Texas GOP Mandamus

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IN THE SUPREME COURT OF TEXAS
In re Vanessa Cahill
Relator
PETITION FOR WRIT OF MANDAMUS
Original Proceeding
In connection with primary election
Attorney for Relator:
Bruce C. Matzke
State Bar #13234475
P.O. Box 2641
Corpus Christi, Tx 78403
361-888·9255 phone
361-888-9285 fax
--- - '" --.- - . ------- -- - --------- "--- -

-
IDENTITY OF PARTIES AND COUNSEL
RELATOR COUNSEL
Vanessa Cahill Bruce C. Matzke

6050 Rio Vista State Bar No. 13234475
Corpus Christi, Texas 78412 P.O. Box 2641
832.816.2944 phone Corpus Christi, Texas 78403
361.888.9255 phone
361.888.9288 fax
REAL PARTY IN INTEREST
The Republican Party of Texas

900 Congress Avenue
Suite 300
Austin, Texas 78701
512.477.9821 phone
512.480.0709 fax
RESPONDANT
Michael A. Bertuzzi
Nueces County Republican Party Chairman
433 Cape Cod
Corpus Christi, Texas 78412
361-994-5019
361-887-4388
The Republican Party of Texas

900 Congress Avenue
Suite 300
Austin, Texas 78701
512.477.9821 phone
512.480.0709 fax
- 1
TO THE HONORABLE SUPREME COURT OF TEXAS
Relator, Vanessa Cahill, having no adequate remedy, other than access to
precinct minutes, is respectfully requesting this court to issue a writ of mandamus
upon the respondent, Michael Bertuzzi, Nueces County Republican Party
Chairman. Under the Texas Election Code, the county chairman is required to
maintain a copy of all precinct minutes within Nueces County. This copy is said to
be public record. AILrequests of these were denied by Mr. Bertuzzi.
The Texas State Republican convention is scheduled to begin on June 12,
2008. Just forty two (42) days before the State convention, Relator was notified that
she was being denied her credentials as a delegate to the State convention. Relator
is convinced that the addition of unelected delegates prevented her from being
elected to the state convention.
The Supreme Court of Texas should consider mandamus review in this
matter as provided by the Texas Constitution ARTICLE V SECTION 3 and The
Texas Election Code. This case has issues of statewide importance involving a
th
party's political convention; it involved relators 14 amendment rights and given
the limited time frame immediate court action is required.
--- - .- --
TABLE OF CONTENTS
IDENTITY OF PARTIES AND COUNSEL. , i
TABLE OF CONTENTS ii
INDEX OF AUTHORITIES iii
STATEMENT OFTHE CASE iv
STATEMENT OF JURISDICTION v
ISSUE PRESENTED vi
The Supreme Court of Texas may issue a writ of mandamus to compel the perfonnance
of a duty in connection with an election or a political party convention regardless of
weather the perSOll responsible for perfonning the duty is a public officer.
STATEMENT OF FACTS 1
ARGUMENT 4
Importance of Case 4
Jurisdiction to accept Relator's Request for Mandamus 5
Public Officer is subject to Mandamus 6
CONCLUSION 7
VERIFICATION 8
CERTIFICATE OF SERVICE 9
CERTIFICATE OF COMPLIANCE I0
- 11
--- - . ---~
INDEX OF AUTHORITIES
CASES
Morse v. Republican Party oj' Virginia 517 U.S. 186 (1996) .4
O'Brien v. BroH'I1, 409 U.S. 1, 92 S.Ct. 2718, 34 L.Ed.2d 1 (1972) 5
Republican Party a/Texas v. Dietz, S.W.2d 86 (Tex.1997), and 924 S.W.2d 932
(Tex.1996) 5
Republican Party a/Texas 1'. Dietz, 940 S.W.2d 86 (Tex. 1997) v
United States v. Clasic 313 U.S.2999 .4
STATUTES
Texas Election Code
~ 273.063(a) v
~ 273.061 5
§ 174.027 6
.
~ 161.004 ' 6
§ 161.009 v,6
§ 163.007 6
RULES
Texas Rule of Appellate Procedure 52.3(e) v
SECRETARY OF STATE OPINION
David A. Dean opinion letter dated June 24, 1982 2
OTHER
Constitution of the State of Texas ARTICLE V , v
FOUlieenth Amendment of the United States Constitution .4
- III
I. STATEMENT OF THE CASE
(a) Nature ofthe Case:

The Respondent, Michael Bertuzzi, the Nueces County Republican Chair,
has a duty imposed upon him by the Texas Election Code, to maintain copies of all
Nueces County precinct minutes for the remainder of the election year.
The Texas Election Code states that these records are public information;
thus implying a duty upon Respondent to make these records available to Relator
upon request. Thus far Michael Bertuzzi has failed and/or refused such request.
This court is being petitioned to enforce Respondant's duty to disclose these
records by a writ of Mandamus.
(b) This is an original proceeding to the Supreme Court of Texas
(c) Present Disposition of dispute:

.
Respondent continues his refusal to allow Relator access to these records.
(d) Court ofAppeals:

None
(e) Parties to this action:

Relator: Vanessa Cahill
Relators Attorney: Bruce C. Matzke
Respondent:
Michael A. Bertuzzi Republican Party of Texas
433 Cape Cod 900 Congress Suite 300
Corpus Christi, Tx 78412 Austin, Tx 78701
361-994-5019 home 512-477-9821
361-883-2600 office
- IV
STATEMENT OF JURISDICTION
The Supreme Court of Texas acquires original jurisdiction of this mandamus
proceedings from:
Constitution ofthe State of Texas ARTICLE V Section 3
Texas Election Code, section 161.009
Texas Election Code, section 273.063(a),
Texas Rule ofAppellate Procedure 52.3(e)
This court's opinion in Republican Party of Texas v. Dietz, 940 S. W.2d 86

(Tex. 1997), listed additional reasons for this Court to accept original jurisdiction
to issue a writ of mandamus on a public officer. The reasons given:
(1) "unique and compelling circumstances"

(2) the state's highest court should determine issues of statewide
importance involving a statewide political convention;
(3) issues that involve Constitutional Rights of the Relator
(4) the case could become moot unless immediate court action was
taken; and "the quick eruption and short time frame of this
constitutional controversy compelled mandamus review
-v
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ISSUE PRESENTED
The Supreme Court of Texas may issue a writ of mandamus to compel

the performance of a duty in connection with an election or a political parf)'
convention regardless of whether the person responsible for performing the duty is
a public officer.
-Vl
IV. THE UNDISPUTED STATEMENT OF FACTS
Thefacts stated herein are supported b,v the C?/fidm'it ofthe Relator.
ciffidal'its ofbusinesses record; and party admissions, Particular caution
lvas taken to insure the Texas Rules of Evidence were follmt'ed.
Therefore, in the follmving statement offacts are true and correct as
far as Relators recollection and are SH10rn to by affidavit by Vanessa Cahill.
Relator, Mrs. Vanessa Cahill, was a registered voter in Nueces
County, Texas, eligible to vote in the primary on March 4, 2008.
Mrs. Cahill voted in the morning on the day of the pJ:imary election,
March 4, 2008. Relator went to precinct 65's polling place, Montclair
Elementary School.
While at the polling place, she learned that she could become a delegate in
the Nueces County Republican Party and was informed to return to the
precinct convention, which was to take place shortly after the polls closed.
At 7pm, Mrs. Cahill went back to attend. The meeting was called to order
by the precinct chair. Twelve delegates, including Mrs. Cahill, were elected
as delegates to the county convention. (EXHIBIT A)
Mrs. Cahill was encouraged to get on one of the committees. Mrs.
- 1
Cahill overheard the precinct chairman say she would be adding additional
names to the delegate list later that evening to fill up the remaining 17
delegate slots.
B"';ng He>"'! I'nt"'rested I',. ., h"'0r,n"';""'g mo"'" ;n"r,l"e rl ;n ·he Nu~~e~;:''--,UUIlLY

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Republican Party, Relator read the Republican Party Rules and the
Republican Party Platform, in addition to an election law opinion by David
A Dean, former Secretary of State (EXHIBIT B). After reading these rules,
Mrs. Cahill became concerned about her precinct chairman's comments.
On March 6, 2008, Mrs. Cahill emailed the Nueces County Chairman,
Michael Bertuzzi, (EXHIBIT C) to express her interest in volunteering at the
headquarters and serving on any of the committees. On March 13, 2008,
Mrs. Cahill sent Mr. Bertuzzi a second email (EXHIBIT D) stating that she
was interested in serving on a committee. In addition, Mrs. Cahill also
requested a copy of precinct minutes.
Relator wanted a list of delegates from precinct 65 so that she could
contact them prior to the county convention. It appeared to Mrs. Cahill that
her attempts to contact Mr. Bertuzzi and become involved in the local party
were being shunned.
A few days later, Mrs. Cahill obtained a copy of precinct minutes for
precincts 17,58,70 and 121 (EXHIBITS E,F,G,H). Mrs. Cahill obtained a
-2
--- - .- ---- - - . ------ --

letter sent by Mr. William Paul Hunt to Mr. Beliuzzi requesting minutes for
all 126 precincts within Nueces County (EXHIBIT I). Mrs. Cahill also
received a copy of the response letter Mr. Hunt received from Mr. Bertuzzi
denying him access to these records. (EXHIBIT J) /\t this juncture, it '>vas
Mrs. Cahill's belief that Mr. Bertuzzi was violating the election code or was
not aware of the rules. As a result, Relator filed a challenge as laid out in the
Rules of the Republican Party (EXHIBIT K).
Upon arrival at the county convention, Mrs. Cahill noticed that there
were 29 names on the list of delegates for her precinct (EXHIBIT L).
Delegates had been added that were not voted on at precinct 65 's
convention. Mrs. Cahill voiced a complaint to the registrar. At the county
convention, Mrs. Cahill learned that the same situation had taken place
numerous precincts. Numerous unauthorized delegates had been seated and
their votes were included in the election of delegates to the state convention.
Mrs. Cahill believes the only way to know the number of delegates
who were added to precincts after adjournment of the precinct conventions is
to have full access to all precinct convention minutes within Nueces County
and Mrs. Cahill humbly asks the court to grant a writ of mandamus to make
these records accessible.
-3
--- - ~ --- - - ------- ---- -- - ~- - _.

V.ARGUMENT
The importance of this case:
Then the United States Supreme Court in Morse v. Republican Party

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political paJ1y conducted its nomination of candidates; either though a

primary election or by a convention. To exclude eligible voters from either
process was in violation of the Fourteenth Amendment to the United States
Constitution. The Court stated that there was no distinction between a
primary election and a nominating convention in that they were both
variations of the electoral process.
All national elections are further subject to the United States

Constitution, and any legislative enactments of the U.S. Congress. See
United States v. Clasic 313 U.S.2999
Presently, the matter before this Court is to allow Relator access to the
list of delegates duly elected at all of the precinct conventions within Nueces
County Texas. If names were added to the delegate lists after the close of
the precinct convention this action would be contrary to both the U.S. and
Texas Constitutions, the Voters Rights Act passed by Congress, and the
Election Laws of the State of Texas.
And in particular the Relator's right to be treated equal under the
Fourteenth Amendment was violated. Relator had followed the Election
Code and Rules of the Republican Party to be a delegate to the Nueces
County Convention. Other individuals appear to have been added as
"unqualified" delegates not having the right to vote on the state delegates.
-4
However, because these votes were counted as valid, Relator lost the
election to be chosen as a State delegate to represent her candidate. Truly, an
example of being treated unequally under the law as guaranteed under the
Fourteenth Amendment.
Jurisdiction to accept Relator's Request for mandamus:
Title 10 of the Texas Election Code § 273.061 gives the Supreme

Court of Texas jurisdiction to issue a writ of mandamus to compel the
performance of a duty imposed by law in connection with a political party
convention. The Election Code further provides that a rule on electoral
affairs is enforceable by writ of mandamus in the same manner as if the rule
were a statute.
In Republican Party of Texas v. Dietz, 940 S.W.2d '86 (Tex. 1997),
and 924 S.W.2d 932 (Tex.1996) This Court gave a number of reasons why
mandamus review was available: (l) because of the "unique and compelling
circumstances" of the case; (2) the state's highest court should determine
issues of statewide importance involving a statewide political convention;
(3) the case involves First Amendment Rights of the Republican Party
(although not reached by the Court); (4) the case could become moot unless
immediate court action was taken; and (5) "the quick eruption and short time
frame of this constitutional controversy compelled mandamus review."
This case was premised upon the considerations of an original
mandamus proceedings filed in the States Supreme Court wherein it issued a
stay. O'Brien v. Brown, 409 U.S. 1, 92 S.Ct. 2718,34 L.Ed.2d 1 (1972).
-5
--- - . ---
Party Officer is subject to mandamus:
Section 161.009 states, "The perfonnance of a duty placed by this

code on an officer of a political party is enforceable by writ of mandamus in
the same manner as if the party officer were a public officer." Section
163.007 also states that these rules are enforceable by writ of mandamus.
Section 174.027 (d) places a duty upon the county chainnan to
maintain a copy of the list of precinct delegates for the remainder of the
election year. Therefore, Mr. Bertuzzi should have these records easily
accessible. Mrs. Cahill is asking for this court to grant a writ of mandamus
that would allow her to access these records.
Section 161.004 states that these documents are public record.
Granting relator access to these requested documents will not place any
undue burden on the respondent. Pursuant to section 174.027 and 161.004,
allowing access to these documents is the implied duty placed upon Mr.
Bertuzzi.
-6
--- .~ ---- - . ~~-~ ~----

CONCLUSION
The exhibits attached to this petition provide some evidence that the
respondent violated the equal protection clause of the 14 th amendment by
C'A<:>t;nn "noffi"l'al
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votes. By including the votes of the unofficial delegates, Mrs. Cahill, among
other properly elected delegates, lost the election to become a state delegate.
There is a limited amount of time remaining in which reviewing these
records may correct this injustice. With immediate access to these requested
documents, relator will have the necessary proof to present her argument to
become a state delegate.
The requested writ of mandamus will require Mr. Bertuzzi, chairman
of the Nueces County Republican Party, to perform no further duty than
what is required of him.
Relator seeks the following relief:
A writ of mandamus compelling the Nueces County Republican

Chairman to immediately grant access to precinct convention minutes.
Respectfully submitted,
~~
State Bar No. 13234475
P.O. Box 2641
Corpus Christi, Texas
78403
Tel: (361) 888-9255
Fax: (361) 888-9288
-7
--- - .. --- - - -~- ---

IN THE SUPREME COURT OF TEXAS
IN RE VANESSA CAHILL
Relator
VERIFlCATION
STATE OF TEXAS §
§
COUNTY OF NlJECES §
Before me, the undersigned authority, on this day personally appeared

Vanessa L. Cahill, and who, upon oath, stated that he has read the foregoing Original
Proceeding for Writ of Mandamus and the factual statements contained therein are, to the
best of her knowledge, true and correct.
Vanessa L. Cahill
Sworn and subscribed before me on this day of May 2008, to

certify which witness my hand and official seal.
Notary Public in and for the

State of Texas
-8
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing

instrument has been forwarded to the Respondent by certified mail in
accordance with the Texas Rules of Appellate Procedure on May 15, 2008.
Kay Lund Fischer
-9
~,eIT A
NUECES COUNTY REPUBLICAN PARTY
aD Corpus 4458 South Staples
Christi, Texas 78411
(3 61 ) 994-9317 (3 61 ) 994-9343 FAX
E-Mail ncrpcctx@grandecom.net
Mike Bertuzzi-ehairman Rebecca Bradford---Vice Chairman
..
Ane:ie Flores- Secretary
~
Bill Payne--Treasurer
.
March 24, 2008
Dear Sir or Madam,
Please be informed that you have been elected as a delegate to represent your voting precinct
at the Nueces County Republican Party Convention (Senate District 20).
The convention is being held at Tuloso-Midway Middle School Auditorium, 9768 La Branch,
(just off Leopard St. between Clarkwood Rd. and McKinze Rd.), Corpus Christi, TX. 78410, on
th
Saturday, March 29 , 2008. The time is 10:00 AM.
This is a very important election year. You are encouraged to participate in this Republican
process. Please be early so that you can be seated before 10:00.
Respectfully yours,
~~#h~
Michael A. Bertuzzi
County Chairman
Nueces County Republican Party
'Roe Lear
344 Poeniscli
Corpus Cliristi, 'IX 78412
March 20, 2008
Vanessa Cahill
6050 Rio Vista
Corpus Christi, TX 78412
Dear vanessa,
Thank you for voting in the Republican primary on March 4, 2008.
Your participation in t~le election process is very important in how
our county and state are represented and governed.
The Republican party of Nueces County will hold its County

Convention on Saturday, March 29, and you have been selected to
serve as delegate from precinct 65. The convention will take place at
the Tuloso-Midway Middle SChool, 9768 La Branch Dr., beginning at 10
a.m. (Directions listed below-l
I hope you will be able to attend. During the convention, you will be
able to meet our local Republican candidates for the November
election and will help determine what will constitute our party's
state platform.
If you have any Questions, please contact me at 980-9253.
Sincerely,
/{I-C LeGk-
Roe Lear
Precinct 65 C~lairman
DIRECTIONS: Take 1-37 (going toward san Antonio). Exit Rand Morgan·
Rd. and go toward Leopard St.. Take a right on Leopard St. then take
tlo.,. .... Q ...
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OFFiCE OF THE SECRETARY OF 5T ATE
~;Xv'i[) A DFAN ;,'!I\TE CAf'rrOl_

.)~, ~'. r"o ~'-~.;!" f>'(;. G[)~ '26'1:'
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,]url(~ 7.4, 1982
Mr. Edward M. Sullivan
Chairman, COffinlittee on Credentials
County Convention
Republican Party of Travis County
315 Medical ~ark Tower
Austin, Texas 78705
Election Law Opinion DAD-31

Re: Authority of a Political
Party Convention Creden
tials Committee
Dear Mr. Sullivan:
This opinion is in response to your letter of May 28, 1982.
This official election law opinion is rendered by me as

chief election officer of the state in accordance with Tex.
Elcc. Code Ann. ar~. 1.03, sUbd. 1 (V~r~cn Supp. 1982).
Tn your letter, you inquired \"'hether a crc~denti;:-;ls co:nrni ttee

of pol itical p?..>:ty convc'T~'I':i(Jn could alto.r <1 delegation by
(l
adding or deletinq ~ delegate.
The Texas Blection Code orovides the sole method by which

delegates to the county ~nd state conventions of a-political
parties holding primary elections may be selected. Tex.
Elec. Code Ann. art. 13.34 (Vernon Supp. 1982).
In my opinion, the authority of a convention credentials

co~~ittee, or of any person or persons charged by the party
rules with examining the credentials of persons seeking to
be seated as delegates, extends only to determining whether
delegates have been selected in compliance with the Election
Code. All delegates whose selection complies with the
Election Code must be seated, and no other persons may be
seated as delegates.
_ _ _ _ ...-::.. - .. .....
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Mr. Edward M. Sullivan
Page 2
SUIvl.1'!ARY
Tex. Elee. Code Ann. art. 13.34 (Vernon Supp. 1982) provides
the sole method for the selection of delegates to county and
state conventions of political parties holding primaries.
Party conventions must seat delegates whose selection
complies with the Texas Election Code and may not seat any
other delegates.
Sincerely,
/. - i.r:;.. / ..
,I / /' .
I/
/ . ~(/y:';;/fh:.~ __
;7 ~
David A. Dean
Secr~tary of Stdte
Hillis Hhatl2Y
Counsel to th0 Secretary of State
Charlc~ C. Bailey
Special Assistant far Elections
Prepared by Karen Gladney
APPROVED:
OPINION COMIHTTEE
Karen Gladney, Chairman
Charles E. Evans
Horace Jennings III
Felix R. Sanchez
,J"ohn Ste iner
August Toudouze
Election Law Opinion DAD-31
Request from Edward M. Sullivan, Austin, concerning the
authority of credentials committees of conventions of
political parties holding primary elections.
Sm1MhRY
Te:{. Elcc. Code Ann. art. 13.34 (Vernon Supp_ 1982) provides
the sale method fer the selection of delegates to county and
state conver.tions of political parties holdin~primaries.
Party conventions must seat delegates whose selection
complies with the Texas Election Code and may not seat any
other delegates.
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Contacts Mr. Bertuzzi,
• Quick Contacts It was pleasant talking with you this afternoon. My mother-in-law, Margaret Fratila,
speaks very highly of you and it is good to finally get a chance to meet. I hope we will
,fSearch:add,cor invit soon be able to put a face to the name...as the saying goes.
.. vanessa cahill
Set status here .. My husband, Antonio, and I just moved back to Corpus Christi this past summer.
Margaret has been encouraging me to become more involved in the Republican Party and
Alex Haupt what better time to do so than the election season! With all of the hype surrounding the
antoniofratila Democratic race, I think it is important for everyone in our party to get involved so we can
Robert Lund retain the White House in November.
Benjamin Bernier
I am very interested in volunteering my time in any way triat I can. I would love to serve
dmedina@prudent
on any of the committees as well as attend the meetings of the committees that are
John Falasca already full. If at all possible, could you send me a list of these committes and the
Kay Fischer scheduled meeting dates and times. In addition, could you give me the phone
Margaret Fratila numberslemail addresses of Art Granado and Victor Bird. I believe they are heading up
Paul Hunt the Nominations and Resolutions Committees.
ronpaul-10
Also, if my services are also needed at the headquarters, feel free to contact me.
Add
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contact
Thank you for your patience.
• Labels
Sincerely,
6050 Rio Vista

Vanessa
Ron Paul 832-816-2944
Super Bowl 08
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I would like to be sure that my recollection of our first
Trash
telephone conversation is correct(March 6, 2008). As
Sponsored Link~
per my memory, I requested information on the dates,
Contacts
1imes and locations of the Credentials and
T Quick Contacts Nominations Committees for Nueces County. You $250K+ 1st year income pc
then asked that I send my request in writing, which I No selling. $2K - $9K startu
acid, or inv;lf: promptly did via email (March 6, 2008). From the www.TheFreshFinancial.co
".., vanessa cahill email attachment I received from Mike Bergsma

(March 13,2008), I have made the reasonable
:~.-:)ct :;t;)t:.. ;3 tlcrr; ... 100% online executive edul
assumption that you have opened and read my email

Robert Lund request for this information. certification. Learn more no
Alex Haupt www.NotreDameOnline.cor
anton iofratila I would also like to clarify the second and last
Bruce C. Matzke conversation we had over the telephone (March 12,
1 Minute Poll
Debra Medina 2008). As per my memory, you told me that you

Has he Been a Good Presil
would not be providing to me the information I was

Dennis Rodenbeck Your-Votes.com/GeorgeWE
requesting. From what I understood, your reluctance

jfalasca to provide the requested information to me stemmed
John Falasca from my affiliation with a local meetup group, in which Sales/Presentation Skills C
Kay Fischer a fellow member, Chuck Burnett, voiced his opinions Call this expert TODAY 72/
Margaret Fratila of local leadership in the Republican Party. sheryLcom
I would also like clarification from you on the 14th

Rule of the General Rules for All Conventions and Engage successfUlly with C
T Labels Meetings of the Republican Party of Texas which Increase sales success. JUI
6050 Rio Vista states: www.SeIIXL.com
Ron Paul
Super Bowl 08 II "All meetings of any committee or sub-committee Become the best coach YOL
Sh
Edit I~fjers of any convention, whether it be in temporary or ICF Accredited Life Coach I
permanent organization, shall be open to any www.iCoachAcademy.com
delegate or alternate to that convention... "

T Invite a friend
As a voter in the Republican Primary and a delegate Your personalized system i
Give Gmail to: in my precinct. I would again like to request the dates, With expert guidance, it's si
times, and locations for the following committees: www.OrganizeYourselfOnli;
I Send InVi~ 50 left Credentials, Resolutions, Rules, and Nominations

More about...
Republican State Conventi(
preview invite
In addition, I would also like to request a copy of Republican Conferences»
accurate written records (minutes) from every Precinct Republican Fundraiser "
in Nueces County. Please notify me when these Republican National Comm
copies have been completed and I will pick them up

from the Republican Party Headquarters. About these link:
Thank you for your time.
htto://mail.coocle.com/maill?ui= 1&ik=559db3fdOO&view=cv&search=sent&th=119c5ce2... 5/15/2008

Cause No.
.,..,err &
VANESSA L. CAHILL § SUPREME COURT OF TEXAS
§
VS. § 201 W. 14 TH STREET RM 104
§
NUECESCOUNTY § AUSTIN, TEXAS
REPUBLICAN PARTY §
§
REPUBLICAN PARTY OF TEXAS §
BUSINESS RECORDS AFFIDAVIT
Before me, the undersigned authority, on this day personally appeared Darryl Smith, who
being by me duly sworn, deposed and stated as follows:
"My name is Darryl Smith. I am of sound mind, capable of making this
affidavit, and personally acquainted with the facts stated herein.
I am chairman of precinct 17. In my capacity as precinct chairman, I have access to
and am familiar with the attached pages of accurate written minutes fr~m precinct 17. Such
records were made at the precinct convention held on March 4, 2008. The records attached
hereto are an exact duplicate of the original.
Further, affiant sayeth not."

'l
(~~
Darryl Smi
SUBSCRIBED AND SWORN TO before me on this May 6, 2008, to which I place my
signature and official seal.

.A. .A.
.it.. ... A... .... .;...
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Notary Public
STATE OF TEXAS
~.:
LOndo- P,~CL/
\.;.~~~'l
I." .........
My Comm. Exp. 11.26.2011

,
~ "V" V' "V" "V" ,.,..
Printed Name
My commission expires: 1-c:< /; - c2 D / I !

Notary Public for the State of Texas
FROM :DANE AND EDIE SMITH FAX NO. :351 334 1242 ~1ar. 07 2008 12: 28PM P2
MINUTES OF THE REPUBLICAN PARTY PRECINCT CONVENTION
Qualified voters of electlo precinct number I 7. senate district number ~ tJ , congr~S . io.n.al d..IIss\rrllcctt /l
number , of county. Texas met at J'MI+td G/e#1-.e-.Ik ,, __ &~
(location) on .J.-QQ f (date) to hold a precinct convention.
1. Call to Order ""- I (I .. \ •
The convention was called to order by temporary chairman J.) G\.( ( 1-\.-~'\.1. I'----Th---'--'---"----_ _ ,at 7: .s-Op.m.
2. Preparation of LIst of Participants

The temporary chairman prepared a list of all qualified members present. The list was shown to those present and is
attached to these minutes as Exhibit A. Only registered voters of this precinct who voted in the Republican Primary either
in person or by mailed ballot are eligible to participate in this convention (Rule 20). The temporary chair announced
~ (numbGJr) qualified participants were present (Rule 21b).
The temporary chairman announced the convention would be conducted in accordance with the Texas Election Coda and
the Republican Party of Texas Rules adopted in accordance with the Election Code; Robart Rules of Order. current
edition, newly revised, would govern parliamentary procedure. The temporary chairman then explained how the actions of
.,,!I]~._c~n,!,el'ti~I1~911Ig..i.r:!ttu.en9~importantparj:y decisions at subsequentcQnv.en~ions,.
3. Election of Permanent Officers.
The temporary chairman announced that nominations for permanent chairman of this precinct convention woUld be
acceh~~~tIlO~,~ tft
0ns were nominated as candidates: .. " . - - -
The convention elected

The convention elected
ba:'!f' SOl"
=:n::a~
Swt,·...fI,
"2- r/.{..,
as permanent chairman of the precinct convention.
as secretary of the precinct convention.
Theaermanent chairman and secretary assumed leadership of the convention. The permanent chairman announced that
(number) qualified participants were present and that the convention was entitled to elect I'll (number)
delegates and ,10 (number) alternates to represent the precinct at the county or senatorial district convention.
4. Election of Delegates and Alternates to the County or state Senatorial District ~o"vention.
After explaining the method by which delegates and alternates would be elected, nominations were made. Delegates and
alternates were elected. The delegates are listed in Exhibit B and the alternates are listed in Exhibit C.
5. Resolutions
The permanent chairman announcedthat the next order of business would be the adoption of resolutions. __ ,~
L
(number) resolutions were proposed, debated, and separately submrtted to the convention for approval. The resolutions
adopted by a majority vote are included with these minutes.
6. Other Business
The permanent chairman then asked if there was any other business that should properly come before the convention.
7. Announcements
The permanent chairman announced that in accordance with Rule 22, a signed copy of the written record of the
convention would be available for copying by any participant for a 30-minute period immediately following adjournment,
and that the record included a list of the delegates and alternates elected to the county or senatorial district convention.
The oormanent chairman then announced that be/she would official I): sign. seal, and safely deliver in person within three
days or by mail within two days, a record of the convention. as reguired..Py Ryle 22 and the Election Code (174.0270), The
chairman annoynced the time and place for the county or senatorial district convention.
8. Adjournment
In accordance with a motion properly moved and seconded and adopted by a majority vote, the precinct convention was
ZJned~t.~p:m~_ Jj)~----
perm~rmen
.
. Permenent Secretary
Return to your county chairman. The permanent chairman should also copy and retain a record of all documents.
PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

f"1
0...
Precinct # fl Page of ___
EXIDBITB
E:
0...
Senate District # 20
(l)
(\J List of DELEGATES elected to County I Senatorial District Convention,
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First: M.I.: JV1 Address: 0. 9> 5~ La ke vi t.. LA.J. Pbo~, 30:L - 334--lLA-Z- I
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Cause No. SQ""T F
§
VS. § 201 W. 14TH STREET RM 104
§
NUECESCOUNTY § AUSTIN, TEXAS
REPUBLICAN PARTY §
§
Before me, the undersigned authority, on this day personally appeared Kay Lund, who being
by me duly sworn, deposed and stated as follows:
"My name is Kay Lund. I am of sound mind, capable of making this affidavit, and
personally acquainted with the facts stated herein.
I am a Precinct Judge of precinct 58. In my capacity as precinct judge, I have access
to and am familiar with the attached pages of accurate written minutes~from precinct 58. Such
records were made at the precinct convention held on March 4, 2008. The records attached
~{lff·L?nL
Kay'Lu
;)dQ&y M-u J11du~

VICKIE JOY VAN MAREN

Signature
Notary Public
STATE OF TEXAS
My Comm Exp. 10-05-2008
dele J&y;lt-£! 7'/}/1LeAJ

Printed Name
My commission expires: //1 -.!J-d~t?cf

C..J3 ; ,ed v~ ters a election precinct nymber 5~g ,senate district numt er , congressional district
LJmber , of ~ county, Texas met at '-n'K~ ~4A-<j
(:Jcci"on) C1 _ _trh-<l /l..cJV L-/ ,,}.,oog (date) to hold a precinct convent; xf.
-, C:::.:I to Order _!-~ J , / r(/3

-1e ionver-tion ",as called to order by temporary chairman , ' _dM'!.~'1 , at ~-p.m,
/ '
:. P'~parar;on 0' List of Participants (
-le :?mpoary cr airm:in prepared a list of all qualified members present. !'he Ijst was shown to those present and is
cc1a: led te these minutes as Exhibit A. Only registered voters of this precinctNho voted in the Republican Primary either
! ", p.~son v by mailed ballot are eligible to participate in this convention (Rule 20). The temporary chair announced
. _; (num'Jer) qualified participants were present (Rule 21 b),
--.1E campcary at airn13n announced the convention would be conducted in accordance with the Texas Election Code and
Ie -=epubican P3.rty of Texas Rules adopted in accordance with the Election Code; Robert Rules of Order, current
dit en, ne'Nly re\ ised would govern parliamentary procedure, The temporary chairman then explained how the actions of
lis :::mvention ","auld influence important party decisions at subsequent convl,ntions.
-hE~onvention Elected as permanent chairman of the precinct convention.
-~. Election of DI~legates and Alternates to the County or State Senatorial District Convention.
-"Ifter explaining 1he method by which delegates and alternates would be elected, nominations were made. Delegates and
",Itulates were idected. The delegates are listed in Exhibit B and the alternat?s are listed in Exhibit C.
5. t'!esolutions
The ;:>ermanent chairr'1an announced that the next order of business would bn the adoption of resolutions. _
nL~7ber) resolutions Nere proposed, debated, and separately submitted to the convention for approval. The resolutions
s.dopted b; a mcjority vote are included with these minutes.
5. Other Business
Ths permanent chairman then asked if there was any other business that shc,uld properly come before the convention.
7. Announcemf,nts
Th; permanent ,;hairman announced that in accordance with Rule 22, a sign,~d copy of the written record of the
::;or-:'.fention woulj be available for copying by any participant for a 30-minute Jeriod immediately following adjournment,
,mJ that the record included a list of the delegates and alternates elected to tle county or senatorial district convention.
The permanent ~hairman then announced that he/she would officially sign, st,al, and safely deliver in person within three
days or by mail Nithin two days, a record of the convention, as required by R Jle 22 and the Election Code (174.027c). The
chairman announced the time and place for the county or senatorial district c::>nvention.
8. Adjournmen t
iq,
fit};.~ --
pm
~.-..e d
J
In accordance vli~ha)motion properly moved and seconded and adopted by a majority vote, the precinct convention was
ad;~ed at I,
lZi 'Aft-t/=
ermanent hairman ~ Secretary
Return to y)ur county chairman. The permanent chairman should also I;Opy and retain a record of all documents.

INSTRUCTIONS FOR THE PRECINCT CONVENTIONS
TIME/PLACE: Precinct conventions must be held on the same day as the Republican Primary Election and must be at
the pre(:inct voting location unless physical conditions prevent the number of participants from gathering there. The
specific time to convene is set by the county party executive committee, and must begin between 7:00 p.m. and 9:00 p.m.
Notice of the convention must be posted at the voting location.
CALL TO ORDER BY THE TEMPORARY CHAIRMAN: The convention is called to order by the incumbent precinct
chairman. If the precinct chairman is not present at the time to convene, any voter who participated in that precinct's
primary may act as temporary precinct convention chairman and call the convention to order. If people are still in line to
vote, the temporary chairman should call a recess to allow time for them to finish voting and participate in the convention.
QUORUM: There is no minimum number of participants required to hold a precinct convention. If only one person
attends, that person fills out the minutes form and may elect delegates to the county/senatorial convention.
BASIC RULES OF PROCEDURE: The convention must be conducted in compliance with the Texas Election Code, the
Rules of the Republican Party of Texas, and Robert's Rules of Order. Questions regarding optional procedures are to be
decided by general consent or by majority vote of those present. For a copy of the RPT Rules and RPT Platform, please
visit www.texasgop.org/ and click on the "GOP Resources" link.
PREPARATION OF LIST OF QUAL.lFIED PARTICIPANTS: Attendees must have voted in that precinct's primary election
to be eligible to participate. There is no deadline for appearing at the convention and no quorum is required. To establish
eligibility, names of convention attendees should be compared to the list of registered voters which was checked off
during the day as voters were accepted to vote.
ELECTION OF PERMANENT OFFICERS: After preparing a list of qualified participants, the convention must elect a
permanent convention chairman. This person is the chairman of the precinct convention only and does not become the
precinct chairman. Voters at the polls elect a precinct chairman. The permanent precinct convention chairman is elected
by majority vote of those attending the precinct convention.
Once the permanent convention chairman is elected, he/she takes the chair and oversees the election of the permanent
secretary. If necessary, the chairman and the secretary may be the same person.
ANNOUNCEME.NT.OF COUNTY/SENATORIA.J-PI~TRICT COf'.lVENTION: The convention will convene on Saturday,

March 29 th at IcY0cJ ~.~ (time) in q76R kA!.f;r:;-I4[~ (location). Announcement of committee
meetings time ~nd location should be stated if known.
ELECTION OF DELEGATES AND ALTERNATES and CERTIFICATION OF ELIGIBILITY: State that the precinct
convention is to elect delegates and alternates to the county/senatorial district convention. Any participant may place a
name in nomination. The convention first elects delegates and then alternates, both by majority vote. The precinct
convention secretary must certify to the convention that all elected delegates and alternates are qualified by virtue of
having voted in the Republican primary election in that precinct.
Attendance at the precinct convention is not required in order to be elected to the county/senatorial district
convention. However, the final list of deleqates and alternates must be approved at the precinct convention. No
additional names may be added once the precinct convention adjourns.
CONSIDERATION OF RESOLUTIONS: Resolutions mayor may not be presented. The chair may require that
resolutions of more than a few words be placed in writing. A resolution must be moved and seconded; it is debatable and
amendable; and it must receive a majority vote for adoption. Resolutions which are adopted should be written and
included with the submission of the precinct convention minutes.
FOLLOW-UP: Records must be available for 30 minutes after adjournment for participants or media. Use this time to
finalize paperwork. Delegates and alternates elected to the county/senatorial district convention who are not in
attendance at the precinct convention need to be notified as soon as possible. A notice and agenda of the
county/senatorial district convention should be sent to every delegate and alternate. The Texas Election Code requires
that the originals of all convention documents be delivered to the County Chairman within three days or mailed
within two days.

Precinct # GV >Page I of -----L
EXHIBIT A
Senate District # _ _
List of qualified voters who ATTENDED precinct convention.
VOTERCERT# PRINT NAME PRINT MAILING ADDRESS CONTACT INFORMATION
)(; M.I.: Phone: 1- ff ~-OcJ& g

(DY ro3 ofJ 1 ()ft E-Mail:
M.I.: Phone: ~- ~ST- t;zs-

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v"L!T E-Mail:
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Last: Cit :
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First:
-
Phone:
E-Mail:
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Phone: •
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E-Mail:
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I I i~a... I ('it;,: Zio: _~_ I E-Mail:
~Flrs!: ,_,_.> .. _,... . M.I::.. .. I Address: >----- I Phone: I

Lasl: City: Zip: E-Mail:
I
PROVIDED BY THE REPUBLICAN PARTY OF 'TEXAS
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Precinct #.At - ". EXHIBIT . ' .
Senate District # - - List of DELEGATES elected to County I

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.. PRINTs--MAU~!!· ..... 14IJ!t .. .".. ' '·;Iil. '•.••••~..
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VOTERCERT# ,PRINT AME J
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Last: _J E-Mail: I
First: M,I.: fJ :::,:, 6 t; ( ~S-" -(Po </~ I
City:
ML, M Ph."~' 3(p I ZC-s--/)'/3(;, !
E-Mail:
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E-Mail:
~".e.... MIT:- IAdd,,~, .]0 ( q).t'L,6<>' ~ Ph."" 3(,,( J {'of P -oJ.H=-I

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First:
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City:
PR(')VTnf.D BY THE RFPHBUCAN PARTY OF TEXAS

___....__...
Zip:
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Cause No.
exttIIMT (i

§
VS. § 201 W. 14TH STREET RM 104
§
NUECES COUNTY § AUSTIN, TEXAS
REPUBLICAN PARTY §
§
Before me, the undersigned authority, on this day personally appeared Maria Angela
Hultgren, who being by me duly sworn, deposed and stated as follows:
"My name is Maria Angela Hultgren. I am of sound mind, capable of making this
I am Chairman of precinct 70. In my capacity as precinct chainnan, I have access
to and am familiar with the attached pages of accurate written minutesTrom precinct 70. Such
records were made at the precinct convention held on March 4,2008. The records attached
"ric/Cd i itL C 'I

U
/I c
Maria Angela Hultgren

\,L{c I[;UL .~
j/~.
~,"I"'"
. NORMA J. ALANIZ
~:-;.~
"~' 'ol',-,
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""l9~ NOlOIV P\tlllC. Stote 01 Texas
.~. .t*
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My CQrnmIssIon EJPlres
JoNJOIV 1S. 200Q
~"'7"r.',1\
A)J /Z-IJ') /1 :f /I-iet~ / j
Printed Name
My commission expires: SKYP) - I S

J ;1 () V 9
Notary Public for the State of texas
Qualified voters of election precinct number1-0 , senate district number 20 , congressional distri~t
number 23 , of N\ \QC~v county, Texas met at III I050-midu,1Cl",I.\ m'lckH

e ~bo')\
(location) on 3/ Lf 2C"lOB (date) to hold a precinct convention.

I ,-'
1. Call to Order
The convention was called to order by temporary chairman (!}a(j 6 A· kh )l+Qre '() ,at 7;5''7 p.m.
2. Preparation of List of Participants .

The temporary chairman prepared a list of all qualified members present. The list was shown to those present and is
attached to these minutes as Exhibit A. Only registered voters of this precinct who voted in th.e Republican Primary either
in pejson or by mailed ballot are eligiblre to participate in tliis convention (Rule 20). The temporary chair announced
_-:=..:.L=-_ (number) qualified participants were present (Rule 21 b).
The temporary chairman announced the convention would be conducted in accordance with the Texas Election Code and
the Republican Party of Texas Rules adopted in accordance with the Election Code; Robert Rules of Order, current
edition, newly revised, would govern parliamentary procedure. The temporary chairman then explained how the actions of
this convention would influence important party decisions at subsequent conventions.
3. Election of Permanent Officers
The temporary chairman announced that nominations for permanent chairman of this precinct convention would be
accepted. The follpwing persons were nominated as candidates:
rYlofiiA Anet\(/, til) L~~Cf-.........-{J-,--- ~ _
The convention elected ' as permanent chairman of the precinct convention.

The convention elected as secretary of the precinct convention.
Thepermanent chairman and secretary assumed I ership of the convention. The permanent chairman announced that
---=J.,,-,-_ (number) qualified participants were present and that the convention was entitled to elect q (number)
delegates and 9 (number) alternates to represent the precinct at the county or senatorial district convention.
4. Election of Delegates and Alternates to the County or State Senatorial District Convention.
After explaining the method by which delegates and alternates would be elected, nominations were made. Delegates and
alternates were elected. The delegates are listed in Exhibit B and the alternates are listed in Exhibit C.
5. Resolutions
The permanent chairman announced that the next order of business would be the adoption of resolutions. --"'=2=-;.... _
(number) resolutions were proposed, debated, and separately submitted to the convention for approval. The resolutions
6. Other Business
The permanent chairman then asked if there was any other business that should properly come before the convention.
7. Announcements
The permanent chairman announced that in accordance with Rule 22, a signed copy of the written record of the
convention would be available for copying by any participant for a 30-minute period immediately following adjournment,
The permanent chairman then announced that he/she would officially sign, seal, and safely deliver in person within three
days or by mail within two days. a record of the convention, as required by Rule 22 and the Election Code (174.027cl. The
chairman announced the time and place for the county or senatorial district convention.
is
8. Adjournment
In accordance with a motion properly moved and seconded and adopted by a majority vote, the precinct convention was
ad.journed at
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Permanent Chairman Permanent Secretary .

Precinct # '1...Q Page I of 3
EXHIBIT A
Senate District # ..2.Q.
List of qualified voters who ATTENDED precinct convention.
VOTERCERT# PRINT NAME PRINT MAILING ADDRESS CONTACTINFO~TION
1J4q&z/~q'D First: n1nr i(\ M.l.: n Address: J:)()I { a..lUT~~~'l' 0,......• Phone: (3(nl' crPD - =?-J-1(0(
Last: HlJl+ct.'(~ rJ City: C'r1rN ')"-, 0nr\":~-\ ZIJ): 7A4 II E·Mall: \-}( ') J..t.a.(~ 0 .4fh6)( l':lYaJ.Cd'l n\
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[<'irst: M.l.: Address:' Phone:
Last: City: Zip: E·Mall:
First: 1\'1.1.: Address: Phone:
Last: City: ZIn: E-Mail: I

First: M.I.: Address: Phone:
Last: Cltv: Zip: E-Mail:
i First: M.l.: Address: Phone: I

I I Last: I Cltv:
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First: M.I.:
Address: Phone:
Last:
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Precinct # 10 ·Page ;;L of ~
EXHIBITB
Senate District # 2D.
List of DELEGATES elected to County / Senatorial District COllvention.
VOTERCERT# PRINT NAME PRINT MAILING ADDRESS
114Qt,173C1'3 First: M.I.: Phone:
Last: E-Mail:
Last: I City: Zln: I E-Mail:
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, March 4 th , 2008
r acknowledge that I am a registered voter living in Nucces County Precinct # '7 {J _' and that I have voted in the
th
March 4 , 2008 Republican Primary Election.
Furthermore, 1acknowledge receipt of: (A) Precinct Convention Kit for Precinct #~7 C~~
(B)Votcr Registration Book for Precinct # "'-1 c.)_
I am aware that I must return this kit and registration book to the Republican Pat1y Chairman, Mike Be~!rtzr-i' 4458 So.
St~ples,
Corpus Christi, TX 784 J 1, as per instructions within the Convention Kit, (the deadlinetc)r retu 'ni9g is 5:00PM
Fnday, Marcb7th, 2008). /". I" ;J c~'
PRINTED NAMEJ~1a.(/'a. It· I-lv~

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Please sign and giv~ this receipt bac["'~o the Eleoli011 J~dge... . .
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IfYOlI are the ElectIOn Judge, please SIgn and return thIs receipt WIth your election supplies. , ' . 'J;i,::J
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N\
Cause No. ex"'alr H
§
TH
VS. § 201 W. 14 STREET RM 104
§
NUECES COUNTY § AUSTIN, TEXAS
REPUBLICAN PARTY §
§
Before me, the undersigned authority, on this day personally appeared Benjamin Bernier, who
being by me duly sworri, deposed and stated as follows:
"My name is Benjamin Bernier. I am of sound mind, capable of making this
I am a duly elected delegate of precinct 121. In my capacity as precinct delegate, I
have access to and am familiar with the attached pages of accurate wri~en minutes from
precinct 121. Such records were made at the precinct convention held on March 4,2008. The
records attached hereto are an exact duplicate of the original.

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, BenJa n BernIer
signature and official seal. C._.

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NORMA J. ALANIZ
Notary PI.dc. Stole 01 relICs
My Commission fJll,l/Jes
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Printed N arne
My commission expires: 04-70 .

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EXHIBIT C
Senate District # -2 2.'
List of ALTERNATES elected to County / Senatorial Di"trict COll\cntiol1.

VOTER CERT# PRI:\lT NAME PRINT MAILING ADDRESS COI\TACT INFORMA 1'ION
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PROVIDED BY THE REPl'BLlCA:\ PARTY OF TEXAS

Oualified voters of election precinct number ~~, senate district number --'--'---"-'-__ congressional district
number _ '_ _ , of~_" . county, Texas met at ...' •. ;
ifocation) on . ;:.:. (date) to hold a precinct convention.
1. Call to Order
Tr1e convention was called to order by temporal'V chairman Z'--' . at p.lil.
2. Preparation of List of Participants

The temporary ch.:urnwn prepared a list of al! qualified members present The list was shown to those presetl! and IS
attCl.ched to these minutes as Exhibit A. Only registered voters of this precinct WilD voted III tile Republican Primary either
in person or by mailed ballot are eligible to participate in this convention (Rule 20). The temporary chair announced
-"" (number) qualified participants were present (Rule 21 b).
The temporary chairman announced the convention would be conducted in accordance with the Texas Election Code and
the Republican Party of Texas Rules adopted in accordance with the Election Code: Robert Rules of Order. current
edition. newly revised, would govern parliamentary procedure. The temporary chairman then explained how the actions ot
this convention would II1fluence Important party decisions at subsequent conventions.
3. Election of Permanent Offi·cers .
The temporary chairman announced that nominations for permanent chairman of this precinct convention would be
accepted. The foilowll1g persons were nominated as candidates:
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The convention elected, ~.",~. '£~' /1"';: '~-F,';' ~".L.._. as permanent chairman of the prec!llct convention
u.
The convention elected:.:;:.,,,,:;;.,,.-; "_)-r;,,,;,, i;;.; ~j'/~ as secretary of the prec!llct convention.
The permanent chairman and secretary assumed leadership of the convention. The permanent chairman announced that
.4 (number) qualified participants were present and that the convention was entitled to elect ~' ... (number)
delegates and [.> (number) alternates to represent the precinct at the county or senatorial district convention
4, Election of Delegates and Alternates to the County or State Senatorial District Convention.
After expla!lling the method by which delegates and alternates would be elected, nominations were made. Delegates and
alternates were elected. The delegates are listed in Exhibit 8 and the alternates are listed in EXhibit C
5. Resolutions
The permanent chairman announced that the next order of business would be the adoption of resolutions.
(number) resolutions were proposed. debated, and separately submitted to the convention for approval. The resolutions
6. Other Business
The permanent chairman then asked if there was any other business that should properly come before the convention
7. Announcements
The permanent chairman announced that in accordance with Rule 22. a signed copy of the written record of the
convention would be available for copying by any participant for a 30-minute period immediately following adjournment.
The permanent chairman then announced that he/she would officially sign, seal. and safely deliver in person within three
days or by mail within two days, a record of the convention. as required by Rule 22 and the Election Code (174.027 c). The
chairman announced the time and place for the county or senatorial district convention.
8. Adjournment
In accordance If,'th a motion properly moved and seconded and adoPt~Jfa majority vote. the precinct convention was
adjo)Jfned at rt
Db p.m., / -1 /::/
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erm nent hairman~' ----- Perman nt Se"C:retary
/

Cause No.
etttIeaTX

§
VS. § 201 W. 14TH STREET lUll 104
§
NUECES C01J}~TY § AUSTll'~, TEXAS
REPUBLICAN PARTY §
§
Before me, the imdersigned authority, on this day personally appeared William Paul
Hunt, who after being duly sworn, upon his oath stated that he is a duly elected delegate of
precinct 79 in the above-captioned cause; that he has read the foregoing document; and that
every statement contained therein is true and correct within his personal knowledge.
~~
William Paul un
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My commission expires: \ ~. 000'8
t·O
April 26, 2008
Wm. Paul Hunt
137 Tropical Lane
Via U.S. Mail CERTIFIED RETURN RECEIPT 70062760000405214509
Mr. Michael Bertuzzi, County Chairman
4458 South Staples
Re: Minutes of2oo8 Nueces County Republican Party Precinct Convention Meetings
Dear Mr. Bertuzzi:
Please consider this letter as my formal request for copies ofthe minutes of all of the
Nueces County Republican Party Precinct Convention meetings held March 4, 2008. I
do not need copies ofthe resolutions, however I do need the follOwing:
Minutes ofthe Republican Party Precinct Convention (for each precinct)

Exhibit'A,' List ofqualified voters who ATTENDED precinct convention
Exhibit 'B: List ofDELEGATES elected to County Convention
.'Exlnoit 'C: List ofALTERNATES elected to County Convention
I will biing my copier and paper and furnish all labor. Wednesday, April 30, 2008, or
Thursday, May 1,2008, are best for me. Please indicate your preference by calling me at
361-779-4811.
7006 2760 0004 0521 4509
Thank you for your cooperation. ('): ~ td g:l m:a :n
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NUECES COUNTY REPUBLICAN PARTY

Corpus 4458 South Staples
Christi, Texas 78411
(3 61 ) 994-9317 (3 61 ) 994-9343 FAX
E-Mail ncrpcctx@grandecom.net
Mike Bertuzzi-ehairman Rebecca Bradford-Vice Chairman
.. ..............•.................................... ............................
Ane:ie Flores- Secretary

~
Bill Payne-Treasurer
April 29, 2008
.- ·f)ear Mr.. Jiunt,
The Nueces County Republican Party is not required to make the records that you are
requesting available to the public. Your request is denied.
Respectfully yours,
Michael A. Bertuzzi
County Chairman
To Whom It May Concern: ~err Ie.

In accordance with the Republican Party of Texas' General Rules for All Conventions and Meetings Rule
lIb and Rule 27a, I, Vanessa Cahill, an elected delegate of Precinct 65 within the Nueces County of Texas,
wish to file a formal challenge against County Chairman Michael A. Bertuzzi for not fulfilling his duties as
laid out within these rules and refusing to uphold both Rule No. 14 and Rule No. 22.
Specifically, Texas Republican Party Rule 14 stipulates:
"All meetings of any committee or sub-committee of any convention, whether it be in temporary or

permanent organization, shall be open to any delegate or alternate or that convention, any State or
County Republican Party Officer, any elected Republican Officeholder or any Republican Candidate.
These same people shall have the right to appear before any convention committee or subcommittee
and make recommendations for the committee's consideration or testify concerning any item under
purview ofthe committee. The committee may adopt reasonable rules including time limits for such
presentations and may establish a reasonable limit of time for these presentations. This privilege
shall include delegates and alternates under challenge at any convention."
Mr. Bertuzzi has intentionally and flagrantly violated these rules and as such has harmed this delegate
as well as other delegates to this convention by depriving me of my right to fully participate in this
process.
On March 6, 2008, I telephoned and emailed Mr. Bertuzzi to express my interest in serving on any of the
committee meetings held prior to the County Convention. Specifically, I requested meeting dates and times
for the Nominations and Resolutions Committees as well as offered my services as a volunteer at the County
Headquarters.
As shown in EXHIBIT "A", ATTACHMENT No.1, Mr. Bertuzzi received my email request and forwarded
it to Mr. Bergsma, who then forwarded it to me as an attachment to his email stating his concerns. From this
exhibit, I have made the reasonable assumption that Mr. Bertuzzi opened and read my request.
On March 13,2008, after receiving no response to my request, I contacted Mr. Bertuzzi, via telephone, at
which time he told me he was not going to give me any information about these meetings.
On March 16, 2008, as shown in EXHIBIT "B", I sent Mr. Bertuzzi another email requesting clarification on
Rule No. 14 which states:
"All meetings of any committee of sub-committee of any convention, whether it be in temporary or

permanent organization, shall be open to any delegate or alternate to that
convention..."
Mr. Bertuzzi has failed in every instance to provide any notice or contact information regarding the
functioning or meeting of the temporary committees as requested. Consequently, I have been deprived of
my right to participate in those meetings.
In addition, Mr. Bertuzzi has knowingly, intentionally and flagrantly violated Rule 22b.
Texas Republican Party Rule 22b states:

"Transmittal of Precinct Convention Minutes: The Permanent Chairman ofthe Precinct Convention
shall sign and safely transmit to the County Chairman no later than the third day after the date of the
precinct convention or deposit in the mail not later than the second day after the date of the precinct
convention such record (minutes) and a copy thereof, and maintain a third copy for himself at least
until the end of that year's biennial state convention. In multi district counties, the County Chairman
shall deliver the original record to the temporary chairmen of the Senatorial District Conventions.
This copy shall be public record."
I requested a copy of accurate written records (minutes) from every Republican Party Precinct Convention
held in Nueces County on March 4, 2008. These rules clearly indicate that the County Chairman is
responsible for maintaining a copy of these minutes as public record.
As shown in EXHIBIT "c" and EXHIBIT "D", on March 17,2008, I made my third request to Mr. Bertuzzi
for this information. After failing to receive copies of the requested documents, I traveled to the Nueces
. County Republican Party Headquarters and again made my request for copies of these records. I spoke with
two different individuals who refused to provide the requested documents. I offered to wait until Mr.
Bertuzzi could be reached. After waiting for over an hour, I told the secretary that I was going to get a cup
of coffee and would return momentarily. When I returned, the headquarters had been closed. I then posted a
request at the door (as shown in EXHIBIT "C"). Upon returning to see if the headquarters had been opened,
I found my request X-ed out and signed, "NO!! MAB." I assume these initials belong to Mr. Michael A.
Bertuzzi (full name as shown in EXHIBIT "E").
Texas Election Code 161.004 states:
"If a document, record, or other paper is expressly required by this title to be filed, prepared, or
preserved, it is public information unless this title provides otherwise."
Texas Republican Party Rule lIb provides:

"Any officer or committee chairman of any convention, whether it be in temporary or permanent
organization, who intentionally violates the Rules of the Republican Party of Texas or the
directives of the Texas Election Code, shall be subject to a challenge filed under the provisions of
Rule No.27; and if such challenge is upheld by the convention which hears the challenge, that
officer or committee chairman shell be removed from serving as a delegate to any convention of
the Party at any level throughout the year."
Mr. Bertuzzi clearly knew the rules. He had been provided with copies of the rules and was the recipient of
numerous requests to allow open participation by delegates. He has intentionally violated these rules and the
duties of his office. I pray that the delegation present will uphold this challenge and the integrity of the
Republican Party.
•
anessa Cahill
Delegate, Pct. 65
\\ 11,;11lWS LIve Hotmail
J:'qU~rr . ,(, \ 'C I (i\
iii(C:I"lling Margaret Fratila's email

Mike Bergsma (bergsmaconsulting@davlin,netl
[!"lUI! 13/082:58 pre,
C
f.rlC Von Wade' (encllonwade@holmail,com): 'Bol) J<)n,~s' (IJol)Jon<",14;.101(F~YS0j'YiJhOO ((10"), 'VCtn,~,,~,,)
dllill' (cahiilvanessaC0hotmall.com); 'Tx Fed of Ror,\jol1lan' (ctgolcl<,m,Ul('i'<'Io',corn), ·Nall:J.Cli1i Rq)J:',IJ ,n ',,"i';, c..
(oll1mitlee' (women«")gop5enators,com); 'Cliff la:'5Ic,l (cliff/ilIS"y./:' <;:;:.~':;')(11 1'.(':); PR'C.. CT",S [~i',iii
1"l!,I{IA' (ilfrill:ila(j.j'forc:'eS5inv,com): 'Setty an(J AI Cer'Jera' (hcer,c;,J;ll Iwslor\(pnITf'corn), '!\,;r"illd I. \(i '>"'~'"
!)"iCCW (ldodge@calallen,k12,lx,usj; 'bobbie anderson' (ilnderslaw(til,n',,', corn); 'Ana Cooper ((jna((lu:'(",L:I':"'io'
:.. Jlld' (uJelunClc@aol,com),Cill:l1ie Adams' (cathieadallls@lexn:c;ea,J. ee',:'j; e.t1MJ 1/'1 linnks Rep,JIJU:n'i l,l'"ylI.'I',iil,'
(onferenCt:' (info@Cjopconference,corn), 'l!ebL)I€ we~I' ((lttwe';t(i:'v,iI' '10 ((!'Il ,; De<lIlll!' \:V(,:II'O' (dhiri: ,::,r",:pII' '~Ie :;0 I .~
I)('olilna Gelaek' (workfuture@aol.com); 'Dr Robin /\r"T1st"ong (rol;i1r:l'1'i1r(cil!wtmailcom); 'Davie:

:(iLl', (dave 1181 S2@aol.r:olll); 'Doris White' ((Jor,sjwnite@yahoo «,"l: :i'elli';' ';a ntill1?,' (juclgi!enr lej Ut<ril'/dlw(). cnr, i ;\/
I~Cl"ey HoJtclli50n Campaign' (infO@l:exansforkay,col1l!; 'Krystal ~l,fVI'r') \mfO@[)1l1Q',onvbrnq,com)' 'I(.lll'
i~v'l:r':)iJn' (texilsvolunteers@glllclll.com); 'Becky I(an pe' (becky,ki)nlpe«',;da's,slate,lx,u~,): ']':riH,,1
'·IMI inez' (imartinez@netnetweb,com); 'William IJ Dodge' JII' (wdiilrl'c1cirjdqciil@rr1sn,(nn,), 'Nick
J'IIIC!'lCZ (l'ditor@caler.com)
li~ , i ,1/ (!;,' !' (\ t (1 1 ') 1 KI, ) ";: :,( <.Ii 'k f! .~l\ r·~ Et-H}
;"" .: '.' ~,
I I '\ ~-;()ITy :011(5 that Margaret Fratila has involved you in her bromide d:jCllnst our County Chairman Mii<,{,) E,k,rtu//' ·1
,I, !ii~.;! ~:;av

that she is not a reliable source of information, I am atlachinq two cJocuments f!'Om I,t)! dauqhler 1\)<,
';Ij i\jn<;ts t11<11 something else is involved, It appears tl1;;:,t some of tile F~Cin FJaul foiks arE'! tryin~J to I<lke O\lr:, t:I(: :
iii' ! ;'r(: callil1g our county leadership "Marxist, Fascist. and warrnonqers" This is a pathetic (JIGtr,;ci,on f(()rn (jeH,
~ ,'j,~iilr f<ilelin rEH:dected and adding to our numb(,"rs In other office~'
Vi! I Cd'1 cali lYlE: about this is you would like at 537696j~
i « ... \a(d~').
'\'111 I; Hr:rCjsma
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:11): ell r 07\,v,blu 107,mail.Jive.com/maiI/ReadMessageLight.aspx? Action==MarkAsNorJunk&FoJder[Oc:O", 3 'OOk

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Benu;l2i, Michael A(CORPUS CHRISTI CU 532)
From: vanessa cahill [vanessafratila@gmail.comJ

SfFIt Thursday March 06, 200B 3 12 PM
ro' Bertuzzi, Michael A(CORPUS CHRISTI CU 532)
SUbject: Committee Intonnation
,1: h:nnzzi,
,. \,\ ~t.', pJl~asant talking viithyou this afternoon. rVfy n1otJ\er-in~!a\'V1 !\1argaret Fraltla'l speaks very highly of \t HI -J it::·
'.(lod 'll finally gel a chance to meet. J hope we will soon he C3ble to put a fan: to the name...as the saying goc:-..
/ly 11lIsbilJ1d, Antonio, and 1 just moved back to Corpus Christi this past summer. Margaret has heen encouragi,; rill'
;) hCl:IHllC more involved in the Republican Party and wl"at b(,:tler t1ll1C to do so than the election ~ca~;nnl \Vilh, I If
hI.: il"!l(: :iulTounding the Democratic race, {think it is important for everyone in our p<lrty to gel If1voh,:d 'iU Wl' '.[1
;:Lull 111<' White House in November.
am 'l'l'Y interested in volunteering lUY time in any way that I can. I would love to serve on any of the cornmill' . as
.'ell
i.\' atll;nd the meetings of the committees that arc already fuJI. lfal all possible, could you send me a list qf. "c
omn I.lte.'; and t.he scheduled meeting dates and times. In addition, could you give me the phone numbers email
ddn:;scs uf Art Granado and Victor Bird. I believe they are heading up the Nominations and Re.'iolulions
'<'r11I;lllkcs.
I hl1. i r my services are also needed at th(.~ headquarters. f;~el free to contact me,
halill \ 011 fur your patience.
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~';i.,bJect: ....,: [ro"paUf~10] VERY IMFORTANTlll!

Dlltf/l: Fri, 0'7 M.v:200S 12:11:20 ·0600
(n .. r ::1s,
r "ope th~~ rrw5t of yr)IJ '.J:W step bed< and look ilt Wi1,at i$ I',appenlr)g here
1,-, orj/;}t' to change things In Che!! Nuectil!:5 c,~unty COP the countY chalrrfli.'tll
?~ "(~ l~af.fI;!lr$r:lp relillme nQ(-l(1", to.I:)e rtJpll.lced .
i 11f..' leadi:rgt!ip herl.; iJre m~lndst, F~SGi$t ",nd wwn;oflg€r~-i !

Strong words? Yes, But sa,jlv true.
If' y:J:.J wllnt to return tl1e 10(;/',11 GOP to Itl~i capltZlII.~;t, cQnsla.rvative, (OI1<;[,!'utlonal,
:IiT:;Lt:<I gclv~rl'ill'1t~rt ri;JO~~i g(~l ready for a long and m'l·';t.y bl.l::tl';· .
:t CI~N be \ll!OI~. FSI.lr ,t won't be easy or 5hO"t.
: 'el I'Fltl-·el· Ignore them llll and get good peQr1e on tlv" ballot withQtJt tl"em
["r,'t that thp. real ~~oal anywolJY 7'
"tip /1 www ,knowyourrl.·lo .(orn/CP~Pr9s08.hnn
:::(,. c,li:;ll'y.
:'i;uClc eLlrnr:'~t
... ~t the revOlu tl"n continue! I

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;, o~, .. : Ju,St tt;tikf.:c/ ~o Mike Bertunl and I thrlc h~'", ,~nl_\) .J!'. DO NOT
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""1;;1I1k"Jlly hI! kr'O'NS my rr1Qth~r in law and 1 '''''',:'1:. 41ble to ~.;o(l:en ,lWI lip i)
, 0 t, r'Ie ~el:;: that all of the COI''''ln-:lttelfts IFe full (5· i' pl':()pl~; "'/1(;1 t'<€?;-,:
I',: d hst {')f 1'Ii9h $S aCJI·,~ter£ thi~t 'Nill be ~sed as J t ?IIVltt~<; in thr
;- ~:venf th ·~t SQmecnl!! .a~$19')ed to t~le cornmlr~e 11i!CUS to b", r,,'pl 'j".ld. !
, t (JIG nim that [ Just ~l(lved 1.0 the city ~tr.d wa:o ~/1C"U r~~t:d ov nw '11 :r!'e,
;. ~r :aw co gt.~t involved with th.;; ;~eJubll,a:, pa-ty Oy Jolnlr,'1 f.lry
" r:(,'r7'\I'·It.I.~S, SCI I h~v~ sart ht.r, an Arnall r9(,tI",stil"'~ th'J c;>,r~!; of [·'1ese.
'c;nvrit'te 1"",ce!:in~/$ an:;; t.urd h>n that'; 1JI1ou!c1 (il--.e ~.) :$ t 11 on eH'V tildt I
,. rim I.,b:~ to IHtMd.
, I IJ'II:k !t would bo te~t (or me to g~t ~tle I)i;ltl;''; ;;'!'11.1 ~Qli." Ulli:nl 'nco
, ':c't:.'r{on~ Insta!.ld of ali cf L,S clillirrg him (or ~he he~dqllarLi.!rs,i. T:l~V
.1, I'C cildrti'I,1 to SIJSpee:t SOlTlet~ing iJrd I don "r 'III1.'l nl- ~()ose \:t.,s
) <"(11':'''' Also, 1 rGlrlle It vvould r::~ " go::-d i(JI;J for e\{l~ryrJn~ wittl
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;,. 'JI't,~cirh:-t pa<.:i<e~ to hold ont::J them aild turr ~herTi in tomorn: IV i1rter'
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« fJ~~k tQStlIot Mt'til i\.k (
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Request for Clarificati()fI /'lhoY
:'i\~111 Mail
";~[ i;: " 1!j(J pm (E) nell,S a91;
fl'OI1~ '!IIi \/lllnesaa C:8JhiU 'C·\.;l'lf.'<i,;::,1r;'Jil,:1 . , ' I •.
OrAb (4l
to michael_bertuzzi@ml.com
\/I;lli
(:(: ~ vanassafratila@grn;)il.com
~}umr! (l) cldlf: Mar 16, 2008 ' tiC ['M
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~iuhl~;cl Request for Clanfic:ltion
'1'~1i1f'~dby gmail.com
Contact!>
Me. 8ertu:zzi.
T : ILJI(>\ COlltoC\S
, I J ;'rj' :r It)VJIJ.~ I would like to be sure thaI my rncollectlor: :If Ol.lr fll'$t telephone conversation IS cO"rect (,V;:r ?Oo(·
;:jr-'('
As per my memory, I requested Informatin!' 01 tile dates, times and locations of the Credent
Ii· . :;",essa catll,', Nominations Committees for i'",eces COl)n1y You \;len asked that I send my request in WII\I wlllc)'
';1.1' herr' 'W promptly did via email (Marcil 6 7000) Frorn the email attachment I receiverJ frOm !\J1ike Bp." (M>
'1;-)
,~()hfort L.•,nd
13,2008), I have made the rem.onable as.'iIJn\ption tlla! you have opened anc "eoc: '"Y1y er"ai i lilesi'
'\Iex Haupt
thiS Information.
\Ic!rich, Chns
) 20Cr
I would also ItI~e to clarify the u~cond and I£1Sl ulr'versation we had over the t.elephone (Mel' -.
11',,' n! As per my memory, you tolcl tllat ymJ 'Nould noll)e provI,jlng to me tile idormation I WB:' •
!TIC .. est:I'
\0'1 f'l~ict'er from what I understood, your rduclance 'C rrowie tbe requested InforlT1ati~',n 10 me stemrw:, .;Jrtl nov
'1:la/flarel Fratile affiliation with a local meetup woup. In w'""ch ;;J fellGw rnember.~ClllJCI\ B,p'pt' voiced hit> op 1'~J of .
}11l'lJe'.bertuzzi leadersJ1ip in the Republican F'c,rty.

"C,T;":'ion1
,,,. ·:·aIl12008 I would also like clarification fOil you 011 1I1e 14th RIJ!oe of the General Rules for AI! Convr" '!Hi "n,
nr'pdli ·10 Meetings of the RepUblican Party of Tll~lU"~ W11C states:
"All meetings of any COmmiHo'Ie or sub-(,ommlttee of any convention, whether it I:)e i111' . 'porw'
permanent organization, shull be open ~o ~!'ly dl;)legat~ 011' altl;1lrnate to that convention
'" )/.) (' I~,
" ,C PIt) Vista

As a voter in the Republican Fnmary and 8 elelAq2tA in my precinct, I wouid again like 10 (f~Cj lllf'
r,~ . r), I
dates, times, and locations tor ne (ollowing cOfT1,y:::tces
, '''I li,ll'vl OI.JSI~
Edfr?~ Credentials, Resolutions, Rule,s, and NominatJOns
In addition, I would also like to request a copy of accurate written records (minu:esi from el/f'~ '((-)C;,,':
.", , ,/,tc f:l frieneJ Nueces County, Please notify me when tJ)eSI~ copies have been completed and i /!j ;Jlck:ior dO I"n
the Republican Party Headquarters
f.,:~maillo
Thank you for your time,
. "[0/ liO leh Sincerely,
Vanessa
! 'l1\jitf.')
" RepLy ..~ Reply fo a l l " rorvvard
ijj\ vanessa cahill to Kay ;':"'1', (li,j'1" 1 52 p'T' (6 h{)urr, 3rw'
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I C\i'''' ~ .thlcS C0l1"1Jl1ISSI0n P,O. Ro' I }OiO '\U."ll'n, Texa.;.. 7K? II ~l)' f) 151:'H6' ."-,
STATE / COUNTY CHAIR FOR'; Sf'
CAMPAIGN FINANCE REPORT COVEN S In>~
rh~ sc C/ou I \('( 'OliN I Ii I' \( ,I

NSTRlifTION G IIIDE e.plalns how to
) -hic~ ('n"TlIOI~~I"/j tikr:.,
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JNAME: MS MRS 1J\.Jil 1':Rs'r "I
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COIJlUS Christi Lx 78412 ')IJ\l' p;\'I,t
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~ CA'I,1PAIGN MSIMR.~ 'MR IRST ;\.fl

Dr Rl) Jen L
TRE.'\SURER f);ltl' P ,~~ "'<"'~':
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fI{,EASURER
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ttp:! ~)09.R5, 165.1 04/search?q=cache:A W50vUFdDNwl:1xprod.ethics.state.tx,us/public /300935.pciff-JTIi c... In. I()()S

ectfterr L 900 Congress Avenue, Suite ~H 10
Austin, TX 787' I)
Phone: 512.477.98>1
Fax: 512.480.01')9
www.texasgop.trg
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'. ·TinaJ. Benhser,C9p1r:: fl0
April 18, 2008
Ms. Sally Hunt
137 Tropical Lane
Corpus Clui.sti, TX 78408
Dear Ms. Hunt:
Per your request, enclosed are the Minutes 1'1:001 the Nueces County Republican
Convention held on March 29, 2008. The lists of delegates and alternates elected to the
State Convention have also been included.
Sincerely,
(
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g,Y~-e-Pl\~
Execu( e 'rector
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----------------------, I
!ic~T-'------Last-----L-First---i ML. i -. _ SIGN IN
~~IShirley . IRobert .•,IP. .I,.6?Jcl Jt~ ,
04 I Stephens i Carol ! i
64 IStruve
I \
Joe
r
I
---+-'1- - - - +III - / l - - - - - - ¥ - - ·
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--L.L PRECINCT 1 65 I U--'
Pet. j
1
Last - -
I First ML. iI
SIGN IN
65 (Anderson Amy B. I
65 IAnderson
----.-'
Shane . ,-~._-.
D. I
I
65 i Bailes Rebecca _-+--i_--+--- _
65 I Bertuzzi Caroline I I
-651Sertuzzi Michael I I~~~Z
65 i Cahill/ ~rf( Vanessa
65 iCheetham Gerald ,
65 !Collins-- Mrs. Bruce : 14v &.. u- ~~_I
65 ! Eigueda Maria : I
RECEi VEO APR (I 4 Lu08
~ i"<c" ." ~ ~ . ~ rt.'<:9 =;-"~ t::

;;,~ 1I~" ~: 'C'~ ~ 'i\~8,'
Y~j
~
,;
Pet. i Last First i ML. SIGN IN

~5 IFratila P - A~toniO--
tiS I Gonzalez Nllza
A.
L.
65 ! Moore Richard R. , .A100 I]'-Y'
~65 IPrice Paul D.
65 ISchroeder K
I
Mike
65 !Seaman F- Ellen v~
65 i Seama_~ Eugene J.
_65 JSheldon ¥- Jean
..... -'..J
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''''~J •.
, RECEiVED APR 042008
',h,g iF"',;P, 81\'4

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ECt. ~Lasi----' ._--~ -F-irs-t-·--ML.I ,___ SIGN 711~

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65 ISlattery {Q. IChantal j?SendtoCredentiills

~
65 (Webster IDean {', I 4tU0 t. iJ~
65 jWebster 1M. 'ary L. I 7JJ~
6~ IWhitt Betty' I ~.;JIr~
(,bl G ~Cll\id~ I Av+

PRECINCT 167 i I
Pct.lf--.---Last,~ t<,~-~/'~~ I First i ML. i SIGN IN
67 Burger
f CJ)/).J~! ~ Gary R./~
61 iY~ung Christopher P. /'/ // ~ //
t
;~\
GOP RULeI.
GENERAL RULES FOR ALL CONVENTIONS
AND MEETINGS
Rule No.1 - Adoption and Amendment of Rules; Clarification
These Rules, having been filed with the Secretary of State of Texas, together with the st<ltutes.
rules and bylaws adopted by reference shall constitute the Rules of the Republican Party of
Texas.
Rule No.4 - Adoption of Reference - U.S. Constitution, Texas Constitution and Statutes
The Constitution of the United States, The Constitution of the State of Texas, and the statutes of
the State of Texas, insofar as they may be applicable, are hereby adopted by reference and shall
govern the conduct of all conventions and meetings of the Republican Party of Texas from the
precinct level through the state level.
Rule No.5 - Parliamentary Authority
Unless otherwise provide.d for by the United States Constitution, Texas Constitution, United
States and Texas statutes, or these Rules, the current edition of Robert's Rules o(Order
. Ncvdv

Rel'ised, which is hereby adopted by reference, shall be the parliamentary authority governing all
conventions and meetings of the Republican Party of Texas from the precinct level through the
state level, inclusive.
Rule No. 18 - Voting Strength - Number of Delegates

The convention will continue to enjoy its full strength in the cases of preceding conventions not
electing all delegates to which it is entitled. No convention shall elect fractional delegates: i.e. no
convention shall elect more delegates or alternates than the number to which it is entitled.
Rule No. 21 - Agenda for Precinct Conventions

f Election of delegates and alternates to county or senatorial district convention, as the case may
be, by majority vote, and certification of eligibility of each delegate and alternate by the precinct
convention secretary, where the primary voters list is available.
Rule No. 22 - Chairman's Responsibilities

a. Record of the Precinct Convention: The Permanent Chairman of the Precinct Convention shall
be responsible for seeing that an accurate written record (minutes) is kept of all convention
proceedings, including the list of persons present and their residence addresses and a list of
delegates and alternates elected to the county or Senatorial District convention with residence
addresses, including towns shown thereon. The Permanent Chairman of the Precinct Convention
shall record the list of persons present and the list of delegates and alternates elected to the
county or Senatorial District Convention in triplicate. A signed copy of this written record shall
be available for copying by any participant in the convention for a period of thirty (30) minutes
immediately following adjournment of the convention. Upon request, the permanent chairman
shall certify any correct copy.
b. Transmittal of Precinct Convention Minutes: The Permanent Chairman of the Precinct
Convention shall sign and safely transmit to the county chairman no later than the third day after
the date of the precinct convention or deposit in the mail not later than the second day after the
date of the precinct convention such record (minutes) and a copy thereof, and maintain a third
copy for himself at least until the end of that year's biennial state convention. In multidistrict
counties, the County Chairman shall deliver the original record to the temporary chairmen of the (
Senatorial District conventions. The copy shall be public record. (emphasis added)
etec4\. CMc,
§ 161.004. PARTY DOCUMENT AS PUBLIC INFORMATION. Ifa document, record, or
other paper is expressly required by this title to be filed, prepared, or preserved, it is public
infonnation unless this title provides otherwise.
Acts 1985, 69th Leg., ch. 211, § 1, efT. Jan. 1, 1986.
§ 161.009. PARTY OFFICER SUBJECT TO MANDAMUS. The perfonnance ofa duty
placed by this code on an officer of a political party is enforceable by writ of mandamus in the
same manner as if the party officer were a public officer.
Acts 1985, 69th Leg., ch. 211, § 1, eff. Jan. 1, 1986.
§ 163.002. REQUIRED RULES. A political party that makes nominations in this state shall
adopt rules that:
(3) prescribe the manner of selecting party officers, convention delegates, convention
alternates, and convention officials;
Acts 1985, 69th Leg., ch"211, § 1, eff. Jan. 1,1986.
§ 163.007. RULES ENFORCEABLE BY MANDAMUS. A rule on electoral affairs is

enforceable by writ of mandamus in the same manner as if the rule were a statute.
Acts 1985, 69th Leg., ch. 211, § 1, eff. Jan. 1, 1986.
§ 174.021. SELECTION OF DELEGATES TO COUNTY AND SENATORIAL

DISTRICT CONVENTIONS. The delegates to a political party's cOUIity and senatorial district
conventions held under this chapter shall be selected in accordance with party rules at precinct
conventions held as provided by this subchapter.
Acts 1985, 69th Leg., ch. 211, § I, eff. Jan. I, 1986
§ 174.027. RECORDS OF CONVENTION. (a) The convention chair shall prepare, sign, and
make a copy of a list of the names and residence addresses of the delegates and any alternates
selected by the convention.
(b) The convention chair shall sign and make a copy of the list of precinct convention
participants required by Section 174.025(c).
(c) The convention chair shall deliver the originals and copies of the lists to the county
chair not later than the third day after the date of the precinct convention, except that if delivered
by mail, they shall be deposited in the mail not later than the second day after the date of the
precinct convention.
(d) The county chair shall retain the copies of the lists until the end of the voting
year in which they are received.
(e) If senatorial district conventions will be held in the county, the county chair shall
deliver the originals of the lists to the temporary chairs of the senatorial district conventions
before the conventions convene.
Acts 1985, 69th Leg., ch. 211, § I, eff. Jan. 1, 1986. Amended by Acts 1987, 70th Leg., ch. 472,
§ 47, eff. Sept. I, 1987; Acts 1987, 70th Leg., ch. 499, § I, eff. Sept. I, 1987; Acts 1997, 75th
Leg., ch. 864, § 179, eff. Sept. I, 1997.
§ 273.061. JURISDICTION. The supreme court or a court of appeals may issue a writ of
mandamus to compel the perfonnance of any duty imposed by law in connection with the
holding of an election or a political party convention, regardless of whether the person
responsible for perfonning the duty is a public officer.
Acts 1985, 69th Leg., ch. 211, ~ I, efT. Jan. J, 1986.
§ 273.063. VENlJE IN COlJRT OF APPEALS. (a) A petition to a court of appeals for a writ
of mandamus under this subchapter must be filed with the court specified by this section.
Acts 1985, 69th Leg., ch. 211, ~ I, efT. Jan. I, 1986. Amended by Acts 1987, 70th Leg., ch. 54,
§ 15(c), eff. Sept. 1,1987.

Texas GOP Mandamus

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Texas GOP Mandamus

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H'\~~ iv) ~

IN THE SUPREME COURT OF TEXAS

PETITION FOR WRIT OF MANDAMUS

In connection with primary election

Attorney for Relator:

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Vanessa Cahill Bruce C. Matzke

REAL PARTY IN INTEREST

The Republican Party of Texas

The Republican Party of Texas

Relator, Vanessa Cahill, having no adequate remedy, other than access to

precinct minutes, is respectfully requesting this court to issue a writ of mandamus

upon the respondent, Michael Bertuzzi, Nueces County Republican Party

be public record. AILrequests of these were denied by Mr. Bertuzzi.

The Texas State Republican convention is scheduled to begin on June 12,

elected to the state convention.

The Supreme Court of Texas should consider mandamus review in this

matter as provided by the Texas Constitution ARTICLE V SECTION 3 and The

the limited time frame immediate court action is required.

IDENTITY OF PARTIES AND COUNSEL. , i

INDEX OF AUTHORITIES iii

STATEMENT OFTHE CASE iv

of a duty in connection with an election or a political party convention regardless of

Jurisdiction to accept Relator's Request for Mandamus 5

Public Officer is subject to Mandamus 6

David A. Dean opinion letter dated June 24, 1982 2

Constitution of the State of Texas ARTICLE V , v

FOUlieenth Amendment of the United States Constitution .4

(a) Nature ofthe Case:

(b) This is an original proceeding to the Supreme Court of Texas

(c) Present Disposition of dispute:

(d) Court ofAppeals:

(e) Parties to this action:

The Supreme Court of Texas acquires original jurisdiction of this mandamus

Constitution ofthe State of Texas ARTICLE V Section 3

Texas Election Code, section 161.009

Texas Election Code, section 273.063(a),

Texas Rule ofAppellate Procedure 52.3(e)

This court's opinion in Republican Party of Texas v. Dietz, 940 S. W.2d 86

(1) "unique and compelling circumstances"

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The Supreme Court of Texas may issue a writ of mandamus to compel

ciffidal'its ofbusinesses record; and party admissions, Particular caution

lvas taken to insure the Texas Rules of Evidence were follmt'ed.

Therefore, in the follmving statement offacts are true and correct as

far as Relators recollection and are SH10rn to by affidavit by Vanessa Cahill.

Relator, Mrs. Vanessa Cahill, was a registered voter in Nueces

County, Texas, eligible to vote in the primary on March 4, 2008.

March 4, 2008. Relator went to precinct 65's polling place, Montclair

as delegates to the county convention. (EXHIBIT A)

Mrs. Cahill was encouraged to get on one of the committees. Mrs.

B"';ng He>"'! I'nt"'rested I',. ., h"'0r,n"';""'g mo"'" ;n"r,l"e rl ;n ·he Nu~~e~;:''--,UUIlLY

Republican Party Platform, in addition to an election law opinion by David

Mrs. Cahill became concerned about her precinct chairman's comments.

On March 6, 2008, Mrs. Cahill emailed the Nueces County Chairman,

Michael Bertuzzi, (EXHIBIT C) to express her interest in volunteering at the

headquarters and serving on any of the committees. On March 13, 2008,

was interested in serving on a committee. In addition, Mrs. Cahill also

requested a copy of precinct minutes.

Relator wanted a list of delegates from precinct 65 so that she could

were being shunned.

precincts 17,58,70 and 121 (EXHIBITS E,F,G,H). Mrs. Cahill obtained a

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