US v. Texas joint scheduling proposal

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    IN THE UNITED STATES DISTRICT COURT

    FOR THE SOUTHERN DISTRICT OF TEXAS

    CORPUS CHRISTI DIVISION

    MARC VEASEY,et al.,

    Plaintiffs,

    v.

    RICK PERRY,et al.,

    Defendants.

    Civil Action No. 2:13-cv-193 (NGR)

    UNITED STATES OF AMERICA,

    Plaintiff,

    TEXAS LEAGUE OF YOUNG VOTERS

    EDUCATION FUND, et al.,

    Plaintiff-Intervenors,

    TEXAS ASSOCIATION OF HISPANICCOUNTY JUDGES AND COUNTY

    COMMISSIONERS, et al.,

    Civil Action No. 2:13-cv-263 (NGR)

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    TEXAS STATE CONFERENCE OF NAACP

    BRANCHES, et al.,

    Plaintiffs,

    v.

    JOHN STEEN, et al.,

    Defendants.

    Civil Action No. 2:13-cv-291 (NGR)

    JOINT REPORT OF THE RULE 26(f) MEETING AND

    JOINT DISCOVERY/CASE MANAGEMENT PLAN

    1. State when the Rule 26 Conference of the parties was held and identify the counselwho attended for each party.

    On September 18, 2013, the parties held a telephonic Rule 26(f) conference at which

    the following counsel participated:

    Armand Derfner, Gerry Hebert, and Neil Baron for Plaintiffs in Veasey v.Perry

    Meredith Bell-Platts, Elizabeth Westfall, Bruce Gear, Anna Baldwin, DanielFreeman, and Jennifer Maranzano for the Plaintiff in United States v. Texas Danielle Conley, Ryan Haygood, Leah Aden, Hasan Ali, and Kelly Dunbar

    for Plaintiff-Intervenors Texas League of Young Voters Education Fund, et al.

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    John Scott, Reed Clay, and David Whitley for the Defendants State of Texaset al.

    Rolando Rios for Movant-Intervenors Texas Association of Hispanic Judgesand Commissioners, et al.

    Joseph Nixon for Movant-Intervenor True the Vote2. List any cases related to the present action that are pending in any state or federal

    court, with the style, case number, court, and a brief description of the case.

    Saldana, et al. v. Hidalgo County, et al., No. C-6392-13I (398th Judicial District

    Court, Hidalgo County, Texas) (filed Oct. 18, 2013). Plaintiffs seek temporary and

    permanent enjoinment of Senate Bill 14 (2011) (SB 14).

    On August 30, 2013, the Court ordered the consolidation of United States v. Texas,

    No. 2:13-cv-263 (S.D. Tex.) (NGR) with Veasey v. Perry, No. 2:13-cv-193 (S.D.Tex.) (NGR) (ECF No. 14).

    On September 19, 2013, the Court ordered the consolidation ofTexas State

    Conference of NAACP Branches v. Steen, No. 2:13-cv-291 (S.D. Tex.) (NGR) with

    Veasey v. Perry, No. 2:13-cv-193 (S.D. Tex.) (NGR) and United States v. Texas, No.

    2:13-cv-263 (S.D. Tex.) (NGR) (ECF No. 31).

    3. Briefly describe the pertinent facts and legal theories upon which the present actionsare based.

    United States v. Texasis a challenge under Section 2 of the Voting Rights Act, 42U.S.C. 1973, to the State of Texass photographic voter identification law, SB 14, to

    enforce the voting rights guaranteed by the Fourteenth and Fifteenth Amendments tothe United States Constitution.

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    7. If this is a class action, describe any issues regarding certification of the class.The parties do not seek certification of a class.

    8. State whether each party represents that it has made the initial disclosures required byRule 26(a). If not, describe the arrangements that have been made to complete the

    disclosures.

    The plaintiff United States, the Veaseyplaintiffs, the plaintiffs in Texas NAACP,and

    Plaintiff-Intervenors Texas League of Young Voters Education Fund will make theirinitial disclosures on November 21, 2013.

    9. Describe the proposed discovery plan the parties have agreed upon, including:A. Responses to all the matters raised in Rule 26(f). The parties have been unable to

    agree upon a joint scheduling order. The Courts standard deadlines are not

    applicable to this case. The plaintiff United States, the Texas NAACPplaintiffs,

    and the Plaintiff-Intervenors Texas League of Young Voters Education Fund

    propose the schedule that is attached as Exhibit 1. The plaintiff United Statessubmits a statement in support of its proposed schedule at Exhibit 2. The Veasey

    plaintiffs propose the schedule that is attached as Exhibit 3. The Veaseyplaintiffs

    submit a statement in support of their proposed schedule at Exhibit 4. The Stateof Texas proposes the schedule that is attached as Exhibit 5.

    *

    a.

    Interrogatories: The plaintiff United States, the Texas NAACPplaintiffs, theVeaseyPlaintiffs, and the Plaintiff-Intervenors Texas League of Young Voters

    Education Fundpropose that each party shall be permitted to propound twenty-

    five (25) interrogatories on any other party. Fed. R. Civ. P. 33(a)(1); S.D. Tex. R.

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    b. Depositions of Fact Witnesses: Notwithstanding the limits set forth in FederalRule of Civil Procedure 30(a)(2), Plaintiffs, Plaintiff-Intervenors, and Movant-

    Intervenors Texas Association of Hispanic Judges and Commissioners (ifintervention is granted) shall be permitted to depose sixty (60) fact witnesses

    collectively. Likewise, Defendants and Movant-Intervenor True the Vote (if

    intervention is granted) shall be permitted to depose sixty (60) fact witnessescollectively. The parties will attempt to coordinate the issuance of notices and

    subpoenas for depositions so as to avoid duplication of effort and promote

    efficiency. The parties will attempt to coordinate the scheduling of depositions in

    advance of submitting notices for deposition.

    c. Discovery Cut-Off Date:The plaintiff United States, the plaintiffs in Texas NAACP, Plaintiff-Intervenors

    Texas League of Young Voters Education Fund, and the Defendants State of

    Texas et al. propose the following: fact discovery shall conclude on August 15,2014; expert discovery shall conclude onNovember 21, 2014; and the parties may

    conduct fact discovery limited to the 2014 November general election between

    October 1, 2014 and December 23, 2014. The plaintiff United States further

    proposes that, notwithstanding Federal Rules of Civil Procedure 33(b)(2),34(b)(2)(A), during this supplemental discovery period, the responding party must

    serve or produce, where applicable, answers, objections, and responsive

    documents within twenty-one (21) days.

    The Veaseyplaintiffs propose that fact discovery shall conclude on May 2, 2014,

    and expert discovery shall conclude on July 15, 2014.

    d. Federal Rule 26(a)(2) Disclosure (Experts):

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    to the history of the states consideration and/or enactment of legislation requiring

    photographic identification, up to and including SB 14, as a requirement to cast a

    ballot in person. If Texas does make such an assertion, the plaintiff United States,the Veaseyplaintiffs, the plaintiffs in Texas NAACP, and the Plaintiff-Intervenors

    Texas League of Young Voters Education Fundwill likely move to compel at

    least a portion of the discovery withheld on those grounds.

    f. Dispositive Motions:The plaintiff United States, the plaintiffs in Texas NAACP, Plaintiff-Intervenors

    Texas League of Young Voters Education Fund, and the Defendants State ofTexas et al. propose that dispositive motions shall be filed on January 12, 2015,

    responses shall be due February 11, 2015, and replies to responses shall be due

    February 23, 2015.

    The Veaseyplaintiffs propose that dispositive motions shall be filed by July 22,

    2014, responses shall be filed by August 4, 2014, and replies to responses shall befiled by August 11, 2014.

    g. Pretrial Order: The pretrial statement shall be due 14 days before the pretrialconference. Pursuant to Local Rule 46, objections to exhibits shall be made at

    least seven days before trial.

    h. Electronic Discovery: The parties have agreed on a proposed production formatfor documents and electronically stored information. SeeAgreement Concerning

    Production Format (Ex. 6).

    i. Protective Orders: The plaintiff United States has circulated several drafts ofproposed protective orders to govern the exchange of certain confidential

    i f i i l di b li i d h id i d h i i f

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    Defendants will serve interrogatories at any time during fact discovery provided

    that sufficient time is given to respond by the fact discovery cut-off. Defendantswill serve interrogatories on opposing parties including named individual

    plaintiffs and various federal agencies. Defendants reserve the right to serve

    interrogatories on additional parties.

    D. When and from whom Plaintiff(s) anticipate(s) taking oral depositions.

    The plaintiff United States, the Veaseyplaintiffs, the plaintiffs in Texas NAACP,

    and Plaintiff-Intervenors Texas League of Young Voters Education Fundwillnotice depositions of current and former state legislators; state and local officials,

    employees, agents, and counsel of the State of Texas, including, but not limitedto, the Office of the Texas Secretary of State, the Texas Division of Elections, the

    Texas Department of Public Safety, and other state agencies responsible for

    issuing identification; county and local election officials; and third parties whomay have information relevant to the United States claim. Additionally, the

    plaintiff United States, the Veaseyplaintiffs, the plaintiffs in Texas NAACP, and

    Plaintiff-Intervenors Texas League of Young Voters Education Fund intend todepose the fact and expert witnesses on whom Defendants intend to rely insupport of their defenses.

    The plaintiff United States, the Veaseyplaintiffs, the plaintiffs in Texas NAACP,and Plaintiff-Intervenors Texas League of Young Voters Education Fundwill

    begin noticing depositions of fact witnesses after they have received and reviewed

    Defendants responses to written discovery requests and no earlier than December1, 2013.

    E. When and from whom Defendant(s) anticipate(s) taking oral depositions.

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    reports shall be disclosed by October 6, 2014. Surrebuttal experts and surrebuttal

    reports shall be disclosed by October 31, 2014.

    The Veaseyplaintiffs request that the Court instead order the following schedule

    for the disclosure of experts and expert reports: Experts and expert reports shall

    be disclosed as required by Rule 26(a)(2) by May 9, 2014. Rebuttal experts andrebuttal reports shall be disclosed by June 6, 2014. Surrebuttal experts and

    surrebuttal reports shall be disclosed by June 13, 2014.

    G. List expert depositions Plaintiff(s) (or the party or parties with the burden of proof

    on an issue) anticipate(s) taking and their anticipated completion date.

    The plaintiff United States, the Veaseyplaintiffs, the plaintiffs in Texas NAACP,and Plaintiff-Intervenors Texas League of Young Voters Education Fund

    anticipate that they will depose all experts disclosed by any Defendant.

    The plaintiff United States, the plaintiffs in Texas NAACP, and Plaintiff-

    Intervenors Texas League of Young Voters Education Fundanticipate that they

    will complete all such expert depositions by November 21, 2014.

    The Veaseyplaintiffs anticipate that they will complete all such expert depositions

    by July 15, 2014.

    H. List expert depositions the opposing party or parties anticipate(s) taking and their

    anticipated completion date.

    Defendants will depose experts disclosed by any Plaintiff or Plaintiff-Intervenor.

    Defendants anticipate they will complete all such expert depositions by November

    21, 2014.

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    the combined total number of hours that it will take for all parties to present evidence

    in this case is 100 hours, with the division of time per side to be allotted later.

    The State of Texas anticipates that the combined total number of hours that it will

    take for all parties to present evidence in this case is 60 hours. Each side should be

    allocated 30 hours to present its case.

    17. List pending motions that could be ruled on at the Initial Pretrial Conference.Motions to intervene by True the Vote (ECF No. 38) and Texas Association of

    Hispanic County Judges, et al. (ECF No. 41).

    18. List other pending motions.Defendants filed a motion to dismiss on October 25, 2013. Pursuant to the minute

    order issued on October 18, 2013, responses are due by November 22, 2013, and theDefendants reply is due by December 6, 2013.

    19. Indicate other matters peculiar to this caseincluding discoverythat deserve thespecial attention of the Court at the Initial Pretrial Conference.

    The plaintiff United States and defendant the State of Texas have stipulated, without

    waiving any other objection under the Federal Rules of Evidence, to the authenticityof documents produced in discovery inTexas v. Holder, No. 1:12-cv-128 (D.D.C.).

    20. Certify that all parties have filed Certificates of Interested Partiesas directed in theOrder of Conference and Disclosure of Interested Partieslisting the date of filing

    for the originals and any amendments to the Certificates.

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    /s/ Elizabeth S. Westfall

    T. Christian Herren Jr.

    [email protected]

    AL Bar No. HER025

    Robert S. Berman

    [email protected]

    WI Bar No. 1015402

    Meredith Bell-Platts

    [email protected] Bar No. 048948

    OH Bar No. 0072917

    Elizabeth S. Westfall

    [email protected]

    DC Bar No. 458792NY Bar No. 2799963

    Bruce I. Gear

    [email protected] Bar No. 463388

    Jennifer L. [email protected]

    DC Bar No. 483420

    Case 2:13-cv-00193 Document 61 Filed in TXSD on 11/04/13 Page 12 of 19

    mailto:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]
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    John A. Smith, III

    Assistant United States Attorney

    800 N. Shoreline, Suite 500Corpus Christi, TX 78401

    (361) 903-7926

    [email protected] No. 18627450

    For Plaintiffs Marc Veasey, et al.

    /s/ Chad W. Dunn

    Armand G. Derfner

    [email protected]

    South Carolina State Bar No. 1650South Carolina Federal Bar No. 502

    Derfner, Altman & Wilborn, LLC

    P.O. Box 600Charleston, SC 29402Phone: (843) 723-9804

    Chad W. [email protected]

    Texas State Bar No. 24036507

    K. Scott Brazil

    [email protected]

    Texas State Bar No. 02934050

    Case 2:13-cv-00193 Document 61 Filed in TXSD on 11/04/13 Page 13 of 19

    mailto:[email protected]:[email protected]
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    Neil G. Baron

    [email protected] State Bar No. 01797080

    Law Office of Neil G. Baron

    914 FM 517 W, Suite 242Dickinson, TX 77539

    Phone: (281) 534-2748

    Fax: (281) 534-4309

    David [email protected]

    Texas State Bar No. 16846000Richards, Rodriguez & Skeith, LLP

    816 Congress Avenue, Suite 1200

    Austin, TX 78701Phone: (512) 476-0005

    Fax: (512) 476-1513

    Luis Roberto Vera, Jr.LULAC National General Counsel

    Texas State Bar No. 20546740

    The Law Offices of Luis Vera Jr., and Associates1325 Riverview Towers, 111 Soledad

    San Antonio, TX 78205

    Phone: (210) 225-3300Fax: (210) 225-2060

    Craig M. Watkins

    Case 2:13-cv-00193 Document 61 Filed in TXSD on 11/04/13 Page 14 of 19

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    Ste 500

    Princeton, NJ 08540-6531

    (609-955-3200)[email protected]

    Amy L. Rudd (TX 24043561, S.D. TX 1149768)Steven B. Weisburd (TX 24054515, S.D. TX 1691215)

    Lindsey B. Stelcen (TX 24083903)

    Dechert LLP

    300 West 6th Street

    Suite 2010Austin, TX 78701

    [email protected]@dechert.com

    [email protected]

    Wendy Weiser (NY 2919595)

    Myrna Perez (NY 4874095)

    Jennifer Clark (NY 5064100)Vishal Agraharkar (NY 4931457)Brennan Ctr for Justice

    NYU School of Law

    161 Avenue of the Americas, 12th Fl.New York, NY 10013

    (646-292-8310)

    [email protected]@nyu.edu

    [email protected]

    [email protected]

    Case 2:13-cv-00193 Document 61 Filed in TXSD on 11/04/13 Page 15 of 19

    http://maps.google.com/maps?saddr=&daddr=30.269103,-97.745672+(Austin%20Office:%20300%20West%206th%20Street,%20Suite%202010,%20+1.512.394.3000)http://maps.google.com/maps?saddr=&daddr=30.269103,-97.745672+(Austin%20Office:%20300%20West%206th%20Street,%20Suite%202010,%20+1.512.394.3000)http://maps.google.com/maps?saddr=&daddr=30.269103,-97.745672+(Austin%20Office:%20300%20West%206th%20Street,%20Suite%202010,%20+1.512.394.3000)mailto:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]://maps.google.com/maps?saddr=&daddr=30.269103,-97.745672+(Austin%20Office:%20300%20West%206th%20Street,%20Suite%202010,%20+1.512.394.3000)http://maps.google.com/maps?saddr=&daddr=30.269103,-97.745672+(Austin%20Office:%20300%20West%206th%20Street,%20Suite%202010,%20+1.512.394.3000)http://maps.google.com/maps?saddr=&daddr=30.269103,-97.745672+(Austin%20Office:%20300%20West%206th%20Street,%20Suite%202010,%20+1.512.394.3000)
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    Austin, TX 78701

    (512-474-7563)

    [email protected]

    Gary Bledsoe (TX 02476500)

    PotterBledsoe, LLP316 West 12

    thStreet, Suite 307

    Austin, TX 78701

    (512) 322-9992

    [email protected]

    Kim Keenan (DC 419241)

    Marshall Taylor (DC 454615)Victor Goode (MD 08145525)

    NAACP

    4805 Mt. Hope DriveBaltimore, MD 21215

    (410-580-5120)

    [email protected]@[email protected]

    Jose Garza (TX 07731950)Law Office of Jose Garza

    7414 Robin Rest Drive

    San Antonio, TX 98209(210-392-2856)

    [email protected]

    Case 2:13-cv-00193 Document 61 Filed in TXSD on 11/04/13 Page 16 of 19

    mailto:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]
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    PA Bar. No. 83616

    NY Bar No. 2619252

    Ryan P. Haygood

    [email protected]

    NY Bar No. 4089397

    Natasha M. Korgaonkar

    [email protected]

    NY Bar No. 4653168

    Leah C. Aden

    [email protected] Bar No. 4555207

    NAACP Legal Defense and Education Fund40 Rector Street, 5th Floor

    New York, NY 10006

    Tel: (212) 965-2200Fax: (212) 226-7592

    Danielle Y. Conley

    [email protected] Bar No. 503345

    NY Bar No. 647886

    Jonathan E. Paikin

    [email protected]

    DC Bar No. 466445

    Case 2:13-cv-00193 Document 61 Filed in TXSD on 11/04/13 Page 17 of 19

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    M. Hasan Ali

    [email protected]

    NY Bar No. 5005772DC Bar No. 1014497

    Wilmer Cutler Pickering Hale & Dorr, LLP1875 Pennsylvania Ave., N.W.

    Washington, D.C. 20006

    Tel: (202) 663-6000

    Fax: (202) 663-6363

    For Defendants State of Texas, et al.:

    /s/John B. Scott

    John B. [email protected]

    Texas State Bar No. 17901500

    Jonathan [email protected]

    Texas State Bar No. 24075463

    Reed Clay

    [email protected]

    Texas State Bar No. 24072039

    Patrick Sweeten

    [email protected]

    Case 2:13-cv-00193 Document 61 Filed in TXSD on 11/04/13 Page 18 of 19

    mailto:[email protected]:[email protected]:[email protected]:[email protected]
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    Texas State Bar No. 24059754

    Office of the Texas Attorney GeneralP.O. Box 12548

    Austin, Texas 78711-2458

    Phone: 512-936-1414Fax: 512-936-0545

    Case 2:13-cv-00193 Document 61 Filed in TXSD on 11/04/13 Page 19 of 19

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    Exhibit 1

    Case 2:13-cv-00193 Document 61-1 Filed in TXSD on 11/04/13 Page 1 of 4

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    IN THE UNITED STATES DISTRICT COURT

    FOR THE SOUTHERN DISTRICT OF TEXAS

    CORPUS CHRISTI DIVISION

    MARC VEASEY,et al.,

    Plaintiffs,

    v.

    RICK PERRY,et al.,

    Defendants.

    Civil Action No. 2:13-cv-193 (NGR)

    UNITED STATES OF AMERICA,

    Plaintiff,

    TEXAS LEAGUE OF YOUNG VOTERS

    EDUCATION FUND, et al.,

    Plaintiff-Intervenors,

    TEXAS ASSOCIATION OF HISPANIC

    COUNTY JUDGES AND COUNTY

    COMMISSIONERS, et al.,

    Civil Action No. 2:13-cv-263 (NGR)

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    TEXAS STATE CONFERENCE OF NAACP

    BRANCHES, et al.,

    Plaintiffs,

    v.

    JOHN STEEN, et al.,

    Defendants.

    Civil Action No. 2:13-cv-291 (NGR)

    (PROPOSED) ORDER

    Pursuant to Fed. R. Civ. P. 16 and upon consideration of the parties joint report of theRule 26(f) meeting and joint discovery/case management plan, the following schedule is hereby

    ORDERED:

    1. Fact discovery shall conclude on August 15, 2014. Notwithstanding the limits set forth inFed. R. Civ. P. 30(a)(2), Plaintiffs, Plaintiff-Intervenors, and Movant- Intervenors Texas

    Association of Hispanic Judges and Commissioners, et al. (if intervention is granted)shall be permitted to depose sixty (60) fact witnesses collectively. Likewise, Defendants

    and Movant-Intervenor True the Vote (if intervention is granted) shall be permitted to

    depose sixty (60) fact witnesses collectively.

    2. The deadline to amend pleadings is August 15, 2014.

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    motions filed prior to January 12, 2015, responses shall be filed within thirty (30) days

    and replies within ten (10) days after that.

    7. The pretrial statement shall be filed two weeks prior to the pretrial conference.8. The parties will be ready for trial as of March 17, 2015.

    _________________________

    NELVA GONZALES RAMOS

    United States District Judge

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    Exhibit 2

    Case 2:13-cv-00193 Document 61-2 Filed in TXSD on 11/04/13 Page 1 of 5

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    UNITED STATES STATEMENT IN SUPPORT OF ITS PROPOSED SCHEDULE

    The scheduling order that the plaintiff United States requests (Ex. 1) requires the parties

    to be ready for trial as of March 17, 2015; the plaintiff Texas State Conference of NAACP and

    the plaintiff-intervenor Texas League of Young Voters Education Fund join in this request, and

    the defendant State of Texas does not oppose it. The proposed trial date is based on two factors:

    (1) the necessity that this Court has a full, complete, and accurate record upon which to render its

    decision; and (2) the litigation experience of several of the parties in the instant case in litigating

    a challenge to SB 14 under an expedited schedule last year.

    The scheduling order provides for nine months of fact discovery, followed by a period of

    expert discovery and limited fact discovery related to the 2014 general election, then an

    opportunity to file dispositive motions, and finally, preparation of the necessary pre-trial papers,

    such as motions in limineand proposed findings of fact and conclusions of law.

    At the outset, the United States fully understands the gravity of the issues that this case

    presents. The ability of all qualified citizens to participate fully and equally in the electoral

    process is fundamental. The United States will seek to avoid any unnecessary delay in providing

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    Examining the previous litigation over SB 14 should obviate any concern that the

    requested time for fact and expert discovery is not warranted. The State of Texas filed a

    declaratory judgment action under Section 5 of the Voting Rights Act, 42 U.S.C. 1973c,

    seeking a judicial determination that SB 14 had neither a discriminatory purpose nor would have

    a discriminatory effect. Texasv.Holder, No. 1:12-cv-128 (D.D.C. 2012). On March 14, 2012,

    Texas requested a decision by a date that, if the court ruled in its favor, would permit it to

    implement SB 14 for the November 2012 election. The court granted this request, indicated that

    it would issue a decision by August 31, 2012, and ordered an expedited trial schedule.

    In the months that followed, the parties undertook complex and voluminous discovery.

    To determine which voters in Texas possessed requisite state forms of photographic

    identification under SB 14, the United States and defendant-intervenors sought data from Texas

    voter registration, driver license, and license to carry concealed handguns databases.

    Data discovery in this action will be even more complex. As a result of the expedited

    trial schedule, the parties did not exchange or present expert testimony on the federal forms of

    photographic identification permitted by SB 14. Nor did the parties analyze data maintained by

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    Here, Texas has already indicated that it will seek data from five federal agencies related

    to federal forms of allowable photographic identification under SB 14 and exemptions from SB

    14s identification requirements based on disability status. The agencies are the Department of

    Defense, Department of Veterans Affairs, Social Security Administration, State Department, and

    the Citizenship and Immigration Services. None of these agencies produced any information

    during the Section 5 declaratory judgment action. This has the potential to magnify the data

    discovery issues considerably. As with the state databases, these are massive databases that

    contain large quantities of personal identification information, statutorily protected from

    disclosure under federal law. Although the parties have already started discussions as to

    appropriate protective orders and methods of production, it is likely that disputes will arise

    concerning the appropriate scope and relevance of the discovery that Texas will seek. Based on

    our past experiences, these disputes are likely to be complex and resolving them will be time

    consuming. For example, during a seven-week period, the court hearing the Section 5

    declaratory judgment action held six telephonic conferences related to protective orders and

    discovery of data maintained by Texas. Once these issues are resolved, experts will require

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    withholding large categories of documents and deposition testimony. The legal issues

    surrounding these disputes were complicated and necessitated several rounds of briefing. The

    briefing of privilege issues occurred over the course of two months, from March 22, 2012,

    through May 30, 2012, and the court issued several orders related to privilege during that period

    up until June 7, 2012.

    In this action, the United States again intends to seek discovery from Texas legislators

    and staff and executive agencies to show that passage of SB 14 was motivated by discriminatory

    intent. Texas has stated that it will continue to assert, at least as broadly as it did during the

    declaratory judgment action, that such an inquiry is precluded by legislative privilege. Because

    the United States expects that it will again be required to compel some portion of the discovery

    that Texas withholds on the basis of legislative or other privileges, its proposed schedule

    provides sufficient time for the parties to brief motions to compel, the Court to consider the

    arguments and issue orders, and the parties to conduct discovery based on those orders.

    In sum, the Court should enter a scheduling order that provides the parties with an

    adequate period of time to prepare a complete factual record and an adequate time for the Court

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    Exhibit 3

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    IN THE UNITED STATES DISTRICT COURT

    FOR THE SOUTHERN DISTRICT OF TEXAS

    CORPUS CHRISTI DIVISION

    MARC VEASEY,et al.,

    Plaintiffs,

    v.

    RICK PERRY,et al.,

    Defendants.

    Civil Action No. 2:13-cv-193 (NGR)

    UNITED STATES OF AMERICA,

    Plaintiff,

    TEXAS LEAGUE OF YOUNG VOTERS

    EDUCATION FUND, et al.,

    Plaintiff-Intervenors,

    TEXAS ASSOCIATION OF HISPANIC

    COUNTY JUDGES AND COUNTY

    COMMISSIONERS, et al.,

    Civil Action No. 2:13-cv-263 (NGR)

    Case 2:13-cv-00193 Document 61-3 Filed in TXSD on 11/04/13 Page 2 of 4

    C 2 3 00 93 6 3 il d i S /0 / 3 3 f

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    TEXAS STATE CONFERENCE OF NAACP

    BRANCHES,et al.

    ,

    Plaintiffs,

    v.

    JOHN STEEN, et al.,

    Defendants.

    Civil Action No. 2:13-cv-291 (NGR)

    (PROPOSED) ORDER

    Pursuant to Fed. R. Civ. P. 16 and upon consideration of the parties joint report of the

    Rule 26(f) meeting and joint discovery/case management plan, the following schedule is hereby

    ORDERED:

    1. Fact discovery shall conclude on May 2, 2014. Notwithstanding the limits set forth inFed. R. Civ. P. 30(a)(2), Plaintiffs, Plaintiff-Intervenors, and Movant- Intervenors Texas

    Association of Hispanic Judges and Commissioners, et al. (if intervention is granted)shall be permitted to depose sixty (60) fact witnesses collectively. Likewise, Defendants

    and Movant-Intervenor True the Vote (if intervention is granted) shall be permitted to

    depose sixty (60) fact witnesses collectively.

    2. Expert disclosure under Fed. R. Civ. P 26(a)(2)(A) and disclosure of all expert reportsunder Fed. R. Civ. P. 26(a)(2)(B) shall be no later than May 9, 2014. Disclosure of

    Case 2:13-cv-00193 Document 61-3 Filed in TXSD on 11/04/13 Page 3 of 4

    C 2 13 00193 D t 61 3 Fil d i TXSD 11/04/13 P 4 f 4

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    _________________________

    NELVA GONZALES RAMOSUnited States District Judge

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    C 2 13 00193 D t 61 4 Fil d i TXSD 11/04/13 P 1 f 4

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    Exhibit 4

    Case 2:13-cv-00193 Document 61-4 Filed in TXSD on 11/04/13 Page 1 of 4

    C 2 13 00193 D t 61 4 Fil d i TXSD 11/04/13 P 2 f 4

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    THE VEASEY PLAINTIFFS POSITION WITH RESPECT TO SCHEDULING

    The Veasey plaintiffs propose a schedule thatunlike the other parties schedulewould

    provide an opportunity for plaintiffs to obtain relief on behalf of Texas voters in time for the

    November 2014 elections, the first major turnout elections in which Texas seeks to enforce the

    Voter ID law. The Veasey plaintiffs believe it is critically important to obtain a decision on SB

    14s validity before, not after, the first major elections, and they further believe it is feasible for

    the parties and the Court to have a trial on such a schedule.

    The Veasey plaintiffs filed their initial complaint on June 26, 2013, the day after the

    Supreme Court handed down its decision in Shelby County v. Holder, 133 S. Ct. 2612, and the

    State of Texas announced its intention to implement SB 14. This Court promptly entered a

    scheduling order in which trial was scheduled for June 2014. The Veasey plaintiffs then filed an

    amended complaint, and other parties filed complaints or sought to intervene, within 60 days

    thereafter. Thus, even if this Courts initial scheduling order were pushed back by 60 days, the

    parties could still have a trial in time for a decision before the November 2014 elections.

    Under the schedule proposed by the other parties, however, trial would not occur until

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    Accordingly, the Veasey plaintiffs propose the following schedule:

    Initial Disclosures Due November 21, 2013

    Fact Discovery Ends May 2, 2014

    Expert Reports Due May 9, 2014

    States Expert Rebuttal Reports Due June 6, 2014

    Plaintiffs Expert Reply Reports Due June 13, 2014

    Expert Witness Discovery Deadline July 15, 2014

    Dispositive Motions Due1

    July 22, 2014

    Dispositive Motion Responses Due August 4, 2014

    Replies to Dispositive Responses Due August 11, 2014

    Trial September 2, 2014

    In proposing the foregoing schedule, the Veasey plaintiffs are mindful of the need to

    develop a complete factual record in this case, but believe this schedule would permit the

    development of such a record. Adopting the Veasey plaintiffs proposed schedule does not

    t th t th liti ti ill b bl f T ill b bj ti t

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    In support of the Veasey plaintiffs proposed schedule, it is important to note that the

    parties are not starting from scratch in this case. A three-judge federal court in Washington, D.C.

    held a week-long trial in July 2012 and concluded that the Texas photo voter ID law

    discriminated against minority voters. The parties took dozens of depositions in that case, and

    the record included hundreds of exhibits and hundreds of pages of trial testimony. The

    significant evidence the parties have already amassed should allow a shorter discovery schedule

    here, and a trial before the November 2014 elections.

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    Exhibit 5

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    Case 2:13 cv 00193 Document 61 5 Filed in TXSD on 11/04/13 Page 2 of 4

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    IN THE UNITED STATES DISTRICT COURT

    FOR THE SOUTHERN DISTRICT OF TEXAS

    CORPUS CHRISTI DIVISION

    MARC VEASEY,et al.,

    Plaintiffs,

    v.

    RICK PERRY,et al.,

    Defendants.

    Civil Action No. 2:13-cv-193 (NGR)

    UNITED STATES OF AMERICA,

    Plaintiff,

    TEXAS LEAGUE OF YOUNG VOTERS

    EDUCATION FUND, et al.,

    Plaintiff-Intervenors,

    TEXAS ASSOCIATION OF HISPANIC

    COUNTY JUDGES AND COUNTYCOMMISSIONERS, et al.,

    Civil Action No. 2:13-cv-263 (NGR)

    Case 2:13-cv-00193 Document 61-5 Filed in TXSD on 11/04/13 Page 2 of 4

    Case 2:13-cv-00193 Document 61-5 Filed in TXSD on 11/04/13 Page 3 of 4

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    TEXAS STATE CONFERENCE OF NAACP

    BRANCHES,et al.

    ,

    Plaintiffs,

    v.

    JOHN STEEN, et al.,

    Defendants.

    Civil Action No. 2:13-cv-291 (NGR)

    (PROPOSED) ORDER

    Pursuant to Fed. R. Civ. P. 16 and upon consideration of the parties joint report of the

    Rule 26(f) meeting and joint discovery/case management plan, the following schedule is hereby

    ORDERED:

    1. The deadline for adding new parties is December 6, 2013.2. The deadline to amend pleadings deadline is May 1, 2014.3. Fact discovery shall conclude on August 15, 2014. Notwithstanding the limits set forth in

    Fed. R. Civ. P. 30(a)(2), Plaintiffs, Plaintiff-Intervenors, and Movant- Intervenors Texas

    Association of Hispanic Judges and Commissioners, et al. (if intervention is granted)shall be permitted to depose sixty (60) fact witnesses collectively. Likewise, Defendants

    and Movant-Intervenor True the Vote (if intervention is granted) shall be permitted to

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    7. Dispositive motions shall be filed by January 12, 2015; responses shall be filed byFebruary 11, 2015; and replies shall be filed by February 23, 2015. For any dispositive

    motions filed prior to January 12, 2015, responses shall be filed within thirty (30) daysand replies within ten (10) days after that.

    8. The pretrial statement shall be filed two weeks prior to the pretrial conference.9. The parties will be ready for trial as of March 17, 2015.

    _________________________NELVA GONZALES RAMOS

    United States District Judge

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    Exhibit 6

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    Case 2:13-cv-00193 Document 61-6 Filed in TXSD on 11/04/13 Page 2 of 18

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    IN THE UNITED STATES DISTRICT COURTFOR THE SOUTHERN DISTRICT OF TEXAS

    CORPUS CHRISTI DIVISION

    MARC VEASEY,et al.,

    Plaintiffs,

    v.

    RICK PERRY,et al.,

    Defendants.

    Civil Action No. 2:13-cv-193 (NGR)

    UNITED STATES OF AMERICA,

    Plaintiff,

    TEXAS LEAGUE OF YOUNG VOTERSEDUCATION FUND, et al.,

    Plaintiff-Intervenors,

    TEXAS ASSOCIATION OF HISPANIC

    COUNTY JUDGES AND COUNTYCOMMISSIONERS, et al.,

    Civil Action No. 2:13-cv-263 (NGR)

    Case 2:13 cv 00193 Document 61 6 Filed in TXSD on 11/04/13 Page 2 of 18

    Case 2:13-cv-00193 Document 61-6 Filed in TXSD on 11/04/13 Page 3 of 18

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    TEXAS STATE CONFERENCE OF NAACP

    BRANCHES, et al.,Plaintiffs,

    v.

    JOHN STEEN,et al.,

    Defendants.

    Civil Action No. 2:13-cv-291 (NGR)

    AGREEMENT CONCERNING PRODUCTION FORMAT

    Pursuant to Rules 26 and 34 of the Federal Rules of Civil Procedure, the parties agree to

    adhere to the following methods of production of documents and electronically stored

    information (ESI):

    1. With the exception of the items specified in paragraphs 10-18, below, the parties agree

    that documents and ESI that can be accurately represented in black and white shall be scanned or

    converted to single page Tagged Image File Format (TIFF or .tiff format) files, using CCITT

    Provisions for the Production of Documents and ESI

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    shall be produced in native form. Native files shall be saved in a directory named NATIVE with

    the proper Windows-associated extension.

    2. The parties agree to produce all imaged documents with a legible, unique page identifier

    (Bates Number) electronically burned onto the image in the lower right hand corner orif

    placement in the lower right hand corner would obliterate, conceal, or interfere with any

    information from the source documentanother blank portion of the TIFF image. The Bates

    numbering convention shall be in the format XXX######## where XXX represents the

    short character abbreviation for the producing party and ######## represents the eight-digit

    sequential number of the page being produced by that party. Documents produced by the parties

    shall be abbreviated as follows: Veasey Plaintiffs = VES, United States of America = USA,

    Texas League of Young Voters Education Fund = LYV, Texas State Conference of NAACP

    Branches = TSC, and Defendants = TEX. For example, the first Bates labeled document

    produced by the United States should be labeled USA00000001. Images shall be named as the

    [Bates Number].tif or [Bates Number].jpg. Native files shall be named as [Bates Number].ext,

    where ext denotes the native file extension.

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    identified on the physical Production Media includes: (1) the case number, (2) the producing

    partys name, and (3) the production date. Where practicable, the type of materials on the media

    (e.g., Documents, OCR Text, etc.) and the Bates Number range of the materials on the

    Production Media shall also be denoted thereon; where such material cannot reasonably be listed

    on the Production Media, they shall be provided in an accompanying letter.

    4. The parties agree not to produce documents or ESI using FTP, SFTP, or other hosted

    locations without notifying all parties. All such productions must include a single archive file

    per production wave (e.g., .zip, .rar, or .cab), labeling of such archives in numerical sequence in

    accordance with paragraph 4,supra, and immediate notice to all parties after a new archive has

    been uploaded to a hosted location. All requirements of this agreement shall apply to any

    production using FTP, SFTP, or other hosted locations.

    5. The parties shall produce an image cross reference file in Concordance Opticon .log

    format, to accompany the produced images. The image cross reference file shall provide the

    Bates Numbers, relative path to images, and document break indicators. The image cross

    reference file shall be provided in a directory named DATA.

    Case 3 c 00 93 ocu e t 6 6 ed S o /0 / 3 age 5 o 8

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    Character Recognition (OCR) text files. The OCR and extracted text files shall be produced in

    ASCII text format and shall be labeled and produced on Production Media in accordance with

    the provisions of paragraph 3, above. These text files will be named with the unique Bates

    Number of the first page of the corresponding document followed by the extension .txt. The

    OCR and extracted text files shall be produced in a manner suitable for importing the

    information into Concordance. OCR and extracted text files shall be saved in a directory named

    TEXT. All documents should have an accompanying text file, even if that file is of zero size.

    8. Irrespective of which party issued the requests for production of documents, tangible

    things, and ESI, the producing party shall serve a copy of responsive production to each of the

    other parties.

    Format for the Production of ESI

    9. E-mail will be produced as image files with related searchable text and available

    metadata as described in Attachment A.

    10. All spreadsheets, e.g., Excel or Quattropro, should be produced only in native format

    with related searchable text and available metadata as described in Attachment A. Spreadsheets

    g

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    materials, or a determination by a producing party that such materials are responsive to a broader

    request, and any such conference shall include the custodians of the materials, as well as

    technicians with sufficient knowledge to explain the content and format of the material at issue.

    13. The parties will meet and confer regarding the production of records or data from systems

    of record, databases, or federal agency comparisons in an agreed upon format. Any such

    conference shall be held within fourteen (14) days (unless the parties agree to a later date) of

    identification of databases in initial disclosures, a direct request for the production of databases,

    or a determination by a producing party that databases are responsive to a broader request, and

    any such conference shall include the custodians of the databases, as well as technicians with

    sufficient knowledge to explain the content and format of the databases.

    14. Other electronic documents not specifically discussed elsewhere will be produced as

    image files with related searchable text and available metadata as described in Attachment A. If

    said documents in their original form cannot be converted to TIFF as described above, the parties

    will promptly meet and confer concerning the form of such production.

    15. Documents with children (e.g., email with attachments, archive files, and files with

    g

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    17. Encryption or password protection of any file is to be removed or the passwords

    provided. If software is required to open encrypted files, the party producing the encrypted files

    must provide the software.

    Search of Electronically Stored Information

    18. To the extent that any party intends to limit the scope of a response to a request for

    production through the use of search terms, the parties agree to meet and confer regarding the

    responding partys search of ESI, including the partys technological search capability and the

    most effective means of defining search criteria, such as date ranges, custodians, and key words.

    19. The parties agree that the use of an agreed-on search process or set of search criteria shall

    not be construed as a waiver of any partys right to request subsequent searches and productions,

    particularly where there is a showing that the agreed-to search process and criteria have resulted

    in inadequate productions or failed to identify relevant materials. The parties also reserve their

    right to object to any additional requests or subsequent searches.

    20. The parties agree that documents identified by search terms may be reviewed for

    privilege, confidentiality, relevance, or responsiveness prior to production.

    g

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    23. To the extent possible, the parties will endeavor to apply unitization practices consistent

    with the following description: Each page of a hard copy document shall be scanned into an

    image and if a document is more than one page, the unitization of the document and any

    attachments shall be maintained as it existed in the original when creating the image file. For

    documents that contain fixed notes, (e.g., post-it notes), the pages will be scanned both with and

    without the notes and those pages will be treated as part of the same document. The relationship

    of documents in a document collection (e.g., cover letter and enclosures, email and attachments,

    binder containing multiple documents, or other documents where a parent-child relationship

    exists between the documents) shall be maintained through the scanning or conversion process.

    If more than one level of parent-child relationship exists, documents will be kept in order, but all

    will be treated as children of the initial parent document. Such information shall be produced in

    conformity with the Attachment Range field in Attachment A in a manner which enables the

    parent-child relationship among documents in a document collection to be reconstituted by the

    receiving party in Concordance.

    Privilege Logs

    g

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    25. The parties agree to provide sufficient information privilege logs to establish the elements

    of each asserted privilege. See, e.g., Taylor Energy Co. v. Underwriters at Lloyds of London,

    No. C.A. 09-6383, 2010 WL 3952208 (E.D. La. Oct. 7, 2010). However, the Parties need not

    note on a privilege log any documentincluding but not limited to draft documentsexchanged

    solely among counsel, individuals working directly on behalf of counsel in connection with this

    litigation (e.g., paralegals, analysts, and litigation support staff), or supervisory staff of the U.S.Department of Justice or the Office of the Texas Attorney General.

    26. E-mail attachments must be separately identified and described if they are withheld based

    on an assertion of privilege or protection.

    Inadvertent Production of Documents and Clawback

    27. The parties agree that a disclosure of communications, documents, tangible things, and

    ESI covered by the attorney-client privilege, work product protection, or governmental privileges

    does not operate as a waiver in this proceeding if (1) the disclosure is inadvertent and is made in

    connection with this litigation or prior proceedings under Section 5 of the Voting Rights Act, 42

    U.S.C. 1973c, and (2) the holder of the privilege or protection took reasonable precautions to

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    producing party or destroyed at the producing partys option. This includes all copies

    electronic or otherwiseof any such materials and the parties agree that no further copies of the

    inadvertently disclosed materials will be made. In the event that copies of inadvertently

    produced materials that are privileged or protected are captured on a partys back-up media used

    for disaster recovery, the parties will over-write those copies according to their established back-

    up procedures.29. If privileged or protected information is contained within an item of otherwise

    discoverable material, the parties recognize that the requesting party may not be able to destroy

    only the portion of the item of the disclosed material that is privileged or protected. Instead, the

    requesting party may need to destroy the privileged or protected information along with all of the

    otherwise discoverable material within that item. Whenever that is the case, the producing

    partywithin fourteen (14) days of notification of the inadvertent disclosureshall provide the

    requesting party with a replacement copy of the item materials that are not privileged or

    protected and are otherwise discoverable.

    30. In the event that the requesting party disputes the producing partys assertions with

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    31. If the producing party does not request the return or destruction of material within

    fourteen (14) days of notification by the receiving party of the receipt of material it believes was

    inadvertently produced, the producing party waives any claim of privilege or protection as to the

    material.

    Sample Production

    32. On or before fourteen (14) days following the effective date of this Agreement, theparties shall exchange a sample production of documents formatted to be consistent with this

    Agreement. The sample production shall contain a combination of scanned paper files and ESI

    and shall include at least one spreadsheet and one email. The production need not be relevant to

    this case, as it is intended only to test the adequacy of the specifications in this Agreement and

    the compatibility of the parties systems. If any party reports problems with the sample

    productions, the parties shall confer regarding the terms of this agreement.

    Duty to Supplement Discovery Responses

    33. The parties must supplement their disclosures and responses in a timely manner if a party

    learns that a disclosure was materially incorrect or incomplete, in accordance with Federal Rule

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    Dated: November 4, 2013

    For the Veasey Plaintiffs

    /s/ Chad W. Dunn

    CHAD W. DUNNK. SCOTT BRAZILBrazil & Dunn4201 Cypress Creek ParkwaySuite 530

    Houston, Texas 77068J. GERALD HEBERTCampaign Legal Center215 E Street, NEWashington, D.C. 20002

    NEIL G. BARON

    Law Office of Neil G. Baron914 FM 517 WestSuite 242Dickinson, Texas 77539

    DAVID RICHARDSRichards, Rodriguez & Skeith LLP816 Congress Avenue

    Suite 1200Austin, Texas 78701

    For the United States of America

    KENNETH MAGIDSONUnited States AttorneySouthern District of Texas

    JOCELYN SAMUELSActing Assistant Attorney General

    Civil Rights Division

    /s/ Elizabeth S. Westfall

    T. CHRISTIAN HERREN, JR.MEREDITH BELL-PLATTSELIZABETH S. WESTFALLBRUCE I. GEARJENNIFER L. MARANZANO

    ANNA M. BALDWINDANIEL J. FREEMANAttorneys, Voting SectionCivil Rights DivisionU.S. Department of Justice950 Pennsylvania Avenue, N.W.Washington, D.C. 20530

    JOHN A. SMITH IIIAssistant United States Attorney800 N Shoreline Suite 500

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    For NAACP Plaintiffs:

    /s/ Ezra D. Rosenberg

    EZRA D. ROSENBERGDechert LLP902 Carnegie Center, Suite 500Princeton, New Jersey 08540

    STEVEN B. WEISBURD

    AMY L. RUDDLINDSEY B. STELCENDechert LLP500 W. 6th Street, Suite 2010Austin, Texas 78701

    ROBERT A. KENGLEMARK A. POSNER

    SONIA KAUR GILLERANDI ZAMORALawyers Committee for Civil Rights

    Under Law1401 New York Avenue, NWSuite 400Washington, D.C. 20005

    WENDYWEISERMYRNA PREZVISHAL AGRAHARKAR

    KIM KEENANMARSHALL TAYLORVICTOR GOODENAACP4805 Mt. Hope DriveBaltimore, Maryland 21215

    JOSE GARZALaw Office of Jose Garza7414 Robin Rest DriveSan Antonio, Texas 98209

    CLAY BONILLADANIEL G. COVICH

    The Law Offices of William Bonilla, P.C.2727 Morgan Ave.Corpus Christi, Texas 78405

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    For Texas League of Young Voters

    Educational Fund, et al. Intervenors:

    /s/ Ryan P. HaygoodSHERRILYN IFILLCHRISTINA SWARNSRYAN P. HAYGOODNATASHA M. KORGAONKARLEAH C. ADENNAACP Legal Defense and

    Educational Fund, Inc.40 Rector Street, 5th FloorNew York, New York 10006

    DANIELLE CONLEYJONATHAN PAIKINKELLY P. DUNBARSONYA L. LEBSACK

    Wilmer Cutler PickeringHale and Dorr LLP1875 Pennsylvania Ave., NWWashington, D.C. 20006

    For the State of Texas et al.

    GREG ABBOTTAttorney General of Texas

    DANIEL T. HODGEFirst Assistant Attorney General

    /s/ John B. Scott

    JOHN B. SCOTT

    Deputy Attorney General209 West 14th StreetAustin, Texas 78711

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    1

    Attachment A

    Name of Field Type of

    field

    Contents

    E-mail Word Processingor PDFs

    Spreadsheets Digital Photos Paper

    Begin_Bates Text Bates number forthe TIFF/jpg

    image of the first

    page

    Bates number forthe TIFF/jpg

    image of the first

    page

    Bates number ofthe placeholder

    page

    Bates number forthe TIFF/jpg

    image of the first

    page

    Bates number forthe TIFF/jpg

    image of the first

    page

    End_Bates Text Bates number forthe TIFF/jpg

    image of the last

    page

    Bates number forthe TIFF/jpg

    image of the last

    page

    Bates number ofthe placeholder

    page

    Bates number forthe TIFF/jpg

    image of the last

    page

    Bates number forthe TIFF/jpg

    image of the last

    page

    AttachmentRange

    Text Bates rangestarting with thefirst page of the

    parent documentthrough the last

    page of the lastattachment.

    Blank if there are

    no childdocuments

    Bates rangestarting with thefirst page of the

    parent documentthrough the last

    page of the lastattachment or

    embedded file.

    Included only ifpart of a group of

    documents like anemail or zip file.

    Bates rangestarting with thefirst page of the

    parent documentthrough the last

    page of the lastattachment or

    embedded file.

    Included only ifpart of a group of

    documents like anemail or zip file.

    Bates rangestarting with thefirst page of the

    parent documentthrough the last

    page of the lastattachment or

    embedded file.

    Included only ifpart of a group of

    documents like anemail or zip file.

    Bates range of alldocuments thatwere grouped

    together/physically attached

    by clips, staples, orbinding or folder.

    Blank if a single

    non groupeddocument

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    Name of Field Type of

    field

    Contents

    E-mail Word Processing

    or PDFs

    Spreadsheets Digital Photos Paper

    Custodian Text The name of the

    person who had

    primary controlover the location

    from which thedocument was

    collected

    The name of the

    person who had

    primary controlover the location

    from which thedocument was

    collected

    The name of the

    person who had

    primary controlover the location

    from which thedocument was

    collected

    The name of the

    person who had

    primary controlover the location

    from which thedocument was

    collected

    The name of the

    person maintaining

    the file from whichthe paper was

    obtained

    Author Paragraph From field

    To Paragraph To field

    CC Paragraph CC field

    BCC Paragraph BCC field

    Subject Paragraph Subject field

    DateSent Date The date themessage was

    sent (format:9/28/2012)

    TimeSent Text The time themessage was

    sent (format:11:16:46 AM)

    MD5Hash Text The MD5 hash

    value calculated

    when the filewas collected or

    processed.

    The MD5 hash

    value calculated

    when the file wascollected or

    processed.

    The MD5 hash

    value calculated

    when the file wascollected or

    processed.

    The MD5 hash

    value calculated

    when the file wascollected or

    processed.

    Prod_FilePath Paragraph The path to the

    native file on theproduction

    media

    The path to the

    native file on theproduction media

    The path to the

    native file on theproduction media

    The path to the

    native file on theproduction media

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    3

    Name of Field Type of

    field

    Contents

    E-mail Word Processing

    or PDFs

    Spreadsheets Digital Photos Paper

    Orig_filename Paragraph Original name of

    the native file

    when the filewas collected or

    processed

    Original name of

    the native file

    when the file wascollected or

    processed

    Original name of

    the native file

    when the file wascollected or

    processed

    Original name of

    the native file

    when the file wascollected or

    processed

    Responsive to Text Document

    request numbers

    for which this

    document is

    responsive.

    Document request

    numbers for which

    this document is

    responsive.

    Document request

    numbers for which

    this document is

    responsive

    Document request

    numbers for which

    this document is

    responsive

    Document request

    numbers for which

    this document is

    responsive