysis of SB 14 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill as required by house rules and that was
3/21/2011 (82nd
Legislature)
TLC (RESEARCH DIVISION) Liz Morris Rep. Bonnen
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 23 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 23 of 181
24
requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
TX_00042287 TX_00042288 Legislative Privilege
Drafting file for house second-reading stage analysis of SB 14 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill as required by house rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
2/25/2011 (82nd
Legislature)
TLC (RESEARCH DIVISION) Liz Morris Rep. Bonnen
TX_00042289 TX_00042308
Attorney-Client Privilege; Legislative Privilege
Drafting file for house committee-stage analysis of SB 14 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill
2/25/2011 (82nd
Legislature)
TLC (RESEARCH DIVISION) Liz Morris Sen. Fraser
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 24 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 24 of 181
25
as required by house rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
TX_00042309 TX_00042309 Legislative Privilege
Conference committee report side-by-side drafting file reflecting legislator communications. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
4/18/2011 (82nd
Legislature)
TLC (RESEARCH DIVISION) Liz Morris Sen. Fraser
TX_00042310 TX_00042319 Legislative Privilege
Conference committee report side-by-side drafting file reflecting legislator communications. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
4/27/2011 (82nd
Legislature)
TLC (RESEARCH DIVISION) Liz Morris Sen. Fraser
TX_00042320 TX_00042329 Legislative Privilege
Conference committee report side-by-side drafting file reflecting legislator communications. (Part.) Reflects legislator thoughts, opinions, or mental
4/29/2011 (82nd
Legislature)
TLC (RESEARCH DIVISION) Liz Morris Sen. Fraser
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 25 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 25 of 181
26
impressions on Voter ID.
TX_00042330 TX_00042339 Legislative Privilege
Conference committee report side-by-side drafting file reflecting legislator communications. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
4/29/2011 (82nd
Legislature)
TLC (RESEARCH DIVISION) Liz Morris Sen. Fraser
TX_00042340 TX_00042349 Legislative Privilege
Conference committee report side-by-side drafting file reflecting legislator communications. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
4/27/2011 (82nd
Legislature)
TLC (RESEARCH DIVISION) Liz Morris Sen. Fraser
TX_00042350 TX_00042359 Legislative Privilege
Conference committee report side-by-side drafting file reflecting legislator communications. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
4/27/2011 (82nd
Legislature)
TLC (RESEARCH DIVISION) Liz Morris Sen. Fraser
TX_00042360 TX_00042369 Legislative Privilege
Conference committee report side-by-side drafting file reflecting legislator
4/27/2011 (82nd
Legislature)
TLC (RESEARCH DIVISION) Liz Morris Sen. Fraser
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 26 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 26 of 181
27
communications. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
TX_00042370 TX_00042379 Legislative Privilege
Conference committee report side-by-side drafting file reflecting legislator communications. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
4/27/2011 (82nd
Legislature)
TLC (RESEARCH DIVISION) Liz Morris Sen. Fraser
TX_00042380 TX_00042396 Legislative Privilege
Conference committee report side-by-side drafting file reflecting legislator communications. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
TLC (RESEARCH DIVISION) Liz Morris Sen. Fraser
TX_00042397 TX_00042401 Legislative Privilege
Drafting file for house second-reading stage analysis of SB 14 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill as required by house rules and that was
3/15/2011 (82nd
Legislature)
TLC (RESEARCH DIVISION) Liz Morris Rep. Bonnen
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 27 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 27 of 181
28
requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
TX_00042402 TX_00042406 Legislative Privilege
Drafting file for house second-reading stage analysis of SB 14 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill as required by house rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
3/21/2011 (82nd
Legislature)
TLC (RESEARCH DIVISION) Liz Morris Rep. Bonnen
TX_00042407 TX_00042407 Legislative Privilege
Drafting file for house second-reading stage analysis of SB 14 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill
3/25/2011 (82nd
Legislature)
TLC (RESEARCH DIVISION) Liz Morris Rep. Bonnen
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 28 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 28 of 181
29
as required by house rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
TX_00042408 TX_00042408 Legislative Privilege
Drafting file for house second-reading stage analysis of SB 14 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill as required by house rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
3/15/2011 (82nd
Legislature)
TLC (RESEARCH DIVISION) Liz Morris Rep. Bonnen
TX_00042409 TX_00042409 Legislative Privilege
Drafting file for house second-reading stage analysis of SB 14 documenting information relating to the production of confidential proposed detailed analysis of the
3/15/2011 (82nd
Legislature)
TLC (RESEARCH DIVISION) Liz Morris Rep. Bonnen
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 29 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 29 of 181
30
subject matter and other content of a bill as required by house rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
TX_00042410 TX_00042413 Legislative Privilege
Drafting file for house second-reading stage analysis of SB 14 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill as required by house rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
3/15/2011 (82nd
Legislature)
TLC (RESEARCH DIVISION)
Liz Morris; Jennifer Jackson (Atty.) Rep. Bonnen
TX_00042414 TX_00042428 Legislative Privilege
Drafting file for house second-reading stage analysis of SB 14 documenting information relating to the production of
3/15/2011 (82nd
Legislature)
TLC (RESEARCH DIVISION) Liz Morris Rep. Bonnen
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 30 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 30 of 181
31
confidential proposed detailed analysis of the subject matter and other content of a bill as required by house rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
TX_00042429 TX_00042429 Legislative Privilege
Drafting file for house second-reading stage analysis of SB 14 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill as required by house rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
3/15/2011 (82nd
Legislature)
TLC (RESEARCH DIVISION) Liz Morris Rep. Bonnen
TX_00042430 TX_00042433 Legislative Privilege
Drafting file for house committee stage analysis of SB 14 documenting
2/25/2011 (82nd
Legislature)
TLC (RESEARCH DIVISION) Liz Morris Rep. Bonnen
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 31 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 31 of 181
32
information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill as required by house rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
TX_00042434 TX_00042434 Legislative Privilege
Drafting file for house second-reading stage analysis of SB 14 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill as required by house rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
2/25/2011 (82nd
Legislature)
TLC (RESEARCH DIVISION) Liz Morris Rep. Bonnen
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 32 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 32 of 181
33
TX_00042435 TX_00042435 Legislative Privilege
Drafting file for house second-reading stage analysis of SB 14 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill as required by house rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
2/25/2011 (82nd
Legislature)
TLC (RESEARCH DIVISION) Liz Morris Rep. Bonnen
TX_00042436 TX_00042436 Legislative Privilege
Drafting file for house second-reading stage analysis of SB 14 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill as required by house rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental
2/25/2011 (82nd
Legislature)
TLC (RESEARCH DIVISION) Liz Morris Rep. Bonnen
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 33 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 33 of 181
34
impressions on Voter ID.
TX_00042437 TX_00042437 Legislative Privilege
Drafting file for house second-reading stage analysis of SB 14 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill as required by house rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
2/25/2011 (82nd
Legislature)
TLC (RESEARCH DIVISION) Liz Morris Rep. Bonnen
TX_00042438 TX_00042438 Legislative Privilege
Drafting file for house second-reading stage analysis of SB 14 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill as required by house rules and that was requested by and provided to the
3/21/2011 (82nd
Legislature)
TLC (RESEARCH DIVISION) Liz Morris Rep. Bonnen
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 34 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 34 of 181
35
legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
TX_00042439 TX_00042439 Legislative Privilege
Drafting file for house second-reading stage analysis of SB 14 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill as required by house rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
3/15/2011 (82nd
Legislature)
TLC (RESEARCH DIVISION) Liz Morris Rep. Bonnen
TX_00042440 TX_00042440
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the
2/25/2011 (82nd
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Harless
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 35 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 35 of 181
36
legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
TX_00042441 TX_00042473
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
1/13/2011 (82nd
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Hopson
TX_00042474 TX_00042501
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
10/25/2010 (82nd
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Harless
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 36 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 36 of 181
37
Voter ID.
TX_00042502 TX_00042516
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
1/3/2011 (82nd
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Harless
TX_00042517 TX_00042522
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
2/17/2011 (82nd
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Isaac
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 37 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 37 of 181
38
Voter ID.
TX_00042523 TX_00042578
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
7/20/2010 (82nd
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Riddle
TX_00042579 TX_00042592
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
11/12/2010 (82nd
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Rep. Hilderbran
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 38 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 38 of 181
39
Voter ID.
TX_00042593 TX_00042659
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
7/21/2010 (82nd
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Rep. Betty Brown
TX_00042660 TX_00042730
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
11/12/2010 (82nd
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Rep. Hilderbran
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 39 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 39 of 181
40
Voter ID.
TX_00042731 TX_00042778
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
11/18/2010 (82nd
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Rep. Todd Smith
TX_00042779 TX_00042804
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
12/17/2010 (82nd
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Bonnen
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 40 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 40 of 181
41
Voter ID.
TX_00042805 TX_00042831
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
11/5/2010 (82nd
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Rep. “Doc” Anderson
TX_00042832 TX_00042835
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
3/23/2011 (82nd
Legislature) TLC (LEGAL DIVISION)
Anne Peters (Atty.) Rep. Castro
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 41 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 41 of 181
42
Voter ID.
TX_00042850 TX_00042852
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
1/24/2011 (82nd
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Sen. Williams
TX_00042900 TX_00042904
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
1/21/2011 (82nd
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Sen. Birdwell
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 42 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 42 of 181
43
Voter ID.
TX_00042995 TX_00043013
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID. (Lieutenant governor acts in a legislative capacity when serving as president of the senate.)
1/26/2011 (82nd
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Lt. Gov. Dewhurst
TX_00043014 TX_00043016
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as
1/26/2011 (82nd
Legislature) TLC (LEGAL DIVISION)
Anne Peters (Atty.)
Sen. Dan Patrick
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 43 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 43 of 181
44
requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
TX_00043028 TX_00043078
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
2/2/2011 (82nd
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Bohac
TX_00043079 TX_00043090
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or
2/2/2011 (82nd
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Rep. Van Taylor
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 44 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 44 of 181
45
mental impressions on Voter ID.
TX_00043091 TX_00043127
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
2/17/2011 (82nd
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Bonnen
TX_00043128 TX_00043171
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
2/25/2011 (82nd
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Harless
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 45 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 45 of 181
46
Voter ID.
TX_00043172 TX_00043177
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
3/15/2011 (82nd
Legislature) TLC (LEGAL DIVISION)
Anne Peters (Atty.) Rep. Bonnen
TX_00043178 TX_00043183
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
3/15/2011 (82nd
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Bonnen
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 46 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 46 of 181
47
Voter ID.
TX_00043184 TX_00043190
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
3/15/2011 (82nd
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Bonnen
TX_00043191 TX_00043212
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
3/15/2011 (82nd
Legislature) TLC (LEGAL DIVISION)
Anne Peters (Atty.) Rep. Bonnen
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 47 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 47 of 181
48
Voter ID.
TX_00043213 TX_00043218
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
3/15/2011 (82nd
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Bonnen
TX_00043237 TX_00043244
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
3/17/2011 (82nd
Legislature) TLC (LEGAL DIVISION)
David Hanna (Atty.) Rep. Alonzo
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 48 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 48 of 181
49
Voter ID.
TX_00043245 TX_00043252
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
3/17/2011 (82nd
Legislature) TLC (LEGAL DIVISION)
David Hanna (Atty.) Rep. Alonzo
TX_00043253 TX_00043265
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
3/17/2011 (82nd
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Alonzo
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 49 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 49 of 181
50
Voter ID.
TX_00043266 TX_00043290
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
3/17/2011 (82nd
Legislature) TLC (LEGAL DIVISION)
Allison Zaby (Atty.) Rep. Alonzo
TX_00043291 TX_00043298
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
3/17/2011 (82nd
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Alonzo
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 50 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 50 of 181
51
Voter ID.
TX_00043299 TX_00043307
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
3/17/2011 (82nd
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Alonzo
TX_00043308 TX_00043312
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
3/21/2011 (82nd
Legislature) TLC (LEGAL DIVISION)
Anne Peters (Atty.) Rep. Zedler
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 51 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 51 of 181
52
Voter ID.
TX_00043313 TX_00043322
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
3/21/2011 (82nd
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Zedler
TX_00043323 TX_00043330
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
3/21/2011 (82nd
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Branch
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 52 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 52 of 181
53
Voter ID.
TX_00043339 TX_00043343
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
3/21/2011 (82nd
Legislature) TLC (LEGAL DIVISION)
Mark Wimmer (Atty.) Rep. Alonzo
TX_00043344 TX_00043347
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
3/22/2011 (82nd
Legislature) TLC (LEGAL DIVISION)
Anne Peters (Atty.) Rep. Alonzo
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 53 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 53 of 181
54
Voter ID.
TX_00043348 TX_00043353
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
3/22/2011 (82nd
Legislature) TLC (LEGAL DIVISION)
Anne Peters (Atty.) Rep. Bonnen
TX_00043354 TX_00043359
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
3/23/2011 (82nd
Legislature) TLC (LEGAL DIVISION)
Anne Peters (Atty.)
Rep. Castro; Rep. Martinez-Fisher (Martinez-Fisher has waived privileges.)
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 54 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 54 of 181
55
Voter ID.
TX_00043372 TX_00043375
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
3/23/2011 (82nd
Legislature) TLC (LEGAL DIVISION)
Anne Peters (Atty.) Rep. Alonzo
TX_00043376 TX_00043379
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client.
3/23/2011 (82nd
Legislature) TLC (LEGAL DIVISION)
Anne Peters (Atty.) Rep. Alonzo
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 55 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 55 of 181
56
Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
TX_00043390 TX_00043395
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
3/27/2011 (82nd
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Lozano
TX_00043405 TX_00043413
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
4/1/2011 (82nd
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Sen. Watson
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 56 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 56 of 181
57
Voter ID.
TX_00043414 TX_00043493
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
4/18/2011 (82nd
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Sen. Fraser
TX_00043494 TX_00043513
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
4/20/2011 (82nd
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Sen. Fraser
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 57 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 57 of 181
58
Voter ID.
TX_00043514 TX_00043527
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
4/20/2011 (82nd
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Sen. Fraser
TX_00043528 TX_00043545
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
4/26/2011 (82nd
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Sen. Fraser
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 58 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 58 of 181
59
Voter ID.
TX_00043546 TX_00043562
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
12/21/2010 (82nd
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Sen. Williams
TX_00043563 TX_00043578
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
12/21/2010 (82nd
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Sen. Williams
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 59 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 59 of 181
60
Voter ID.
TX_00043579 TX_00043610
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
10/11/2010 (82nd
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Sen. Birdwell & Sen. Fraser
TX_00043611 TX_00043644
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
12/13/2010 (82nd
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Rep. Hilderbran
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 60 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 60 of 181
61
Voter ID.
TX_00043645 TX_00043657
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
12/13/2010 (82nd
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Elkins
TX_00043658 TX_00043716
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
10/11/2010 (82nd
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Rep. Todd Smith
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 61 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 61 of 181
62
Voter ID.
TX_00043717 TX_00043737
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
11/29/2010 (82nd
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Bohac
TX_00043738 TX_00043747
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
2/16/2011 (82nd
Legislature) TLC (LEGAL DIVISION)
Anne Peters (Atty.) Rep. Sheets
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 62 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 62 of 181
63
Voter ID.
TX_00043748 TX_00043772 Legislative Privilege
Research relating to Arizona Voter ID law and reflecting legislator communications. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
4/14/2009 (81st
Legislature)
TLC (RESEARCH DIVISION) Jason Bane
Rep. Todd Smith
TX_00043773 TX_00043774 Legislative Privilege
Research relating to Arizona Voter ID law and reflecting legislator communications. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
4/14/2009 (81st
Legislature)
TLC (RESEARCH DIVISION) Jason Bane
Rep. Todd Smith
TX_00043775 TX_00044164 Legislative Privilege
Research relating to Voter/ballot fraud in the State of Texas and reflecting legislator communications. 2/24/2006
TLC (RESEARCH DIVISION)
Amy Young (Deceased.) Rep. Denny
TX_00044165 TX_00044170 Legislative Privilege
Research relating to Florida voter ID law and acceptance of provisional ballots and reflecting legislator communications. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter
3/26/2009 (81st
Legislature)
TLC (RESEARCH DIVISION) Jason Bane
Rep. Todd Smith
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 63 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 63 of 181
64
ID.
TX_00044171 TX_00044171 Legislative Privilege
Research relating to Florida voter ID law and acceptance of provisional ballots and reflecting legislator communications. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
3/26/2009 (81st
Legislature)
TLC (RESEARCH DIVISION) Jason Bane
Rep. Todd Smith
TX_00044172 TX_00044191 Legislative Privilege
Update of research relating to Voter/ballot fraud in the State of Texas and reflecting legislator communications. Reflects legislator thoughts, opinions, or mental impressions on Voter ID. 1/2/2008
TLC (RESEARCH DIVISION)
Chandler Lewis Rep. Berman
TX_00075930 TX_00075931 Legislative Privilege
Drafting file for house committee stage bill analysis for HB 125 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill as required by house rules and that was
3/31/2009 (81st
Legislature)
TLC (RESEARCH DIVISION) Liz Morris
Rep. Todd Smith
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 64 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 64 of 181
65
requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
TX_00075932 TX_00075932 Legislative Privilege
Drafting file for house committee stage bill analysis for HB 125 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill as required by house rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
3/31/2009 (81st
Legislature)
TLC (RESEARCH DIVISION) Liz Morris
Rep. Todd Smith
TX_00075933 TX_00075935 Legislative Privilege
Drafting file for house committee stage bill analysis for HB 125 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill
3/31/2009 (81st
Legislature)
TLC (RESEARCH DIVISION) Liz Morris
Rep. Todd Smith
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 65 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 65 of 181
66
as required by house rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
TX_00075936 TX_00075938 Legislative Privilege
Drafting file for house committee stage bill analysis for HB 125 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill as required by house rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
3/31/2009 (81st
Legislature)
TLC (RESEARCH DIVISION) Liz Morris
Rep. Todd Smith
TX_00075939 TX_00075941 Legislative Privilege
Drafting file for house committee stage bill analysis for HB 125 documenting information relating to the production of confidential proposed detailed analysis of the
3/31/2009 (81st
Legislature)
TLC (RESEARCH DIVISION) Liz Morris
Rep. Todd Smith
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 66 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 66 of 181
67
subject matter and other content of a bill as required by house rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
TX_00075949 TX_00075949 Legislative Privilege
Drafting file for house committee stage bill analysis for HB 3556 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill as required by house rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
3/31/2009 (81st
Legislature)
TLC (RESEARCH DIVISION) Liz Morris
Rep. Todd Smith
TX_00075950 TX_00075952 Legislative Privilege
Drafting file for house committee stage bill analysis for HB 3556 documenting information relating to the production of
3/31/2009 (81st
Legislature)
TLC (RESEARCH DIVISION) Liz Morris
Rep. Todd Smith
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 67 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 67 of 181
68
confidential proposed detailed analysis of the subject matter and other content of a bill as required by house rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
TX_00075953 TX_00075955 Legislative Privilege
Drafting file for house committee stage bill analysis for HB 3556 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill as required by house rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
3/31/2009 (81st
Legislature)
TLC (RESEARCH DIVISION) Liz Morris
Rep. Todd Smith
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 68 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 68 of 181
69
TX_00075956 TX_00075960 Legislative Privilege
Drafting file for house committee stage bill analysis for HB 3556 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill as required by house rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
3/31/2009 (81st
Legislature)
TLC (RESEARCH DIVISION) Liz Morris
Rep. Todd Smith
TX_00075961 TX_00075962 Legislative Privilege
Drafting file for house committee stage bill analysis for HB 3556 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill as required by house rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental
3/31/2009 (81st
Legislature)
TLC (RESEARCH DIVISION) Liz Morris
Rep. Todd Smith
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 69 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 69 of 181
70
impressions on Voter ID.
TX_00075969 TX_00075977 Legislative Privilege
Drafting file for house committee stage bill analysis for SB 362 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill as required by house rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
3/31/2009 (81st
Legislature)
TLC (RESEARCH DIVISION) Liz Morris
Rep. Todd Smith
TX_00075978 TX_00075986 Legislative Privilege
Drafting file for house committee stage bill analysis for SB 362 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill as required by house rules and that was requested by and
3/31/2009 (81st
Legislature)
TLC (RESEARCH DIVISION) Liz Morris
Rep. Todd Smith
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 70 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 70 of 181
71
provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
TX_00075987 TX_00075989 Legislative Privilege
Drafting file for house committee stage bill analysis for SB 362 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill as required by house rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
3/31/2009 (81st
Legislature)
TLC (RESEARCH DIVISION) Liz Morris
Rep. Todd Smith
TX_00075990 TX_00075992 Legislative Privilege
Drafting file for house committee stage bill analysis for SB 362 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill as required by house
3/31/2009 (81st
Legislature)
TLC (RESEARCH DIVISION) Liz Morris
Rep. Todd Smith
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 71 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 71 of 181
72
rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
TX_00075993 TX_00075995 Legislative Privilege
Drafting file for house committee stage bill analysis for SB 362 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill as required by house rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
3/31/2009 (81st
Legislature)
TLC (RESEARCH DIVISION) Liz Morris
Rep. Todd Smith
TX_00075996 TX_00075997 Legislative Privilege
Drafting file for house committee stage bill analysis for SB 362 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and
3/31/2009 (81st
Legislature)
TLC (RESEARCH DIVISION) Liz Morris
Rep. Todd Smith
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 72 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 72 of 181
73
other content of a bill as required by house rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
TX_00075998 TX_00075998 Legislative Privilege
Drafting file for house committee stage bill analysis for SB 362 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill as required by house rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
3/31/2009 (81st
Legislature)
TLC (RESEARCH DIVISION) Liz Morris
Rep. Todd Smith
TX_00075999 TX_00076000 Legislative Privilege
Drafting file for house committee stage bill analysis for SB 362 documenting information relating to the production of confidential proposed
3/31/2009 (81st
Legislature)
TLC (RESEARCH DIVISION) Liz Morris
Rep. Todd Smith
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 73 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 73 of 181
74
detailed analysis of the subject matter and other content of a bill as required by house rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
TX_00076001 TX_00076003 Legislative Privilege
Drafting file for house committee stage bill analysis for SB 362 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill as required by house rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
3/31/2009 (81st
Legislature)
TLC (RESEARCH DIVISION) Liz Morris
Rep. Todd Smith
TX_00205341 TX_00205341 Legislative Privilege
Confidential email between TLC and committee staff discussing the timing of the consideration of
3/07/2011 (82nd Legislature)
TLC (RESEARCH DIVISION)
Carey Eskridge
Tammy Edgerly; Liz Morris; Kindal Wetuski
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 74 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 74 of 181
75
legislation and reflecting legislator communications. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
TX_00205342 TX_00205345 Legislative Privilege
Email attachment--analysis of proposed legislation documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill as required by house rules and that was requested by and provided to the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
(82nd Legislature)
TLC (RESEARCH DIVISION)
TX_00205346 TX_00205360 Legislative Privilege
Email attachment--proposed legislation. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
(82nd Legislature)
TLC (RESEARCH DIVISION)
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 75 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 75 of 181
76
TX_00206169 TX_00206170
Attorney-Client Privilege; Legislative Privilege
Confidential email from third-party attorney to legislative staff sent for the purpose of providing legal advice regarding voter ID legislation.
3/26/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Glen Shuffler (Atty. assisting Rep. Bonnen's office.)
Steven Schar (Rep. Todd Smith); Jennifer Jackson (Atty.); Travis Richmond (Rep. Todd Smith)
TX_00206173 TX_00206173 Legislative Privilege
Confidential email between TLC and committee staff relating to the background and purpose section of an analysis of legislation and reflecting legislator communications. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
2/23/2011 (82nd
Legislature)
TLC (RESEARCH DIVISION)
Carey Eskridge
Steven Schar (Rep. Bonnen)
TX_00206174 TX_00206174 Legislative Privilege
Confidential email between TLC and committee staff relating to the timing of an analysis of legislation and reflecting legislator communications. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
3/2/2011 (82nd
Legislature)
TLC (RESEARCH DIVISION)
Carey Eskridge
Steven Schar (Rep. Bonnen)
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 76 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 76 of 181
77
TX_00206175 TX_00206175 Legislative Privilege
Confidential email between TLC and committee staff relating to the timing of an analysis of legislation and reflecting legislator communications. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
3/2/2011 (82nd
Legislature)
TLC (RESEARCH DIVISION)
Steven Schar (Rep. Bonnen)
Carey Eskridge
TX_00206176 TX_00206176 Legislative Privilege
Confidential email between TLC and committee staff relating to the retraction of a request for the analysis of legislation and reflecting legislator communications. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
3/3/2011 (82nd
Legislature)
TLC (RESEARCH DIVISION)
Carey Eskridge
Steven Schar (Rep. Bonnen)
TX_00206177 TX_00206177 Legislative Privilege
Confidential email between TLC and committee staff relating to the timing of the consideration of voter ID legislation and to the substance of the legislation and reflecting legislator communications. Reflects legislator thoughts, opinions, or mental impressions on
3/7/2011 (82nd
Legislature)
TLC (RESEARCH DIVISION)
Steven Schar (Rep. Bonnen)
Carey Eskridge; Jason Thurlkill
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 77 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 77 of 181
78
Voter ID.
TX_00206178 TX_00206181 Legislative Privilege
Email attachment--proposed language for analysis of legislation reflecting legislator communications. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
(82nd Legislature)
TLC (RESEARCH DIVISION)
TX_00206182 TX_00206196 Legislative Privilege
Email attachment--proposed legislation. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
(82nd Legislature)
TLC (RESEARCH DIVISION)
TX_00206197 TX_00206197 Legislative Privilege
Confidential email between TLC and committee staff relating to the substance of an analysis of legislation and reflecting legislator communications. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
3/15/2011 (82nd
Legislature)
TLC (RESEARCH DIVISION)
Steven Schar (Rep. Bonnen)
Carey Eskridge
TX_00206198 TX_00206199 Legislative Privilege
Confidential email between TLC and committee staff relating to the delivery of an analysis of
3/15/2011 (82nd
Legislature)
TLC (RESEARCH DIVISION)
Steven Schar (Rep. Bonnen)
Carey Eskridge
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 78 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 78 of 181
79
legislation and reflecting legislator communications. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
TX_00206200 TX_00206200 Legislative Privilege
Confidential email between TLC and committee staff relating to the delivery of a comparison between two analyses of legislation and reflecting legislator communications. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
3/22/2011 (82nd
Legislature)
TLC (RESEARCH DIVISION)
Carey Eskridge
Steven Schar (Rep. Bonnen); Tammy Edgerly
TX_00206201 TX_00206205 Legislative Privilege
Email attachment—proposed analysis of proposed legislation. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
(82nd Legislature)
TLC (RESEARCH DIVISION)
TX_00206206 TX_00206206 Legislative Privilege
Nonresponsive confidential email between TLC and committee staff requesting analysis of legislation not related to voter ID reflecting legislator communications. Reflects legislator thoughts, opinions, or
5/7/2011 (82nd
Legislature)
TLC (RESEARCH DIVISION)
Bonnie L. Bruce (Rep. Solomons)
Tammy Edgerly; Liz Morris; B. Fitzgibbons (Rep. Deshotel)
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 79 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 79 of 181
80
mental impressions on Voter ID.
TX_00206207 TX_00206212 Legislative Privilege
Nonresponsive email attachment—proposed language for analysis of legislation not related to voter ID reflecting legislator communications. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
(82nd Legislature)
TLC (RESEARCH DIVISION)
TX_00206556 TX_00206569
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
3/21/2005 (79th
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Denny
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 80 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 80 of 181
81
TX_00206570 TX_00206579
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
3/29/2005 (79th
Legislature) TLC (LEGAL DIVISION)
David Hanna (Atty.) Rep. Denny
TX_00206612 TX_00206617
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
4/19/2005 (79th
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Escobar
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 81 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 81 of 181
82
TX_00206618 TX_00206626
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
4/19/2005 (79th
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Denny
TX_00206631 TX_00206643
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
4/19/2005 (79th
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Coleman
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 82 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 82 of 181
83
TX_00206644 TX_00206655
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
4/19/2005 (79th
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Chavez
TX_00206656 TX_00206659
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
4/18/2005 (79th
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Coleman
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 83 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 83 of 181
84
TX_00206751 TX_00206755
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/2/2005 (79th
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Leibowitz
TX_00206756 TX_00206767
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/2/2005 (79th
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Leibowitz
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 84 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 84 of 181
85
TX_00206768 TX_00206771
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/2/2005 (79th
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Leibowitz
TX_00206772 TX_00206775
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/2/2005 (79th
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Leibowitz
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 85 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 85 of 181
86
TX_00206776 TX_00206779
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/2/2005 (79th
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Leibowitz
TX_00206780 TX_00206783
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/2/2005 (79th
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Leibowitz
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 86 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 86 of 181
87
TX_00206784 TX_00206787
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/2/2005 (79th
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Leibowitz
TX_00206788 TX_00206791
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/2/2005 (79th
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Rep. Al Edwards
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 87 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 87 of 181
88
TX_00206792 TX_00206795
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/2/2005 (79th
Legislature) TLC (LEGAL DIVISION)
Cynthia Stein (Atty.) Rep. Chavez
TX_00206796 TX_00206799
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/2/2005 (79th
Legislature) TLC (LEGAL DIVISION)
Cynthia Stein (Atty.) Rep. Chavez
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 88 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 88 of 181
89
TX_00206800 TX_00206803
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/2/2005 (79th
Legislature) TLC (LEGAL DIVISION)
Cynthia Stein (Atty.) Rep. Chavez
TX_00206804 TX_00206825
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/20/2005 (79th
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Sen. Williams
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 89 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 89 of 181
90
TX_00206826 TX_00206836
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
2/25/2005 (79th
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Denny
TX_00206837 TX_00206852
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
3/4/2005 (79th
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Denny
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 90 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 90 of 181
91
TX_00206853 TX_00206873
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/17/2005 (79th
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Denny
TX_00206874 TX_00206904
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/18/2005 (79th
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Denny
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 91 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 91 of 181
92
TX_00206905 TX_00206916
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/21/2005 (79th
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Denny
TX_00206917 TX_00206920
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/24/2005 (79th
Legislature) TLC (LEGAL DIVISION)
Peg Peterson (Atty.) Rep. Solis
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 92 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 92 of 181
93
TX_00206921 TX_00206924
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/24/2005 (79th
Legislature) TLC (LEGAL DIVISION)
Peg Peterson (Atty.) Rep. Chavez
TX_00206925 TX_00206928
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/24/2005 (79th
Legislature) TLC (LEGAL DIVISION)
Peg Peterson (Atty.) Rep. Chavez
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 93 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 93 of 181
94
TX_00206929 TX_00206932
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/24/2005 (79th
Legislature) TLC (LEGAL DIVISION)
Peg Peterson (Atty.) Rep. Alonzo
TX_00206933 TX_00206937
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/24/2005 (79th
Legislature) TLC (LEGAL DIVISION)
Peg Peterson (Atty.) Rep. Chavez
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 94 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 94 of 181
95
TX_00206938 TX_00206941
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/25/2005 (79th
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Coleman
TX_00206942 TX_00206949
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/25/2005 (79th
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Coleman
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 95 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 95 of 181
96
TX_00206950 TX_00206956
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/25/2005 (79th
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Coleman
TX_00206957 TX_00206986
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
12/20/2004 (79th
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Nixon
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 96 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 96 of 181
97
TX_00206987 TX_00206990
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
2/23/2005 (79th
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Denny
TX_00206991 TX_00207020
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
3/7/2007 (80th
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Rep. Betty Brown
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 97 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 97 of 181
98
TX_00207283 TX_00207286
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
4/10/2007 (80th
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Leibowitz
TX_00207287 TX_00207298
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
4/10/2007 (80th
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Leibowitz
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 98 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 98 of 181
99
TX_00207299 TX_00207309
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
4/10/2007 (80th
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Leibowitz
TX_00207313 TX_00207322
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
4/13/2007 (80th
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Rep. Betty Brown
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 99 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 99 of 181
100
TX_00207323 TX_00207333
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
4/13/2007 (80th
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Rep. Betty Brown
TX_00207334 TX_00207343
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
4/13/2007 (80th
Legislature) TLC (LEGAL DIVISION)
Jon Heining (Atty.) Rep. Leibowitz
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 100 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 100 of 181
101
TX_00207344 TX_00207364
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
4/13/2007 (80th
Legislature) TLC (LEGAL DIVISION)
Anne Peters (Atty.) Rep. Leibowitz
TX_00207378 TX_00207389
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
4/16/2007 (80th
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Rep. Betty Brown
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 101 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 101 of 181
102
TX_00207401 TX_00207404
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
4/16/2007 (80th
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Rep. Betty Brown
TX_00207405 TX_00207415
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
4/16/2007 (80th
Legislature) TLC (LEGAL DIVISION)
Anne Peters (Atty.)
Rep. Betty Brown
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 102 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 102 of 181
103
TX_00207504 TX_00207513
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
4/19/2007 (80th
Legislature) TLC (LEGAL DIVISION)
David Hanna (Atty.)
Rep. Betty Brown
TX_00207514 TX_00207517
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
4/19/2007 (80th
Legislature) TLC (LEGAL DIVISION)
David Hanna (Atty.)
Rep. Betty Brown
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 103 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 103 of 181
104
TX_00207605 TX_00207614
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
4/20/2007 (80th
Legislature) TLC (LEGAL DIVISION)
Anne Peters (Atty.)
Rep. Betty Brown
TX_00207615 TX_00207620
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
4/21/2007 (80th
Legislature) TLC (LEGAL DIVISION)
David Hanna (Atty.) Rep. Strama
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 104 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 104 of 181
105
TX_00207621 TX_00207625
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
4/21/2007 (80th
Legislature) TLC (LEGAL DIVISION)
David Hanna (Atty.) Rep. Strama
TX_00207626 TX_00207637
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
4/23/2007 (80th
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Sen. Jackson
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 105 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 105 of 181
106
TX_00207642 TX_00207648
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
4/23/2007 (80th
Legislature) TLC (LEGAL DIVISION)
Anne Peters (Atty.) Rep. Raymond
TX_00207649 TX_00207652
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
4/23/2007 (80th
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Leibowitz
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 106 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 106 of 181
107
TX_00207653 TX_00207656
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
4/23/2007 (80th
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Heflin
TX_00207657 TX_00207660
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
4/23/2007 (80th
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Chavez
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 107 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 107 of 181
108
TX_00207690 TX_00207706
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
10/30/2006 (80th
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Rep. Betty Brown
TX_00207707 TX_00207734
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
11/10/2006 (80th
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Rep. Harper-Brown
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 108 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 108 of 181
109
TX_00207735 TX_00207764
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
12/5/2006 (80th
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Rep. Kolkhorst
TX_00207765 TX_00207809
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
7/10/2006 (80th
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Riddle
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 109 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 109 of 181
110
TX_00207863 TX_00207912
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
3/4/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Rep. Betty Brown
TX_00207913 TX_00207927
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
3/23/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Rep. Betty Brown
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 110 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 110 of 181
111
TX_00207928 TX_00207958
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
4/28/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Rep. Betty Brown
TX_00207959 TX_00207976
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
4/29/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Rep. Betty Brown
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 111 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 111 of 181
112
TX_00207977 TX_00207991
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/12/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Hopson
TX_00207992 TX_00208018
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
4/28/2008 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Phil King
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 112 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 112 of 181
113
TX_00208019 TX_00208067
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
9/26/2008 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Rep. Betty Brown
TX_00208068 TX_00208095
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
10/9/2008 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Riddle
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 113 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 113 of 181
114
TX_00208096 TX_00208125
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
10/28/2008 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Rep. Betty Brown
TX_00208126 TX_00208139
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
12/4/2008 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Sen. Fraser
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 114 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 114 of 181
115
TX_00208140 TX_00208162
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
1/22/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Bohac
TX_00208163 TX_00208184
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
2/17/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Bonnen
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 115 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 115 of 181
116
TX_00208185 TX_00208206
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
2/18/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Hopson
TX_00208207 TX_00208221
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
2/19/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Rep. Todd Smith
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 116 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 116 of 181
117
TX_00208222 TX_00208230
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
2/20/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Chisum
TX_00208231 TX_00208249
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
3/30/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Eric Hougland (Atty.) Rep. Chisum
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 117 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 117 of 181
118
TX_00208250 TX_00208259
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
3/30/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Eric Hougland (Atty.) Rep. Chisum
TX_00208260 TX_00208273
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
3/30/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Anne Peters (Atty.) Rep. Alonzo
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 118 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 118 of 181
119
TX_00208274 TX_00208287
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
3/30/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Anne Peters (Atty.) Rep. Alonzo
TX_00208288 TX_00208306
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
4/30/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Bohac
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 119 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 119 of 181
120
TX_00208307 TX_00208309
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/15/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Rep. Betty Brown
TX_00208310 TX_00208312
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/15/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Anne Peters (Atty.)
Rep. Betty Brown
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 120 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 120 of 181
121
TX_00208313 TX_00208315
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/15/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Rep. Betty Brown
TX_00208316 TX_00208328
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
2/18/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Sen. Shapleigh
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 121 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 121 of 181
122
TX_00208329 TX_00208355
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID. (Lieutenant governor acts in a legislative capacity when serving as president of the senate.)
1/20/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Lt. Gov. Dewhurst
TX_00208356 TX_00208369
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
2/18/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Sen. Shapleigh
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 122 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 122 of 181
123
Voter ID.
TX_00208370 TX_00208388
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
2/18/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Sen. Shapleigh
TX_00208389 TX_00208406
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
2/18/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Sen. Shapleigh
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 123 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 123 of 181
124
Voter ID.
TX_00208407 TX_00208422
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID. (Lieutenant governor acts in a legislative capacity when serving as president of the senate.)
3/2/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Lt. Gov. Dewhurst
TX_00208423 TX_00208437
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as
3/8/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Sen. Watson
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 124 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 124 of 181
125
requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
TX_00208438 TX_00208456
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID. (Lieutenant governor acts in a legislative capacity when serving as president of the senate.)
3/9/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Lt. Gov. Dewhurst
TX_00208457 TX_00208487
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential
3/12/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Sen. Fraser
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 125 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 125 of 181
126
proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
TX_00208488 TX_00208498
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
3/16/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Sen. Fraser
TX_00208499 TX_00208505
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator
3/17/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Anne Peters (Atty.)
Rep. V. Gonzales
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 126 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 126 of 181
127
thoughts, opinions, or mental impressions on Voter ID.
TX_00208506 TX_00208513
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
3/17/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Rep. V. Gonzales
TX_00208514 TX_00208574
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
3/25/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Rep. Todd Smith
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 127 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 127 of 181
128
Voter ID.
TX_00208575 TX_00208581
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
3/30/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Anne Peters (Atty.) Rep. Alonzo
TX_00208582 TX_00208604
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
3/30/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Anne Peters (Atty) Rep. Alonzo
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 128 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 128 of 181
129
Voter ID.
TX_00208605 TX_00208611
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
4/6/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Dutton
TX_00208612 TX_00208642
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
4/9/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Rep. Todd Smith
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 129 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 129 of 181
130
Voter ID.
TX_00208643 TX_00208681
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
4/9/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Rep. Todd Smith
TX_00208682 TX_00208703
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
4/16/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Rep. Todd Smith
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 130 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 130 of 181
131
Voter ID.
TX_00208704 TX_00208715
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
4/20/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Miklos
TX_00208716 TX_00208770
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
4/26/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Rep. Todd Smith
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 131 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 131 of 181
132
Voter ID.
TX_00208771 TX_00208810
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client.
4/27/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
House Parliamentarian Denise Davis (Atty.)
TX_00208811 TX_00208837
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
4/28/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Rep. Todd Smith
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 132 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 132 of 181
133
TX_00208838 TX_00208882
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client.
4/28/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
House Parliamentarian Denise Davis (Atty.)
TX_00208883 TX_00208912
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
4/29/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Rep. Todd Smith
TX_00208913 TX_00208935
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the
4/30/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Rep. Todd Smith
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 133 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 133 of 181
134
production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
TX_00208936 TX_00208994
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
4/30/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Rep. Betty Brown
TX_00208995 TX_00209039
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the
5/1/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Rep. Todd Smith
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 134 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 134 of 181
135
legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
TX_00209040 TX_00209063
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/4/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Rep. Todd Smith
TX_00209064 TX_00209130
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
5/5/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Anne Peters (Atty.) & Jennifer Jackson (Atty.)
Rep. Todd Smith
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 135 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 135 of 181
136
Voter ID.
TX_00209131 TX_00209155
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/5/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Rep. Todd Smith
TX_00209156 TX_00209168
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
5/11/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Rep. Todd Smith
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 136 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 136 of 181
137
Voter ID.
TX_00209169 TX_00209175
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/11/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Rep. Todd Smith
TX_00209176 TX_00209183
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
5/11/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Rep. Todd Smith
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 137 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 137 of 181
138
Voter ID.
TX_00209184 TX_00209197
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/11/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Rep. Todd Smith
TX_00209198 TX_00209248
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
5/12/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Rep. Betty Brown
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 138 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 138 of 181
139
Voter ID.
TX_00209249 TX_00209296
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/12/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Bonnen
TX_00209297 TX_00209312
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
5/12/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Gabe Brake (Atty.) Rep. Hopson
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 139 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 139 of 181
140
Voter ID.
TX_00209313 TX_00209336
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/12/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Hopson
TX_00209337 TX_00209342
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
5/12/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Hopson
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 140 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 140 of 181
141
Voter ID.
TX_00209422 TX_00209435
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/13/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Rep. Hopson; Rep. Leibowitz; Rep. Veasey (Veasey has waived privileges.)
TX_00209436 TX_00209443
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
5/13/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Rep. Hopson; Rep. Anchia (Anchia has waived privileges.)
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 141 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 141 of 181
142
Voter ID.
TX_00209444 TX_00209448
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/13/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Hopson
TX_00209449 TX_00209488
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
5/14/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Rep. Todd Smith
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 142 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 142 of 181
143
Voter ID.
TX_00209489 TX_00209492
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/14/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Rep. Todd Smith
TX_00209493 TX_00209498
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
5/14/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Rep. Todd Smith
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 143 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 143 of 181
144
Voter ID.
TX_00209499 TX_00209518
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/14/2009 (81st
Legislature) TLC ((LEGAL DIVISION))
Jennifer Jackson (Atty.)
Rep. Todd Smith
TX_00209519 TX_00209525
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
5/14/2009 (81st
Legislature) TLC ((LEGAL DIVISION))
Jennifer Jackson (Atty.)
Rep. Todd Smith
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 144 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 144 of 181
145
Voter ID.
TX_00209526 TX_00209534
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/14/2009 (81st
Legislature) TLC ((LEGAL DIVISION))
Jennifer Jackson (Atty.)
Rep. Todd Smith
TX_00209535 TX_00209542
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
5/14/2009 (81st
Legislature) TLC ((LEGAL DIVISION))
Jennifer Jackson (Atty.)
Rep. Todd Smith
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 145 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 145 of 181
146
Voter ID.
TX_00209543 TX_00209550
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/14/2009 (81st
Legislature) TLC ((LEGAL DIVISION))
Jennifer Jackson (Atty.)
Rep. Todd Smith
TX_00209551 TX_00209561
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
5/15/2009 (81st
Legislature) TLC ((LEGAL DIVISION))
Jennifer Jackson (Atty.)
Rep. Betty Brown
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 146 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 146 of 181
147
Voter ID.
TX_00209562 TX_00209569
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/15/2009 (81st
Legislature) TLC ((LEGAL DIVISION))
Jennifer Jackson (Atty.)
Rep. Betty Brown
TX_00209570 TX_00209575
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
5/15/2009 (81st
Legislature) TLC ((LEGAL DIVISION))
Jennifer Jackson (Atty.)
Rep. Betty Brown
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 147 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 147 of 181
148
Voter ID.
TX_00209576 TX_00209582
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/15/2009 (81st
Legislature) TLC ((LEGAL DIVISION))
Jennifer Jackson (Atty.)
Rep. Betty Brown
TX_00209583 TX_00209587
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
5/15/2009 (81st
Legislature) TLC ((LEGAL DIVISION))
Anne Peters (Atty.)
Rep. Betty Brown
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 148 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 148 of 181
149
Voter ID.
TX_00209588 TX_00209594
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/15/2009 (81st
Legislature) TLC ((LEGAL DIVISION))
Anne Peters (Atty.)
Rep. Betty Brown
TX_00209595 TX_00209602
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
5/15/2009 (81st
Legislature) TLC ((LEGAL DIVISION))
Jennifer Jackson (Atty.)
Rep. Betty Brown
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 149 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 149 of 181
150
Voter ID.
TX_00209603 TX_00209613
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/15/2009 (81st
Legislature) TLC ((LEGAL DIVISION))
Jennifer Jackson (Atty.)
Rep. Betty Brown
TX_00209614 TX_00209630
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
5/15/2009 (81st
Legislature) TLC ((LEGAL DIVISION))
Anne Peters (Atty.)
Rep. Betty Brown
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 150 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 150 of 181
151
Voter ID.
TX_00209631 TX_00209648
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/17/2009 (81st
Legislature) TLC ((LEGAL DIVISION))
Anne Peters (Atty.)
Rep. Hernandez
TX_00209649 TX_00209673
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
5/18/2009 (81st
Legislature) TLC ((LEGAL DIVISION))
Jennifer Jackson (Atty.)
Rep. Leibowitz; Rep. Herrero; Rep. A. Martinez; (Martinez has waived privileges.)
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 151 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 151 of 181
152
Voter ID.
TX_00209674 TX_00209679
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/18/2009 (81st
Legislature) TLC ((LEGAL DIVISION))
Anne Peters (Atty.) Rep. Leibowitz
TX_00209680 TX_00209685
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client.
5/18/2009 (81st
Legislature) TLC ((LEGAL DIVISION))
Anne Peters (Atty.) Rep. Leibowitz
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 152 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 152 of 181
153
Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
TX_00209686 TX_00209707
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/18/2009 (81st
Legislature) TLC ((LEGAL DIVISION))
Jennifer Jackson (Atty.)
Rep. Todd Smith
TX_00209708 TX_00209720
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
5/18/2009 (81st
Legislature) TLC ((LEGAL DIVISION))
Jennifer Jackson (Atty.)
Rep. Todd Smith
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 153 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 153 of 181
154
Voter ID.
TX_00209721 TX_00209729
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/18/2009 (81st
Legislature) TLC ((LEGAL DIVISION))
Jennifer Jackson (Atty.)
Rep. Todd Smith
TX_00209730 TX_00209738
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
5/18/2009 (81st
Legislature) TLC ((LEGAL DIVISION))
Jennifer Jackson (Atty.)
Rep. Todd Smith
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 154 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 154 of 181
155
Voter ID.
TX_00209785 TX_00209839
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/18/2009 (81st
Legislature) TLC ((LEGAL DIVISION))
Jennifer Jackson (Atty.)
Rep. Todd Smith
TX_00209840 TX_00209847
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
5/19/2009 (81st
Legislature) TLC ((LEGAL DIVISION))
Jennifer Jackson (Atty.) Rep. Riddle
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 155 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 155 of 181
156
Voter ID.
TX_00209848 TX_00209856
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/19/2009 (81st
Legislature) TLC ((LEGAL DIVISION))
Jennifer Jackson (Atty.)
Rep. Todd Smith
TX_00209857 TX_00209876
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
5/19/2009 (81st
Legislature) TLC ((LEGAL DIVISION))
Jennifer Jackson (Atty.)
Rep. Todd Smith
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 156 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 156 of 181
157
Voter ID.
TX_00209877 TX_00209944
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/19/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Anne Peters (Atty.)
Rep. C. Turner
TX_00209945 TX_00209950
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
5/19/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Anne Peters (Atty.)
Rep. C. Turner
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 157 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 157 of 181
158
Voter ID.
TX_00209951 TX_00209957
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/19/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Sarah Munson (Atty.) Rep. Alonzo
TX_00209958 TX_00209963
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
5/19/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Anne Peters (Atty.)
Rep. C. Turner
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 158 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 158 of 181
159
Voter ID.
TX_00209964 TX_00209967
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/19/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Rep. Todd Smith
TX_00209968 TX_00209982
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
5/20/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Hopson
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 159 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 159 of 181
160
Voter ID.
TX_00209983 TX_00210001
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/20/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Rep. Todd Smith
TX_00210002 TX_00210020
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
5/20/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Rep. Todd Smith
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 160 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 160 of 181
161
Voter ID.
TX_00210021 TX_00210029
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/20/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Rep. Todd Smith
TX_00210030 TX_00210038
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
5/20/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Rep. Todd Smith
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 161 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 161 of 181
162
Voter ID.
TX_00210039 TX_00210056
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/20/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Bonnen
TX_00210084 TX_00210088
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
5/21/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Dutton
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 162 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 162 of 181
163
Voter ID.
TX_00210089 TX_00210104
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/21/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Emily Howell (Atty.) Rep. Herrero
TX_00210105 TX_00210112
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
5/21/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Anne Peters (Atty.) Rep. Herrero
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 163 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 163 of 181
164
Voter ID.
TX_00210113 TX_00210139
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/22/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Anne Peters (Atty.)
Rep. C. Turner
TX_00210140 TX_00210150
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
5/22/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Anne Peters (Atty.)
Rep. C. Turner
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 164 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 164 of 181
165
Voter ID.
TX_00210151 TX_00210161
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/22/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Anne Peters (Atty.)
Rep. C. Turner
TX_00210162 TX_00210174
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
5/22/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Anne Peters (Atty.)
Rep. C. Turner
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 165 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 165 of 181
166
Voter ID.
TX_00210175 TX_00210183
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/22/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Anne Peters (Atty.)
Rep. C. Turner
TX_00210184 TX_00210191
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
5/22/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Anne Peters (Atty.)
Rep. C. Turner
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 166 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 166 of 181
167
Voter ID.
TX_00210192 TX_00210198
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/22/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Anne Peters (Atty.)
Rep. C. Turner
TX_00210199 TX_00210224
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
5/22/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Anne Peters (Atty.)
Rep. C. Turner
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 167 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 167 of 181
168
Voter ID.
TX_00210225 TX_00210234
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/22/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Anne Peters (Atty.)
Rep. C. Turner
TX_00210235 TX_00210243
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
5/22/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Anne Peters (Atty.)
Rep. C. Turner
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 168 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 168 of 181
169
Voter ID.
TX_00210244 TX_00210251
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/22/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Anne Peters (Atty.)
Rep. C. Turner
TX_00210252 TX_00210274
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
5/22/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Anne Peters (Atty.)
Rep. C. Turner
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 169 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 169 of 181
170
Voter ID.
TX_00210275 TX_00210284
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/22/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Anne Peters (Atty.)
Rep. C. Turner
TX_00210285 TX_00210296
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
5/22/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Anne Peters (Atty.)
Rep. C. Turner
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 170 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 170 of 181
171
Voter ID.
TX_00210297 TX_00210319
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/22/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Anne Peters (Atty.)
Rep. C. Turner
TX_00210335 TX_00210401
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
5/22/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Rep. Todd Smith
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 171 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 171 of 181
172
Voter ID.
TX_00210628 TX_00210640
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/22/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Eric Hougland (Atty.)
Rep. Betty Brown; Rep. Button
TX_00210641 TX_00210660
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
5/22/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Rep. Todd Smith
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 172 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 172 of 181
173
Voter ID.
TX_00210661 TX_00210689
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/22/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Rep. Todd Smith
TX_00210690 TX_00210694
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
5/22/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Rep. Todd Smith
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 173 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 173 of 181
174
Voter ID.
TX_00210695 TX_00210701
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/22/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Rep. Todd Smith
TX_00210702 TX_00210710
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
5/22/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Rep. Todd Smith
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 174 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 174 of 181
175
Voter ID.
TX_00210711 TX_00210729
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/23/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Sen. Patrick
TX_00210750 TX_00210769
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
5/24/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Rep. Betty Brown
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 175 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 175 of 181
176
Voter ID.
TX_00210770 TX_00210775
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/24/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.)
Rep. Todd Smith
TX_00210776 TX_00210783
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
5/24/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Sen. Patrick
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 176 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 176 of 181
177
Voter ID.
TX_00210828 TX_00210833
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/24/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Miklos
TX_00210834 TX_00210846
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
5/25/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Sen. Patrick
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 177 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 177 of 181
178
Voter ID.
TX_00210847 TX_00210853
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/25/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Anne Peters (Atty.) Rep. Dunnam
TX_00210854 TX_00210862
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
5/25/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Dunnam
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 178 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 178 of 181
179
Voter ID.
TX_00210863 TX_00210868
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/25/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Dunnam
TX_00210869 TX_00210875
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on
5/25/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Jennifer Jackson (Atty.) Rep. Dunnam
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 179 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 179 of 181
180
Voter ID.
TX_00210876 TX_00210882
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.
5/25/2009 (81st
Legislature) TLC (LEGAL DIVISION)
Anne Peters (Atty.) Rep. Dunnam
TX_00210883 TX_00210890
Attorney-Client Privilege; Legislative Privilege
Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on 39958
TLC (LEGAL DIVISION)
Anne Peters (Atty.) Rep. Dunnam
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 180 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 180 of 181
181
Voter ID.
Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 181 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 181 of 181
1
Office of the Governor Contested Document Privilege Claim Index Legislative Privilege
Materials in the Possession of an Executive Agency over which the State of Texas Has Asserted a Legislative Privilege TX_00034902-TX_00034902, TX_00037744-TX_00037744, TX_00038291-TX_00038291 Attorney-Client Privilege Materials for which the State of Texas Failed to Provide Sufficient Information Regarding Attorney-Client Privilege TX_00057324-TX_00057324, TX_00057547-TX_00057562, TX_00089306-TX_00089307 Materials over which the State of Texas Has Asserted the Attorney-Client Privilege Where the Parties to the Communication Have Not Entered an Attorney-Client Relationship TX_00057456-TX_00057475, TX_00057699-TX_00057746, TX_00089130-TX_00089187, TX_00089226-TX_00089227 Materials over which the State of Texas Has Asserted the Attorney-Client Privilege Where the Advice Appears to Concern Political, Strategic, or Policy Issues TX_00057294-TX_00057308, TX_00057321-TX_00057323, TX_00057357-TX_00057366, TX_00057367-TX_00057368, TX_00057369-TX_00057414, TX_00057415-TX_00057417, TX_00057418-TX_00057455, TX_00057538-TX_00057539, TX_00057565-TX_00057609, TX_00057608-TX_00057678, TX_00057756-TX_00057759, TX_00057807-TX_00057999, TX_00058039-TX_00058068, TX_00058070-TX_00058304, TX_00058334-TX_00058336, TX_00058353-TX_00058783, TX_00058792-TX_00058829, TX_00058830-TX_00058449, TX_00059450-TX_00060257, TX_00060258-TX_00060258, TX_00060259-TX_00060260, TX_00060641-TX_00073627, TX_00073800-TX_00074003; TX_00089076-TX_00089078, TX_00089251-TX_00089305, TX_00089308-TX_00089309 Deliberative Process Privilege Materials over which the State of Texas Has Asserted the Deliberative Process Privilege that Address SB 14 and Predate Enactment TX_00057287-TX_00057288, TX_00057294-TX_00057308, TX_00057369-TX_00057414, TX_00057418-TX_00057455, TX_00057538-TX_00057539, TX_00057608-TX_00057678, TX_00058001-TX_00058038, TX_00058039-TX_00058068, TX_00058299-TX_00058310, TX_00058343-TX_00058352, TX_00058784-TX_00058791, TX_00058830-TX_00058449,
Case 1:12-cv-00128-RMC-DST-RLW Document 152-5 Filed 05/25/12 Page 1 of 2
2
TX_00073709-TX_00073722, TX_00073764-TX_00073773, TX_00074010-TX_00074011, TX_00074226-TX_00074234, TX_00074236-TX_00074236; TX_00089064-TX_00089075
Case 1:12-cv-00128-RMC-DST-RLW Document 152-5 Filed 05/25/12 Page 2 of 2
1
Texas Legislative Council Contested Document Privilege Claim Index
Attorney-Client Privilege Materials over which the State of Texas Has Asserted the Attorney-Client Privilege that Reflect Communications with the Texas Legislative Council:
TX_00041842-TX_00042111, TX_00042138-TX_00042138, TX_00042142-TX_00042147, TX_00042440-TX_00042852, TX_00042995-TX_00043016, TX_00043028-TX_00043090, TX_00043091-TX_00043218, TX_00043237-TX_00043244, TX_00043245-TX_00043330, TX_00043339-TX_00043359, TX_00043376-TX_00043379, TX_00043390-TX_00043395, TX_00043405-TX_00043657, TX_00043717-TX_00043747, TX_00206556-TX_00206579, TX_00206612-TX_00206626, TX_00206631-TX_00206659, TX_00206751-TX_00207020, TX_00207283-TX_00207309, TX_00207313-TX_00207364, TX_00207378-TX_00207389, TX_00207401-TX_00207415, TX_00207504-TX_00207517, TX_00207605-TX_00207637, TX_00207642-TX_00207660, TX_00207690-TX_00207809, TX_00207863-TX_00209342, TX_00209422-TX_00209738, TX_00209785-TX_00210056, TX_00210084-TX_00210319, TX_00210335-TX_00210401, TX_00210628-TX_00210729, TX_00210750-TX_00210783, TX_00210770-TX_00210783, TX_00210828-TX_00210890 Materials over which the State of Texas Has Asserted the Attorney-Client Privilege that Reflect Internal Research within the Texas Legislative Council:
TX_00042145-TX_00042145 Legislative Privilege
Public Documents over which the State of Texas Has Asserted a State Legislative Privilege:
TX_00043748-TX_00044191 Materials over which the State of Texas Has Asserted a State Legislative Privilege Despite the Relevant Legislators Not Having Invoked a Privilege:
TX_00043237-TX_00043244, TX_00043245-TX_00043307, TX_00043339-TX_00043347, TX_00043354-TX_00043359, TX_00043372-TX_00043379, TX_00206631-TX_00206643, TX_00206656-TX_00206659, TX_00206929-TX_00206932, TX_00206938-TX_00206956, TX_00208260-TX_00208287, TX_00208499-TX_00208513, TX_00208575-TX_00208604, TX_00209631-TX_00209673, TX_00209951-TX_00209957 Materials Concerning Sponsors of SB 14 over which the State of Texas Has Asserted a State Legislative Privilege:
TX_00041842-TX_00042111, TX_00042138-TX_00042138, TX_00042139-TX_00042141, TX_00042309-TX_00042396, TX_00042440-TX_00042440, TX_00042474-TX_00042501,
Case 1:12-cv-00128-RMC-DST-RLW Document 152-6 Filed 05/25/12 Page 1 of 3
2
TX_00042502-TX_00042516, TX_00043128-TX_00043171, TX_00043414-TX_00043545, TX_00043579-TX_00043610, TX_00208126-TX_00208139, TX_00208457-TX_00208498 Materials Concerning Committee Chairs, Committee Staff, or Legislative Leadership over which the State of Texas Has Asserted a State Legislative Privilege:
TX_00042151-TX_00042308, TX_00042397-TX_00042438, TX_00042779-TX_00042804, TX_00042995-TX_00043013, TX_00043091-TX_00043127, TX_00043172-TX_00043218, TX_00043348-TX_00043353, TX_00206173-TX_00206212, TX_00208163-TX_00208184, TX_00208329-TX_00208355, TX_00208407-TX_00208422, TX_00208438-TX_00208456, TX_00209249-TX_00209296, TX_00210039-TX_00210056 Materials Concerning Legislators Who Spoke in Favor of SB 14 over which the State of Texas Has Asserted a State Legislative Privilege:
TX_00042142-TX_00042142, TX_00042523-TX_00042578, TX_00042731-TX_00042778, TX_00042850-TX_00042852, TX_00043546-TX_00043578, TX_00043658-TX_00043716, TX_00043748-TX_00043774, TX_00044165-TX_00044171, TX_00075930-TX_00075941, TX_00075949-TX_00075962, TX_00075969-TX_00076003, TX_00206169-TX_00206170, TX_00206804-TX_00206825, TX_00207765-TX_00207809, TX_00208068-TX_00208095, TX_00208207-TX_00208221, TX_00208514-TX_00208574, TX_00208612-TX_00208703, TX_00208716-TX_00208770, TX_00208811-TX_00208837, TX_00208883-TX_00208935, TX_00208995-TX_00209197, TX_00209449-TX_00209550, TX_00209686-TX_00209738, TX_00209785-TX_00209876, TX_00209964-TX_00209967, TX_00209983-TX_00210038, TX_00210335-TX_00210401, TX_00210641-TX_00210729, TX_00210770-TX_00210783, TX_00210834-TX_00210846 Other Materials Concerning SB14 over which the State of Texas Has Asserted a State Legislative Privilege:
TX_00042139-TX_00042141, TX_00042146-TX_00042147, TX_00042441-TX_00042473, TX_00042517-TX_00042522, TX_00042579-TX_00042730, TX_00042805-TX_00042835, TX_00042900-TX_00042904, TX_00043014-TX_00043016, TX_00043028-TX_00043090, TX_00043308-TX_00043330, TX_00043354-TX_00043359, TX_00043390-TX_00043395, TX_00043405-TX_00043413, TX_00043579-TX_00043644, TX_00043645-TX_00043657, TX_00043658-TX_00043716, TX_00043717-TX_00043747, TX_00043775-TX_00044164, TX_00044172-TX_00044191, TX_00205341-TX_00205360, TX_00206556-TX_00206579, TX_00206612-TX_00206626, TX_00206644-TX_00206655, TX_00206751-TX_00206803, TX_00206826-TX_00206928, TX_00206933-TX_00206937, TX_00206957-TX_00207020, TX_00207283-TX_00207309, TX_00207313-TX_00207364, TX_00207378-TX_00207389, TX_00207401-TX_00207415, TX_00207504-TX_00207517, TX_00207605-TX_00207637, TX_00207642-TX_00207660, TX_00207690-TX_00207764, TX_00207863-TX_00208067, TX_00208096-TX_00208125, TX_00208140-TX_00208162, TX_00208185-TX_00208206, TX_00208222-TX_00208259, TX_00208288-TX_00208328, TX_00208356-TX_00208406, TX_00208423-TX_00208437, TX_00208605-TX_00208611, TX_00208704-TX_00208715, TX_00208771-TX_00208810, TX_00208838-TX_00208882, TX_00208936-TX_00208994,
Case 1:12-cv-00128-RMC-DST-RLW Document 152-6 Filed 05/25/12 Page 2 of 3
3
TX_00209198-TX_00209248, TX_00209297-TX_00209342, TX_00209422-TX_00209448, TX_00209551-TX_00209630, TX_00209649-TX_00209685, TX_00209877-TX_00209950, TX_00209958-TX_00209963, TX_00209968-TX_00209982, TX_00210084-TX_00210319, TX_00210628-TX_00210640, TX_00210750-TX_00210769, TX_00210828-TX_00210833, TX_00210847-TX_00210890 Materials Concerning Prior Voter ID Proposals over which the State of Texas Has Asserted a State Legislative Privilege:
TX_00075969-TX_00076003 Materials Concerning Other Legislative Proposals over which the State of Texas Has Asserted a State Legislative Privilege:
TX_00075930-TX_00075941, TX_00075932-TX_00075941, TX_00075949-TX_00075962
Case 1:12-cv-00128-RMC-DST-RLW Document 152-6 Filed 05/25/12 Page 3 of 3