STIPULATION BETWEEN AND AMONG STATE DEFENDANTS AND THE LULAC PLAINTIFFS PAGE 1

IN THE UNITED STATES DISTRICT COURT FOR THE

WESTERN DISTRICT OF TEXAS
SAN ANTONIO DIVISION



SHANNON PEREZ, et al.,

Plaintiffs,

v.

STATE OF TEXAS, et al.,

Defendants.





CIVIL ACTION NO.
SA-11-CA-360-OLG-JES-XR
[Lead case]




STIPULATION BETWEEN AND AMONG
DEFENDANTS RICK PERRY, IN HIS OFFICIAL CAPACITY AS
GOVERNOR, NANDITA BERRY, IN HER OFFICIAL CAPACITY AS
SECRETARY OF STATE, AND THE STATE OF TEXAS
AND
PLAINTIFFS LULAC, GABRIEL Y. ROSALES, BELEN ROBLES, RAY
VELARDE, JOHNNY VILLASTRIGO, BERTHA URTEAGA, BALDOMERO
GARZA, MARCELO H. TAFOYA, RAUL VILLARONGA, ASENET T.
ARMADILLO, ELVIRA RIOS, AND PATRICIA MANCHA



In connection with Defendants Second Motion for Sanctions Against the
LULAC Plaintiffs, counsel for Defendants Rick Perry, in his official capacity as
Governor, Nandita Berry, in her official capacity as Secretary of State, and the
State of Texas (collectively the State Defendants) and Plaintiffs LULAC, Gabriel
Y. Rosales, Belen Robles, Ray Velarde, Johnny Villastrigo, Bertha Urteaga,
Baldomero Garza, Marcelo H. Tafoya, Raul Villaronga, Asenet T. Armadillo, Elvira
Rios, and Patricia Mancha, (collectively the LULAC Plaintiffs), hereby agree as
follows:
Case 5:11-cv-00360-OLG-JES-XR Document 1002 Filed 05/23/14 Page 1 of 3

STIPULATION BETWEEN AND AMONG STATE DEFENDANTS AND THE LULAC PLAINTIFFS PAGE 2

1. LULACs only witness at the 2014 trial will be their disclosed expert
George Korbel. LULAC agrees that it shall not call any other witnesses at the 2014
trial.
2. At trial, LULAC will only offer exhibits that were:
a. previously offered by LULAC in the 2011 Section 2 trial of this matter;
or
b. provided to Defendants on May 24, 2014, and at the deposition of
George Korbel scheduled for May 27, 2014
1
.
3. Nothing in this stipulation constitutes an agreement as to the
authenticity, relevance, or admissibility of such testimony or exhibits. The State
Defendants will not object to any such exhibits as untimely disclosed, but the State
Defendants reserve the right to assert any and all other objections.

/s/ Patrick K. Sweeten
PATRICK K. SWEETEN
Chief, Special Litigation Division
Texas Bar No. 00798537

P.O. Box 12548, Capitol Station
Austin, TX 78711-2548
(512) 463-0150
(512) 936-0545 (fax)

ATTORNEY FOR THE STATE OF
TEXAS



_/s/Luis R. Vera_
LUIS VERA

1
The State Defendants agreement to allow LULAC to use exhibits provided at George Korbels deposition is based
entirely on the Plaintiffs representation that there is only one document they intend to bring to the deposition.
Case 5:11-cv-00360-OLG-JES-XR Document 1002 Filed 05/23/14 Page 2 of 3

STIPULATION BETWEEN AND AMONG STATE DEFENDANTS AND THE LULAC PLAINTIFFS PAGE 3

The Law Offices of Luis Robert Vera, Jr &
Associates
1325 Riverview Towers
111 Soledad
San Antonio, Texas 78205-2260
(210) 225-3300
(210) 2255-2060 (fax)

ATTORNEY FOR LULAC PLAINTIFFS
Case 5:11-cv-00360-OLG-JES-XR Document 1002 Filed 05/23/14 Page 3 of 3