UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF TEXAS

CORPUS CHRISTI DIVISION

MARC VEASEY, et al.,

Plaintiffs,
VS. CIVIL ACTION NO. 2:13-CV-00193

RICK PERRY, et al.,

Defendants.

DEFENDANTS UNOPPOSED MOTION FOR LEAVE TO FILE ADVISORY
CONCERNING GUIDANCE FOR THE NOVEMBER 2014 ELECTIONS

Defendants respectfully request leave to file an advisory concerning guidance
for the November 2014 Elections. Ex. 1 (Advisory). The Court previously foreclosed
the filing of any further pleadings in the case unless leave is first sought with the
Court. Sept. 22, 2014 Tr. at 12:3-5. Therefore, Defendants request leave to file the
attached advisory.
Pursuant to the local rules, counsel for Defendants conferred with counsel for
Plaintiffs, and this motion is unopposed.
Dated: October 10, 2014

Respectfully submitted,

GREG ABBOTT
Attorney General of Texas

DANIEL T. HODGE
First Assistant Attorney General

JONATHAN F. MITCHELL
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Case 2:13-cv-00193 Document 629 Filed in TXSD on 10/10/14 Page 1 of 4
Solicitor General

/s/ J. Reed Clay, Jr.
J. REED CLAY, JR.
Special Assistant and Senior Counsel
to the Attorney General
Southern District of Texas No. 1160600

JOHN B. SCOTT
Deputy Attorney General for Civil Litigation
Southern District of Texas No. 10418
Texas State Bar No. 17901500
ATTORNEY-IN-CHARGE

ADAM W. ASTON
Deputy Solicitor General
Southern District of Texas No. 2157041

G. DAVID WHITLEY
Assistant Deputy Attorney General
Southern District of Texas No. 2080496

STEPHEN RONALD KEISTER
Assistant Attorney General
Southern District of Texas No. 18580

JENNIFER MARIE ROSCETTI
Assistant Attorney General
Southern District of Texas No. 224780

LINDSEY ELIZABETH WOLF
Assistant Attorney General
Southern District of Texas No. 2292940

FRANCES WHITNEY DEASON
Assistant Attorney General
Southern District of Texas No. 2302872

STEPHEN LYLE TATUM, JR.
Assistant Attorney General
Southern District of Texas No. 2338090

209 West 14th Street
P.O. Box 12548
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Case 2:13-cv-00193 Document 629 Filed in TXSD on 10/10/14 Page 2 of 4
Austin, Texas 70711-2548
(512) 475-0131

BEN A. DONNELL
Donnell, Abernethy & Kieschnick
555 N. Carancahua, Suite 1770
Corpus Christi, Texas 78401-0853
Southern District of Texas No. 5689

COUNSEL FOR THE STATE OF TEXAS,
RICK PERRY, JOHN STEEN, and STEVE
MCCRAW

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Case 2:13-cv-00193 Document 629 Filed in TXSD on 10/10/14 Page 3 of 4
CERTIFICATE OF SERVICE

I hereby certify that on October 10, 2014, a true and correct copy of the
foregoing document was served via the Courts ECF system to all counsel of record.




/s/ J. Reed Clay, Jr.
J. REED CLAY, JR.


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Case 2:13-cv-00193 Document 629 Filed in TXSD on 10/10/14 Page 4 of 4


Exhibit 1
(Advisory)
Case 2:13-cv-00193 Document 629-1 Filed in TXSD on 10/10/14 Page 1 of 4
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF TEXAS
CORPUS CHRISTI DIVISION

MARC VEASEY, et al.,

Plaintiffs,
VS. CIVIL ACTION NO. 2:13-CV-00193

RICK PERRY, et al.,

Defendants.

ADVISORY REGARDING GUIDANCE FOR THE NOVEMBER 2014
ELECTIONS

Last night, this Court entered an opinion stating that S.B. 14 is illegal. Yet it
has not entered final judgment or an injunction, though the opinion says they are
forthcoming. The remedy described, although not implemented by the Court, is not
clear. The scope of the planned injunction appears to be quite broad (much broader
than it should be, even assuming the Court is correct regarding the merits of this
case), but it is not described in any detail. Nor does the Courts opinion announce
the anticipated timing of its injunction. It is not clear if the Courts injunction will
apply to this election. On the one hand, this Court has seemed intent on deciding
these issues in time for this election. On the other hand, the Supreme Courts
decision in Purcell (and recent decisions regarding election laws in Wisconsin, Ohio,
and North Carolina) counsel this Court against upsetting the status quo. In Texas,
the status quo is that Voter ID is in effect. It has been already been used, without
incident, in 3 statewide elections.
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If this Courts purpose in implementing a hurried discovery period and
holding trial in the midst of an election (over the protests of most plaintiffs, the
Department of Justice, and the defendants) was designed to impact the current
election, the Court has already succeeded. The issuance of an opinion with no
injunction or direction regarding the timing of the injunction is already adding to
the confusion created by the Courts decision. Texas respectfully requests that the
Court enter the planned injunction and judgment by the close of business today.
Dated: October 10, 2014

Respectfully submitted,

GREG ABBOTT
Attorney General of Texas

DANIEL T. HODGE
First Assistant Attorney General

JONATHAN F. MITCHELL
Solicitor General

/s/ J. Reed Clay, Jr.
J. REED CLAY, JR.
Special Assistant and Senior Counsel
to the Attorney General
Southern District of Texas No. 1160600

JOHN B. SCOTT
Deputy Attorney General for Civil Litigation
Southern District of Texas No. 10418
Texas State Bar No. 17901500
ATTORNEY-IN-CHARGE

ADAM W. ASTON
Deputy Solicitor General
Southern District of Texas No. 2157041

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Case 2:13-cv-00193 Document 629-1 Filed in TXSD on 10/10/14 Page 3 of 4
G. DAVID WHITLEY
Assistant Deputy Attorney General
Southern District of Texas No. 2080496

STEPHEN RONALD KEISTER
Assistant Attorney General
Southern District of Texas No. 18580

JENNIFER MARIE ROSCETTI
Assistant Attorney General
Southern District of Texas No. 224780

LINDSEY ELIZABETH WOLF
Assistant Attorney General
Southern District of Texas No. 2292940

FRANCES WHITNEY DEASON
Assistant Attorney General
Southern District of Texas No. 2302872

STEPHEN LYLE TATUM, JR.
Assistant Attorney General
Southern District of Texas No. 2338090

209 West 14th Street
P.O. Box 12548
Austin, Texas 70711-2548
(512) 475-0131

BEN A. DONNELL
Donnell, Abernethy & Kieschnick
555 N. Carancahua, Suite 1770
Corpus Christi, Texas 78401-0853
Southern District of Texas No. 5689

COUNSEL FOR THE STATE OF TEXAS,
RICK PERRY, JOHN STEEN, and STEVE
MCCRAW

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