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COME NOW, the Dallas County Republican Party (the “DCRP”) and Missy Shorey
(“Shorey”), as Chairwoman of the DCRP, and file this, their Original Petition Challenging the
Certification of a 128 (one hundred and twenty-nine) Democratic Candidates’ Applications For a
Place on the Democratic Primary Ballot, & Application for Temporary Injunction complaining of
CAUSE NO.
DCRP v. DCDP – Plaintiffs’ Original Petition & Application for TRO / Temporary Injunction Page 1
and against the Dallas County Democratic Party (the “DCDP”), Carol Donovan (“Donovan”) as
Chairwoman thereof, and for cause of action would respectfully show unto the Court as follows:
1. This lawsuit arises out of the certification of compliance for and submission to the Secretary
of State by the DCDP of 128 candidates for places on the Democratic Primary Ballot, whose
applications were not accepted by the DCDP’s Chairwoman Donovan, the only individual
2. The Plaintiffs seek injunctive relief to prevent Donovan and the DCDP from including: (a) any
of these candidates, whose applications are attached in Plaintiffs’ Appendix to this Petition on
the March 2018 Democratic Primary ballot; and (b) any of these candidates on the November
2018 General Election Ballot as a result of any such candidates participation in the March
3. The Plaintiffs also seek injunctive relief to prevent Donovan and the DCDP from declaring
any of these candidates administratively ineligible and replacing them, where statute permits,
with a candidate of Donovan’s choice so as to avoid a ruling in the Plaintiffs favor on the
merits.
3. This matter is subject to Discovery Level 2 in accordance with the Texas Rule of Civil
Procedure 190.3.
CAUSE NO.
DCRP v. DCDP – Plaintiffs’ Original Petition & Application for TRO / Temporary Injunction Page 2
III.PARTIES
4. The DCRPis a political party organized in accordance with the Texas Election Code, with its
principal place of business located at 11617 N. Central Expressway, Suite 240, Dallas, Texas,
75243.
5. Shorey, as the Dallas County Republican Party Chairwoman, is an individual who resides in
6. The DCDP is a political party organized in accordance with the Texas Election Code with its
principal place of business located at 4209 Parry Avenue, Dallas, Texas 75223. The Dallas
County Democratic Party may be served with process by serving its Chairwoman, Carol
Donovan, at its principal place of business, or its General Counsel, Sarah Duncan, at 3500
Maple Ave, Dallas, TX 75219, or wherever else either two may be found.
7. Donovan, as the Dallas County Democratic Party Chairwoman, is an individual who resides in
Dallas County Democratic Party located at 4209 Parry Avenue, Dallas, Texas, 75223.
Donovan may be served with process at her principal place of business, or by serving its
General Counsel, Sarah Duncan, at 3500 Maple Ave, Dallas, TX 75219, or wherever else
1. Jurisdiction is proper in this Court in accordance with Texas Election Code §§ 145.035 and
172.117 and the Plaintiff is seeking an injunction against the Defendants in accordance with
CAUSE NO.
DCRP v. DCDP – Plaintiffs’ Original Petition & Application for TRO / Temporary Injunction Page 3
2. Venue is proper in Dallas County, Texas, because the events giving rise to Plaintiffs’ causes
of action occurred in Dallas County, Texas and because all parties are residents of (or have
their principal place of business in) Dallas County for venue purposes.
V.FACTS
A. Background
3. The deadline to submit applications for placement on the March Primary Ballot for Judicial
4. After the filing deadline, a candidate may not file and the county Chair may not accept, an
5. The candidates whose petitions are the subject of this challenge submitted their applications
and/or applications and petitions, along with a fee, to the DCDP for offices sought wholly
within Dallas County, between, DATE RANGE, in accordance with The Texas Election Code
purporting to be Donovan, so certifying the candidates for inclusion on the primary ballot, in
8. The Primary Election is scheduled to be held on March 6, 2018, and early voting ballots were
CAUSE NO.
DCRP v. DCDP – Plaintiffs’ Original Petition & Application for TRO / Temporary Injunction Page 4
B. THE 128 CANDIDATES WHOSE APPLICATIONS WERE NOT
9. The Texas Election Code states that a candidate’s application for a place on the ballot, must
10. The Election Code also makes clear that for any office that is wholly within one county, a
candidate’s application for a place on a party’s primary ballot must be filed with that political
party, specifically with the County Chair or the County Party Secretary.3
11. The Election Code gives the Secretary of State the authority to create and prescribe different
12. The application form (Form 2-2), contains a further admonition within the form warning that
failing to provide required information could result in rejection of the application: “All fields
MUST be completed unless marked optional. Failure to provide required information may
13. The Election Code requires that, once those applications are received by the appropriate
authority (for placement on the March 2018 Dallas Democratic Primary Ballot, the DCDP),
that “authority with whom the application is filed shall review the application to determine
CAUSE NO.
DCRP v. DCDP – Plaintiffs’ Original Petition & Application for TRO / Temporary Injunction Page 5
whether it complies with the requirements as to form, content, and procedure that the
application and petition must satisfy for the candidate’s name to be placed on the ballot.”6
14. After making the relevant authority makes that determination, the Election Code requires it to
certify the names of all candidates who comply, as the names are written on the application,
15. The County Chair, alone, is the presiding officer of a county party, under the Election Code.8
16. The Election Code designates the County Chair, alone, as the sole person responsible for
certifying and authorized to submit the names of complying candidates to the Secretary of
State,9, 10
17. And though the Secretary of State may prescribe deadlines by which these submissions must
be delivered, the Code makes very clear that those candidate submissions are to be made by
the Chair.11
18. The form also indicates, at the bottom, that the certification for submission to the Secretary
19. This authority may not be delegated except in very limited circumstances. In fact, the Code
only makes provision for the a State Party Chair to perform a County Chairs’ job, and then
only makes this provision if: (a) there is an absence of County Party leadership; or (b) the
CAUSE NO.
DCRP v. DCDP – Plaintiffs’ Original Petition & Application for TRO / Temporary Injunction Page 6
County Chair does not perform a duty in a timely manner.12 However, even then, a State
Chair must make special notice to the County Chair or the County Executive Committee if he
or she is going to or has performed one of the Chair’s duties for him or her, including the
20. If the Party Chair has a reasonable impediment to being able to perform those tasks which
the Election Code requires of them with regard to Primary Elections, the County Chair may
request, in advance, that the State Chair or the State Chair’s Designee perform the duty
21. But there is no provision in the Election Code that makes it possible or permissible for
22. On information and belief, Donovan made no such a request to the Texas Democratic Party’s
Chair, nor is there any indication that the Texas Democratic Party Chair notified Donovan or
DCDP of a determination that Donovan was not performing her duties in a timely manner, so
23. Political Parties are expressly prohibited by the Code from making nominations to public
24. In the attached Appendix, Plaintiffs submit all 151 Applications submitted to the DCDP by
candidates (and submitted by the DCDP to the Secretary of State) for inclusion on the March
CAUSE NO.
DCRP v. DCDP – Plaintiffs’ Original Petition & Application for TRO / Temporary Injunction Page 7
25. Donovan signed only 23 of these 151 Applications. The remaining 127 applications bear
someone else’s forgery of Donovan’s name – the forgeries do not resemble Carol
Donovan’s signature as it appears on her own application for inclusion on the Democratic
26. Only a county party chair may accept applications for ballot access (or, in the narrow
exceptions provided by the Code, the State Chair or Designee) or submit complying
27. The following applications for the following candidates in the following district are indeed
accepted and signed by the County Chair, with a signature that matches Defendant
Donovan’s signature on her own application for inclusion on the party primary ballot for
Party Chair:
CAUSE NO.
DCRP v. DCDP – Plaintiffs’ Original Petition & Application for TRO / Temporary Injunction Page 8
18. Dan Patterson, County Criminal Court-at-Law CrtNo.1
19. John F. Warren, County Clerk
20. Curtis “Traylor” Harris, Constable Pct. 3
21. Jeff Bryan, Constable Pct 5
22. Michael Orozco, Constable Pct. 5
28. The following applications for the following candidates in the following district are not
accepted and signed by the County Chair, and are instead signed by a John Doe #1 with a
signature that does not matche Defendant Donovan’s signature on her own application for
CAUSE NO.
DCRP v. DCDP – Plaintiffs’ Original Petition & Application for TRO / Temporary Injunction Page 9
25. Mark Greenbert, Judge, County Court-at-Law No.5
26. Julia Hayes, County Criminal Court-at-Law No. 2
27. Audrey Faye Moorehead, County Criminal Court-at-Law No. 3
28. Remeko Tranisha Edwards, County Criminal Court-at-Law No. 7
29. Carmen White, County Criminal Court-at-Law No. 8
30. Peggy Hoffman, County Criminal Court-at-Law No. 9
31. Wini Cannon, County Commissioner Pct. 2
32. Thomas G. Jones, Justice of the Peace, Pct. 1, Place 1
33. Valencia Nash, Justice of the Peace, Pct. 1, Place 2
34. Norris “Stretch” Rideaux, Justice of the Peace Pct. 4, Place 1
35. Fred “Action” Jackson, Justice of the Peace Pct. 4 Place 2
36. Sara Martinez, Justice of the Peace, Pct. 5, Place 1
37. Juan Jasso, Justice of the Peace, Pct. 5 Place 2
38. Tracey Gulley, Constable Pct. 1
39. Rolando Garcia, Constable Pct. 5
40. Susan E. Lopez-Craig
29. The following applications for the following candidates in the following district are not
accepted and signed by the County Chair, and are instead signed by a John Doe #1 with a
signature that does not match Defendant Donovan’s signature on her own application for
CAUSE NO.
DCRP v. DCDP – Plaintiffs’ Original Petition & Application for TRO / Temporary Injunction Page 10
14. Gena Slaughter, District Judge, 191st Judicial District
15. Lindsay Harrison, District Judge, 193rd Judicial District
16. Joan Ballard, District Judge 193rd Judicial District
17. Ernest White, District Judge 194th Judicial
18. Teresa Hawthorne, District Judge, 203rd Judicial District
19. Raquel “Rocky” Jones, District Judge, 203rd Judicial District
20. Tammy Kemp, District Judge, 204th Judicial District
21. Stephen Duplantis, District Judge, 204th Judicial District
22. Darlene Ewing, District Judge, 254th Judicial District
23. Kim Cooks, District Judge, 255th Judicial District
24. Sandre Moncriffe, District Judge, 255th Judicial District
25. David Lopez, District Judge, 256th Judicial District
26. Myra Mcintosh, District Judge, 265th Judicial District
27. Jennifer Bennett, District Judge, 265th Judicial District
28. Amber Givens-Davis, District Judge, 282nd Judicial District
29. Lela D. Mays, District Judge, 283rd Judicial District
30. Stephanie N. Mitchell, District Judge, 291st Judicial District
31. Brandon Birmingham, District Judge, 292nd Judicial District
32. Sandra Jackson, District Judge, 302nd, Judicial District
33. Thelma Sanders Clardy, District Judge, 302nd, Judicial District
34. LaDeitra Adkins, District Judge, 304th Judicial District
35. Andrea Martin, District Judge, 304th Judicial District
36. Andrea Plumlee, District Judge, 330th Judicial District
37. Tina Yoo Clinton, Criminal District Judge, Dallas County Number 1
38. Monique Ward, Criminal District Judge, Dallas County Number 1
39. Jeanine Howard, Criminal District Judge, Dallas County Number 6
40. Alison Grinter, Criminal District Judge, Dallas County Number 6
41. Mark Watson, Criminal District Judge, Dallas County Number 7
42. Heath Harris, Criminal District Judge, Dallas County Number 7
43. Elizabeth Davis Frizell, Criminal District Attorney Dallas County
44. Dorotha Ocker, Judge, County Court-at-law No 2
45. Melissa J. Bellan, County Court-at-law No 2
46. Rachel Rider, County Court-at-law No 4
47. Tanja Martini, County Court-at-law No 4
48. Ken Tapscott, County Court-at-law No 4
49. Paula Rosales, County Court-at-law No 4
50. Ingrid Michelle Warren, Judge, County Probate Court-at-Law No.2
51. Margaret Jones-Johnson, County Probate Court-at-Law No.3
CAUSE NO.
DCRP v. DCDP – Plaintiffs’ Original Petition & Application for TRO / Temporary Injunction Page 11
52. Marty Jo Taylor, Judge, County Criminal Court of Appeals, No. 1
53. Kristin Wade, Judge, County Criminal Court of Appeals, No. 1
54. Pamela Luther, Judge, County Criminal Court of Appeals, No. 2
55. Bruce Kaye, County Criminal Court of Appeals, No. 2
56. Marilynn Mayse, County Criminal Court of Appeals, No. 2
57. Roberto Canas, County Criminal Court-at-Law, No. 10
58. Etta J. Mullin, County Criminal Court-at-Law, No. 10
59. Shequitta Kelly, County Criminal Court-at-Law, No. 11
60. Symone Redwine, County Criminal Court-at-Law, No. 3
61. Nancy C. Mulder, County Criminal Court-at-Law, No. 4
62. Lisa Green, County Criminal Court-at-Law, No. 5
63. Angela M. King, County Criminal Court-at-Law, No. 6
64. Felicia Pitre, District Clerk
65. Marian Brown, Sheriff
66. Roy Williams, Jr., Sheriff
67. Pauline Medrano, County Treasurer
68. Elba Garcia, County Commissioner, Pct. 4
69. Anthony Elland, Justice of the Peace, Pct. 2, Place 1
70. Margaret O’Brien, Justice of the Peace, Pct. 2, Place 1
71. Katina Whitfield, Justice of the Peace, Pct. 2, Place 2
72. Shannon Bradford, Justice of the Peace, Pct. 3, Place 1
73. Mauri Long, Justice of the Peace, Pct. 3, Place 2
74. Mike JOnes, Justice of the Peace, Pct. 4, Place 1
75. Sasha Moreno, Justice of the Peace, Pct. 4, Place 2
76. Katy Hubener, Justice of the Peace, Pct. 4, Place 2
77. Andrew “Bundy” Goldsmith, Justice of the Peace, Pct. 5, Place 2
78. Alvin “AJ” Johnson, Constable Pct. 1
79. Bill Gipson, Constable Pct. 2
80. Curtis “Traylor” Harris, Constable Pct. 3
81. Kevin Solomon, Constable Pct. 4
82. Bryan D. Woodard, Constable Pct. 4
83. Edward Wright, Constable Pct. 4
84. Donald G. Artis, Constable Pct. 4
85. Sha Steger Knight, Constable Pct. 4
86. Ron E. Bivins, Constable Pct. 4
87. Beth Villarreal, Constable Pct. 5
88. Henry Brown, Justice of the Peace Pct. 2, Place 2
CAUSE NO.
DCRP v. DCDP – Plaintiffs’ Original Petition & Application for TRO / Temporary Injunction Page 12
30. DCDP sent certifications of compliance to the Secretary of State for 128 Candidates whose
applications were accepted in violation of the Election Code. No candidate wrongly accepted
by an unauthorized individual can legally be included on a ballot for the March 2018 primary
election.
C.D C R P T I M E LY F I L E T H I S C H A L L E N G E TO T H E 1 2 8
31. The Election Code authorizes challenges to the form, content, and procedure of an
application until the end of the day before any ballot to be voted on via early mail voting has
been mailed out.16 Early voting ballots for voting by mail were initially scheduled to be
mailed out by the Dallas County Elections Department on Saturday January 20, 2018.
32. This Original Petition initiates a challenge to the form, content, and procedure of the 128
candidates’ whose applications were not accepted and submitted by the DCDP Chair well
VI.CAUSES OF ACTION
33. The Plaintiffs re-allege and incorporate-by-reference the facts and allegations set forth above.
34. A justiciable controversy has arisen between the Plaintiffs and the Defendants. The Plaintiffs
ask the Court to declare that the 128 Candidates whose applications were not accepted by
CAUSE NO.
DCRP v. DCDP – Plaintiffs’ Original Petition & Application for TRO / Temporary Injunction Page 13
Donovan before their wrongful submission to the Secretary of State are not eligible for
35. It was necessary for the Plaintiffs to employ counsel to prosecute this action. In accordance
with §37.001 et seq. of the Texas Civil Practice & Remedies Code, the Plaintiffs are entitled
to recover their reasonable and necessary attorneys’ fees and costs herein, for which they now
sue.
36. All conditions precedent to recovery have been performed, have occurred, or have been
waived.
Injunction
37. The Plaintiffs re-allege and incorporate-by-reference the facts and allegations set forth above.
38. One of the principal purposes behind the Texas Election Code is the prevention of election
fraud and electoral misconduct, and to protect the integrity of the electoral process. Tex. Elec.
Code §1.003(a); In re Bell, 91 S.W.3d 784, 787 (Tex. 2002). “A person who is being harmed
to appropriate injunctive relief to prevent the violation from continuing or occurring.” Tex.
39. The DCDP has submitted to the Secretary of State, in violation of the provisions of the Texas
Election Code in Section 172.029(a), 128 different candidates for the Democratic Primary
who were not accepted by the DCDP Chair Donovan. It is past the statutory deadline set by
CAUSE NO.
DCRP v. DCDP – Plaintiffs’ Original Petition & Application for TRO / Temporary Injunction Page 14
the Secretary of State for any additional Applications to be submitted to the Secretary of
40. Many of the 128 identified candidates seek offices for which the DCRP was unable to timely
certify to the Secretary of State its receipt of a statutorily compliant candidate application.
When no party timely submits to the Secretary of State the name of a candidate certified by
the proper authority as having met the application requirements established by the Election
Code for inclusion on a primary ballot, the Election Code authorizes the parties to
subsequently nominate a designated candidate for office. Accordingly, the Plaintiffs are in
danger of being denied their statutory right to designate nominees for the many offices for
which Donovan, the only individual with the statutory authority to certify candidates’
compliance and submit them to the Secretary of State, did not do so.
41. Others of the 128 identified candidates seek offices for which the DCRP did timely certify to
the Secretary of State its receipt of one or more statutorily compliant candidate applications.
In these instances, the Plaintiffs are in danger of being harmed by by having to face an
opponent in the November 2018 General Election, who the Texas Election Code bars from
inclusion as a candidate. Risner v. Harris County Republican Party, 444 S.W.3d 327, 345
(Tex. App.—Houston [1st Dist] 2014, writ of mandamus denied, 2014 Tex. LEXIS 801 (Tex.
September 8, 2014)).
42. DCRP, and Shorey, have complied with their statutory obligations. They, and their
candidates, would suffer harm from upholding the stringencies of the Election Code, when
their counterparts have not done the same. Additionally, the Plaintiffs, like all Dallasits,
would suffer harm in the form of the damages to the integrity of the elections process that
CAUSE NO.
DCRP v. DCDP – Plaintiffs’ Original Petition & Application for TRO / Temporary Injunction Page 15
would result from an unequal application of the law allowing 128 candidates onto the ballot,
despite the DCDP’s flagarant, willful, systematic submission of candidates to the Secretary of
43. The injunctive relief sought herein is necessary to adequately protect the interests of the
Plaintiffs, and the voting public, from election fraud, misconduct, and manipulation of the
election process. The Plaintiffs do not have an alternative, after-the-fact, adequate remedy at
likelihood that the Defendants will allow the 128 identified candidates to be placed on March
2018 Democratic Primary Baallot, and, thereafter, on the November 2018 General Election
44. The Plaintiffs will suffer immediate and irreparable harm unless the Defendants, their agents,
knowledge of this injunction are immediately restrained from, directly or indirectly, engaging
(a) Certifying any of the identified candidates for inclusion on the March 2018
(b) Certifying any of the identified candidates as DCDP nominees on the November
Primary;
(c) Verifying or certifying the printing of ballots including any of the identified
candidates’ names as candidates for office in the March 2018 Democratic Primary or
behalf, a Primary Election in which any of the identified candidates are listed as
(e) Conducting the November 2018 General Election, participating in the November 2018
General Election, or authorizing anyone else to conduct on their behalf the November
2018 General Election, to the extent that any of the identified candidates is listed as
the DCDP’s primary winner for any office or as the DCDP’s nominee for any office;
and/or
(f) Declaring each and every any identified candidate ineligible under Tex. Elec. Code
§145.003(f);
45. The Plaintiffs have a substantial likelihood of prevailing on the merits. Given the high
likelihood that the Plaintiffs will prove that the Defendants did not comply with the Election
Code and prevail on the merits, no legitimate harm or prejudice will result to the Defendants
from the Court granting the requested injunctive relief before trial. On the other hand, the
Plaintiffs will suffer immediate and irreparable harm from a denial of such injunctive relief.
46. There is no remedy at law for Plaintiffs’ additional statutory rights if the TRO is not granted.
The Texas Election Code provides that when there has not been a Primary Election in either
party, the County Party Committees may so appoint a representative to represent them on the
ballot. If the TRO is granted, particularly in cases where the is no Republican candidate, and
no primary race is held in that seat in either party, both Parties could still appoint an
candidate for the November ballot. However, if the TRO is not granted, and Plaintiff were to
CAUSE NO.
DCRP v. DCDP – Plaintiffs’ Original Petition & Application for TRO / Temporary Injunction Page 17
prevail between the Primary and the General Election, because the Democratic Party held a
VII.CONDITIONS PRECEDENT
47. All conditions precedent necessary for Plaintiffs to have and recover in this action have been
respectfully requests that: (a) citation issue and process be served on the DCDP and Carol
Donovan, its Chairwoman; (b) the Court grant both a Temporary Restraining Order, and, after a
hearing, both a Temporary Injunction and a Permanent Injunction against Defendants; and (c) the
Court grant the Plaintiffs a declaratory judgment as requested, including in its relief the
Plaintiffs’ reasonable and necessary attorney’s fees incurred prosecuting this action, costs and
expenses of suit herein, and both pre- and post-judgment interest on all monetary relief sought
herein at the highest rates allowed by law. Finally, the Plaintiffs ask for any other and further
relief to which the Court determines the Plaintiffs may be justly entitled.
/s/Elizabeth D.Alvarez
Elizabeth D. Alvarez
Texas Bar No. 24071942
CAUSE NO.
DCRP v. DCDP – Plaintiffs’ Original Petition & Application for TRO / Temporary Injunction Page 18
Law Office of Elizabeth Alvarez
555 Republic Drive Ste 200
Plano, Tx 75074
CAUSE NO.
DCRP v. DCDP – Plaintiffs’ Original Petition & Application for TRO / Temporary Injunction Page 19
LOCAL RULE CERTIFICATION
In accordance with Local Rule 2.02, the undersigned hereby certifies that at least two hours
before presenting this application to the Court, the undersigned notified the Defendants of this
application. The undersigned sent a copy of the application and proposed order to Defendants via
email to those Defendants whose e-mail address the undersigned was aware of notifying them of
Plaintiffs’ intention to present this application to the Court ex parte as follows:
In the e-mail, the undersigned provided his cell phone number so that Defendants could contact
her. At least two hours before presenting this application to the Court, the undersigned notified
the following Defendants of the application by telephone and sent the Defendants who provided
her with their e-mail addresses a copy of the application and proposed order as follows:
/s/Elizabeth D. Alvarez
Elizabeth Alvarez
CAUSE NO.
DCRP v. DCDP – Plaintiffs’ Original Petition & Application for TRO / Temporary Injunction Page 20
VERIFICATION
STATE OF TEXAS §
COUNTY OF DALLAS §
I, Davin Bernstein, state and declare that I am over 21 years of age and fully competent to make
this declaration. The facts set forth herein are true and correct and are within my personal
knowledge. I have read the foregoing Plaintiffs’ Original Petition Challenging the Certification of
the Improperly Certified Democratic Candidates Application for a Place on the Democratic
Primary Ballot, Application for Temporary Restraining Order, & Application for Temporary
Injunction, and that the facts stated in paragraphs 4-7, 3-32, 37-43, and 45-47, are within my
personal knowledge and are true and correct, unless otherwise qualified therein.
My name is Davin Bernstein, my date of birth is 08/24/1965, and my address is 228 Hollywood
Drive, Coppell, Tx, 75019. I declare under penalty of perjury that the foregoing is true and
correct.
________________________________
Missy Shorey
As
Chairwoman, Dallas County Republican Party
CAUSE NO.
DCRP v. DCDP – Plaintiffs’ Original Petition & Application for TRO / Temporary Injunction Page 21
CERTIFICATE OF SERVICE
I certify that on January 19th, 2018, I served a copy of this Petition on all counsel of record in
accordance with the Texas Rules of Civil Procedure via email, and through service of process.
DEFENDANTS
CAUSE NO.
DCRP v. DCDP – Plaintiffs’ Original Petition & Application for TRO / Temporary Injunction Page 22
CAUSE NO. ____________
__________________________________________________________________________
__________________________________________________________________________
CAUSE NO.
DCRP v. DCDP, et al,
PLAINTFFS’ APPENDIX TO THEIR ORIGINAL PETITION, APPLICATION
FOR A TEMPORARY RESTRAINING ORDER, & APPLICATION FOR TEMPORARY INJUNCTION
TABLE OF CONTENTS
CERTIFICATE OF SERVICE..........................................................................................................158
CAUSE NO.
DCRP v. DCDP, et al,
PLAINTFFS’ APPENDIX TO THEIR ORIGINAL PETITION, APPLICATION
FOR A TEMPORARY RESTRAINING ORDER, & APPLICATION FOR TEMPORARY INJUNCTION
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RESPECTFULLY SUBMITTED this 19th day of January, 2018.
s/Elizabeth D. Alvarez
Elizabeth D. Alvarez
Texas Bar No. 24071942
CAUSE NO.
DCRP v. DCDP, et al,
PLAINTFFS’ APPENDIX TO THEIR ORIGINAL PETITION, APPLICATION
FOR A TEMPORARY RESTRAINING ORDER, & APPLICATION FOR TEMPORARY INJUNCTION
APPENDIX PAGE 157
CERTIFICATE OF SERVICE
I certify that on January 18th, 2018, I served a copy of this Petition on all counsel of record in
accordance with the Texas Rules of Civil Procedure via email, and/or through service of process.
DEFENDANTS
CAUSE NO.
DCRP v. DCDP, et al,
PLAINTFFS’ APPENDIX TO THEIR ORIGINAL PETITION, APPLICATION
FOR A TEMPORARY RESTRAINING ORDER, & APPLICATION FOR TEMPORARY INJUNCTION
APPENDIX PAGE 158