UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION TEXAS DEMOCRATIC PARTY by mjs17436

VIEWS: 0 PAGES: 60

More Info
									                        UNITED STATES DISTRICT COURT
                     FOR THE SOUTHERN DISTRICT OF TEXAS
                              HOUSTON DIVISION

TEXAS DEMOCRATIC PARTY;                   §
BOYD L. RICHIE, in his capacity as        §
Chairman of the Texas Democratic Party;   §
HARRIS COUNTY DEMOCRATIC                  §
PARTY;                                    §
GERALD BIRNBERG, in his capacity as       §
Chairman of the Harris County             §
Democratic Party;                         §
J. GOODWILLE PIERRE;                      §
ALEXANDRA GIBBS; JEFFREY T.               §
VANSCHOONHOVEN; BONI SUE                  §
LESZCZUK; and ERIC J. GALLOWAY            §                  Cause No. 4:08-CV-03332
                                          §
       Plaintiffs,                        §
                                          §
vs.                                       §
                                          §
LEO VASQUEZ, in his capacity as           §
Harris County Tax Assessor Collector      §
and Harris County Voter Registrar         §
                                          §
       Defendant.                         §

               PLAINTIFFS’ RULE 26(a)(1) INITIAL DISCLOSURES

       Pursuant to Rule 26 (a)(1) of the Federal Rules of Civil Procedure, Texas

Democratic Party; Boyd L. Richie, in his capacity as Chairman of the Texas Democratic

Party; Harris County Democratic Party; Gerald Birnberg, in his capacity as Chairman of

the Harris County Democratic Party; J. Goodwill Pierre; Alexandra Gibbs; Jeffrey T.

Vanschoonhoven; Boni Sue Leszczuk; and Eric J. Galloway submit the following

disclosures in this case:


                                          1
A.   The name and, if known, the address and telephone number of each
     individual likely to have discoverable information relevant to disputed facts
     alleged with particularity in the pleadings, identifying the subjects of the
     information:

     1.    Texas Democratic Party;
           Boyd L. Richie, in his capacity as Chairman of the Texas Democratic Party;
           Harris County Democratic Party;
           Geral Birnberg, in his capacity as Chairman of the Harris County
           Democratic Party;
           J. Goodwill Pierre;
           Alexandra Gibbs;
           Jeffrey T. Vanschoonhoven;
           Boni Sue Leszczuk; and
           Eric J. Galloway
           c/o Mr. Chad Dunn
           TEXAS DEMOCRATIC PARTY
           BRAZIL & DUNN
           4201 FM 1960 West, Suite 550
           Houston, Texas 77002
           Telephone: (281) 580-6310

           Plaintiffs

     2.    Leo Vasquez, in his capacity as
           Harris County Tax Assessor Collector and Harris County Voter Registrar
           c/o Mr. F. Clinton Gambill, II
           SR. ASSISTANT COUNTY ATTORNEY
           1019 Congress, 15th Floor
           Houston, Texas 77002
           Telephone: (713) 755-4985

           Defendant

     3.    Representative Robert Talton
           Texas House of Representatives
           3622 Fairmont Pkwy
           Pasadena, Texas 77504
           (281) 487-8818




                                        2
     Representative for Texas Congressional District 144, who is expected to
     testify regarding his private meetings with Defendant on the topic of voter
     registration, counting provisional ballots, and the ballot board, among other
     things, and will testify regarding private meetings and phone calls with Jim
     Harding.

4.   Jared Woodfill
     Harris County Republican Party Chairman
     3311 Richmond, Suite 218
     Houston, Texas 77098 - 713-838-7900

     Chairman of the Harris County Republican Party, who is expected to testify
     regarding his private meetings with Defendant on the topic of voter
     registration, counting provisional ballots, and the ballot board, among other
     things, and will testify regarding private meetings and phone calls with Jim
     Harding.

5.   Jim Harding
     5010 Sandy Cedar
     Kingwood, Texas 77345
     (281) 360-7334

     Ballot board Chairman, who, based on information and belief, is expected
     to have knowledge of the inner workings of the ballot board the lack of
     response by Defendant to the ballot board and the condition and the timing
     of the ballots that were received from Defendant, among other things. He
     is also expected to testify to Defendant’s and other republican party
     personnel’s contact with him during ballot board operations and the
     subsequent investigation into this contact.

6.   Mary Almendarez
     608 Joyce St.
     Houston, Texas 77009
     (713) 699-9716

     Ballot board member, who, based on information and belief, is expected to
     have knowledge of the inner workings of the ballot board the lack of
     response by Defendant to the ballot board and the condition and the timing
     of the ballots that were received from Defendant, among other things.




                                   3
7.    Imogene Anderson
      2301 Hayes Rd., Apt. 6705
      Houston, Texas 77077
      (713) 782-0919

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

8.    Gwendolyn Bell
      11526 Heathermill Dr.
      Houston, Texas 77066
      (281) 844-8741

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

9.    Priscilla Bloomquist
      12403 Mullins Dr.
      Houston, Texas 77035
      (713) 721-7376

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

10.   Bettye Bruno
      8305 Bigwood St.
      Houston, Texas
      (713) 828-0055

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

11.   Jane Cherry

                                   4
      3616 Garrett #5
      Houston, Texas 77006
      (713) 516-4464

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

12.   Kirk Childress
      3560 Dixie Dr., Apt. 931
      Houston, Texas 77021
      (713) 842-4150

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

13.   Bill Comstock
      245 Malone
      Houston, Texas 77007
      (713) 861-5676

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

14.   Virginia Duke
      211 Eleanor
      Houston, Texas 77009
      (713) 695-3198

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

15.   Guyleene Ebersole
      6666 Chetwood #205

                                   5
      Houston, Texas 77081
      (713) 665-6470

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

16.   Michael Fleming
      1902 Coquitt, Apt. 16C
      Houston, Texas 77098
      (713) 528-3968

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

17.   Billie Rose Gray
      120 E. 3rd
      Houston, Texas 77018
      (713) 861-1034

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

18.   Leif Hatlen
      13527 N. Tracewood Bend
      Houston, Texas 77077
      (281) 493-3107

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

19.   Mary Ann Haxthausen
      323 W. 33rd St.
      Houston, Texas 77018

                                   6
      (713) 864-4855

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

20.   Joan Hinyard
      4902 Libbey Ln.
      Houston, Texas 77092
      (713) 681-6011

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

21.   Stephanie Hrabar
      5005 Gregori Ln, #63
      Houston, Texas 77092
      (713) 683-0638

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

22.   Joe Lovino
      2056 Antoine Dr., Apt. 410
      Houston, Texas 77055
      (713) 382-0619

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

23.   Mary Luckey
      5431 Indigo St.
      Houston, Texas 77096
      (281) 610-7254

                                   7
      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

24.   Sharon Macha
      4730 Willowbend Blvd.
      Houston, Texas 77035
      (713) 723-7416

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

25.   George McAfee
      2801 Arbor St.
      Houston, Texas 77004
      (713) 529-0275

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

26.   Paul Morgan
      10038 Elm Meadow Trail
      Houston, Texas 77064
      (713) 807-9118

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

27.   Linda Omelas
      5627 Valley Scene Way
      Spring, Texas 77379
      (832) 928-1696


                                   8
      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

28.   Marian Parent
      1715 Briarpark Dr.
      Houston, Texas 77042
      (713) 784-0827

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

29.   Troy Preble
      1522 Gardenia
      Houston, Texas 77018
      (832) 891-6782

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

30.   Francisco Rodriguez
      6526 Wynnwood Ln.
      Houston, Texas 77008
      (713) 880-8008

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

31.   Linda George Smith
      6646 Community Dr.
      Houston Texas 77005
      (713) 664-3521




                                   9
      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

32.   Cynthia Thompson
      5814 Silver Forest
      Houston, Texas 77092
      (713) 681-3300

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

33.   Mary Titus
      5202 Viking Dr.
      Houston Texas 77092
      (713) 680-2880

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

34.   Michael Kelly
      6000 Reims, $2208
      Houston, Texas
      (713) 266-0037

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

35.   Gail Holley
      Unknown

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of


                                   10
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

36.   Calvin Wilson
      1527 W. 24th St.
      Houston, Texas
      (281) 415-6299

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

37.   Anna James
      Unknown

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

38.   Georgia Cole
      12144 Sandpiper, #880
      Houston, Texas
      (713) 721-9536

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

39.   Dalea Lugo
      9418 Highmeadow Dr.
      Houston, Texas
      (713) 974-7883

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.


                                   11
40.   Diane Frory
      Unknown

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

41.   Shirley Haynes
      9706 Daisy Mist Ln.
      Houston, Texas
      (281) 999-1642

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

42.   Gertie Oliver
      Unknown

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

43.   Thyea Burks
      5606 Belfort
      Houston, Texas
      (713) 733-6584

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

44.   Allison Cookingham
      16011 Stratton Park
      Spring, Texas 77379
      (281) 370-9755


                                   12
      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

45.   Martha B. Phillips
      1341 Winrock
      Houston, Texas 77057
      (713) 974-6330

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

46.   Gail Boudreaux
      1247 West Pierce
      Houston, Texas 77019
      (832) 860-3818

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

47.   Cynthia Battiste
      4718 Rosebud Dr.
      Houston, Texas 77053
      (832) 541-9317

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

48.   Bill Borden
      4406 Basswood
      Bellaire, Texas 77401
      (713) 660-7241




                                   13
      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

49.   Ton Brunner
      14 Greenway Plaza, 9L
      Houston, Texas 77046
      (713) 622-9442

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

50.   Fran Carrow
      14515 Wunderlich Dr. #401
      Houston, Texas 77069
      (281) 580-8133

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

51.   Jerry Clark
      1911 Post Oak Park Dr., #5218
      Houston, Texas 77027
      (713) 963-8441

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

52.   Pete Goedicke
      4901 Floyd St., #14
      Houston, Texas 77007
      (713) 862-7697




                                   14
      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

53.   Joe Gutheinz
      1854 Raintree Cir.
      Seabrook, Texas 77586
      (281) 488-1280

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

54.   Kathy Haigler
      1509 Garden Park Dr.
      Deer Park, Texas 77536
      (281) 479-1339

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

55.   George G. Huntoon, Jr.
      3918 Shadow Trace Dr.
      Houston, Texas 77082
      (713) 870-9747

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

56.   Jon Keeney
      1314 Spring Cress Ln.
      Seabrook, Texas 77586
      (281) 291-0191




                                   15
      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

57.   Charles Mason
      69 Masonville, #312
      Houston, Texas
      (281) 689-1674

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

58.   Peggy Mason
      69 Masonville, #312
      Houston, Texas
      (281) 689-1674

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

59.   Leonard Negrin
      2818 Blue Glen Ln.
      Houston, Texas 77073
      (281) 821-1968

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

60.   Maxine Negrin
      2818 Blue Glen Ln.
      Houston, Texas 77073
      (281) 821-1968




                                   16
      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

61.   Roman Nietfeld
      6403 Darby Way
      Spring, Texas 77389
      (281) 376-7954

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

62.   Frances Nussbaum
      16818 Clear Oak Way
      Houston, Texas
      (281) 218-9894

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

63.   Margie Phelps
      7634 Langley Rd.
      Houston, Texas 77016
      (713) 633-6293

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

64.   Alice Rekeweg
      4203 Broadleaf
      Kingwood, Texas 77345
      (281) 360-7457




                                   17
      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

65.   Lula Mae Rhodes
      4006 E. Yorkshire St.
      Houston, Texas 77016
      (713) 631-1381

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

66.   Sarah Singleton
      4310 Sanford Rd.
      Houston, Texas 77035

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

67.   Barbara Brehmer
      16018 Capistrano Falls,
      Friendswood, Texas 77546
      (281) 648-1145

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

68.   Walter Carrow
      14515 Wunderlich Dr., #401
      Houston, Texas 77069
      (713) 301-4572

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of

                                   18
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

69.   Ruby Cubley
      15827 Craighurst Dr.
      Houston, Texas 77059
      (281) 488-7022

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

70.   Kristi Dunn Hamilton
      12519 Cooperstown
      Houston, Texas 77089
      (832) 598-2453

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

71.   Nelda Eppes
      5426 Poinciana Dr.
      Houston, Texas 77092
      (713) 858-8176

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

72.   Fran Jolly
      12411 Lago Bend Ln.
      Houston, Texas 77041
      (832) 287-4776

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of


                                   19
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

73.   Cynthia Klenzman
      618 N. Magnolia St.
      Tomball, Texas 77375
      (281) 255-9984

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

74.   Anthony Mason
      56 Masonville Ln.
      New Caney, Texas 77357
      (281) 689-1674

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

75.   Perky Savage
      12502 Bent Pine Dr.
      Cypress, Texas 77429
      (281) 807-0855

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

76.   Mike Sullivan
      4811 Shore Hills
      Kingwood, Texas 77345
      (281) 361-6065

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of


                                   20
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

77.   Rob Todd
      651 Bering Dr., Apt. 1904
      Houston, Texas 77057

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

78.   Kay Boothe
      5451 Kinglet
      Houston, Texas 77096
      (713) 729-7755

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

79.   Chase Camarena
      47 Neyland
      Houston, Texas 77022
      (713) 697-0669

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

80.   Mary Coats
      422 N. Pecan
      Tomball, Texas 77375
      (281) 351-1038

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

                                   21
81.   James Coy
      7810 Kleingreen
      Spring, Texas 77379
      (281) 320-9849

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

82.   Doris Esparza
      1651 Shadow Bend
      Houston, Texas 77043
      (713) 465-3624

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

83.   Connie Grubbs
      1414 Birchwood
      Houston, Texas 77093
      (281) 442-4802

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

84.   Dorothy Porter
      13710 Whitchurch Way
      Houston, Texas 77015
      (713) 453-8872

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.


                                   22
85.   Dawn Shull
      13322 Golden Valley Dr.
      Cypress, Texas 77429
      (281) 376-2067

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

86.   Effie Williams
      5914 Bretshire Dr.
      Houston, Texas 77016
      (713) 631-3576

      Ballot board member, who, based on information and belief, is expected to
      have knowledge of the inner workings of the ballot board the lack of
      response by Defendant to the ballot board and the condition and the timing
      of the ballots that were received from Defendant, among other things.

87.   Ian Meyn
      2825 Bellefontaine St., 106A
      Houston, Texas 77025

      Potential voter who, based upon information and belief, was affected by the
      actions of Defendant and is expected to testify to the actions taken to
      register, the voting process, and the contact, if any, with voting officials,
      Defendant and/or Defendant’s agents.

88.   Lorraine Brown-Spencer
      3602 Windmill Village
      Houston, Texas 77082
      (281) 589-1538

      Potential voter who, based upon information and belief, was affected by the
      actions of Defendant and is expected to testify to the actions taken to
      register, the voting process, and the contact, if any, with voting officials,
      Defendant and/or Defendant’s agents.

89.   Hugo Alvarado
      8502 Pitner, #1205

                                     23
      Houston, Texas 77080

      Potential voter who, based upon information and belief, was affected by the
      actions of Defendant and is expected to testify to the actions taken to
      register, the voting process, and the contact, if any, with voting officials,
      Defendant and/or Defendant’s agents.

90.   Jennifer Baker
      1885 El Paseo, Apt. 315
      Houston, Texas
      (409) 718-7242

      Potential voter who, based upon information and belief, was affected by the
      actions of Defendant and is expected to testify to the actions taken to
      register, the voting process, and the contact, if any, with voting officials,
      Defendant and/or Defendant’s agents.

91.   Johnny Berrones
      2253 Collier
      Houston, Texas 77023
      (713) 926-7035

      Potential voter who, based upon information and belief, was affected by the
      actions of Defendant and is expected to testify to the actions taken to
      register, the voting process, and the contact, if any, with voting officials,
      Defendant and/or Defendant’s agents.

92.   Shawana Ford
      5950 Antoine, Apt. 111
      Houston, Texas 77091
      (713) 688-4716

      Potential voter who, based upon information and belief, was affected by the
      actions of Defendant and is expected to testify to the actions taken to
      register, the voting process, and the contact, if any, with voting officials,
      Defendant and/or Defendant’s agents.

93.   Amelia Gallegos
      2001 Laverne, Apt. 208
      Houston, Texas 77080


                                    24
      Potential voter who, based upon information and belief, was affected by the
      actions of Defendant and is expected to testify to the actions taken to
      register, the voting process, and the contact, if any, with voting officials,
      Defendant and/or Defendant’s agents.

94.   Britney Gonzales
      3443 Addicks-Clodine, $2201
      Houston, Texas 77082
      (832) 890-4178

      Potential voter who, based upon information and belief, was affected by the
      actions of Defendant and is expected to testify to the actions taken to
      register, the voting process, and the contact, if any, with voting officials,
      Defendant and/or Defendant’s agents.

95.   Kevin Hall
      3710 Tierwester
      Houston, Texas

      Potential voter who, based upon information and belief, was affected by the
      actions of Defendant and is expected to testify to the actions taken to
      register, the voting process, and the contact, if any, with voting officials,
      Defendant and/or Defendant’s agents.

96.   Marcus Dwayne Harrell
      12777 Ashford Point Dr., Apt. 824
      Houston, Texas 77082
      (720) 278-4343

      Potential voter who, based upon information and belief, was affected by the
      actions of Defendant and is expected to testify to the actions taken to
      register, the voting process, and the contact, if any, with voting officials,
      Defendant and/or Defendant’s agents.

97.   Theodore Hine
      7553 Brompton
      Houston, Texas 77025

      Potential voter who, based upon information and belief, was affected by the
      actions of Defendant and is expected to testify to the actions taken to


                                    25
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

98.    Edgar Lopez
       4139 Antoinette
       Houston, Texas 77087
       (713) 780-7596

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

99.    Ismenia Matos
       20118 Riverwood Dr.
       Cypress, Texas 77433
       (832) 927-9876

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

100.   Saldana Mauro
       10629 Stafford
       Houston, Texas 77093
       (713) 695-3531

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

101.   Don McKnight
       10307 Rebel Rd.
       Houston, Texas 77016

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

                                     26
102.   Andre Anthony Moore
       13503 North Borough, #205
       Houston, Texas 77067
       (832) 884-9655

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

103.   Jeany Ngo
       18006 Darling Point
       Cypress, Texas 77429
       (408) 206-5518

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

104.   Angie Perez
       420 W. Polk
       Houston, Texas 77019
       (713) 527-0217

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

105.   Steven Pradia II
       12107 Meadow Place
       Houston, Texas 77071
       (832) 549-9543

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.


                                     27
106.   Steven Register
       2825 Belle Fontaine, Apt. 140A
       Houston, Texas 77025

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

107.   Laura Reiber
       6637 W. 43rd
       Houston, Texas 77092
       (713) 939-0354

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

108.   Parris Rhodes
       7600 Creekbend, Apt. 242
       Houston, Texas 77071
       (832) 352-0444

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

109.   Abel Robledo
       5410 Cuerie Crest
       Houston, Texas 77088
       (281) 931-5383

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

110.   Alex Rubit
       4403 Heritage Trail Dr.

                                     28
       Houston, Texas 77047
       (832) 889-2842

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

111.   Juanita Smith
       4242 Bridledon
       Houston, Texas 77014
       (832) 715-8966

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

112.   Danielle Stringer
       1903 Portsmouth, Apt., 22
       Houston, Texas 77098
       (281) 857-0837

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

113.   John Suarez
       22967 Twisting Pine
       Spring, Texas 77373

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

114.   Doris Thomas
       3443 Addicks Clodine, #2204
       Houston, Texas 77082


                                     29
       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

115.   Martha Villanueva
       5019 Calhoun, Apt. 301D
       Houston, Texas 77004
       (956) 472-8258

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

116.   Philip Adesulu
       2111 Holly Hall
       Houston, Texas 77054
       (214) 563-6832

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

117.   Fassika Asrat
       11518 Bowlan
       Houston, Texas 77035
       (713) 721-3905

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

118.   Gerald C. Beloney
       Unknown

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to


                                     30
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

119.   Rodney G. Billings
       4100 W. 34th
       Housotn, Texas 77092
       (713) 957-3666

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

120.   Tiffany L. Bond
       503 El Dorado, #1802
       Houston, Texas 77598

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

121.   Alla Sheena Boyer
       Unknown

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

122.   Donald Brazzeal
       11735 S. Glen
       Houston, Texas
       (281) 988-7960

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

123.   Sean Broussard

                                     31
       503 El Dorado, #201
       Houston, Texas 77598

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

124.   Leonard Bernard Brown
       Unknown

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

125.   Brent Busby
       12703 Laurel Vale
       Houston, Texas 77014
       (281) 923-9373

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

126.   Emma Carper
       Unknown

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

127.   Charles Celestine
       14027 Memorial
       Houston, Texas
       (281) 763-9144

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to

                                     32
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

128.   James Earl Cooper, II
       6614 Roxbury
       Houston, Texas 77087

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

129.   Anthony Cowley
       503 El Dorado, #811
       Houston, Texas 77598

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

130.   Sharde De Lane
       10205 Mayfield
       Houston, Texas 77043
       (713) 365-0535

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

131.   Antoine Dowdy
       2510 Orchard Run Way
       Houston, Texas 77545
       (832) 896-1986

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.


                                     33
132.   Robin Dubose
       12660 Stafford, #1118
       Houston, Texas
       (832) 865-2847

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

133.   Charles Dwight Dunn
       2010 Winrock
       Houston, Texas 77057

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

134.   Deandre Antoine Edwards
       503 El Dorado, #1802
       Houston, Texas 77598

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

135.   Linda Diane Eugene
       8201 W. Belfort, #1312
       Houston, Texas
       (713) 771-3560

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

136.   Lasonya Farr
       Unknown


                                     34
       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

137.   Terry Fox
       503 El Dorado, #1903
       Houston, Texas 77598

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

138.   Leonard Author Garrett
       4625 N. Braeswood, #305
       Houston, Texas
       (713) 838-2485

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

139.   Clay Eric Granger
       Unknown

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

140.   Herbert Wayne Green
       Unknown

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

141.   Gabriel Griffin

                                     35
       1041 Waverly
       Houston, Texas 77008
       (832) 452-8403

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

142.   Jason Griggs
       15802 Baybriar
       Houston, Texas 77489

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

143.   Alesa Guidry
       5557 Wheatley
       Houston, Texas
       (713) 682-2009

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

144.   Marlon J. Guidry
       Unknown

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

145.   Jarrod Gullett
       9307 Woodwind Lakes
       Houston, Texas 77040
       (713) 820-5343


                                     36
       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

146.   Silliman Hale
       Uknown

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

147.   Tamara Harris
       10909 Gulf Frwy, #1008
       Houston, Texas
       (402) 214-4421

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

148.   Richard Hermosa
       956 Stevenage
       Houston, Texas 77530

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

149.   Gabriel Herrera
       6751 Windy River
       Houston, Texas 77449

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.


                                     37
150.   Frederick Holmes
       13725 Cambury, #805
       Houston, Texas 77014

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

151.   Pamela Hunt
       12660 Stafford, #1118
       Houston, Texas
       (832) 865-2847

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

152.   Craig Jackson
       3130 Rita
       Houston, Texas 77051
       (713) 734-0344

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

153.   Leroy Jackson
       4045 N. Frwy, #408
       Houston, Texas 77022
       (713) 691-6671

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

154.   L.B. Jacob
       Unknown

                                     38
       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

155.   Charles F. Jones
       5507 Acres Dr.
       Houston, Texas 77048

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

156.   Cheryl Julien
       1701 Upland, #229
       Houston, Texas

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

157.   Belinda Kent
       11807 Elkington Ct.
       Houston, Texas 77071

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

158.   Adrian King
       2510 Orchard Run Way
       Houston, Texas 77545
       (832) 896-1986

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to


                                     39
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

159.   Diann McAlpin
       7639 Quail Meadows
       Houston, Texas 77071
       (713) 441-4414

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

160.   Junely Sivl Miranda
       17819 Shadow Cypress Ct.
       Houston, Texas 77433

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

161.   Amy Mounger
       15831 Arbor Lake
       Houston, Texas 77377

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

162.   Tyra Nicole Parker
       425 Rayford, #513
       Houston, Texas 77386

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

163.   Ginita O. Phelps

                                     40
       Unknown

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

164.   Rosalind L. Polito
       6060 Enchanted River
       Houston, Texas 77388

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

165.   Julian Abrego Ramirez
       3311 Havner
       Houston, Texas 77093

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

166.   Alan Richard
       Unknown

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

167.   Ramica L. Rideaux
       Unknown

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.


                                     41
168.   Sandra Risper
       5561 Live Oak, #1
       Houston, Texas 77004
       (713) 657-5191

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

169.   Christopher Antonio Rodgers
       425 Rayford, #513
       Houston, Texas 77386

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

170.   Nico Antonio Rodgers
       425 Rayford, #513
       Houston, Texas 77386

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

171.   Josephine Salinas
       4278 Bethel Blvd.
       Houston, Texas 77092
       (713) 748-9213

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

172.   Victoria Sanchez
       Unknown


                                     42
       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

173.   Opal Lynn Sharp
       2600 Westridge, #273
       Houston, Texas 77054

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

174.   Jewel Shepherd
       Unknown

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

175.   Deneatria Sias
       1909 Creek Run
       Houston, Texas 77584
       (281) 381-1913

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

176.   Minerva Smith
       9200 Bissonnet
       Houston, Texas 77074
       (281) 827-1964

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

                                     43
177.   Tavia Gwennell Solari
       1954 Skipwood
       Houston, Texas 77489

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

178.   Betty Stills
       5959 Bonhomme, #302
       Houston, Texas
       (832) 252-7982

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

179.   George Taft
       5410 Samrose
       Houston, Texas 77091

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

180.   Clifford John Taylor
       14719 Barryknoll, #49
       Houston, Texas 77079
       (281) 253-0015

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

181.   Joshua Thibodeaux

                                     44
       2402 Calumet
       Houston, Texas 77004
       (832) 353-7508

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

182.   Kimberlyn Thomas
       10901 Telephone Rd., #106
       Houston, Texas
       (713) 264-6964

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

183.   Shannon Chase Thomas
       Unknown

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

184.   Michael Dion Thomas II
       Unknown

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

185.   Elyse Weidner
       2500 Old Farm Rd., #128
       Houston, Texas
       (316) 258-1356




                                     45
       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

186.   Lasandra Daniels
       3826 Rosemont
       Houston, Texas 77052
       (832) 748-6642

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

187.   Joanna Galindo
       2227 10th St.
       Galena Park, Texas 77547
       (713) 668-9689

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

188.   Melissa Gil
       805 Marshall
       Houston, Texas 77006
       (713) 526-1581

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

189.   Travis Johnson
       1910 Westwind Dr.
       Deerpark, Texas 77356
       (281) 542-9435




                                     46
       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

190.   Ana Martinez
       5915 Sattler Park
       Houston, Texas 77080
       (281) 907-2009

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

191.   Ricardo Montoya
       90 Uvalde, #2003
       Houston Texas 77015
       (713) 455-1373

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

192.   Houston Haynes IV
       6200 Marinette
       Houston, Texas 77036
       (832) 814-2849

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

193.   Andrew Paul Gossen
       2902 Braeswood
       Houston, Texas 77030
       (281) 543-2477




                                     47
       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

194.   Gena Lynn Sylvester
       2007 Mid Lane
       Houston, Texas 77024
       (832) 620-5606

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

195.   Defar Weynishet
       902 Spring Source Pl.
       Spring, Texas 77373
       (281) 350-9402

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

196.   Dee Yuon
       9706 Walford Mill
       Houston, Texas 77095
       (832) 257-2159

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

197.   Concepcion Ali
       6900 Gulfton, #1090
       Houston, Texas 77081

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to

                                     48
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

198.   Nicole Allen
       10210 Forum West, Apt. 413
       Houston, Texas 77063

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

199.   Elena Angeles
       9014 Brookwulf
       Houston, Texas 77099

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

200.   Eddie Blackmon
       10210 Forum West, Apt. 413
       Houston, Texas 77036

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

201.   Deseri Susan Blystone
       18319 Campbellford Dr.
       Tomball, Texas 77377

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

202.   Ronald Gamble
       5711 Lavender

                                     49
       Houston, Texas 77026

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

203.   Chermorrow Jacobs
       9402 ½ Compton
       Houston, Texas 77016

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

204.   Adrienne Jones
       4801 Fondren, #1123
       Houston, Texas 77096

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

205.   Kyung Lee
       7535 Sunbonnet
       Houston, Texas 77064

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

206.   Sarah Nelson
       1214 FM 1960
       Houston, Texas 77090

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to


                                     50
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

207.   Paula Pineros-Gomez
       2100 Tanglewilde
       Houston, Texas 77063

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

208.   Brian Richard
       8605 Lavender
       Houston, Texas 77016

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

209.   Ian M. Tallyn
       2503 Floral Ridge Dr.
       Spring, Texas 77388

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

210.   Lisa Whitting
       2521 Sherwood Forest, #1210
       Houston, Texas

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

211.   Freddie Clark
       442 Forum Park, #442

                                     51
       Houston, Texas 77036
       (832) 721-8990

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

212.   Nona Haynes
       1911 Presley
       Houston, Texas 77093

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

213.   Cacharel Harris
       8447 Lettie
       Houston, Texas 77075

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

214.   Stephen Frketic
       219 Marshall, #235
       Houston, Texas 77006

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.
215.   Desondra Freement
       9002 Sterlingshire, Apt. 1702
       Houston, Texas 77078

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to


                                     52
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

216.   John Kaiser
       3555 Timmons Lane, Ste. 1400
       Houston, Texas 77027

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

217.   Charmain Herbert
       15210 Gray Ridge Apr. 223
       Houston, Texas 77082
       (985) 992-6539

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

218.   Randal Lovejoy
       1901 Lakeside Dr.
       Seabrook, Texas 77586
       (281) 217-1869

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

219.   Robert Mater
       1124 Woodland St.
       Houston, Texas 77009

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.


                                     53
220.   Keslum Terrell Powell
       7245 Scott St.
       Houston, Texas 77021
       (713) 440-0921

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

221.   Christan Williams
       10610 Bucknell
       Houston, Texas 77016
       (713) 631-9082

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

222.   Nancy Weathers
       15915 Kuykendahl
       Houston, Texas 77068
       (281) 964-8858

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

223.   Darryell Billups
       7315 Brompton Ave., #262B
       Houston, Texas 77025
       (281) 914-2626

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

224.   Carin Curbland

                                     54
       650 6 ½ East
       Houston, Texas 77007
       (585) 613-1131

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

225.   Ronald Green
       5750 Gulfton
       Houston, Texas 77081
       (713) 432-1957

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

226.   Ritchie Priddy
       7300 Brompton, #4728
       Houston, Texas 77025
       (225) 245-0004

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

227.   Edwin Shoemaker
       10555 Spice Ln.
       Houston, Texas 77027
       (281) 988-7130

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

228.   Maurice Williams
       3737 Watonga, Apt. 84

                                     55
       Houston, Texas 77092
       (281) 838-7150

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

229.   Victoria Garza
       8326 Heather Market
       Houston, Texas 77064
       (713) 466-6540

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

230.   Angelica Gibbs
       Unknown

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

231.   Peggy Watson
       1608A Francis Street
       Houston, Texas 77004

       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

232.   Daniel Wiegand
       1608A Francis Street
       Houston, Texas 77004




                                     56
       Potential voter who, based upon information and belief, was affected by the
       actions of Defendant and is expected to testify to the actions taken to
       register, the voting process, and the contact, if any, with voting officials,
       Defendant and/or Defendant’s agents.

233.   Victor Claudio Pesina
       4307 Cornell
       Houston, Texas 77022
       (713) 697-5393

       Potential voter, whose, based upon information and belief, voter
       registration was inexplicably cancelled. He is expected to testify to the
       actions taken to register, the voting process, and the contact, if any, with
       voting officials, Defendant and/or Defendant’s agents.

234.   Nile Copeland
       P.O. Box 130199
       Houston, TX, 77219
       (713) 587-0133

       Democratic appointed observer of the ballot board and is expected to have
       knowledge of the ballot board activities.

235.   Cynthia Spooner
       Unknown

       Democratic appointed observer of the ballot board and is expected to have
       knowledge of the ballot board activities.

236.   Collyn A. Peddie
       Williams Kherkher
       8441 Gulf Freeway
       Houston, Texas 77017
       (713) 230-2281

       Democratic appointed observer of the voter registrars office and is expected
       to have knowledge of the inner workings and her contact with that office.


                                     57
       237.   Kathy Heigler
              Unknown

              Republican appointed observer of the ballot board and is expected to have
              knowledge of the ballot board activities.

       238.   Paul Bettencourt

              Former Harris County Tax Assesor/Collector and voter registrar who will
              have knowledge concerning virtually every material issue of fact in this
              case.

       Attached hereto is a list of the 2,413 Deputy Registrars. These Deputy Registrars
are expected to testify to voter registration irregularities.

       Plaintiffs reserve the right to supplement this designation with additional witnesses
and experts within the time limits imposed by the Court or any alterations of same by
subsequent Court Order or agreement of the parties, and pursuant to the Federal Rules of
Civil Procedure and the Federal Rules of Evidence.

       Plaintiffs reserve the right to elicit testimony from persons designated and called
by other parties to the suit. Plaintiffs specifically express their intention to possibly call
any of Defendant’s witnesses.

B.     A description by category and location of all documents, data compilations,
       and tangible things in the possession custody or control of Plaintiffs that are
       relevant to disputed facts alleged with particularity in the pleadings.

       See attached documents numbered 1 through 347.

C.     A computation of any category of damages claimed by the disclosing party,
       making available for inspection and copying as under Rule 34 the documents
       or other evidentiary material, not privileged or protected from disclosure, on
       which such computation is based, including materials bearing on the nature
       of and injuries suffered:



                                             58
       Plaintiffs are not currently seeking recovery of economic damages at this point.
Plaintiffs will seek the recovery of attorneys’ fees and court costs.

D.     For inspection and copying as under Rule 34 any insurance agreement under
       which any person carrying on an insurance business may be liable to satisfy
       part or all of a judgment which may be entered in the action or to indemnify
       or reimburse for payments made to satisfy the judgment:

       Not applicable.


                               SUPPLEMENTATION

       Defendant reserves the right to supplement these initial disclosures as discovery

with this suit progresses.


                                        Respectfully submitted,

                                        TEXAS DEMOCRATIC PARTY and
                                        BOYD L. RICHIE, in his capacity as
                                        Chairman of the Texas Democratic Party

                                        By:      /s/ Chad W. Dunn
                                                Chad W. Dunn – Attorney In Charge
                                                State Bar No. 24036507
                                                Southern District of Texas No. 33467
                                                General Counsel
                                                TEXAS DEMOCRATIC PARTY
                                                BRAZIL & DUNN
                                                K. Scott Brazil
                                                State Bar No. 02934050
                                                Southern District of Texas No. 2585
                                                4201 FM 1960 West, Suite 530
                                                Houston, Texas 77068
                                                Telephone: (281) 580-6310
                                                Facsimile: (281) 580-6362

                                                FABREGA, HOOD & FASS, L.L.P.

                                           59
                                                Mike Prather
                                                State Bar No. 24034634
                                                Southern District of Texas No. 31743
                                                815 Walker, Suite 740
                                                Houston, Texas 77002-5701
                                                Telephone (713) 228-2322
                                                Facsimile (713) 228-0088

                                                ATTORNEYS FOR PLAINTIFFS


                            CERTIFICATE OF SERVICE

       I hereby certify that a true and correct copy of the foregoing Plaintiffs, Texas
Democratic Party; Boyd L. Richie, in his capacity as Chairman of the Texas Democratic
Party; Harris County Democratic Party; Geral Birnberg, in his capacity as Chairman of
the Harris County Democratic Party; J. Goodwill Pierre; Alexandra Gibbs; Jeffrey T.
Vanschoonhoven; Boni Sue Leszczuk; and Eric J. Galloway’s Initial Disclosures
Pursuant to Rule 26 (a)(1) of the Federal Rules of Civil Procedure was forwarded to the
following counsel of record in this cause by e-file and/or other means, as required by the
Federal Rules of Civil Procedure on this 9th day of January, 2009.

      Mr. F. Clinton Gambill, II
      SR. ASSISTANT COUNTY ATTORNEY
      1019 Congress, 15th Floor
      Houston, Texas 77002
      Attorney for Defendant



                                          /s/ Chad W. Dunn
                                         Chad W. Dunn




                                           60

								
To top