United States District Court for the Southern District of Texas Houston Division

UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION TEXAS DEMOCRATIC PARTY; § BOYD L. RICHIE, in his capacity as § Chairman of the Texas Democratic Party; § HARRIS COUNTY DEMOCRATIC § PARTY; § GERALD BIRNBERG, in his capacity as § Chairman of the Harris County § Democratic Party; § J. GOODWILLE PIERRE; § ALEXANDRA GIBBS; JEFFREY T. § VANSCHOONHOVEN; BONI SUE § LESZCZUK; and ERIC J. GALLOWAY § Cause No. 4:08-CV-03332 § Plaintiffs , § § vs. § § LEO VASQUEZ, in his capacity as § Harris County Tax Assessor Collector § and Harris County Voter Registrar § § Defendant . § PLAINTIFFS’ RULE 26(a)(1) INITIAL DISCLOSURES Pursuant to Rule 26 (a)(1) of the Federal Rules of Civil Procedure, Texas Democratic Party; Boyd L. Richie, in his capacity as Chairman of the Texas Democratic Party; Harris County Democratic Party; Gerald Birnberg, in his capacity as Chairman of the Harris County Democratic Party; J. Goodwill Pierre; Alexandra Gibbs; Jeffrey T. Vanschoonhoven; Boni Sue Leszczuk; and Eric J. Galloway submit the following disclosures in this case: 1 A. The name and, if known, the address and telephone number of each individual likely to have discoverable information relevant to disputed facts alleged with particularity in the pleadings, identifying the subjects of the information: 1. Texas Democratic Party; Boyd L. Richie, in his capacity as Chairman of the Texas Democratic Party; Harris County Democratic Party; Geral Birnberg, in his capacity as Chairman of the Harris County Democratic Party; J. Goodwill Pierre; Alexandra Gibbs; Jeffrey T. Vanschoonhoven; Boni Sue Leszczuk; and Eric J. Galloway c/o Mr. Chad Dunn TEXAS DEMOCRATIC PARTY BRAZIL & DUNN 4201 FM 1960 West, Suite 550 Houston, Texas 77002 Telephone: (281) 580-6310 Plaintiffs 2. Leo Vasquez, in his capacity as Harris County Tax Assessor Collector and Harris County Voter Registrar c/o Mr. F. Clinton Gambill, II SR. ASSISTANT COUNTY ATTORNEY 1019 Congress, 15 th Floor Houston, Texas 77002 Telephone: (713) 755-4985 Defendant 3. Representative Robert Talton Texas House of Representatives 3622 Fairmont Pkwy Pasadena, Texas 77504 (281) 487-8818 2 Representative for Texas Congressional District 144, who is expected to testify regarding his private meetings with Defendant on the topic of voter registration, counting provisional ballots, and the ballot board, among other things, and will testify regarding private meetings and phone calls with Jim Harding. 4. Jared Woodfill Harris County Republican Party Chairman 3311 Richmond, Suite 218 Houston, Texas 77098 - 713-838-7900 Chairman of the Harris County Republican Party, who is expected to testify regarding his private meetings with Defendant on the topic of voter registration, counting provisional ballots, and the ballot board, among other things, and will testify regarding private meetings and phone calls with Jim Harding. 5. Jim Harding 5010 Sandy Cedar Kingwood, Texas 77345 (281) 360-7334 Ballot board Chairman, who, based on information and belief, is expected to have knowledge of the inner workings of the ballot board the lack of response by Defendant to the ballot board and the condition and the timing of the ballots that were received from Defendant, among other things. He is also expected to testify to Defendant’s and other republican party personnel’s contact with him during ballot board operations and the subsequent investigation into this contact. 6. Mary Almendarez 608 Joyce St. Houston, Texas 77009 (713) 699-9716 Ballot board member, who, based on information and belief, is expected to have knowledge of the inner workings of the ballot board the lack of response by Defendant to the ballot board and the condition and the timing of the ballots that were received from Defendant, among other things. 3 7. Imogene Anderson 2301 Hayes Rd., Apt. 6705 Houston, Texas 77077 (713) 782-0919 Ballot board member, who, based on information and belief, is expected to have knowledge of the inner workings of the ballot board the lack of response by Defendant to the ballot board and the condition and the timing of the ballots that were received from Defendant, among other things. 8. Gwendolyn Bell 11526 Heathermill Dr. Houston, Texas 77066 (281) 844-8741 Ballot board member, who, based on information and belief, is expected to have knowledge of the inner workings of the ballot board the lack of response by Defendant to the ballot board and the condition and the timing of the ballots that were received from Defendant, among other things. 9. Priscilla Bloomquist 12403 Mullins Dr. Houston, Texas 77035 (713) 721-7376 Ballot board member, who, based on information and belief, is expected to have knowledge of the inner workings of the ballot board the lack of response by Defendant to the ballot board and the condition and the timing of the ballots that were received from Defendant, among other things. 10. Bettye Bruno 8305 Bigwood St. Houston, Texas (713) 828-0055 Ballot board member, who, based on information and belief, is expected to have knowledge of the inner workings of the ballot board the lack of response by Defendant to the ballot board and the condition and the timing of the ballots that were received from Defendant, among other things. 11. Jane Cherry 4 3616 Garrett #5 Houston, Texas 77006 (713) 516-4464 Ballot board member, who, based on information and belief, is expected to have knowledge of the inner workings of the ballot board the lack of response by Defendant to the ballot board and the condition and the timing of the ballots that were received from Defendant, among other things. 12. Kirk Childress 3560 Dixie Dr., Apt. 931 Houston, Texas 77021 (713) 842-4150 Ballot board member, who, based on information and belief, is expected to have knowledge of the inner workings of the ballot board the lack of response by Defendant to the ballot board and the condition and the timing of the ballots that were received from Defendant, among other things. 13. Bill Comstock 245 Malone Houston, Texas 77007 (713) 861-5676 Ballot board member, who, based on information and belief, is expected to have knowledge of the inner workings of the ballot board the lack of response by Defendant to the ballot board and the condition and the timing of the ballots that were received from Defendant, among other things. 14. Virginia Duke 211 Eleanor Houston, Texas 77009 (713) 695-3198 Ballot board member, who, based on information and belief, is expected to have knowledge of the inner workings of the ballot board the lack of response by Defendant to the ballot board and the condition and the timing of the ballots that were received from Defendant, among other things. 15. Guyleene Ebersole 6666 Chetwood #205 5 Houston, Texas 77081 (713) 665-6470 Ballot board member, who, based on information and belief, is expected to have knowledge of the inner workings of the ballot board the lack of response by Defendant to the ballot board and the condition and the timing of the ballots that were received from Defendant, among other things. 16. Michael Fleming 1902 Coquitt, Apt. 16C Houston, Texas 77098 (713) 528-3968 Ballot board member, who, based on information and belief, is expected to have knowledge of the inner workings of the ballot board the lack of response by Defendant to the ballot board and the condition and the timing of the ballots that were received from Defendant, among other things. 17. Billie Rose Gray 120 E. 3 rd Houston, Texas 77018 (713) 861-1034 Ballot board member, who, based on information and belief, is expected to have knowledge of the inner workings of the ballot board the lack of response by Defendant to the ballot board and the condition and the timing of the ballots that were received from Defendant, among other things. 18. Leif Hatlen 13527 N. Tracewood Bend Houston, Texas 77077 (281) 493-3107 Ballot board member, who, based on information and belief, is expected to have knowledge of the inner workings of the ballot board the lack of response by Defendant to the ballot board and the condition and the timing of the ballots that were received from Defendant, among other things. 19. Mary Ann Haxthausen 323 W. 33 rd St. Houston, Texas 77018 6 (713) 864-4855 Ballot board member, who, based on information and belief, is expected to have knowledge of the inner workings of the ballot board the lack of response by Defendant to the ballot board and the condition and the timing of the ballots that were received from Defendant, among other things. 20. Joan Hinyard 4902 Libbey Ln. Houston, Texas 77092 (713) 681-6011 Ballot board member, who, based on information and belief, is expected to have knowledge of the inner workings of the ballot board the lack of response by Defendant to the ballot board and the condition and the timing of the ballots that were received from Defendant, among other things. 21. Stephanie Hrabar 5005 Gregori Ln, #63 Houston, Texas 77092 (713) 683-0638 Ballot board member, who, based on information and belief, is expected to have knowledge of the inner workings of the ballot board the lack of response by Defendant to the ballot board and the condition and the timing of the ballots that were received from Defendant, among other things. 22. Joe Lovino 2056 Antoine Dr., Apt. 410 Houston, Texas 77055 (713) 382-0619 Ballot board member, who, based on information and belief, is expected to have knowledge of the inner workings of the ballot board the lack of response by Defendant to the ballot board and the condition and the timing of the ballots that were received from Defendant, among other things. 23. Mary Luckey 5431 Indigo St. Houston, Texas 77096 (281) 610-7254 7 Ballot board member, who, based on information and belief, is expected to have knowledge of the inner workings of the ballot board the lack of response by Defendant to the ballot board and the condition and the timing of the ballots that were received from Defendant, among other things.

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