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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 PO Box 2641 Corpus Christi Tx 78403 361-888middot9255 phone 361-888-9285 fax

--- - --- - ------- --- --------- --- -shy-

IDENTITY OF PARTIES AND COUNSEL

RELATOR COUNSEL

Vanessa Cahill 6050 Rio Vista Corpus Christi Texas 78412 8328162944 phone

Bruce C Matzke State Bar No 13234475 PO Box 2641 Corpus Christi Texas 78403 3618889255 phone 3618889288 fax

REAL PARTY IN INTEREST

The Republican Party of Texas 900 Congress Avenue Suite 300 Austin Texas 78701 5124779821 phone 5124800709 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 5124779821 phone 5124800709 fax

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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

partys political convention it involved relators 14th amendment rights and given

the limited time frame immediate court action is required

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TABLE OF CONTENTS

IDENTITY OF PARTIES AND COUNSEL i

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

CERTIFICATE OF COMPLIANCE I0

TABLE OF CONTENTS ii

INDEX OF AUTHORITIES iii

STATEMENT OFTHE CASE iv

STATEMENT OF JURISDICTION v

ISSUE PRESENTED vi

STATEMENT OF FACTS 1

ARGUMENT 4

Importance of Case 4 Jurisdiction to accept Relators Request for Mandamus 5 Public Officer is subject to Mandamus 6

CONCLUSION 7

VERIFICATION 8

CERTIFICATE OF SERVICE 9

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--- - ---~

INDEX OF AUTHORITIES

CASES

Morse v Republican Party oj Virginia 517 US 186 (1996) 4

OBrien v BroHI1 409 US 1 92 SCt 2718 34 LEd2d 1 (1972) 5

Republican Party aTexas v Dietz SW2d 86 (Tex1997) and 924 SW2d 932

(Tex1996) 5

Republican Party aTexas 1 Dietz 940 SW2d 86 (Tex 1997) v

United States v Clasic 313 US2999 4

STATUTES

Texas Election Code

~ 273063(a) v

~ 273061 5

sect 174027 6 ~ 161004 6

sect 161009 v6

sect 163007 6

RULES

Texas Rule of Appellate Procedure 523(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

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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 andor refused such request

This court is being petitioned to enforce Respondants 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 ofdispute 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

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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 161009

Texas Election Code section 273063(a)

Texas Rule ofAppellate Procedure 523(e)

This courts opinion in Republican Party of Texas v Dietz 940 S W2d 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 states 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

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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

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IV THE UNDISPUTED STATEMENT OF FACTS

Thefacts stated herein are supported bv the Cfidmit ofthe Relator

ciffidalits ofbusinesses record and party admissions Particular caution

lvas taken to insure the Texas Rules of Evidence were follmted

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 pJimary election

March 4 2008 Relator went to precinct 65s 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

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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

Bng HegtVJ Intrested I h0rng molVVIVnrlerl n middotheII Nu~~e~--UUIlLYr~ ~h llUVllllll Ul 1 --

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 chairmans 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 175870 and 121 (EXHIBITS EFGH) Mrs Cahill obtained a

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---- - - ---- - ------ --shy

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 gtvas

Mrs Cahills 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

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--- - ~ --- - - ------- ---- -- - - _shy~-

VARGUMENT

The importance of this case

Then the United States Supreme Court in Morse v Republican Party

~11middotImiddotamiddot~~ ()4 29 7 117 TT C 86 1996 ~~d~ m~rle n~ rlJfe----- t ow ~VJ ~uuu 17 - JjJ1 LJJbull l 11 J ~al II II au IV U 11 lC11lC 11 d

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 US Congress See

United States v Clasic 313 US2999

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 US and

Texas Constitutions the Voters Rights Act passed by Congress and the

Election Laws of the State of Texas

And in particular the Relators 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

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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 Relators Request for mandamus

Title 10 of the Texas Election Code sect 273061 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 SW2d 86 (Tex 1997)

and 924 SW2d 932 (Tex1996) 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 states 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 OBrien v Brown 409 US 1 92 SCt 271834 LEd2d 1 (1972)

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---shy - ---shy

Party Officer is subject to mandamus

Section 161009 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

163007 also states that these rules are enforceable by writ of mandamus

Section 174027 (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 161004 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 174027 and 161004

allowing access to these documents is the implied duty placed upon Mr

Bertuzzi

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CONCLUSION

The exhibits attached to this petition provide some evidence that the respondent violated the equal protection clause of the 14th amendment by CAltgttnn noffilal delenatAs ltgtt thAountv nnAntnn ltgtnd lnclurlng thAI~vUll115 UJ v lS t Ul II IlJ vVll V vi ltV J Ul Ul 1 l Ivi

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 PO Box 2641 Corpus Christi Texas 78403 Tel (361) 888-9255 Fax (361) 888-9288

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--- - --- - ---shy- -~-

IN THE SUPREME COURT OF TEXAS

IN RE VANESSA CAHILL

Relator

VERIFlCATION

STATE OF TEXAS sect sect

COUNTY OF NlJECES sect

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

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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

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~eIT A NUECES COUNTY REPUBLICAN PARTY aD Corpus 4458 South Staples

Christi Texas 78411

(361 ) 994-9317 (361 ) 994-9343 FAX E-Mail ncrpcctxgrandecomnet

Mike Bertuzzi-ehairman Rebecca Bradford---Vice Chairman Aneie 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 Saturday March 29

th 2008 The time is 1000 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 1000

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 am (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 partys 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 Morganmiddot Rd and go toward Leopard St Take a right on Leopard St then take

fJOT tlo Q

centlt~ o~+-

I~(~ ~~)~lk~~~-~~ -s ~ middot)oR

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~~

OFFiCE OF THE SECRETARY OF 5T ATE

~Xvi[) A DFAN ITE CAfrrOl_ )~ ~ ro ~-~ fgt( G[)~ 261

~ _ ~ ~ i 1L gt- A S - 1 ~

]url(~ 74 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 Credenshytials 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~ 103 sUbd 1 (V~r~cn Supp 1982)

Tn your letter you inquired hether a crc~denti-ls conrni ttee of (l pol itical pgtty convcT~Ii(Jn could altor lt1 delegation by 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 1334 (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

____- -e~~ ~bull ~Wl -- -middotr ___

Mr Edward M Sullivan Page 2

SUIvl1ARY

Tex Elee Code Ann art 1334 (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 ir

7

~ I~(yfh~__

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 John 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 1334 (Vernon Supp_ 1982) provides

the sale method fer the selection of delegates to county and

state convertions 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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Alex Haupt antoniofratila Robert Lund Benjamin Bernier dmedinaprudent John Falasca Kay Fischer Margaret Fratila Paul Hunt ronpaul-10

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Committee Information from vanessa cahill ltvanessafratilagmailcomgt hide details Mar 6 Beply

to michaeLbertuzzimlcom date Mar 62008411 PM

subject Committee Information mailed-by gmailcom

Mr Bertuzzi

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 soon be able to put a face to the nameas the saying goes

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 what better time to do so than the election season With all of the hype surrounding the Democratic race I think it is important for everyone in our party to get involved so we can retain the White House in November

I am very interested in volunteering my time in any way triat I can I would love to serve on any of the committees as well as attend the meetings of the committees that are already full If at all possible could you send me a list of these committes and the scheduled meeting dates and times In addition could you give me the phone numberslemail addresses of Art Granado and Victor Bird I believe they are heading up the Nominations and Resolutions Committees

Also if my services are also needed at the headquarters feel free to contact me

Thank you for your patience

Sincerely Vanessa 832-816-2944

~ Forward

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Request for Clarification Inbox

w vanessa cahill (Ni jdld Mar 16 Reply

Mr Bertuzzi

I would like to be sure that my recollection of our first telephone conversation is correct(March 6 2008) As per my memory I requested information on the dates 1imes and locations of the Credentials and Nominations Committees for Nueces County You then asked that I send my request in writing which I promptly did via email (March 6 2008) From the email attachment I received from Mike Bergsma (March 132008) I have made the reasonable assumption that you have opened and read my email request for this information

I would also like to clarify the second and last conversation we had over the telephone (March 12 2008) As per my memory you told me that you would not be providing to me the information I was requesting From what I understood your reluctance to provide the requested information to me stemmed from my affiliation with a local meetup group in which a fellow member Chuck Burnett voiced his opinions of local leadership in the Republican Party

I would also like clarification from you on the 14th Rule of the General Rules for All Conventions and Meetings of the Republican Party of Texas which states

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 to that convention

As a voter in the Republican Primary and a delegate in my precinct I would again like to request the dates times and locations for the following committees

Credentials Resolutions Rules and Nominations

In addition I would also like to request a copy of accurate written records (minutes) from every Precinct in Nueces County Please notify me when these copies have been completed and I will pick them up from the Republican Party Headquarters

Thank you for your time

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err amp Cause No

VANESSA L CAHILL sect SUPREME COURT OF TEXAS

VS sect sect 201 W 14TH STREET RM 104 sect

NUECESCOUNTY sect AUSTIN TEXAS REPUBLICAN PARTY sect

sect REPUBLICAN PARTY OF TEXAS sect

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 ~~j)~A A it A

~ d i

~fS~~~i LINDA D ZEPEDA f ltJ r~~v Notary Public

~ bull STATE OF TEXAS ~

~~~l My Comm Exp 11262011I LOndo- P~CL~ V V V V

Printed Name

My commission expires 1-clt - 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 IIssrional d rllcctt l number of county Texas met at JMI+td Ge1-e-Ik __amp~ (location) on J-QQ f (date) to hold a precinct convention

1 Call to Order - I (I bull The convention was called to order by temporary chairman J) G( ( 1--~1 I----Th------------__ at 7 s-Opm

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~nelti~I1~911Igirttuen9~importantparjy decisions at subsequentcQnven~ions

3 Election of Permanent Officers The temporary chairman announced that nominations for permanent chairman of this precinct convention woUld be

acceh~~~tIlO~~ tft0ns were nominated as candidates --- shy

The convention elected baf SwtmiddotfI as permanent chairman of the precinct convention The convention elected =na~ 2- SOl r 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 Ill (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 ~ovention

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 beshe 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 reguiredPy Ryle 22 and the Election Code (1740270) 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~pm~_ 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

-i

f1 Precinct fl

0 EXIDBITB E Senate District 20 0 (l) List of DELEGATES elected to County I Senatorial District Convention (J

(J VOTERCERT PRINT NAME PRINT MAILING ADDRESS (l)

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PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

Page of ___

CONTACT INFO~1ATION

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SQT FCause No

VANESSA L CAHILL sect SUPREME COURT OF TEXAS sect

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NUECESCOUNTY sect AUSTIN TEXAS REPUBLICAN PARTY sect

sect REPUBLICAN PARTY OF TEXAS sect

BUSINESS RECORDS AFFIDAVIT

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

hereto are an exact duplicate of the original

Further affiant sayeth not

~lffmiddotLnL KayLu

SUBSCRIBED AND SWORN TO before me on this May 6 2008 to which I place my

signature and official seal )dQampyM-u J11du~ Signature

dele Jampylt-pound 71LeAJ Printed Name

My commission expires 1 -J-d~tcf Notary Public for the State of Texas

VICKIE JOY VAN MAREN Notary Public

STATE OF TEXAS My Comm Exp 10-05-2008

MINUTES OF THE REPUBLICAN PARTY PRECINCT CONVENTION

CJ3 ed v~ ters a election precinct nymber 5~g senate district numt er congressional district LJmber of ~ county Texas met at -nK~ ~4A-ltj (Jccion) C1 __trh-ltl lcJV L- oog (date) to hold a precinct convent xf

- CI to Order _-~ J r(3-1e ionver-tion as called to order by temporary chairman _dM~1 at ~-pm

P~pararon 0 List of Participants ( -le mpoary cr airmin 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 _ (numJer) 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 P3rty of Texas Rules adopted in accordance with the Election Code Robert Rules of Order current dit en neNly re ised would govern parliamentary procedure The temporary chairman then explained how the actions of lis mvention auld influence important party decisions at subsequent convlntions

-hE~onvention Elected as permanent chairman of the precinct convention

-~ Election of DI~legates and Alternates to the County or State Senatorial DistrictConvention -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 alternats are listed in Exhibit C

5 tesolutions The gtermanent chairr1an 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

sdopted b a mcjority vote are included with these minutes

5 Other Business Ths permanent chairman then asked if there was any other business that shculd properly come before the convention

7 Announcemfnts 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 heshe would officially sign stal 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 (174027c) The chairman announced the time and place for the county or senatorial district cgtnvention

8 Adjournmen t In accordance vli~ha)motion properly moved and seconded and adopted by a majority vote the precinct convention was

ad~ed at iq pm I J fit~ -- ~-ed lZi Aft-t=

ermanent hairman ~ Secretary

Return to y)ur county chairman The permanent chairman should also IOpy and retain a record of all documents

PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

INSTRUCTIONS FOR THE PRECINCT CONVENTIONS

TIMEPLACE 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 700 pm and 900 pm 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 precincts 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 countysenatorial 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 Roberts 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 wwwtexasgoporg and click on the GOP Resources link

PREPARATION OF LIST OF QUALlFIED PARTICIPANTS Attendees must have voted in that precincts 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 heshe takes the chair and oversees the election of the permanent secretary If necessary the chairman and the secretary may be the same person

ANNOUNCEMENTOF COUNTYSENATORIAJ-PI~TRICT COflVENTION The convention will convene on Saturday March 29 th at IcY0cJ ~~ (time) in q76R kAfr-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 countysenatorial 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 countysenatorial 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 countysenatorial 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 countysenatorial 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

PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

Precinct GV gtPage I of -----L EXHIBIT A

Senate District __ List of qualified voters who ATTENDED precinct convention

VOTERCERT PRINT NAME PRINT MAILING ADDRESS CONTACT INFORMATION

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IDENTITY OF PARTIES AND COUNSEL

RELATOR COUNSEL

Vanessa Cahill 6050 Rio Vista Corpus Christi Texas 78412 8328162944 phone

Bruce C Matzke State Bar No 13234475 PO Box 2641 Corpus Christi Texas 78403 3618889255 phone 3618889288 fax

REAL PARTY IN INTEREST

The Republican Party of Texas 900 Congress Avenue Suite 300 Austin Texas 78701 5124779821 phone 5124800709 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 5124779821 phone 5124800709 fax

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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

partys political convention it involved relators 14th amendment rights and given

the limited time frame immediate court action is required

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TABLE OF CONTENTS

IDENTITY OF PARTIES AND COUNSEL i

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

CERTIFICATE OF COMPLIANCE I0

TABLE OF CONTENTS ii

INDEX OF AUTHORITIES iii

STATEMENT OFTHE CASE iv

STATEMENT OF JURISDICTION v

ISSUE PRESENTED vi

STATEMENT OF FACTS 1

ARGUMENT 4

Importance of Case 4 Jurisdiction to accept Relators Request for Mandamus 5 Public Officer is subject to Mandamus 6

CONCLUSION 7

VERIFICATION 8

CERTIFICATE OF SERVICE 9

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--- - ---~

INDEX OF AUTHORITIES

CASES

Morse v Republican Party oj Virginia 517 US 186 (1996) 4

OBrien v BroHI1 409 US 1 92 SCt 2718 34 LEd2d 1 (1972) 5

Republican Party aTexas v Dietz SW2d 86 (Tex1997) and 924 SW2d 932

(Tex1996) 5

Republican Party aTexas 1 Dietz 940 SW2d 86 (Tex 1997) v

United States v Clasic 313 US2999 4

STATUTES

Texas Election Code

~ 273063(a) v

~ 273061 5

sect 174027 6 ~ 161004 6

sect 161009 v6

sect 163007 6

RULES

Texas Rule of Appellate Procedure 523(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

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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 andor refused such request

This court is being petitioned to enforce Respondants 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 ofdispute 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

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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 161009

Texas Election Code section 273063(a)

Texas Rule ofAppellate Procedure 523(e)

This courts opinion in Republican Party of Texas v Dietz 940 S W2d 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 states 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

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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

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IV THE UNDISPUTED STATEMENT OF FACTS

Thefacts stated herein are supported bv the Cfidmit ofthe Relator

ciffidalits ofbusinesses record and party admissions Particular caution

lvas taken to insure the Texas Rules of Evidence were follmted

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 pJimary election

March 4 2008 Relator went to precinct 65s 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

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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

Bng HegtVJ Intrested I h0rng molVVIVnrlerl n middotheII Nu~~e~--UUIlLYr~ ~h llUVllllll Ul 1 --

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 chairmans 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 175870 and 121 (EXHIBITS EFGH) Mrs Cahill obtained a

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---- - - ---- - ------ --shy

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 gtvas

Mrs Cahills 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

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--- - ~ --- - - ------- ---- -- - - _shy~-

VARGUMENT

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 US Congress See

United States v Clasic 313 US2999

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 US and

Texas Constitutions the Voters Rights Act passed by Congress and the

Election Laws of the State of Texas

And in particular the Relators 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

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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 Relators Request for mandamus

Title 10 of the Texas Election Code sect 273061 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 SW2d 86 (Tex 1997)

and 924 SW2d 932 (Tex1996) 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 states 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 OBrien v Brown 409 US 1 92 SCt 271834 LEd2d 1 (1972)

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---shy - ---shy

Party Officer is subject to mandamus

Section 161009 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

163007 also states that these rules are enforceable by writ of mandamus

Section 174027 (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 161004 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 174027 and 161004

allowing access to these documents is the implied duty placed upon Mr

Bertuzzi

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CONCLUSION

The exhibits attached to this petition provide some evidence that the respondent violated the equal protection clause of the 14th amendment by CAltgttnn noffilal delenatAs ltgtt thAountv nnAntnn ltgtnd lnclurlng thAI~vUll115 UJ v lS t Ul II IlJ vVll V vi ltV J Ul Ul 1 l Ivi

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 PO Box 2641 Corpus Christi Texas 78403 Tel (361) 888-9255 Fax (361) 888-9288

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--- - --- - ---shy- -~-

IN THE SUPREME COURT OF TEXAS

IN RE VANESSA CAHILL

Relator

VERIFlCATION

STATE OF TEXAS sect sect

COUNTY OF NlJECES sect

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

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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

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~eIT A NUECES COUNTY REPUBLICAN PARTY aD Corpus 4458 South Staples

Christi Texas 78411

(361 ) 994-9317 (361 ) 994-9343 FAX E-Mail ncrpcctxgrandecomnet

Mike Bertuzzi-ehairman Rebecca Bradford---Vice Chairman Aneie 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 Saturday March 29

th 2008 The time is 1000 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 1000

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 am (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 partys 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 Morganmiddot Rd and go toward Leopard St Take a right on Leopard St then take

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OFFiCE OF THE SECRETARY OF 5T ATE

~Xvi[) A DFAN ITE CAfrrOl_ )~ ~ ro ~-~ fgt( G[)~ 261

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]url(~ 74 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 Credenshytials 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~ 103 sUbd 1 (V~r~cn Supp 1982)

Tn your letter you inquired hether a crc~denti-ls conrni ttee of (l pol itical pgtty convcT~Ii(Jn could altor lt1 delegation by 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 1334 (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

____- -e~~ ~bull ~Wl -- -middotr ___

Mr Edward M Sullivan Page 2

SUIvl1ARY

Tex Elee Code Ann art 1334 (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 ir

7

~ I~(yfh~__

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 John 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 1334 (Vernon Supp_ 1982) provides

the sale method fer the selection of delegates to county and

state convertions 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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Committee Information from vanessa cahill ltvanessafratilagmailcomgt hide details Mar 6 Beply

to michaeLbertuzzimlcom date Mar 62008411 PM

subject Committee Information mailed-by gmailcom

Mr Bertuzzi

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 soon be able to put a face to the nameas the saying goes

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 what better time to do so than the election season With all of the hype surrounding the Democratic race I think it is important for everyone in our party to get involved so we can retain the White House in November

I am very interested in volunteering my time in any way triat I can I would love to serve on any of the committees as well as attend the meetings of the committees that are already full If at all possible could you send me a list of these committes and the scheduled meeting dates and times In addition could you give me the phone numberslemail addresses of Art Granado and Victor Bird I believe they are heading up the Nominations and Resolutions Committees

Also if my services are also needed at the headquarters feel free to contact me

Thank you for your patience

Sincerely Vanessa 832-816-2944

~ Forward

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Request for Clarification Inbox

w vanessa cahill (Ni jdld Mar 16 Reply

Mr Bertuzzi

I would like to be sure that my recollection of our first telephone conversation is correct(March 6 2008) As per my memory I requested information on the dates 1imes and locations of the Credentials and Nominations Committees for Nueces County You then asked that I send my request in writing which I promptly did via email (March 6 2008) From the email attachment I received from Mike Bergsma (March 132008) I have made the reasonable assumption that you have opened and read my email request for this information

I would also like to clarify the second and last conversation we had over the telephone (March 12 2008) As per my memory you told me that you would not be providing to me the information I was requesting From what I understood your reluctance to provide the requested information to me stemmed from my affiliation with a local meetup group in which a fellow member Chuck Burnett voiced his opinions of local leadership in the Republican Party

I would also like clarification from you on the 14th Rule of the General Rules for All Conventions and Meetings of the Republican Party of Texas which states

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 to that convention

As a voter in the Republican Primary and a delegate in my precinct I would again like to request the dates times and locations for the following committees

Credentials Resolutions Rules and Nominations

In addition I would also like to request a copy of accurate written records (minutes) from every Precinct in Nueces County Please notify me when these copies have been completed and I will pick them up from the Republican Party Headquarters

Thank you for your time

( Newer 29 of 179 Older)

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httomailcooclecommaillui=1ampik=559db3fdOOampview=cvampsearch=sentampth=119c5ce2 5152008

err amp Cause No

VANESSA L CAHILL sect SUPREME COURT OF TEXAS

VS sect sect 201 W 14TH STREET RM 104 sect

NUECESCOUNTY sect AUSTIN TEXAS REPUBLICAN PARTY sect

sect REPUBLICAN PARTY OF TEXAS sect

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 ~~j)~A A it A

~ d i

~fS~~~i LINDA D ZEPEDA f ltJ r~~v Notary Public

~ bull STATE OF TEXAS ~

~~~l My Comm Exp 11262011I LOndo- P~CL~ V V V V

Printed Name

My commission expires 1-clt - 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 IIssrional d rllcctt l number of county Texas met at JMI+td Ge1-e-Ik __amp~ (location) on J-QQ f (date) to hold a precinct convention

1 Call to Order - I (I bull The convention was called to order by temporary chairman J) G( ( 1--~1 I----Th------------__ at 7 s-Opm

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~nelti~I1~911Igirttuen9~importantparjy decisions at subsequentcQnven~ions

3 Election of Permanent Officers The temporary chairman announced that nominations for permanent chairman of this precinct convention woUld be

acceh~~~tIlO~~ tft0ns were nominated as candidates --- shy

The convention elected baf SwtmiddotfI as permanent chairman of the precinct convention The convention elected =na~ 2- SOl r 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 Ill (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 ~ovention

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 beshe 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 reguiredPy Ryle 22 and the Election Code (1740270) 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~pm~_ 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

-i

f1 Precinct fl

0 EXIDBITB E Senate District 20 0 (l) List of DELEGATES elected to County I Senatorial District Convention (J

(J VOTERCERT PRINT NAME PRINT MAILING ADDRESS (l)

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First Ed i-~ MI JV1 Address 0 9gt 5~ La kevi t LAJ Pbo~ 30L - 334--lLA-Z- I JD3~3D 2D11 Last Srn ~~~ CitdSXDu5 ChiSt Zip 184-12 E-Mail

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PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

Page of ___

CONTACT INFO~1ATION

1-1 -334--124-2shy

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I

SQT FCause No

VANESSA L CAHILL sect SUPREME COURT OF TEXAS sect

VS sect 201 W 14TH STREET RM 104 sect

NUECESCOUNTY sect AUSTIN TEXAS REPUBLICAN PARTY sect

sect REPUBLICAN PARTY OF TEXAS sect

BUSINESS RECORDS AFFIDAVIT

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

hereto are an exact duplicate of the original

Further affiant sayeth not

~lffmiddotLnL KayLu

SUBSCRIBED AND SWORN TO before me on this May 6 2008 to which I place my

signature and official seal )dQampyM-u J11du~ Signature

dele Jampylt-pound 71LeAJ Printed Name

My commission expires 1 -J-d~tcf Notary Public for the State of Texas

VICKIE JOY VAN MAREN Notary Public

STATE OF TEXAS My Comm Exp 10-05-2008

MINUTES OF THE REPUBLICAN PARTY PRECINCT CONVENTION

CJ3 ed v~ ters a election precinct nymber 5~g senate district numt er congressional district LJmber of ~ county Texas met at -nK~ ~4A-ltj (Jccion) C1 __trh-ltl lcJV L- oog (date) to hold a precinct convent xf

- CI to Order _-~ J r(3-1e ionver-tion as called to order by temporary chairman _dM~1 at ~-pm

P~pararon 0 List of Participants ( -le mpoary cr airmin 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 _ (numJer) 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 P3rty of Texas Rules adopted in accordance with the Election Code Robert Rules of Order current dit en neNly re ised would govern parliamentary procedure The temporary chairman then explained how the actions of lis mvention auld influence important party decisions at subsequent convlntions

-hE~onvention Elected as permanent chairman of the precinct convention

-~ Election of DI~legates and Alternates to the County or State Senatorial DistrictConvention -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 alternats are listed in Exhibit C

5 tesolutions The gtermanent chairr1an 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

sdopted b a mcjority vote are included with these minutes

5 Other Business Ths permanent chairman then asked if there was any other business that shculd properly come before the convention

7 Announcemfnts 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 heshe would officially sign stal 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 (174027c) The chairman announced the time and place for the county or senatorial district cgtnvention

8 Adjournmen t In accordance vli~ha)motion properly moved and seconded and adopted by a majority vote the precinct convention was

ad~ed at iq pm I J fit~ -- ~-ed lZi Aft-t=

ermanent hairman ~ Secretary

Return to y)ur county chairman The permanent chairman should also IOpy and retain a record of all documents

PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

INSTRUCTIONS FOR THE PRECINCT CONVENTIONS

TIMEPLACE 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 700 pm and 900 pm 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 precincts 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 countysenatorial 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 Roberts 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 wwwtexasgoporg and click on the GOP Resources link

PREPARATION OF LIST OF QUALlFIED PARTICIPANTS Attendees must have voted in that precincts 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 heshe takes the chair and oversees the election of the permanent secretary If necessary the chairman and the secretary may be the same person

ANNOUNCEMENTOF COUNTYSENATORIAJ-PI~TRICT COflVENTION The convention will convene on Saturday March 29 th at IcY0cJ ~~ (time) in q76R kAfr-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 countysenatorial 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 countysenatorial 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 countysenatorial 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 countysenatorial 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

PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

Precinct GV gtPage I of -----L EXHIBIT A

Senate District __ List of qualified voters who ATTENDED precinct convention

VOTERCERT PRINT NAME PRINT MAILING ADDRESS CONTACT INFORMATION

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PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

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City Zip I E-Mail __1 Last 3 PR()VTnfD BY THE RFPHBUCAN PARTY OF TEXAS

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

partys political convention it involved relators 14th amendment rights and given

the limited time frame immediate court action is required

--- - - --shy

TABLE OF CONTENTS

IDENTITY OF PARTIES AND COUNSEL i

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

CERTIFICATE OF COMPLIANCE I0

TABLE OF CONTENTS ii

INDEX OF AUTHORITIES iii

STATEMENT OFTHE CASE iv

STATEMENT OF JURISDICTION v

ISSUE PRESENTED vi

STATEMENT OF FACTS 1

ARGUMENT 4

Importance of Case 4 Jurisdiction to accept Relators Request for Mandamus 5 Public Officer is subject to Mandamus 6

CONCLUSION 7

VERIFICATION 8

CERTIFICATE OF SERVICE 9

- 11 shy

--- - ---~

INDEX OF AUTHORITIES

CASES

Morse v Republican Party oj Virginia 517 US 186 (1996) 4

OBrien v BroHI1 409 US 1 92 SCt 2718 34 LEd2d 1 (1972) 5

Republican Party aTexas v Dietz SW2d 86 (Tex1997) and 924 SW2d 932

(Tex1996) 5

Republican Party aTexas 1 Dietz 940 SW2d 86 (Tex 1997) v

United States v Clasic 313 US2999 4

STATUTES

Texas Election Code

~ 273063(a) v

~ 273061 5

sect 174027 6 ~ 161004 6

sect 161009 v6

sect 163007 6

RULES

Texas Rule of Appellate Procedure 523(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 shy

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 andor refused such request

This court is being petitioned to enforce Respondants 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 ofdispute 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 shy

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 161009

Texas Election Code section 273063(a)

Texas Rule ofAppellate Procedure 523(e)

This courts opinion in Republican Party of Texas v Dietz 940 S W2d 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 states 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

-vshy

--- - - --- - - ----- ----~- ----- ~~-

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

-Vlshy

IV THE UNDISPUTED STATEMENT OF FACTS

Thefacts stated herein are supported bv the Cfidmit ofthe Relator

ciffidalits ofbusinesses record and party admissions Particular caution

lvas taken to insure the Texas Rules of Evidence were follmted

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 pJimary election

March 4 2008 Relator went to precinct 65s 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 shy

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

Bng HegtVJ Intrested I h0rng molVVIVnrlerl n middotheII Nu~~e~--UUIlLYr~ ~h llUVllllll Ul 1 --

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 chairmans 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 175870 and 121 (EXHIBITS EFGH) Mrs Cahill obtained a

- 2 shy

---- - - ---- - ------ --shy

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 gtvas

Mrs Cahills 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 shy

--- - ~ --- - - ------- ---- -- - - _shy~-

VARGUMENT

The importance of this case

Then the United States Supreme Court in Morse v Republican Party

~11middotImiddotamiddot~~ ()4 29 7 117 TT C 86 1996 ~~d~ m~rle n~ rlJfe----- t ow ~VJ ~uuu 17 - JjJ1 LJJbull l 11 J ~al II II au IV U 11 lC11lC 11 d

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 US Congress See

United States v Clasic 313 US2999

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 US and

Texas Constitutions the Voters Rights Act passed by Congress and the

Election Laws of the State of Texas

And in particular the Relators 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 shy

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 Relators Request for mandamus

Title 10 of the Texas Election Code sect 273061 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 SW2d 86 (Tex 1997)

and 924 SW2d 932 (Tex1996) 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 states 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 OBrien v Brown 409 US 1 92 SCt 271834 LEd2d 1 (1972)

- 5 shy

---shy - ---shy

Party Officer is subject to mandamus

Section 161009 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

163007 also states that these rules are enforceable by writ of mandamus

Section 174027 (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 161004 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 174027 and 161004

allowing access to these documents is the implied duty placed upon Mr

Bertuzzi

- 6 shy

--- shy ~ ----shy - ~~-~ ~----

CONCLUSION

The exhibits attached to this petition provide some evidence that the respondent violated the equal protection clause of the 14th amendment by CAltgttnn noffilal delenatAs ltgtt thAountv nnAntnn ltgtnd lnclurlng thAI~vUll115 UJ v lS t Ul II IlJ vVll V vi ltV J Ul Ul 1 l Ivi

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 PO Box 2641 Corpus Christi Texas 78403 Tel (361) 888-9255 Fax (361) 888-9288

- 7 shy

--- - --- - ---shy- -~-

IN THE SUPREME COURT OF TEXAS

IN RE VANESSA CAHILL

Relator

VERIFlCATION

STATE OF TEXAS sect sect

COUNTY OF NlJECES sect

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 shy

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 shy

~eIT A NUECES COUNTY REPUBLICAN PARTY aD Corpus 4458 South Staples

Christi Texas 78411

(361 ) 994-9317 (361 ) 994-9343 FAX E-Mail ncrpcctxgrandecomnet

Mike Bertuzzi-ehairman Rebecca Bradford---Vice Chairman Aneie 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 Saturday March 29

th 2008 The time is 1000 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 1000

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 am (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 partys 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 Morganmiddot Rd and go toward Leopard St Take a right on Leopard St then take

fJOT tlo Q

centlt~ o~+-

I~(~ ~~)~lk~~~-~~ -s ~ middot)oR

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~~

OFFiCE OF THE SECRETARY OF 5T ATE

~Xvi[) A DFAN ITE CAfrrOl_ )~ ~ ro ~-~ fgt( G[)~ 261

~ _ ~ ~ i 1L gt- A S - 1 ~

]url(~ 74 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 Credenshytials 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~ 103 sUbd 1 (V~r~cn Supp 1982)

Tn your letter you inquired hether a crc~denti-ls conrni ttee of (l pol itical pgtty convcT~Ii(Jn could altor lt1 delegation by 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 1334 (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

____- -e~~ ~bull ~Wl -- -middotr ___

Mr Edward M Sullivan Page 2

SUIvl1ARY

Tex Elee Code Ann art 1334 (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 ir

7

~ I~(yfh~__

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 John 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 1334 (Vernon Supp_ 1982) provides

the sale method fer the selection of delegates to county and

state convertions 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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Alex Haupt antoniofratila Robert Lund Benjamin Bernier dmedinaprudent John Falasca Kay Fischer Margaret Fratila Paul Hunt ronpaul-10

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Committee Information from vanessa cahill ltvanessafratilagmailcomgt hide details Mar 6 Beply

to michaeLbertuzzimlcom date Mar 62008411 PM

subject Committee Information mailed-by gmailcom

Mr Bertuzzi

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 soon be able to put a face to the nameas the saying goes

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 what better time to do so than the election season With all of the hype surrounding the Democratic race I think it is important for everyone in our party to get involved so we can retain the White House in November

I am very interested in volunteering my time in any way triat I can I would love to serve on any of the committees as well as attend the meetings of the committees that are already full If at all possible could you send me a list of these committes and the scheduled meeting dates and times In addition could you give me the phone numberslemail addresses of Art Granado and Victor Bird I believe they are heading up the Nominations and Resolutions Committees

Also if my services are also needed at the headquarters feel free to contact me

Thank you for your patience

Sincerely Vanessa 832-816-2944

~ Forward

bull vanessa cahill to jfalasca show details Apr 5 Beply

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Request for Clarification Inbox

w vanessa cahill (Ni jdld Mar 16 Reply

Mr Bertuzzi

I would like to be sure that my recollection of our first telephone conversation is correct(March 6 2008) As per my memory I requested information on the dates 1imes and locations of the Credentials and Nominations Committees for Nueces County You then asked that I send my request in writing which I promptly did via email (March 6 2008) From the email attachment I received from Mike Bergsma (March 132008) I have made the reasonable assumption that you have opened and read my email request for this information

I would also like to clarify the second and last conversation we had over the telephone (March 12 2008) As per my memory you told me that you would not be providing to me the information I was requesting From what I understood your reluctance to provide the requested information to me stemmed from my affiliation with a local meetup group in which a fellow member Chuck Burnett voiced his opinions of local leadership in the Republican Party

I would also like clarification from you on the 14th Rule of the General Rules for All Conventions and Meetings of the Republican Party of Texas which states

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 to that convention

As a voter in the Republican Primary and a delegate in my precinct I would again like to request the dates times and locations for the following committees

Credentials Resolutions Rules and Nominations

In addition I would also like to request a copy of accurate written records (minutes) from every Precinct in Nueces County Please notify me when these copies have been completed and I will pick them up from the Republican Party Headquarters

Thank you for your time

( Newer 29 of 179 Older)

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httomailcooclecommaillui=1ampik=559db3fdOOampview=cvampsearch=sentampth=119c5ce2 5152008

err amp Cause No

VANESSA L CAHILL sect SUPREME COURT OF TEXAS

VS sect sect 201 W 14TH STREET RM 104 sect

NUECESCOUNTY sect AUSTIN TEXAS REPUBLICAN PARTY sect

sect REPUBLICAN PARTY OF TEXAS sect

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 ~~j)~A A it A

~ d i

~fS~~~i LINDA D ZEPEDA f ltJ r~~v Notary Public

~ bull STATE OF TEXAS ~

~~~l My Comm Exp 11262011I LOndo- P~CL~ V V V V

Printed Name

My commission expires 1-clt - 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 IIssrional d rllcctt l number of county Texas met at JMI+td Ge1-e-Ik __amp~ (location) on J-QQ f (date) to hold a precinct convention

1 Call to Order - I (I bull The convention was called to order by temporary chairman J) G( ( 1--~1 I----Th------------__ at 7 s-Opm

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~nelti~I1~911Igirttuen9~importantparjy decisions at subsequentcQnven~ions

3 Election of Permanent Officers The temporary chairman announced that nominations for permanent chairman of this precinct convention woUld be

acceh~~~tIlO~~ tft0ns were nominated as candidates --- shy

The convention elected baf SwtmiddotfI as permanent chairman of the precinct convention The convention elected =na~ 2- SOl r 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 Ill (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 ~ovention

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 beshe 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 reguiredPy Ryle 22 and the Election Code (1740270) 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~pm~_ 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

-i

f1 Precinct fl

0 EXIDBITB E Senate District 20 0 (l) List of DELEGATES elected to County I Senatorial District Convention (J

(J VOTERCERT PRINT NAME PRINT MAILING ADDRESS (l)

Flm 1)~h1e- MI F Plmnc (J

Ad~b~5~ LakevleuJ~

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~ First l)arrv) 5171 MI 1 Add~ 4632 La kEV iev] - ~-9S5-0923 If1l E lzu~9737b9Z lAst 5th 1~ CillLoroUS Ch r is+( ZIp ~ 8412 E-Mail

First Ed i-~ MI JV1 Address 0 9gt 5~ La kevi t LAJ Pbo~ 30L - 334--lLA-Z- I JD3~3D 2D11 Last Srn ~~~ CitdSXDu5 ChiSt Zip 184-12 E-Mail

(J f (J First 1rL1 Address Pirone-i

f Lim On ZiD E-Mail11

M1 IA~~ Ift~~ Citf Zip EmiddotMlIll

MJ IAdm IPbo Cin Zip E-M81l

MI IA_ IPh~ Cih~ bull Zip E-II-fail

M~ 1--- 1-City Zip E-Mail

gtLL 1--- IPh Citf Zip E-Mail

gt~ 1-- 1 Poo~ City Zip E-Mail

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PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

Page of ___

CONTACT INFO~1ATION

1-1 -334--124-2shy

j I I

1 ~

I

SQT FCause No

VANESSA L CAHILL sect SUPREME COURT OF TEXAS sect

VS sect 201 W 14TH STREET RM 104 sect

NUECESCOUNTY sect AUSTIN TEXAS REPUBLICAN PARTY sect

sect REPUBLICAN PARTY OF TEXAS sect

BUSINESS RECORDS AFFIDAVIT

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

hereto are an exact duplicate of the original

Further affiant sayeth not

~lffmiddotLnL KayLu

SUBSCRIBED AND SWORN TO before me on this May 6 2008 to which I place my

signature and official seal )dQampyM-u J11du~ Signature

dele Jampylt-pound 71LeAJ Printed Name

My commission expires 1 -J-d~tcf Notary Public for the State of Texas

VICKIE JOY VAN MAREN Notary Public

STATE OF TEXAS My Comm Exp 10-05-2008

MINUTES OF THE REPUBLICAN PARTY PRECINCT CONVENTION

CJ3 ed v~ ters a election precinct nymber 5~g senate district numt er congressional district LJmber of ~ county Texas met at -nK~ ~4A-ltj (Jccion) C1 __trh-ltl lcJV L- oog (date) to hold a precinct convent xf

- CI to Order _-~ J r(3-1e ionver-tion as called to order by temporary chairman _dM~1 at ~-pm

P~pararon 0 List of Participants ( -le mpoary cr airmin 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 _ (numJer) 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 P3rty of Texas Rules adopted in accordance with the Election Code Robert Rules of Order current dit en neNly re ised would govern parliamentary procedure The temporary chairman then explained how the actions of lis mvention auld influence important party decisions at subsequent convlntions

-hE~onvention Elected as permanent chairman of the precinct convention

-~ Election of DI~legates and Alternates to the County or State Senatorial DistrictConvention -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 alternats are listed in Exhibit C

5 tesolutions The gtermanent chairr1an 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

sdopted b a mcjority vote are included with these minutes

5 Other Business Ths permanent chairman then asked if there was any other business that shculd properly come before the convention

7 Announcemfnts 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 heshe would officially sign stal 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 (174027c) The chairman announced the time and place for the county or senatorial district cgtnvention

8 Adjournmen t In accordance vli~ha)motion properly moved and seconded and adopted by a majority vote the precinct convention was

ad~ed at iq pm I J fit~ -- ~-ed lZi Aft-t=

ermanent hairman ~ Secretary

Return to y)ur county chairman The permanent chairman should also IOpy and retain a record of all documents

PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

INSTRUCTIONS FOR THE PRECINCT CONVENTIONS

TIMEPLACE 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 700 pm and 900 pm 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 precincts 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 countysenatorial 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 Roberts 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 wwwtexasgoporg and click on the GOP Resources link

PREPARATION OF LIST OF QUALlFIED PARTICIPANTS Attendees must have voted in that precincts 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 heshe takes the chair and oversees the election of the permanent secretary If necessary the chairman and the secretary may be the same person

ANNOUNCEMENTOF COUNTYSENATORIAJ-PI~TRICT COflVENTION The convention will convene on Saturday March 29 th at IcY0cJ ~~ (time) in q76R kAfr-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 countysenatorial 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 countysenatorial 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 countysenatorial 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 countysenatorial 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

PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

Precinct GV gtPage I of -----L EXHIBIT A

Senate District __ List of qualified voters who ATTENDED precinct convention

VOTERCERT PRINT NAME PRINT MAILING ADDRESS CONTACT INFORMATION

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TABLE OF CONTENTS

IDENTITY OF PARTIES AND COUNSEL i

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

CERTIFICATE OF COMPLIANCE I0

TABLE OF CONTENTS ii

INDEX OF AUTHORITIES iii

STATEMENT OFTHE CASE iv

STATEMENT OF JURISDICTION v

ISSUE PRESENTED vi

STATEMENT OF FACTS 1

ARGUMENT 4

Importance of Case 4 Jurisdiction to accept Relators Request for Mandamus 5 Public Officer is subject to Mandamus 6

CONCLUSION 7

VERIFICATION 8

CERTIFICATE OF SERVICE 9

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--- - ---~

INDEX OF AUTHORITIES

CASES

Morse v Republican Party oj Virginia 517 US 186 (1996) 4

OBrien v BroHI1 409 US 1 92 SCt 2718 34 LEd2d 1 (1972) 5

Republican Party aTexas v Dietz SW2d 86 (Tex1997) and 924 SW2d 932

(Tex1996) 5

Republican Party aTexas 1 Dietz 940 SW2d 86 (Tex 1997) v

United States v Clasic 313 US2999 4

STATUTES

Texas Election Code

~ 273063(a) v

~ 273061 5

sect 174027 6 ~ 161004 6

sect 161009 v6

sect 163007 6

RULES

Texas Rule of Appellate Procedure 523(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

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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 andor refused such request

This court is being petitioned to enforce Respondants 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 ofdispute 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

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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 161009

Texas Election Code section 273063(a)

Texas Rule ofAppellate Procedure 523(e)

This courts opinion in Republican Party of Texas v Dietz 940 S W2d 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 states 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

-vshy

--- - - --- - - ----- ----~- ----- ~~-

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

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IV THE UNDISPUTED STATEMENT OF FACTS

Thefacts stated herein are supported bv the Cfidmit ofthe Relator

ciffidalits ofbusinesses record and party admissions Particular caution

lvas taken to insure the Texas Rules of Evidence were follmted

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 pJimary election

March 4 2008 Relator went to precinct 65s 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

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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

Bng HegtVJ Intrested I h0rng molVVIVnrlerl n middotheII Nu~~e~--UUIlLYr~ ~h llUVllllll Ul 1 --

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 chairmans 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 175870 and 121 (EXHIBITS EFGH) Mrs Cahill obtained a

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---- - - ---- - ------ --shy

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 gtvas

Mrs Cahills 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

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--- - ~ --- - - ------- ---- -- - - _shy~-

VARGUMENT

The importance of this case

Then the United States Supreme Court in Morse v Republican Party

~11middotImiddotamiddot~~ ()4 29 7 117 TT C 86 1996 ~~d~ m~rle n~ rlJfe----- t ow ~VJ ~uuu 17 - JjJ1 LJJbull l 11 J ~al II II au IV U 11 lC11lC 11 d

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 US Congress See

United States v Clasic 313 US2999

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 US and

Texas Constitutions the Voters Rights Act passed by Congress and the

Election Laws of the State of Texas

And in particular the Relators 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

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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 Relators Request for mandamus

Title 10 of the Texas Election Code sect 273061 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 SW2d 86 (Tex 1997)

and 924 SW2d 932 (Tex1996) 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 states 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 OBrien v Brown 409 US 1 92 SCt 271834 LEd2d 1 (1972)

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---shy - ---shy

Party Officer is subject to mandamus

Section 161009 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

163007 also states that these rules are enforceable by writ of mandamus

Section 174027 (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 161004 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 174027 and 161004

allowing access to these documents is the implied duty placed upon Mr

Bertuzzi

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--- shy ~ ----shy - ~~-~ ~----

CONCLUSION

The exhibits attached to this petition provide some evidence that the respondent violated the equal protection clause of the 14th amendment by CAltgttnn noffilal delenatAs ltgtt thAountv nnAntnn ltgtnd lnclurlng thAI~vUll115 UJ v lS t Ul II IlJ vVll V vi ltV J Ul Ul 1 l Ivi

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 PO Box 2641 Corpus Christi Texas 78403 Tel (361) 888-9255 Fax (361) 888-9288

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--- - --- - ---shy- -~-

IN THE SUPREME COURT OF TEXAS

IN RE VANESSA CAHILL

Relator

VERIFlCATION

STATE OF TEXAS sect sect

COUNTY OF NlJECES sect

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

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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

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~eIT A NUECES COUNTY REPUBLICAN PARTY aD Corpus 4458 South Staples

Christi Texas 78411

(361 ) 994-9317 (361 ) 994-9343 FAX E-Mail ncrpcctxgrandecomnet

Mike Bertuzzi-ehairman Rebecca Bradford---Vice Chairman Aneie 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 Saturday March 29

th 2008 The time is 1000 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 1000

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 am (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 partys 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 Morganmiddot Rd and go toward Leopard St Take a right on Leopard St then take

fJOT tlo Q

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OFFiCE OF THE SECRETARY OF 5T ATE

~Xvi[) A DFAN ITE CAfrrOl_ )~ ~ ro ~-~ fgt( G[)~ 261

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]url(~ 74 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 Credenshytials 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~ 103 sUbd 1 (V~r~cn Supp 1982)

Tn your letter you inquired hether a crc~denti-ls conrni ttee of (l pol itical pgtty convcT~Ii(Jn could altor lt1 delegation by 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 1334 (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

____- -e~~ ~bull ~Wl -- -middotr ___

Mr Edward M Sullivan Page 2

SUIvl1ARY

Tex Elee Code Ann art 1334 (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 ir

7

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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 John 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 1334 (Vernon Supp_ 1982) provides

the sale method fer the selection of delegates to county and

state convertions 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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Alex Haupt antoniofratila Robert Lund Benjamin Bernier dmedinaprudent John Falasca Kay Fischer Margaret Fratila Paul Hunt ronpaul-10

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Committee Information from vanessa cahill ltvanessafratilagmailcomgt hide details Mar 6 Beply

to michaeLbertuzzimlcom date Mar 62008411 PM

subject Committee Information mailed-by gmailcom

Mr Bertuzzi

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 soon be able to put a face to the nameas the saying goes

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 what better time to do so than the election season With all of the hype surrounding the Democratic race I think it is important for everyone in our party to get involved so we can retain the White House in November

I am very interested in volunteering my time in any way triat I can I would love to serve on any of the committees as well as attend the meetings of the committees that are already full If at all possible could you send me a list of these committes and the scheduled meeting dates and times In addition could you give me the phone numberslemail addresses of Art Granado and Victor Bird I believe they are heading up the Nominations and Resolutions Committees

Also if my services are also needed at the headquarters feel free to contact me

Thank you for your patience

Sincerely Vanessa 832-816-2944

~ Forward

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Request for Clarification Inbox

w vanessa cahill (Ni jdld Mar 16 Reply

Mr Bertuzzi

I would like to be sure that my recollection of our first telephone conversation is correct(March 6 2008) As per my memory I requested information on the dates 1imes and locations of the Credentials and Nominations Committees for Nueces County You then asked that I send my request in writing which I promptly did via email (March 6 2008) From the email attachment I received from Mike Bergsma (March 132008) I have made the reasonable assumption that you have opened and read my email request for this information

I would also like to clarify the second and last conversation we had over the telephone (March 12 2008) As per my memory you told me that you would not be providing to me the information I was requesting From what I understood your reluctance to provide the requested information to me stemmed from my affiliation with a local meetup group in which a fellow member Chuck Burnett voiced his opinions of local leadership in the Republican Party

I would also like clarification from you on the 14th Rule of the General Rules for All Conventions and Meetings of the Republican Party of Texas which states

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 to that convention

As a voter in the Republican Primary and a delegate in my precinct I would again like to request the dates times and locations for the following committees

Credentials Resolutions Rules and Nominations

In addition I would also like to request a copy of accurate written records (minutes) from every Precinct in Nueces County Please notify me when these copies have been completed and I will pick them up from the Republican Party Headquarters

Thank you for your time

( Newer 29 of 179 Older)

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VANESSA L CAHILL sect SUPREME COURT OF TEXAS

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NUECESCOUNTY sect AUSTIN TEXAS REPUBLICAN PARTY sect

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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 ~~j)~A A it A

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~ bull STATE OF TEXAS ~

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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 IIssrional d rllcctt l number of county Texas met at JMI+td Ge1-e-Ik __amp~ (location) on J-QQ f (date) to hold a precinct convention

1 Call to Order - I (I bull The convention was called to order by temporary chairman J) G( ( 1--~1 I----Th------------__ at 7 s-Opm

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~nelti~I1~911Igirttuen9~importantparjy decisions at subsequentcQnven~ions

3 Election of Permanent Officers The temporary chairman announced that nominations for permanent chairman of this precinct convention woUld be

acceh~~~tIlO~~ tft0ns were nominated as candidates --- shy

The convention elected baf SwtmiddotfI as permanent chairman of the precinct convention The convention elected =na~ 2- SOl r 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 Ill (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 ~ovention

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 beshe 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 reguiredPy Ryle 22 and the Election Code (1740270) 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~pm~_ 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

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PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

Page of ___

CONTACT INFO~1ATION

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SQT FCause No

VANESSA L CAHILL sect SUPREME COURT OF TEXAS sect

VS sect 201 W 14TH STREET RM 104 sect

NUECESCOUNTY sect AUSTIN TEXAS REPUBLICAN PARTY sect

sect REPUBLICAN PARTY OF TEXAS sect

BUSINESS RECORDS AFFIDAVIT

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

hereto are an exact duplicate of the original

Further affiant sayeth not

~lffmiddotLnL KayLu

SUBSCRIBED AND SWORN TO before me on this May 6 2008 to which I place my

signature and official seal )dQampyM-u J11du~ Signature

dele Jampylt-pound 71LeAJ Printed Name

My commission expires 1 -J-d~tcf Notary Public for the State of Texas

VICKIE JOY VAN MAREN Notary Public

STATE OF TEXAS My Comm Exp 10-05-2008

MINUTES OF THE REPUBLICAN PARTY PRECINCT CONVENTION

CJ3 ed v~ ters a election precinct nymber 5~g senate district numt er congressional district LJmber of ~ county Texas met at -nK~ ~4A-ltj (Jccion) C1 __trh-ltl lcJV L- oog (date) to hold a precinct convent xf

- CI to Order _-~ J r(3-1e ionver-tion as called to order by temporary chairman _dM~1 at ~-pm

P~pararon 0 List of Participants ( -le mpoary cr airmin 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 _ (numJer) 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 P3rty of Texas Rules adopted in accordance with the Election Code Robert Rules of Order current dit en neNly re ised would govern parliamentary procedure The temporary chairman then explained how the actions of lis mvention auld influence important party decisions at subsequent convlntions

-hE~onvention Elected as permanent chairman of the precinct convention

-~ Election of DI~legates and Alternates to the County or State Senatorial DistrictConvention -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 alternats are listed in Exhibit C

5 tesolutions The gtermanent chairr1an 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

sdopted b a mcjority vote are included with these minutes

5 Other Business Ths permanent chairman then asked if there was any other business that shculd properly come before the convention

7 Announcemfnts 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 heshe would officially sign stal 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 (174027c) The chairman announced the time and place for the county or senatorial district cgtnvention

8 Adjournmen t In accordance vli~ha)motion properly moved and seconded and adopted by a majority vote the precinct convention was

ad~ed at iq pm I J fit~ -- ~-ed lZi Aft-t=

ermanent hairman ~ Secretary

Return to y)ur county chairman The permanent chairman should also IOpy and retain a record of all documents

PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

INSTRUCTIONS FOR THE PRECINCT CONVENTIONS

TIMEPLACE 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 700 pm and 900 pm 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 precincts 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 countysenatorial 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 Roberts 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 wwwtexasgoporg and click on the GOP Resources link

PREPARATION OF LIST OF QUALlFIED PARTICIPANTS Attendees must have voted in that precincts 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 heshe takes the chair and oversees the election of the permanent secretary If necessary the chairman and the secretary may be the same person

ANNOUNCEMENTOF COUNTYSENATORIAJ-PI~TRICT COflVENTION The convention will convene on Saturday March 29 th at IcY0cJ ~~ (time) in q76R kAfr-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 countysenatorial 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 countysenatorial 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 countysenatorial 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 countysenatorial 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

PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

Precinct GV gtPage I of -----L EXHIBIT A

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INDEX OF AUTHORITIES

CASES

Morse v Republican Party oj Virginia 517 US 186 (1996) 4

OBrien v BroHI1 409 US 1 92 SCt 2718 34 LEd2d 1 (1972) 5

Republican Party aTexas v Dietz SW2d 86 (Tex1997) and 924 SW2d 932

(Tex1996) 5

Republican Party aTexas 1 Dietz 940 SW2d 86 (Tex 1997) v

United States v Clasic 313 US2999 4

STATUTES

Texas Election Code

~ 273063(a) v

~ 273061 5

sect 174027 6 ~ 161004 6

sect 161009 v6

sect 163007 6

RULES

Texas Rule of Appellate Procedure 523(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

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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 andor refused such request

This court is being petitioned to enforce Respondants 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 ofdispute 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

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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 161009

Texas Election Code section 273063(a)

Texas Rule ofAppellate Procedure 523(e)

This courts opinion in Republican Party of Texas v Dietz 940 S W2d 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 states 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

-vshy

--- - - --- - - ----- ----~- ----- ~~-

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

-Vlshy

IV THE UNDISPUTED STATEMENT OF FACTS

Thefacts stated herein are supported bv the Cfidmit ofthe Relator

ciffidalits ofbusinesses record and party admissions Particular caution

lvas taken to insure the Texas Rules of Evidence were follmted

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 pJimary election

March 4 2008 Relator went to precinct 65s 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

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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

Bng HegtVJ Intrested I h0rng molVVIVnrlerl n middotheII Nu~~e~--UUIlLYr~ ~h llUVllllll Ul 1 --

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 chairmans 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 175870 and 121 (EXHIBITS EFGH) Mrs Cahill obtained a

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---- - - ---- - ------ --shy

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 gtvas

Mrs Cahills 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

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--- - ~ --- - - ------- ---- -- - - _shy~-

VARGUMENT

The importance of this case

Then the United States Supreme Court in Morse v Republican Party

~11middotImiddotamiddot~~ ()4 29 7 117 TT C 86 1996 ~~d~ m~rle n~ rlJfe----- t ow ~VJ ~uuu 17 - JjJ1 LJJbull l 11 J ~al II II au IV U 11 lC11lC 11 d

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 US Congress See

United States v Clasic 313 US2999

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 US and

Texas Constitutions the Voters Rights Act passed by Congress and the

Election Laws of the State of Texas

And in particular the Relators 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

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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 Relators Request for mandamus

Title 10 of the Texas Election Code sect 273061 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 SW2d 86 (Tex 1997)

and 924 SW2d 932 (Tex1996) 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 states 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 OBrien v Brown 409 US 1 92 SCt 271834 LEd2d 1 (1972)

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---shy - ---shy

Party Officer is subject to mandamus

Section 161009 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

163007 also states that these rules are enforceable by writ of mandamus

Section 174027 (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 161004 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 174027 and 161004

allowing access to these documents is the implied duty placed upon Mr

Bertuzzi

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--- shy ~ ----shy - ~~-~ ~----

CONCLUSION

The exhibits attached to this petition provide some evidence that the respondent violated the equal protection clause of the 14th amendment by CAltgttnn noffilal delenatAs ltgtt thAountv nnAntnn ltgtnd lnclurlng thAI~vUll115 UJ v lS t Ul II IlJ vVll V vi ltV J Ul Ul 1 l Ivi

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 PO Box 2641 Corpus Christi Texas 78403 Tel (361) 888-9255 Fax (361) 888-9288

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--- - --- - ---shy- -~-

IN THE SUPREME COURT OF TEXAS

IN RE VANESSA CAHILL

Relator

VERIFlCATION

STATE OF TEXAS sect sect

COUNTY OF NlJECES sect

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

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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

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~eIT A NUECES COUNTY REPUBLICAN PARTY aD Corpus 4458 South Staples

Christi Texas 78411

(361 ) 994-9317 (361 ) 994-9343 FAX E-Mail ncrpcctxgrandecomnet

Mike Bertuzzi-ehairman Rebecca Bradford---Vice Chairman Aneie 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 Saturday March 29

th 2008 The time is 1000 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 1000

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 am (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 partys 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 Morganmiddot Rd and go toward Leopard St Take a right on Leopard St then take

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OFFiCE OF THE SECRETARY OF 5T ATE

~Xvi[) A DFAN ITE CAfrrOl_ )~ ~ ro ~-~ fgt( G[)~ 261

~ _ ~ ~ i 1L gt- A S - 1 ~

]url(~ 74 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 Credenshytials 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~ 103 sUbd 1 (V~r~cn Supp 1982)

Tn your letter you inquired hether a crc~denti-ls conrni ttee of (l pol itical pgtty convcT~Ii(Jn could altor lt1 delegation by 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 1334 (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

____- -e~~ ~bull ~Wl -- -middotr ___

Mr Edward M Sullivan Page 2

SUIvl1ARY

Tex Elee Code Ann art 1334 (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 ir

7

~ I~(yfh~__

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 John 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 1334 (Vernon Supp_ 1982) provides

the sale method fer the selection of delegates to county and

state convertions 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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Alex Haupt antoniofratila Robert Lund Benjamin Bernier dmedinaprudent John Falasca Kay Fischer Margaret Fratila Paul Hunt ronpaul-10

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Committee Information from vanessa cahill ltvanessafratilagmailcomgt hide details Mar 6 Beply

to michaeLbertuzzimlcom date Mar 62008411 PM

subject Committee Information mailed-by gmailcom

Mr Bertuzzi

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 soon be able to put a face to the nameas the saying goes

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 what better time to do so than the election season With all of the hype surrounding the Democratic race I think it is important for everyone in our party to get involved so we can retain the White House in November

I am very interested in volunteering my time in any way triat I can I would love to serve on any of the committees as well as attend the meetings of the committees that are already full If at all possible could you send me a list of these committes and the scheduled meeting dates and times In addition could you give me the phone numberslemail addresses of Art Granado and Victor Bird I believe they are heading up the Nominations and Resolutions Committees

Also if my services are also needed at the headquarters feel free to contact me

Thank you for your patience

Sincerely Vanessa 832-816-2944

~ Forward

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Request for Clarification Inbox

w vanessa cahill (Ni jdld Mar 16 Reply

Mr Bertuzzi

I would like to be sure that my recollection of our first telephone conversation is correct(March 6 2008) As per my memory I requested information on the dates 1imes and locations of the Credentials and Nominations Committees for Nueces County You then asked that I send my request in writing which I promptly did via email (March 6 2008) From the email attachment I received from Mike Bergsma (March 132008) I have made the reasonable assumption that you have opened and read my email request for this information

I would also like to clarify the second and last conversation we had over the telephone (March 12 2008) As per my memory you told me that you would not be providing to me the information I was requesting From what I understood your reluctance to provide the requested information to me stemmed from my affiliation with a local meetup group in which a fellow member Chuck Burnett voiced his opinions of local leadership in the Republican Party

I would also like clarification from you on the 14th Rule of the General Rules for All Conventions and Meetings of the Republican Party of Texas which states

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 to that convention

As a voter in the Republican Primary and a delegate in my precinct I would again like to request the dates times and locations for the following committees

Credentials Resolutions Rules and Nominations

In addition I would also like to request a copy of accurate written records (minutes) from every Precinct in Nueces County Please notify me when these copies have been completed and I will pick them up from the Republican Party Headquarters

Thank you for your time

( Newer 29 of 179 Older)

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httomailcooclecommaillui=1ampik=559db3fdOOampview=cvampsearch=sentampth=119c5ce2 5152008

err amp Cause No

VANESSA L CAHILL sect SUPREME COURT OF TEXAS

VS sect sect 201 W 14TH STREET RM 104 sect

NUECESCOUNTY sect AUSTIN TEXAS REPUBLICAN PARTY sect

sect REPUBLICAN PARTY OF TEXAS sect

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 ~~j)~A A it A

~ d i

~fS~~~i LINDA D ZEPEDA f ltJ r~~v Notary Public

~ bull STATE OF TEXAS ~

~~~l My Comm Exp 11262011I LOndo- P~CL~ V V V V

Printed Name

My commission expires 1-clt - 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 IIssrional d rllcctt l number of county Texas met at JMI+td Ge1-e-Ik __amp~ (location) on J-QQ f (date) to hold a precinct convention

1 Call to Order - I (I bull The convention was called to order by temporary chairman J) G( ( 1--~1 I----Th------------__ at 7 s-Opm

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~nelti~I1~911Igirttuen9~importantparjy decisions at subsequentcQnven~ions

3 Election of Permanent Officers The temporary chairman announced that nominations for permanent chairman of this precinct convention woUld be

acceh~~~tIlO~~ tft0ns were nominated as candidates --- shy

The convention elected baf SwtmiddotfI as permanent chairman of the precinct convention The convention elected =na~ 2- SOl r 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 Ill (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 ~ovention

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 beshe 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 reguiredPy Ryle 22 and the Election Code (1740270) 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~pm~_ 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

-i

f1 Precinct fl

0 EXIDBITB E Senate District 20 0 (l) List of DELEGATES elected to County I Senatorial District Convention (J

(J VOTERCERT PRINT NAME PRINT MAILING ADDRESS (l)

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First Ed i-~ MI JV1 Address 0 9gt 5~ La kevi t LAJ Pbo~ 30L - 334--lLA-Z- I JD3~3D 2D11 Last Srn ~~~ CitdSXDu5 ChiSt Zip 184-12 E-Mail

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PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

Page of ___

CONTACT INFO~1ATION

1-1 -334--124-2shy

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I

SQT FCause No

VANESSA L CAHILL sect SUPREME COURT OF TEXAS sect

VS sect 201 W 14TH STREET RM 104 sect

NUECESCOUNTY sect AUSTIN TEXAS REPUBLICAN PARTY sect

sect REPUBLICAN PARTY OF TEXAS sect

BUSINESS RECORDS AFFIDAVIT

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

hereto are an exact duplicate of the original

Further affiant sayeth not

~lffmiddotLnL KayLu

SUBSCRIBED AND SWORN TO before me on this May 6 2008 to which I place my

signature and official seal )dQampyM-u J11du~ Signature

dele Jampylt-pound 71LeAJ Printed Name

My commission expires 1 -J-d~tcf Notary Public for the State of Texas

VICKIE JOY VAN MAREN Notary Public

STATE OF TEXAS My Comm Exp 10-05-2008

MINUTES OF THE REPUBLICAN PARTY PRECINCT CONVENTION

CJ3 ed v~ ters a election precinct nymber 5~g senate district numt er congressional district LJmber of ~ county Texas met at -nK~ ~4A-ltj (Jccion) C1 __trh-ltl lcJV L- oog (date) to hold a precinct convent xf

- CI to Order _-~ J r(3-1e ionver-tion as called to order by temporary chairman _dM~1 at ~-pm

P~pararon 0 List of Participants ( -le mpoary cr airmin 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 _ (numJer) 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 P3rty of Texas Rules adopted in accordance with the Election Code Robert Rules of Order current dit en neNly re ised would govern parliamentary procedure The temporary chairman then explained how the actions of lis mvention auld influence important party decisions at subsequent convlntions

-hE~onvention Elected as permanent chairman of the precinct convention

-~ Election of DI~legates and Alternates to the County or State Senatorial DistrictConvention -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 alternats are listed in Exhibit C

5 tesolutions The gtermanent chairr1an 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

sdopted b a mcjority vote are included with these minutes

5 Other Business Ths permanent chairman then asked if there was any other business that shculd properly come before the convention

7 Announcemfnts 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 heshe would officially sign stal 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 (174027c) The chairman announced the time and place for the county or senatorial district cgtnvention

8 Adjournmen t In accordance vli~ha)motion properly moved and seconded and adopted by a majority vote the precinct convention was

ad~ed at iq pm I J fit~ -- ~-ed lZi Aft-t=

ermanent hairman ~ Secretary

Return to y)ur county chairman The permanent chairman should also IOpy and retain a record of all documents

PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

INSTRUCTIONS FOR THE PRECINCT CONVENTIONS

TIMEPLACE 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 700 pm and 900 pm 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 precincts 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 countysenatorial 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 Roberts 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 wwwtexasgoporg and click on the GOP Resources link

PREPARATION OF LIST OF QUALlFIED PARTICIPANTS Attendees must have voted in that precincts 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 heshe takes the chair and oversees the election of the permanent secretary If necessary the chairman and the secretary may be the same person

ANNOUNCEMENTOF COUNTYSENATORIAJ-PI~TRICT COflVENTION The convention will convene on Saturday March 29 th at IcY0cJ ~~ (time) in q76R kAfr-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 countysenatorial 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 countysenatorial 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 countysenatorial 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 countysenatorial 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

PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

Precinct GV gtPage I of -----L EXHIBIT A

Senate District __ List of qualified voters who ATTENDED precinct convention

VOTERCERT PRINT NAME PRINT MAILING ADDRESS CONTACT INFORMATION

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PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

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City Zip I E-Mail __1 Last 3 PR()VTnfD BY THE RFPHBUCAN PARTY OF TEXAS

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 andor refused such request

This court is being petitioned to enforce Respondants 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 ofdispute 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 shy

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 161009

Texas Election Code section 273063(a)

Texas Rule ofAppellate Procedure 523(e)

This courts opinion in Republican Party of Texas v Dietz 940 S W2d 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 states 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

-vshy

--- - - --- - - ----- ----~- ----- ~~-

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

-Vlshy

IV THE UNDISPUTED STATEMENT OF FACTS

Thefacts stated herein are supported bv the Cfidmit ofthe Relator

ciffidalits ofbusinesses record and party admissions Particular caution

lvas taken to insure the Texas Rules of Evidence were follmted

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 pJimary election

March 4 2008 Relator went to precinct 65s 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 shy

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

Bng HegtVJ Intrested I h0rng molVVIVnrlerl n middotheII Nu~~e~--UUIlLYr~ ~h llUVllllll Ul 1 --

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 chairmans 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 175870 and 121 (EXHIBITS EFGH) Mrs Cahill obtained a

- 2 shy

---- - - ---- - ------ --shy

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 gtvas

Mrs Cahills 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 shy

--- - ~ --- - - ------- ---- -- - - _shy~-

VARGUMENT

The importance of this case

Then the United States Supreme Court in Morse v Republican Party

~11middotImiddotamiddot~~ ()4 29 7 117 TT C 86 1996 ~~d~ m~rle n~ rlJfe----- t ow ~VJ ~uuu 17 - JjJ1 LJJbull l 11 J ~al II II au IV U 11 lC11lC 11 d

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 US Congress See

United States v Clasic 313 US2999

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 US and

Texas Constitutions the Voters Rights Act passed by Congress and the

Election Laws of the State of Texas

And in particular the Relators 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 shy

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 Relators Request for mandamus

Title 10 of the Texas Election Code sect 273061 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 SW2d 86 (Tex 1997)

and 924 SW2d 932 (Tex1996) 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 states 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 OBrien v Brown 409 US 1 92 SCt 271834 LEd2d 1 (1972)

- 5 shy

---shy - ---shy

Party Officer is subject to mandamus

Section 161009 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

163007 also states that these rules are enforceable by writ of mandamus

Section 174027 (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 161004 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 174027 and 161004

allowing access to these documents is the implied duty placed upon Mr

Bertuzzi

- 6 shy

--- shy ~ ----shy - ~~-~ ~----

CONCLUSION

The exhibits attached to this petition provide some evidence that the respondent violated the equal protection clause of the 14th amendment by CAltgttnn noffilal delenatAs ltgtt thAountv nnAntnn ltgtnd lnclurlng thAI~vUll115 UJ v lS t Ul II IlJ vVll V vi ltV J Ul Ul 1 l Ivi

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 PO Box 2641 Corpus Christi Texas 78403 Tel (361) 888-9255 Fax (361) 888-9288

- 7 shy

--- - --- - ---shy- -~-

IN THE SUPREME COURT OF TEXAS

IN RE VANESSA CAHILL

Relator

VERIFlCATION

STATE OF TEXAS sect sect

COUNTY OF NlJECES sect

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 shy

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 shy

~eIT A NUECES COUNTY REPUBLICAN PARTY aD Corpus 4458 South Staples

Christi Texas 78411

(361 ) 994-9317 (361 ) 994-9343 FAX E-Mail ncrpcctxgrandecomnet

Mike Bertuzzi-ehairman Rebecca Bradford---Vice Chairman Aneie 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 Saturday March 29

th 2008 The time is 1000 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 1000

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 am (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 partys 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 Morganmiddot Rd and go toward Leopard St Take a right on Leopard St then take

fJOT tlo Q

centlt~ o~+-

I~(~ ~~)~lk~~~-~~ -s ~ middot)oR

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~~

OFFiCE OF THE SECRETARY OF 5T ATE

~Xvi[) A DFAN ITE CAfrrOl_ )~ ~ ro ~-~ fgt( G[)~ 261

~ _ ~ ~ i 1L gt- A S - 1 ~

]url(~ 74 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 Credenshytials 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~ 103 sUbd 1 (V~r~cn Supp 1982)

Tn your letter you inquired hether a crc~denti-ls conrni ttee of (l pol itical pgtty convcT~Ii(Jn could altor lt1 delegation by 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 1334 (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

____- -e~~ ~bull ~Wl -- -middotr ___

Mr Edward M Sullivan Page 2

SUIvl1ARY

Tex Elee Code Ann art 1334 (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 ir

7

~ I~(yfh~__

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 John 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 1334 (Vernon Supp_ 1982) provides

the sale method fer the selection of delegates to county and

state convertions 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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Alex Haupt antoniofratila Robert Lund Benjamin Bernier dmedinaprudent John Falasca Kay Fischer Margaret Fratila Paul Hunt ronpaul-10

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Committee Information from vanessa cahill ltvanessafratilagmailcomgt hide details Mar 6 Beply

to michaeLbertuzzimlcom date Mar 62008411 PM

subject Committee Information mailed-by gmailcom

Mr Bertuzzi

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 soon be able to put a face to the nameas the saying goes

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 what better time to do so than the election season With all of the hype surrounding the Democratic race I think it is important for everyone in our party to get involved so we can retain the White House in November

I am very interested in volunteering my time in any way triat I can I would love to serve on any of the committees as well as attend the meetings of the committees that are already full If at all possible could you send me a list of these committes and the scheduled meeting dates and times In addition could you give me the phone numberslemail addresses of Art Granado and Victor Bird I believe they are heading up the Nominations and Resolutions Committees

Also if my services are also needed at the headquarters feel free to contact me

Thank you for your patience

Sincerely Vanessa 832-816-2944

~ Forward

bull vanessa cahill to jfalasca show details Apr 5 Beply

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Request for Clarification Inbox

w vanessa cahill (Ni jdld Mar 16 Reply

Mr Bertuzzi

I would like to be sure that my recollection of our first telephone conversation is correct(March 6 2008) As per my memory I requested information on the dates 1imes and locations of the Credentials and Nominations Committees for Nueces County You then asked that I send my request in writing which I promptly did via email (March 6 2008) From the email attachment I received from Mike Bergsma (March 132008) I have made the reasonable assumption that you have opened and read my email request for this information

I would also like to clarify the second and last conversation we had over the telephone (March 12 2008) As per my memory you told me that you would not be providing to me the information I was requesting From what I understood your reluctance to provide the requested information to me stemmed from my affiliation with a local meetup group in which a fellow member Chuck Burnett voiced his opinions of local leadership in the Republican Party

I would also like clarification from you on the 14th Rule of the General Rules for All Conventions and Meetings of the Republican Party of Texas which states

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 to that convention

As a voter in the Republican Primary and a delegate in my precinct I would again like to request the dates times and locations for the following committees

Credentials Resolutions Rules and Nominations

In addition I would also like to request a copy of accurate written records (minutes) from every Precinct in Nueces County Please notify me when these copies have been completed and I will pick them up from the Republican Party Headquarters

Thank you for your time

( Newer 29 of 179 Older)

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httomailcooclecommaillui=1ampik=559db3fdOOampview=cvampsearch=sentampth=119c5ce2 5152008

err amp Cause No

VANESSA L CAHILL sect SUPREME COURT OF TEXAS

VS sect sect 201 W 14TH STREET RM 104 sect

NUECESCOUNTY sect AUSTIN TEXAS REPUBLICAN PARTY sect

sect REPUBLICAN PARTY OF TEXAS sect

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 ~~j)~A A it A

~ d i

~fS~~~i LINDA D ZEPEDA f ltJ r~~v Notary Public

~ bull STATE OF TEXAS ~

~~~l My Comm Exp 11262011I LOndo- P~CL~ V V V V

Printed Name

My commission expires 1-clt - 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 IIssrional d rllcctt l number of county Texas met at JMI+td Ge1-e-Ik __amp~ (location) on J-QQ f (date) to hold a precinct convention

1 Call to Order - I (I bull The convention was called to order by temporary chairman J) G( ( 1--~1 I----Th------------__ at 7 s-Opm

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~nelti~I1~911Igirttuen9~importantparjy decisions at subsequentcQnven~ions

3 Election of Permanent Officers The temporary chairman announced that nominations for permanent chairman of this precinct convention woUld be

acceh~~~tIlO~~ tft0ns were nominated as candidates --- shy

The convention elected baf SwtmiddotfI as permanent chairman of the precinct convention The convention elected =na~ 2- SOl r 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 Ill (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 ~ovention

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 beshe 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 reguiredPy Ryle 22 and the Election Code (1740270) 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~pm~_ 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

-i

f1 Precinct fl

0 EXIDBITB E Senate District 20 0 (l) List of DELEGATES elected to County I Senatorial District Convention (J

(J VOTERCERT PRINT NAME PRINT MAILING ADDRESS (l)

Flm 1)~h1e- MI F Plmnc (J

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First Ed i-~ MI JV1 Address 0 9gt 5~ La kevi t LAJ Pbo~ 30L - 334--lLA-Z- I JD3~3D 2D11 Last Srn ~~~ CitdSXDu5 ChiSt Zip 184-12 E-Mail

(J f (J First 1rL1 Address Pirone-i

f Lim On ZiD E-Mail11

M1 IA~~ Ift~~ Citf Zip EmiddotMlIll

MJ IAdm IPbo Cin Zip E-M81l

MI IA_ IPh~ Cih~ bull Zip E-II-fail

M~ 1--- 1-City Zip E-Mail

gtLL 1--- IPh Citf Zip E-Mail

gt~ 1-- 1 Poo~ City Zip E-Mail

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PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

Page of ___

CONTACT INFO~1ATION

1-1 -334--124-2shy

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1 ~

I

SQT FCause No

VANESSA L CAHILL sect SUPREME COURT OF TEXAS sect

VS sect 201 W 14TH STREET RM 104 sect

NUECESCOUNTY sect AUSTIN TEXAS REPUBLICAN PARTY sect

sect REPUBLICAN PARTY OF TEXAS sect

BUSINESS RECORDS AFFIDAVIT

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

hereto are an exact duplicate of the original

Further affiant sayeth not

~lffmiddotLnL KayLu

SUBSCRIBED AND SWORN TO before me on this May 6 2008 to which I place my

signature and official seal )dQampyM-u J11du~ Signature

dele Jampylt-pound 71LeAJ Printed Name

My commission expires 1 -J-d~tcf Notary Public for the State of Texas

VICKIE JOY VAN MAREN Notary Public

STATE OF TEXAS My Comm Exp 10-05-2008

MINUTES OF THE REPUBLICAN PARTY PRECINCT CONVENTION

CJ3 ed v~ ters a election precinct nymber 5~g senate district numt er congressional district LJmber of ~ county Texas met at -nK~ ~4A-ltj (Jccion) C1 __trh-ltl lcJV L- oog (date) to hold a precinct convent xf

- CI to Order _-~ J r(3-1e ionver-tion as called to order by temporary chairman _dM~1 at ~-pm

P~pararon 0 List of Participants ( -le mpoary cr airmin 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 _ (numJer) 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 P3rty of Texas Rules adopted in accordance with the Election Code Robert Rules of Order current dit en neNly re ised would govern parliamentary procedure The temporary chairman then explained how the actions of lis mvention auld influence important party decisions at subsequent convlntions

-hE~onvention Elected as permanent chairman of the precinct convention

-~ Election of DI~legates and Alternates to the County or State Senatorial DistrictConvention -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 alternats are listed in Exhibit C

5 tesolutions The gtermanent chairr1an 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

sdopted b a mcjority vote are included with these minutes

5 Other Business Ths permanent chairman then asked if there was any other business that shculd properly come before the convention

7 Announcemfnts 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 heshe would officially sign stal 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 (174027c) The chairman announced the time and place for the county or senatorial district cgtnvention

8 Adjournmen t In accordance vli~ha)motion properly moved and seconded and adopted by a majority vote the precinct convention was

ad~ed at iq pm I J fit~ -- ~-ed lZi Aft-t=

ermanent hairman ~ Secretary

Return to y)ur county chairman The permanent chairman should also IOpy and retain a record of all documents

PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

INSTRUCTIONS FOR THE PRECINCT CONVENTIONS

TIMEPLACE 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 700 pm and 900 pm 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 precincts 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 countysenatorial 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 Roberts 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 wwwtexasgoporg and click on the GOP Resources link

PREPARATION OF LIST OF QUALlFIED PARTICIPANTS Attendees must have voted in that precincts 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 heshe takes the chair and oversees the election of the permanent secretary If necessary the chairman and the secretary may be the same person

ANNOUNCEMENTOF COUNTYSENATORIAJ-PI~TRICT COflVENTION The convention will convene on Saturday March 29 th at IcY0cJ ~~ (time) in q76R kAfr-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 countysenatorial 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 countysenatorial 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 countysenatorial 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 countysenatorial 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

PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

Precinct GV gtPage I of -----L EXHIBIT A

Senate District __ List of qualified voters who ATTENDED precinct convention

VOTERCERT PRINT NAME PRINT MAILING ADDRESS CONTACT INFORMATION

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City Zip I E-Mail __1 Last 3 PR()VTnfD BY THE RFPHBUCAN PARTY OF TEXAS

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 161009

Texas Election Code section 273063(a)

Texas Rule ofAppellate Procedure 523(e)

This courts opinion in Republican Party of Texas v Dietz 940 S W2d 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 states 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

-vshy

--- - - --- - - ----- ----~- ----- ~~-

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

-Vlshy

IV THE UNDISPUTED STATEMENT OF FACTS

Thefacts stated herein are supported bv the Cfidmit ofthe Relator

ciffidalits ofbusinesses record and party admissions Particular caution

lvas taken to insure the Texas Rules of Evidence were follmted

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 pJimary election

March 4 2008 Relator went to precinct 65s 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 shy

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

Bng HegtVJ Intrested I h0rng molVVIVnrlerl n middotheII Nu~~e~--UUIlLYr~ ~h llUVllllll Ul 1 --

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 chairmans 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 175870 and 121 (EXHIBITS EFGH) Mrs Cahill obtained a

- 2 shy

---- - - ---- - ------ --shy

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 gtvas

Mrs Cahills 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 shy

--- - ~ --- - - ------- ---- -- - - _shy~-

VARGUMENT

The importance of this case

Then the United States Supreme Court in Morse v Republican Party

~11middotImiddotamiddot~~ ()4 29 7 117 TT C 86 1996 ~~d~ m~rle n~ rlJfe----- t ow ~VJ ~uuu 17 - JjJ1 LJJbull l 11 J ~al II II au IV U 11 lC11lC 11 d

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 US Congress See

United States v Clasic 313 US2999

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 US and

Texas Constitutions the Voters Rights Act passed by Congress and the

Election Laws of the State of Texas

And in particular the Relators 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 shy

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 Relators Request for mandamus

Title 10 of the Texas Election Code sect 273061 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 SW2d 86 (Tex 1997)

and 924 SW2d 932 (Tex1996) 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 states 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 OBrien v Brown 409 US 1 92 SCt 271834 LEd2d 1 (1972)

- 5 shy

---shy - ---shy

Party Officer is subject to mandamus

Section 161009 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

163007 also states that these rules are enforceable by writ of mandamus

Section 174027 (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 161004 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 174027 and 161004

allowing access to these documents is the implied duty placed upon Mr

Bertuzzi

- 6 shy

--- shy ~ ----shy - ~~-~ ~----

CONCLUSION

The exhibits attached to this petition provide some evidence that the respondent violated the equal protection clause of the 14th amendment by CAltgttnn noffilal delenatAs ltgtt thAountv nnAntnn ltgtnd lnclurlng thAI~vUll115 UJ v lS t Ul II IlJ vVll V vi ltV J Ul Ul 1 l Ivi

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 PO Box 2641 Corpus Christi Texas 78403 Tel (361) 888-9255 Fax (361) 888-9288

- 7 shy

--- - --- - ---shy- -~-

IN THE SUPREME COURT OF TEXAS

IN RE VANESSA CAHILL

Relator

VERIFlCATION

STATE OF TEXAS sect sect

COUNTY OF NlJECES sect

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 shy

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 shy

~eIT A NUECES COUNTY REPUBLICAN PARTY aD Corpus 4458 South Staples

Christi Texas 78411

(361 ) 994-9317 (361 ) 994-9343 FAX E-Mail ncrpcctxgrandecomnet

Mike Bertuzzi-ehairman Rebecca Bradford---Vice Chairman Aneie 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 Saturday March 29

th 2008 The time is 1000 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 1000

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 am (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 partys 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 Morganmiddot Rd and go toward Leopard St Take a right on Leopard St then take

fJOT tlo Q

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OFFiCE OF THE SECRETARY OF 5T ATE

~Xvi[) A DFAN ITE CAfrrOl_ )~ ~ ro ~-~ fgt( G[)~ 261

~ _ ~ ~ i 1L gt- A S - 1 ~

]url(~ 74 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 Credenshytials 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~ 103 sUbd 1 (V~r~cn Supp 1982)

Tn your letter you inquired hether a crc~denti-ls conrni ttee of (l pol itical pgtty convcT~Ii(Jn could altor lt1 delegation by 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 1334 (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

____- -e~~ ~bull ~Wl -- -middotr ___

Mr Edward M Sullivan Page 2

SUIvl1ARY

Tex Elee Code Ann art 1334 (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 ir

7

~ I~(yfh~__

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 John 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 1334 (Vernon Supp_ 1982) provides

the sale method fer the selection of delegates to county and

state convertions 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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Alex Haupt antoniofratila Robert Lund Benjamin Bernier dmedinaprudent John Falasca Kay Fischer Margaret Fratila Paul Hunt ronpaul-10

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laquo Back to Sent Mail More actions ltNewer 71 of 155 Older)

Committee Information from vanessa cahill ltvanessafratilagmailcomgt hide details Mar 6 Beply

to michaeLbertuzzimlcom date Mar 62008411 PM

subject Committee Information mailed-by gmailcom

Mr Bertuzzi

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 soon be able to put a face to the nameas the saying goes

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 what better time to do so than the election season With all of the hype surrounding the Democratic race I think it is important for everyone in our party to get involved so we can retain the White House in November

I am very interested in volunteering my time in any way triat I can I would love to serve on any of the committees as well as attend the meetings of the committees that are already full If at all possible could you send me a list of these committes and the scheduled meeting dates and times In addition could you give me the phone numberslemail addresses of Art Granado and Victor Bird I believe they are heading up the Nominations and Resolutions Committees

Also if my services are also needed at the headquarters feel free to contact me

Thank you for your patience

Sincerely Vanessa 832-816-2944

~ Forward

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Request for Clarification Inbox

w vanessa cahill (Ni jdld Mar 16 Reply

Mr Bertuzzi

I would like to be sure that my recollection of our first telephone conversation is correct(March 6 2008) As per my memory I requested information on the dates 1imes and locations of the Credentials and Nominations Committees for Nueces County You then asked that I send my request in writing which I promptly did via email (March 6 2008) From the email attachment I received from Mike Bergsma (March 132008) I have made the reasonable assumption that you have opened and read my email request for this information

I would also like to clarify the second and last conversation we had over the telephone (March 12 2008) As per my memory you told me that you would not be providing to me the information I was requesting From what I understood your reluctance to provide the requested information to me stemmed from my affiliation with a local meetup group in which a fellow member Chuck Burnett voiced his opinions of local leadership in the Republican Party

I would also like clarification from you on the 14th Rule of the General Rules for All Conventions and Meetings of the Republican Party of Texas which states

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 to that convention

As a voter in the Republican Primary and a delegate in my precinct I would again like to request the dates times and locations for the following committees

Credentials Resolutions Rules and Nominations

In addition I would also like to request a copy of accurate written records (minutes) from every Precinct in Nueces County Please notify me when these copies have been completed and I will pick them up from the Republican Party Headquarters

Thank you for your time

( Newer 29 of 179 Older)

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err amp Cause No

VANESSA L CAHILL sect SUPREME COURT OF TEXAS

VS sect sect 201 W 14TH STREET RM 104 sect

NUECESCOUNTY sect AUSTIN TEXAS REPUBLICAN PARTY sect

sect REPUBLICAN PARTY OF TEXAS sect

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 ~~j)~A A it A

~ d i

~fS~~~i LINDA D ZEPEDA f ltJ r~~v Notary Public

~ bull STATE OF TEXAS ~

~~~l My Comm Exp 11262011I LOndo- P~CL~ V V V V

Printed Name

My commission expires 1-clt - 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 IIssrional d rllcctt l number of county Texas met at JMI+td Ge1-e-Ik __amp~ (location) on J-QQ f (date) to hold a precinct convention

1 Call to Order - I (I bull The convention was called to order by temporary chairman J) G( ( 1--~1 I----Th------------__ at 7 s-Opm

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~nelti~I1~911Igirttuen9~importantparjy decisions at subsequentcQnven~ions

3 Election of Permanent Officers The temporary chairman announced that nominations for permanent chairman of this precinct convention woUld be

acceh~~~tIlO~~ tft0ns were nominated as candidates --- shy

The convention elected baf SwtmiddotfI as permanent chairman of the precinct convention The convention elected =na~ 2- SOl r 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 Ill (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 ~ovention

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 beshe 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 reguiredPy Ryle 22 and the Election Code (1740270) 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~pm~_ 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

-i

f1 Precinct fl

0 EXIDBITB E Senate District 20 0 (l) List of DELEGATES elected to County I Senatorial District Convention (J

(J VOTERCERT PRINT NAME PRINT MAILING ADDRESS (l)

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~ First l)arrv) 5171 MI 1 Add~ 4632 La kEV iev] - ~-9S5-0923 If1l E lzu~9737b9Z lAst 5th 1~ CillLoroUS Ch r is+( ZIp ~ 8412 E-Mail

First Ed i-~ MI JV1 Address 0 9gt 5~ La kevi t LAJ Pbo~ 30L - 334--lLA-Z- I JD3~3D 2D11 Last Srn ~~~ CitdSXDu5 ChiSt Zip 184-12 E-Mail

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PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

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CONTACT INFO~1ATION

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VANESSA L CAHILL sect SUPREME COURT OF TEXAS sect

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BUSINESS RECORDS AFFIDAVIT

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

hereto are an exact duplicate of the original

Further affiant sayeth not

~lffmiddotLnL KayLu

SUBSCRIBED AND SWORN TO before me on this May 6 2008 to which I place my

signature and official seal )dQampyM-u J11du~ Signature

dele Jampylt-pound 71LeAJ Printed Name

My commission expires 1 -J-d~tcf Notary Public for the State of Texas

VICKIE JOY VAN MAREN Notary Public

STATE OF TEXAS My Comm Exp 10-05-2008

MINUTES OF THE REPUBLICAN PARTY PRECINCT CONVENTION

CJ3 ed v~ ters a election precinct nymber 5~g senate district numt er congressional district LJmber of ~ county Texas met at -nK~ ~4A-ltj (Jccion) C1 __trh-ltl lcJV L- oog (date) to hold a precinct convent xf

- CI to Order _-~ J r(3-1e ionver-tion as called to order by temporary chairman _dM~1 at ~-pm

P~pararon 0 List of Participants ( -le mpoary cr airmin 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 _ (numJer) 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 P3rty of Texas Rules adopted in accordance with the Election Code Robert Rules of Order current dit en neNly re ised would govern parliamentary procedure The temporary chairman then explained how the actions of lis mvention auld influence important party decisions at subsequent convlntions

-hE~onvention Elected as permanent chairman of the precinct convention

-~ Election of DI~legates and Alternates to the County or State Senatorial DistrictConvention -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 alternats are listed in Exhibit C

5 tesolutions The gtermanent chairr1an 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

sdopted b a mcjority vote are included with these minutes

5 Other Business Ths permanent chairman then asked if there was any other business that shculd properly come before the convention

7 Announcemfnts 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 heshe would officially sign stal 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 (174027c) The chairman announced the time and place for the county or senatorial district cgtnvention

8 Adjournmen t In accordance vli~ha)motion properly moved and seconded and adopted by a majority vote the precinct convention was

ad~ed at iq pm I J fit~ -- ~-ed lZi Aft-t=

ermanent hairman ~ Secretary

Return to y)ur county chairman The permanent chairman should also IOpy and retain a record of all documents

PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

INSTRUCTIONS FOR THE PRECINCT CONVENTIONS

TIMEPLACE 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 700 pm and 900 pm 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 precincts 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 countysenatorial 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 Roberts 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 wwwtexasgoporg and click on the GOP Resources link

PREPARATION OF LIST OF QUALlFIED PARTICIPANTS Attendees must have voted in that precincts 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 heshe takes the chair and oversees the election of the permanent secretary If necessary the chairman and the secretary may be the same person

ANNOUNCEMENTOF COUNTYSENATORIAJ-PI~TRICT COflVENTION The convention will convene on Saturday March 29 th at IcY0cJ ~~ (time) in q76R kAfr-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 countysenatorial 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 countysenatorial 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 countysenatorial 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 countysenatorial 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

PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

Precinct GV gtPage I of -----L EXHIBIT A

Senate District __ List of qualified voters who ATTENDED precinct convention

VOTERCERT PRINT NAME PRINT MAILING ADDRESS CONTACT INFORMATION

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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

-Vlshy

IV THE UNDISPUTED STATEMENT OF FACTS

Thefacts stated herein are supported bv the Cfidmit ofthe Relator

ciffidalits ofbusinesses record and party admissions Particular caution

lvas taken to insure the Texas Rules of Evidence were follmted

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 pJimary election

March 4 2008 Relator went to precinct 65s 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 shy

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

Bng HegtVJ Intrested I h0rng molVVIVnrlerl n middotheII Nu~~e~--UUIlLYr~ ~h llUVllllll Ul 1 --

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 chairmans 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 175870 and 121 (EXHIBITS EFGH) Mrs Cahill obtained a

- 2 shy

---- - - ---- - ------ --shy

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 gtvas

Mrs Cahills 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 shy

--- - ~ --- - - ------- ---- -- - - _shy~-

VARGUMENT

The importance of this case

Then the United States Supreme Court in Morse v Republican Party

~11middotImiddotamiddot~~ ()4 29 7 117 TT C 86 1996 ~~d~ m~rle n~ rlJfe----- t ow ~VJ ~uuu 17 - JjJ1 LJJbull l 11 J ~al II II au IV U 11 lC11lC 11 d

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 US Congress See

United States v Clasic 313 US2999

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 US and

Texas Constitutions the Voters Rights Act passed by Congress and the

Election Laws of the State of Texas

And in particular the Relators 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 shy

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 Relators Request for mandamus

Title 10 of the Texas Election Code sect 273061 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 SW2d 86 (Tex 1997)

and 924 SW2d 932 (Tex1996) 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 states 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 OBrien v Brown 409 US 1 92 SCt 271834 LEd2d 1 (1972)

- 5 shy

---shy - ---shy

Party Officer is subject to mandamus

Section 161009 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

163007 also states that these rules are enforceable by writ of mandamus

Section 174027 (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 161004 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 174027 and 161004

allowing access to these documents is the implied duty placed upon Mr

Bertuzzi

- 6 shy

--- shy ~ ----shy - ~~-~ ~----

CONCLUSION

The exhibits attached to this petition provide some evidence that the respondent violated the equal protection clause of the 14th amendment by CAltgttnn noffilal delenatAs ltgtt thAountv nnAntnn ltgtnd lnclurlng thAI~vUll115 UJ v lS t Ul II IlJ vVll V vi ltV J Ul Ul 1 l Ivi

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 PO Box 2641 Corpus Christi Texas 78403 Tel (361) 888-9255 Fax (361) 888-9288

- 7 shy

--- - --- - ---shy- -~-

IN THE SUPREME COURT OF TEXAS

IN RE VANESSA CAHILL

Relator

VERIFlCATION

STATE OF TEXAS sect sect

COUNTY OF NlJECES sect

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 shy

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 shy

~eIT A NUECES COUNTY REPUBLICAN PARTY aD Corpus 4458 South Staples

Christi Texas 78411

(361 ) 994-9317 (361 ) 994-9343 FAX E-Mail ncrpcctxgrandecomnet

Mike Bertuzzi-ehairman Rebecca Bradford---Vice Chairman Aneie 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 Saturday March 29

th 2008 The time is 1000 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 1000

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 am (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 partys 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 Morganmiddot Rd and go toward Leopard St Take a right on Leopard St then take

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OFFiCE OF THE SECRETARY OF 5T ATE

~Xvi[) A DFAN ITE CAfrrOl_ )~ ~ ro ~-~ fgt( G[)~ 261

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]url(~ 74 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 Credenshytials 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~ 103 sUbd 1 (V~r~cn Supp 1982)

Tn your letter you inquired hether a crc~denti-ls conrni ttee of (l pol itical pgtty convcT~Ii(Jn could altor lt1 delegation by 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 1334 (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

____- -e~~ ~bull ~Wl -- -middotr ___

Mr Edward M Sullivan Page 2

SUIvl1ARY

Tex Elee Code Ann art 1334 (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 ir

7

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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 John 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 1334 (Vernon Supp_ 1982) provides

the sale method fer the selection of delegates to county and

state convertions 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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Alex Haupt antoniofratila Robert Lund Benjamin Bernier dmedinaprudent John Falasca Kay Fischer Margaret Fratila Paul Hunt ronpaul-10

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Mr Bertuzzi

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 soon be able to put a face to the nameas the saying goes

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 what better time to do so than the election season With all of the hype surrounding the Democratic race I think it is important for everyone in our party to get involved so we can retain the White House in November

I am very interested in volunteering my time in any way triat I can I would love to serve on any of the committees as well as attend the meetings of the committees that are already full If at all possible could you send me a list of these committes and the scheduled meeting dates and times In addition could you give me the phone numberslemail addresses of Art Granado and Victor Bird I believe they are heading up the Nominations and Resolutions Committees

Also if my services are also needed at the headquarters feel free to contact me

Thank you for your patience

Sincerely Vanessa 832-816-2944

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Request for Clarification Inbox

w vanessa cahill (Ni jdld Mar 16 Reply

Mr Bertuzzi

I would like to be sure that my recollection of our first telephone conversation is correct(March 6 2008) As per my memory I requested information on the dates 1imes and locations of the Credentials and Nominations Committees for Nueces County You then asked that I send my request in writing which I promptly did via email (March 6 2008) From the email attachment I received from Mike Bergsma (March 132008) I have made the reasonable assumption that you have opened and read my email request for this information

I would also like to clarify the second and last conversation we had over the telephone (March 12 2008) As per my memory you told me that you would not be providing to me the information I was requesting From what I understood your reluctance to provide the requested information to me stemmed from my affiliation with a local meetup group in which a fellow member Chuck Burnett voiced his opinions of local leadership in the Republican Party

I would also like clarification from you on the 14th Rule of the General Rules for All Conventions and Meetings of the Republican Party of Texas which states

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 to that convention

As a voter in the Republican Primary and a delegate in my precinct I would again like to request the dates times and locations for the following committees

Credentials Resolutions Rules and Nominations

In addition I would also like to request a copy of accurate written records (minutes) from every Precinct in Nueces County Please notify me when these copies have been completed and I will pick them up from the Republican Party Headquarters

Thank you for your time

( Newer 29 of 179 Older)

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httomailcooclecommaillui=1ampik=559db3fdOOampview=cvampsearch=sentampth=119c5ce2 5152008

err amp Cause No

VANESSA L CAHILL sect SUPREME COURT OF TEXAS

VS sect sect 201 W 14TH STREET RM 104 sect

NUECESCOUNTY sect AUSTIN TEXAS REPUBLICAN PARTY sect

sect REPUBLICAN PARTY OF TEXAS sect

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 ~~j)~A A it A

~ d i

~fS~~~i LINDA D ZEPEDA f ltJ r~~v Notary Public

~ bull STATE OF TEXAS ~

~~~l My Comm Exp 11262011I LOndo- P~CL~ V V V V

Printed Name

My commission expires 1-clt - 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 IIssrional d rllcctt l number of county Texas met at JMI+td Ge1-e-Ik __amp~ (location) on J-QQ f (date) to hold a precinct convention

1 Call to Order - I (I bull The convention was called to order by temporary chairman J) G( ( 1--~1 I----Th------------__ at 7 s-Opm

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~nelti~I1~911Igirttuen9~importantparjy decisions at subsequentcQnven~ions

3 Election of Permanent Officers The temporary chairman announced that nominations for permanent chairman of this precinct convention woUld be

acceh~~~tIlO~~ tft0ns were nominated as candidates --- shy

The convention elected baf SwtmiddotfI as permanent chairman of the precinct convention The convention elected =na~ 2- SOl r 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 Ill (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 ~ovention

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 beshe 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 reguiredPy Ryle 22 and the Election Code (1740270) 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~pm~_ 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

-i

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0 EXIDBITB E Senate District 20 0 (l) List of DELEGATES elected to County I Senatorial District Convention (J

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PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

Page of ___

CONTACT INFO~1ATION

1-1 -334--124-2shy

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I

SQT FCause No

VANESSA L CAHILL sect SUPREME COURT OF TEXAS sect

VS sect 201 W 14TH STREET RM 104 sect

NUECESCOUNTY sect AUSTIN TEXAS REPUBLICAN PARTY sect

sect REPUBLICAN PARTY OF TEXAS sect

BUSINESS RECORDS AFFIDAVIT

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

hereto are an exact duplicate of the original

Further affiant sayeth not

~lffmiddotLnL KayLu

SUBSCRIBED AND SWORN TO before me on this May 6 2008 to which I place my

signature and official seal )dQampyM-u J11du~ Signature

dele Jampylt-pound 71LeAJ Printed Name

My commission expires 1 -J-d~tcf Notary Public for the State of Texas

VICKIE JOY VAN MAREN Notary Public

STATE OF TEXAS My Comm Exp 10-05-2008

MINUTES OF THE REPUBLICAN PARTY PRECINCT CONVENTION

CJ3 ed v~ ters a election precinct nymber 5~g senate district numt er congressional district LJmber of ~ county Texas met at -nK~ ~4A-ltj (Jccion) C1 __trh-ltl lcJV L- oog (date) to hold a precinct convent xf

- CI to Order _-~ J r(3-1e ionver-tion as called to order by temporary chairman _dM~1 at ~-pm

P~pararon 0 List of Participants ( -le mpoary cr airmin 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 _ (numJer) 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 P3rty of Texas Rules adopted in accordance with the Election Code Robert Rules of Order current dit en neNly re ised would govern parliamentary procedure The temporary chairman then explained how the actions of lis mvention auld influence important party decisions at subsequent convlntions

-hE~onvention Elected as permanent chairman of the precinct convention

-~ Election of DI~legates and Alternates to the County or State Senatorial DistrictConvention -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 alternats are listed in Exhibit C

5 tesolutions The gtermanent chairr1an 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

sdopted b a mcjority vote are included with these minutes

5 Other Business Ths permanent chairman then asked if there was any other business that shculd properly come before the convention

7 Announcemfnts 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 heshe would officially sign stal 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 (174027c) The chairman announced the time and place for the county or senatorial district cgtnvention

8 Adjournmen t In accordance vli~ha)motion properly moved and seconded and adopted by a majority vote the precinct convention was

ad~ed at iq pm I J fit~ -- ~-ed lZi Aft-t=

ermanent hairman ~ Secretary

Return to y)ur county chairman The permanent chairman should also IOpy and retain a record of all documents

PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

INSTRUCTIONS FOR THE PRECINCT CONVENTIONS

TIMEPLACE 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 700 pm and 900 pm 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 precincts 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 countysenatorial 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 Roberts 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 wwwtexasgoporg and click on the GOP Resources link

PREPARATION OF LIST OF QUALlFIED PARTICIPANTS Attendees must have voted in that precincts 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 heshe takes the chair and oversees the election of the permanent secretary If necessary the chairman and the secretary may be the same person

ANNOUNCEMENTOF COUNTYSENATORIAJ-PI~TRICT COflVENTION The convention will convene on Saturday March 29 th at IcY0cJ ~~ (time) in q76R kAfr-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 countysenatorial 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 countysenatorial 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 countysenatorial 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 countysenatorial 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

PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

Precinct GV gtPage I of -----L EXHIBIT A

Senate District __ List of qualified voters who ATTENDED precinct convention

VOTERCERT PRINT NAME PRINT MAILING ADDRESS CONTACT INFORMATION

(DY ro3 ofJ1

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MI Phone 1- ff ~-OcJamp g)( ()ft E-Mail

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PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

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First MI Address _____ I Phone

City Zip I E-Mail __1 Last 3 PR()VTnfD BY THE RFPHBUCAN PARTY OF TEXAS

IV THE UNDISPUTED STATEMENT OF FACTS

Thefacts stated herein are supported bv the Cfidmit ofthe Relator

ciffidalits ofbusinesses record and party admissions Particular caution

lvas taken to insure the Texas Rules of Evidence were follmted

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 pJimary election

March 4 2008 Relator went to precinct 65s 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 shy

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

Bng HegtVJ Intrested I h0rng molVVIVnrlerl n middotheII Nu~~e~--UUIlLYr~ ~h llUVllllll Ul 1 --

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 chairmans 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 175870 and 121 (EXHIBITS EFGH) Mrs Cahill obtained a

- 2 shy

---- - - ---- - ------ --shy

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 gtvas

Mrs Cahills 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 shy

--- - ~ --- - - ------- ---- -- - - _shy~-

VARGUMENT

The importance of this case

Then the United States Supreme Court in Morse v Republican Party

~11middotImiddotamiddot~~ ()4 29 7 117 TT C 86 1996 ~~d~ m~rle n~ rlJfe----- t ow ~VJ ~uuu 17 - JjJ1 LJJbull l 11 J ~al II II au IV U 11 lC11lC 11 d

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 US Congress See

United States v Clasic 313 US2999

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 US and

Texas Constitutions the Voters Rights Act passed by Congress and the

Election Laws of the State of Texas

And in particular the Relators 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 shy

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 Relators Request for mandamus

Title 10 of the Texas Election Code sect 273061 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 SW2d 86 (Tex 1997)

and 924 SW2d 932 (Tex1996) 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 states 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 OBrien v Brown 409 US 1 92 SCt 271834 LEd2d 1 (1972)

- 5 shy

---shy - ---shy

Party Officer is subject to mandamus

Section 161009 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

163007 also states that these rules are enforceable by writ of mandamus

Section 174027 (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 161004 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 174027 and 161004

allowing access to these documents is the implied duty placed upon Mr

Bertuzzi

- 6 shy

--- shy ~ ----shy - ~~-~ ~----

CONCLUSION

The exhibits attached to this petition provide some evidence that the respondent violated the equal protection clause of the 14th amendment by CAltgttnn noffilal delenatAs ltgtt thAountv nnAntnn ltgtnd lnclurlng thAI~vUll115 UJ v lS t Ul II IlJ vVll V vi ltV J Ul Ul 1 l Ivi

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 PO Box 2641 Corpus Christi Texas 78403 Tel (361) 888-9255 Fax (361) 888-9288

- 7 shy

--- - --- - ---shy- -~-

IN THE SUPREME COURT OF TEXAS

IN RE VANESSA CAHILL

Relator

VERIFlCATION

STATE OF TEXAS sect sect

COUNTY OF NlJECES sect

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 shy

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 shy

~eIT A NUECES COUNTY REPUBLICAN PARTY aD Corpus 4458 South Staples

Christi Texas 78411

(361 ) 994-9317 (361 ) 994-9343 FAX E-Mail ncrpcctxgrandecomnet

Mike Bertuzzi-ehairman Rebecca Bradford---Vice Chairman Aneie 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 Saturday March 29

th 2008 The time is 1000 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 1000

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 am (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 partys 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 Morganmiddot Rd and go toward Leopard St Take a right on Leopard St then take

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OFFiCE OF THE SECRETARY OF 5T ATE

~Xvi[) A DFAN ITE CAfrrOl_ )~ ~ ro ~-~ fgt( G[)~ 261

~ _ ~ ~ i 1L gt- A S - 1 ~

]url(~ 74 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 Credenshytials 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~ 103 sUbd 1 (V~r~cn Supp 1982)

Tn your letter you inquired hether a crc~denti-ls conrni ttee of (l pol itical pgtty convcT~Ii(Jn could altor lt1 delegation by 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 1334 (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

____- -e~~ ~bull ~Wl -- -middotr ___

Mr Edward M Sullivan Page 2

SUIvl1ARY

Tex Elee Code Ann art 1334 (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 ir

7

~ I~(yfh~__

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 John 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 1334 (Vernon Supp_ 1982) provides

the sale method fer the selection of delegates to county and

state convertions 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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Alex Haupt antoniofratila Robert Lund Benjamin Bernier dmedinaprudent John Falasca Kay Fischer Margaret Fratila Paul Hunt ronpaul-10

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Committee Information from vanessa cahill ltvanessafratilagmailcomgt hide details Mar 6 Beply

to michaeLbertuzzimlcom date Mar 62008411 PM

subject Committee Information mailed-by gmailcom

Mr Bertuzzi

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 soon be able to put a face to the nameas the saying goes

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 what better time to do so than the election season With all of the hype surrounding the Democratic race I think it is important for everyone in our party to get involved so we can retain the White House in November

I am very interested in volunteering my time in any way triat I can I would love to serve on any of the committees as well as attend the meetings of the committees that are already full If at all possible could you send me a list of these committes and the scheduled meeting dates and times In addition could you give me the phone numberslemail addresses of Art Granado and Victor Bird I believe they are heading up the Nominations and Resolutions Committees

Also if my services are also needed at the headquarters feel free to contact me

Thank you for your patience

Sincerely Vanessa 832-816-2944

~ Forward

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Request for Clarification Inbox

w vanessa cahill (Ni jdld Mar 16 Reply

Mr Bertuzzi

I would like to be sure that my recollection of our first telephone conversation is correct(March 6 2008) As per my memory I requested information on the dates 1imes and locations of the Credentials and Nominations Committees for Nueces County You then asked that I send my request in writing which I promptly did via email (March 6 2008) From the email attachment I received from Mike Bergsma (March 132008) I have made the reasonable assumption that you have opened and read my email request for this information

I would also like to clarify the second and last conversation we had over the telephone (March 12 2008) As per my memory you told me that you would not be providing to me the information I was requesting From what I understood your reluctance to provide the requested information to me stemmed from my affiliation with a local meetup group in which a fellow member Chuck Burnett voiced his opinions of local leadership in the Republican Party

I would also like clarification from you on the 14th Rule of the General Rules for All Conventions and Meetings of the Republican Party of Texas which states

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 to that convention

As a voter in the Republican Primary and a delegate in my precinct I would again like to request the dates times and locations for the following committees

Credentials Resolutions Rules and Nominations

In addition I would also like to request a copy of accurate written records (minutes) from every Precinct in Nueces County Please notify me when these copies have been completed and I will pick them up from the Republican Party Headquarters

Thank you for your time

( Newer 29 of 179 Older)

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httomailcooclecommaillui=1ampik=559db3fdOOampview=cvampsearch=sentampth=119c5ce2 5152008

err amp Cause No

VANESSA L CAHILL sect SUPREME COURT OF TEXAS

VS sect sect 201 W 14TH STREET RM 104 sect

NUECESCOUNTY sect AUSTIN TEXAS REPUBLICAN PARTY sect

sect REPUBLICAN PARTY OF TEXAS sect

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 ~~j)~A A it A

~ d i

~fS~~~i LINDA D ZEPEDA f ltJ r~~v Notary Public

~ bull STATE OF TEXAS ~

~~~l My Comm Exp 11262011I LOndo- P~CL~ V V V V

Printed Name

My commission expires 1-clt - 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 IIssrional d rllcctt l number of county Texas met at JMI+td Ge1-e-Ik __amp~ (location) on J-QQ f (date) to hold a precinct convention

1 Call to Order - I (I bull The convention was called to order by temporary chairman J) G( ( 1--~1 I----Th------------__ at 7 s-Opm

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~nelti~I1~911Igirttuen9~importantparjy decisions at subsequentcQnven~ions

3 Election of Permanent Officers The temporary chairman announced that nominations for permanent chairman of this precinct convention woUld be

acceh~~~tIlO~~ tft0ns were nominated as candidates --- shy

The convention elected baf SwtmiddotfI as permanent chairman of the precinct convention The convention elected =na~ 2- SOl r 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 Ill (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 ~ovention

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 beshe 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 reguiredPy Ryle 22 and the Election Code (1740270) 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~pm~_ 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

-i

f1 Precinct fl

0 EXIDBITB E Senate District 20 0 (l) List of DELEGATES elected to County I Senatorial District Convention (J

(J VOTERCERT PRINT NAME PRINT MAILING ADDRESS (l)

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First Ed i-~ MI JV1 Address 0 9gt 5~ La kevi t LAJ Pbo~ 30L - 334--lLA-Z- I JD3~3D 2D11 Last Srn ~~~ CitdSXDu5 ChiSt Zip 184-12 E-Mail

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PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

Page of ___

CONTACT INFO~1ATION

1-1 -334--124-2shy

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I

SQT FCause No

VANESSA L CAHILL sect SUPREME COURT OF TEXAS sect

VS sect 201 W 14TH STREET RM 104 sect

NUECESCOUNTY sect AUSTIN TEXAS REPUBLICAN PARTY sect

sect REPUBLICAN PARTY OF TEXAS sect

BUSINESS RECORDS AFFIDAVIT

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

hereto are an exact duplicate of the original

Further affiant sayeth not

~lffmiddotLnL KayLu

SUBSCRIBED AND SWORN TO before me on this May 6 2008 to which I place my

signature and official seal )dQampyM-u J11du~ Signature

dele Jampylt-pound 71LeAJ Printed Name

My commission expires 1 -J-d~tcf Notary Public for the State of Texas

VICKIE JOY VAN MAREN Notary Public

STATE OF TEXAS My Comm Exp 10-05-2008

MINUTES OF THE REPUBLICAN PARTY PRECINCT CONVENTION

CJ3 ed v~ ters a election precinct nymber 5~g senate district numt er congressional district LJmber of ~ county Texas met at -nK~ ~4A-ltj (Jccion) C1 __trh-ltl lcJV L- oog (date) to hold a precinct convent xf

- CI to Order _-~ J r(3-1e ionver-tion as called to order by temporary chairman _dM~1 at ~-pm

P~pararon 0 List of Participants ( -le mpoary cr airmin 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 _ (numJer) 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 P3rty of Texas Rules adopted in accordance with the Election Code Robert Rules of Order current dit en neNly re ised would govern parliamentary procedure The temporary chairman then explained how the actions of lis mvention auld influence important party decisions at subsequent convlntions

-hE~onvention Elected as permanent chairman of the precinct convention

-~ Election of DI~legates and Alternates to the County or State Senatorial DistrictConvention -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 alternats are listed in Exhibit C

5 tesolutions The gtermanent chairr1an 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

sdopted b a mcjority vote are included with these minutes

5 Other Business Ths permanent chairman then asked if there was any other business that shculd properly come before the convention

7 Announcemfnts 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 heshe would officially sign stal 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 (174027c) The chairman announced the time and place for the county or senatorial district cgtnvention

8 Adjournmen t In accordance vli~ha)motion properly moved and seconded and adopted by a majority vote the precinct convention was

ad~ed at iq pm I J fit~ -- ~-ed lZi Aft-t=

ermanent hairman ~ Secretary

Return to y)ur county chairman The permanent chairman should also IOpy and retain a record of all documents

PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

INSTRUCTIONS FOR THE PRECINCT CONVENTIONS

TIMEPLACE 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 700 pm and 900 pm 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 precincts 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 countysenatorial 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 Roberts 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 wwwtexasgoporg and click on the GOP Resources link

PREPARATION OF LIST OF QUALlFIED PARTICIPANTS Attendees must have voted in that precincts 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 heshe takes the chair and oversees the election of the permanent secretary If necessary the chairman and the secretary may be the same person

ANNOUNCEMENTOF COUNTYSENATORIAJ-PI~TRICT COflVENTION The convention will convene on Saturday March 29 th at IcY0cJ ~~ (time) in q76R kAfr-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 countysenatorial 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 countysenatorial 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 countysenatorial 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 countysenatorial 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

PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

Precinct GV gtPage I of -----L EXHIBIT A

Senate District __ List of qualified voters who ATTENDED precinct convention

VOTERCERT PRINT NAME PRINT MAILING ADDRESS CONTACT INFORMATION

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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

Bng HegtVJ Intrested I h0rng molVVIVnrlerl n middotheII Nu~~e~--UUIlLYr~ ~h llUVllllll Ul 1 --

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 chairmans 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 175870 and 121 (EXHIBITS EFGH) Mrs Cahill obtained a

- 2 shy

---- - - ---- - ------ --shy

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 gtvas

Mrs Cahills 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 shy

--- - ~ --- - - ------- ---- -- - - _shy~-

VARGUMENT

The importance of this case

Then the United States Supreme Court in Morse v Republican Party

~11middotImiddotamiddot~~ ()4 29 7 117 TT C 86 1996 ~~d~ m~rle n~ rlJfe----- t ow ~VJ ~uuu 17 - JjJ1 LJJbull l 11 J ~al II II au IV U 11 lC11lC 11 d

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 US Congress See

United States v Clasic 313 US2999

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 US and

Texas Constitutions the Voters Rights Act passed by Congress and the

Election Laws of the State of Texas

And in particular the Relators 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 shy

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 Relators Request for mandamus

Title 10 of the Texas Election Code sect 273061 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 SW2d 86 (Tex 1997)

and 924 SW2d 932 (Tex1996) 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 states 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 OBrien v Brown 409 US 1 92 SCt 271834 LEd2d 1 (1972)

- 5 shy

---shy - ---shy

Party Officer is subject to mandamus

Section 161009 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

163007 also states that these rules are enforceable by writ of mandamus

Section 174027 (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 161004 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 174027 and 161004

allowing access to these documents is the implied duty placed upon Mr

Bertuzzi

- 6 shy

--- shy ~ ----shy - ~~-~ ~----

CONCLUSION

The exhibits attached to this petition provide some evidence that the respondent violated the equal protection clause of the 14th amendment by CAltgttnn noffilal delenatAs ltgtt thAountv nnAntnn ltgtnd lnclurlng thAI~vUll115 UJ v lS t Ul II IlJ vVll V vi ltV J Ul Ul 1 l Ivi

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 PO Box 2641 Corpus Christi Texas 78403 Tel (361) 888-9255 Fax (361) 888-9288

- 7 shy

--- - --- - ---shy- -~-

IN THE SUPREME COURT OF TEXAS

IN RE VANESSA CAHILL

Relator

VERIFlCATION

STATE OF TEXAS sect sect

COUNTY OF NlJECES sect

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 shy

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 shy

~eIT A NUECES COUNTY REPUBLICAN PARTY aD Corpus 4458 South Staples

Christi Texas 78411

(361 ) 994-9317 (361 ) 994-9343 FAX E-Mail ncrpcctxgrandecomnet

Mike Bertuzzi-ehairman Rebecca Bradford---Vice Chairman Aneie 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 Saturday March 29

th 2008 The time is 1000 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 1000

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 am (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 partys 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 Morganmiddot Rd and go toward Leopard St Take a right on Leopard St then take

fJOT tlo Q

centlt~ o~+-

I~(~ ~~)~lk~~~-~~ -s ~ middot)oR

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~~

OFFiCE OF THE SECRETARY OF 5T ATE

~Xvi[) A DFAN ITE CAfrrOl_ )~ ~ ro ~-~ fgt( G[)~ 261

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]url(~ 74 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 Credenshytials 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~ 103 sUbd 1 (V~r~cn Supp 1982)

Tn your letter you inquired hether a crc~denti-ls conrni ttee of (l pol itical pgtty convcT~Ii(Jn could altor lt1 delegation by 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 1334 (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

____- -e~~ ~bull ~Wl -- -middotr ___

Mr Edward M Sullivan Page 2

SUIvl1ARY

Tex Elee Code Ann art 1334 (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 ir

7

~ I~(yfh~__

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 John 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 1334 (Vernon Supp_ 1982) provides

the sale method fer the selection of delegates to county and

state convertions 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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Alex Haupt antoniofratila Robert Lund Benjamin Bernier dmedinaprudent John Falasca Kay Fischer Margaret Fratila Paul Hunt ronpaul-10

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Committee Information from vanessa cahill ltvanessafratilagmailcomgt hide details Mar 6 Beply

to michaeLbertuzzimlcom date Mar 62008411 PM

subject Committee Information mailed-by gmailcom

Mr Bertuzzi

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 soon be able to put a face to the nameas the saying goes

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 what better time to do so than the election season With all of the hype surrounding the Democratic race I think it is important for everyone in our party to get involved so we can retain the White House in November

I am very interested in volunteering my time in any way triat I can I would love to serve on any of the committees as well as attend the meetings of the committees that are already full If at all possible could you send me a list of these committes and the scheduled meeting dates and times In addition could you give me the phone numberslemail addresses of Art Granado and Victor Bird I believe they are heading up the Nominations and Resolutions Committees

Also if my services are also needed at the headquarters feel free to contact me

Thank you for your patience

Sincerely Vanessa 832-816-2944

~ Forward

bull vanessa cahill to jfalasca show details Apr 5 Beply

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Request for Clarification Inbox

w vanessa cahill (Ni jdld Mar 16 Reply

Mr Bertuzzi

I would like to be sure that my recollection of our first telephone conversation is correct(March 6 2008) As per my memory I requested information on the dates 1imes and locations of the Credentials and Nominations Committees for Nueces County You then asked that I send my request in writing which I promptly did via email (March 6 2008) From the email attachment I received from Mike Bergsma (March 132008) I have made the reasonable assumption that you have opened and read my email request for this information

I would also like to clarify the second and last conversation we had over the telephone (March 12 2008) As per my memory you told me that you would not be providing to me the information I was requesting From what I understood your reluctance to provide the requested information to me stemmed from my affiliation with a local meetup group in which a fellow member Chuck Burnett voiced his opinions of local leadership in the Republican Party

I would also like clarification from you on the 14th Rule of the General Rules for All Conventions and Meetings of the Republican Party of Texas which states

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 to that convention

As a voter in the Republican Primary and a delegate in my precinct I would again like to request the dates times and locations for the following committees

Credentials Resolutions Rules and Nominations

In addition I would also like to request a copy of accurate written records (minutes) from every Precinct in Nueces County Please notify me when these copies have been completed and I will pick them up from the Republican Party Headquarters

Thank you for your time

( Newer 29 of 179 Older)

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httomailcooclecommaillui=1ampik=559db3fdOOampview=cvampsearch=sentampth=119c5ce2 5152008

err amp Cause No

VANESSA L CAHILL sect SUPREME COURT OF TEXAS

VS sect sect 201 W 14TH STREET RM 104 sect

NUECESCOUNTY sect AUSTIN TEXAS REPUBLICAN PARTY sect

sect REPUBLICAN PARTY OF TEXAS sect

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 ~~j)~A A it A

~ d i

~fS~~~i LINDA D ZEPEDA f ltJ r~~v Notary Public

~ bull STATE OF TEXAS ~

~~~l My Comm Exp 11262011I LOndo- P~CL~ V V V V

Printed Name

My commission expires 1-clt - 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 IIssrional d rllcctt l number of county Texas met at JMI+td Ge1-e-Ik __amp~ (location) on J-QQ f (date) to hold a precinct convention

1 Call to Order - I (I bull The convention was called to order by temporary chairman J) G( ( 1--~1 I----Th------------__ at 7 s-Opm

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~nelti~I1~911Igirttuen9~importantparjy decisions at subsequentcQnven~ions

3 Election of Permanent Officers The temporary chairman announced that nominations for permanent chairman of this precinct convention woUld be

acceh~~~tIlO~~ tft0ns were nominated as candidates --- shy

The convention elected baf SwtmiddotfI as permanent chairman of the precinct convention The convention elected =na~ 2- SOl r 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 Ill (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 ~ovention

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 beshe 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 reguiredPy Ryle 22 and the Election Code (1740270) 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~pm~_ 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

-i

f1 Precinct fl

0 EXIDBITB E Senate District 20 0 (l) List of DELEGATES elected to County I Senatorial District Convention (J

(J VOTERCERT PRINT NAME PRINT MAILING ADDRESS (l)

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PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

Page of ___

CONTACT INFO~1ATION

1-1 -334--124-2shy

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SQT FCause No

VANESSA L CAHILL sect SUPREME COURT OF TEXAS sect

VS sect 201 W 14TH STREET RM 104 sect

NUECESCOUNTY sect AUSTIN TEXAS REPUBLICAN PARTY sect

sect REPUBLICAN PARTY OF TEXAS sect

BUSINESS RECORDS AFFIDAVIT

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

hereto are an exact duplicate of the original

Further affiant sayeth not

~lffmiddotLnL KayLu

SUBSCRIBED AND SWORN TO before me on this May 6 2008 to which I place my

signature and official seal )dQampyM-u J11du~ Signature

dele Jampylt-pound 71LeAJ Printed Name

My commission expires 1 -J-d~tcf Notary Public for the State of Texas

VICKIE JOY VAN MAREN Notary Public

STATE OF TEXAS My Comm Exp 10-05-2008

MINUTES OF THE REPUBLICAN PARTY PRECINCT CONVENTION

CJ3 ed v~ ters a election precinct nymber 5~g senate district numt er congressional district LJmber of ~ county Texas met at -nK~ ~4A-ltj (Jccion) C1 __trh-ltl lcJV L- oog (date) to hold a precinct convent xf

- CI to Order _-~ J r(3-1e ionver-tion as called to order by temporary chairman _dM~1 at ~-pm

P~pararon 0 List of Participants ( -le mpoary cr airmin 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 _ (numJer) 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 P3rty of Texas Rules adopted in accordance with the Election Code Robert Rules of Order current dit en neNly re ised would govern parliamentary procedure The temporary chairman then explained how the actions of lis mvention auld influence important party decisions at subsequent convlntions

-hE~onvention Elected as permanent chairman of the precinct convention

-~ Election of DI~legates and Alternates to the County or State Senatorial DistrictConvention -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 alternats are listed in Exhibit C

5 tesolutions The gtermanent chairr1an 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

sdopted b a mcjority vote are included with these minutes

5 Other Business Ths permanent chairman then asked if there was any other business that shculd properly come before the convention

7 Announcemfnts 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 heshe would officially sign stal 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 (174027c) The chairman announced the time and place for the county or senatorial district cgtnvention

8 Adjournmen t In accordance vli~ha)motion properly moved and seconded and adopted by a majority vote the precinct convention was

ad~ed at iq pm I J fit~ -- ~-ed lZi Aft-t=

ermanent hairman ~ Secretary

Return to y)ur county chairman The permanent chairman should also IOpy and retain a record of all documents

PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

INSTRUCTIONS FOR THE PRECINCT CONVENTIONS

TIMEPLACE 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 700 pm and 900 pm 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 precincts 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 countysenatorial 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 Roberts 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 wwwtexasgoporg and click on the GOP Resources link

PREPARATION OF LIST OF QUALlFIED PARTICIPANTS Attendees must have voted in that precincts 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 heshe takes the chair and oversees the election of the permanent secretary If necessary the chairman and the secretary may be the same person

ANNOUNCEMENTOF COUNTYSENATORIAJ-PI~TRICT COflVENTION The convention will convene on Saturday March 29 th at IcY0cJ ~~ (time) in q76R kAfr-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 countysenatorial 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 countysenatorial 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 countysenatorial 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 countysenatorial 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

PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

Precinct GV gtPage I of -----L EXHIBIT A

Senate District __ List of qualified voters who ATTENDED precinct convention

VOTERCERT PRINT NAME PRINT MAILING ADDRESS CONTACT INFORMATION

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PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

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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 gtvas

Mrs Cahills 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 shy

--- - ~ --- - - ------- ---- -- - - _shy~-

VARGUMENT

The importance of this case

Then the United States Supreme Court in Morse v Republican Party

~11middotImiddotamiddot~~ ()4 29 7 117 TT C 86 1996 ~~d~ m~rle n~ rlJfe----- t ow ~VJ ~uuu 17 - JjJ1 LJJbull l 11 J ~al II II au IV U 11 lC11lC 11 d

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 US Congress See

United States v Clasic 313 US2999

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 US and

Texas Constitutions the Voters Rights Act passed by Congress and the

Election Laws of the State of Texas

And in particular the Relators 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 shy

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 Relators Request for mandamus

Title 10 of the Texas Election Code sect 273061 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 SW2d 86 (Tex 1997)

and 924 SW2d 932 (Tex1996) 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 states 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 OBrien v Brown 409 US 1 92 SCt 271834 LEd2d 1 (1972)

- 5 shy

---shy - ---shy

Party Officer is subject to mandamus

Section 161009 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

163007 also states that these rules are enforceable by writ of mandamus

Section 174027 (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 161004 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 174027 and 161004

allowing access to these documents is the implied duty placed upon Mr

Bertuzzi

- 6 shy

--- shy ~ ----shy - ~~-~ ~----

CONCLUSION

The exhibits attached to this petition provide some evidence that the respondent violated the equal protection clause of the 14th amendment by CAltgttnn noffilal delenatAs ltgtt thAountv nnAntnn ltgtnd lnclurlng thAI~vUll115 UJ v lS t Ul II IlJ vVll V vi ltV J Ul Ul 1 l Ivi

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 PO Box 2641 Corpus Christi Texas 78403 Tel (361) 888-9255 Fax (361) 888-9288

- 7 shy

--- - --- - ---shy- -~-

IN THE SUPREME COURT OF TEXAS

IN RE VANESSA CAHILL

Relator

VERIFlCATION

STATE OF TEXAS sect sect

COUNTY OF NlJECES sect

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 shy

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 shy

~eIT A NUECES COUNTY REPUBLICAN PARTY aD Corpus 4458 South Staples

Christi Texas 78411

(361 ) 994-9317 (361 ) 994-9343 FAX E-Mail ncrpcctxgrandecomnet

Mike Bertuzzi-ehairman Rebecca Bradford---Vice Chairman Aneie 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 Saturday March 29

th 2008 The time is 1000 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 1000

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 am (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 partys 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 Morganmiddot Rd and go toward Leopard St Take a right on Leopard St then take

fJOT tlo Q

centlt~ o~+-

I~(~ ~~)~lk~~~-~~ -s ~ middot)oR

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~~

OFFiCE OF THE SECRETARY OF 5T ATE

~Xvi[) A DFAN ITE CAfrrOl_ )~ ~ ro ~-~ fgt( G[)~ 261

~ _ ~ ~ i 1L gt- A S - 1 ~

]url(~ 74 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 Credenshytials 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~ 103 sUbd 1 (V~r~cn Supp 1982)

Tn your letter you inquired hether a crc~denti-ls conrni ttee of (l pol itical pgtty convcT~Ii(Jn could altor lt1 delegation by 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 1334 (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

____- -e~~ ~bull ~Wl -- -middotr ___

Mr Edward M Sullivan Page 2

SUIvl1ARY

Tex Elee Code Ann art 1334 (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 ir

7

~ I~(yfh~__

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 John 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 1334 (Vernon Supp_ 1982) provides

the sale method fer the selection of delegates to county and

state convertions 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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Alex Haupt antoniofratila Robert Lund Benjamin Bernier dmedinaprudent John Falasca Kay Fischer Margaret Fratila Paul Hunt ronpaul-10

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Committee Information from vanessa cahill ltvanessafratilagmailcomgt hide details Mar 6 Beply

to michaeLbertuzzimlcom date Mar 62008411 PM

subject Committee Information mailed-by gmailcom

Mr Bertuzzi

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 soon be able to put a face to the nameas the saying goes

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 what better time to do so than the election season With all of the hype surrounding the Democratic race I think it is important for everyone in our party to get involved so we can retain the White House in November

I am very interested in volunteering my time in any way triat I can I would love to serve on any of the committees as well as attend the meetings of the committees that are already full If at all possible could you send me a list of these committes and the scheduled meeting dates and times In addition could you give me the phone numberslemail addresses of Art Granado and Victor Bird I believe they are heading up the Nominations and Resolutions Committees

Also if my services are also needed at the headquarters feel free to contact me

Thank you for your patience

Sincerely Vanessa 832-816-2944

~ Forward

bull vanessa cahill to jfalasca show details Apr 5 Beply

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Request for Clarification Inbox

w vanessa cahill (Ni jdld Mar 16 Reply

Mr Bertuzzi

I would like to be sure that my recollection of our first telephone conversation is correct(March 6 2008) As per my memory I requested information on the dates 1imes and locations of the Credentials and Nominations Committees for Nueces County You then asked that I send my request in writing which I promptly did via email (March 6 2008) From the email attachment I received from Mike Bergsma (March 132008) I have made the reasonable assumption that you have opened and read my email request for this information

I would also like to clarify the second and last conversation we had over the telephone (March 12 2008) As per my memory you told me that you would not be providing to me the information I was requesting From what I understood your reluctance to provide the requested information to me stemmed from my affiliation with a local meetup group in which a fellow member Chuck Burnett voiced his opinions of local leadership in the Republican Party

I would also like clarification from you on the 14th Rule of the General Rules for All Conventions and Meetings of the Republican Party of Texas which states

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 to that convention

As a voter in the Republican Primary and a delegate in my precinct I would again like to request the dates times and locations for the following committees

Credentials Resolutions Rules and Nominations

In addition I would also like to request a copy of accurate written records (minutes) from every Precinct in Nueces County Please notify me when these copies have been completed and I will pick them up from the Republican Party Headquarters

Thank you for your time

( Newer 29 of 179 Older)

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httomailcooclecommaillui=1ampik=559db3fdOOampview=cvampsearch=sentampth=119c5ce2 5152008

err amp Cause No

VANESSA L CAHILL sect SUPREME COURT OF TEXAS

VS sect sect 201 W 14TH STREET RM 104 sect

NUECESCOUNTY sect AUSTIN TEXAS REPUBLICAN PARTY sect

sect REPUBLICAN PARTY OF TEXAS sect

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 ~~j)~A A it A

~ d i

~fS~~~i LINDA D ZEPEDA f ltJ r~~v Notary Public

~ bull STATE OF TEXAS ~

~~~l My Comm Exp 11262011I LOndo- P~CL~ V V V V

Printed Name

My commission expires 1-clt - 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 IIssrional d rllcctt l number of county Texas met at JMI+td Ge1-e-Ik __amp~ (location) on J-QQ f (date) to hold a precinct convention

1 Call to Order - I (I bull The convention was called to order by temporary chairman J) G( ( 1--~1 I----Th------------__ at 7 s-Opm

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~nelti~I1~911Igirttuen9~importantparjy decisions at subsequentcQnven~ions

3 Election of Permanent Officers The temporary chairman announced that nominations for permanent chairman of this precinct convention woUld be

acceh~~~tIlO~~ tft0ns were nominated as candidates --- shy

The convention elected baf SwtmiddotfI as permanent chairman of the precinct convention The convention elected =na~ 2- SOl r 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 Ill (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 ~ovention

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 beshe 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 reguiredPy Ryle 22 and the Election Code (1740270) 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~pm~_ 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

-i

f1 Precinct fl

0 EXIDBITB E Senate District 20 0 (l) List of DELEGATES elected to County I Senatorial District Convention (J

(J VOTERCERT PRINT NAME PRINT MAILING ADDRESS (l)

Flm 1)~h1e- MI F Plmnc (J

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First Ed i-~ MI JV1 Address 0 9gt 5~ La kevi t LAJ Pbo~ 30L - 334--lLA-Z- I JD3~3D 2D11 Last Srn ~~~ CitdSXDu5 ChiSt Zip 184-12 E-Mail

(J f (J First 1rL1 Address Pirone-i

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M1 IA~~ Ift~~ Citf Zip EmiddotMlIll

MJ IAdm IPbo Cin Zip E-M81l

MI IA_ IPh~ Cih~ bull Zip E-II-fail

M~ 1--- 1-City Zip E-Mail

gtLL 1--- IPh Citf Zip E-Mail

gt~ 1-- 1 Poo~ City Zip E-Mail

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PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

Page of ___

CONTACT INFO~1ATION

1-1 -334--124-2shy

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1 ~

I

SQT FCause No

VANESSA L CAHILL sect SUPREME COURT OF TEXAS sect

VS sect 201 W 14TH STREET RM 104 sect

NUECESCOUNTY sect AUSTIN TEXAS REPUBLICAN PARTY sect

sect REPUBLICAN PARTY OF TEXAS sect

BUSINESS RECORDS AFFIDAVIT

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

hereto are an exact duplicate of the original

Further affiant sayeth not

~lffmiddotLnL KayLu

SUBSCRIBED AND SWORN TO before me on this May 6 2008 to which I place my

signature and official seal )dQampyM-u J11du~ Signature

dele Jampylt-pound 71LeAJ Printed Name

My commission expires 1 -J-d~tcf Notary Public for the State of Texas

VICKIE JOY VAN MAREN Notary Public

STATE OF TEXAS My Comm Exp 10-05-2008

MINUTES OF THE REPUBLICAN PARTY PRECINCT CONVENTION

CJ3 ed v~ ters a election precinct nymber 5~g senate district numt er congressional district LJmber of ~ county Texas met at -nK~ ~4A-ltj (Jccion) C1 __trh-ltl lcJV L- oog (date) to hold a precinct convent xf

- CI to Order _-~ J r(3-1e ionver-tion as called to order by temporary chairman _dM~1 at ~-pm

P~pararon 0 List of Participants ( -le mpoary cr airmin 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 _ (numJer) 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 P3rty of Texas Rules adopted in accordance with the Election Code Robert Rules of Order current dit en neNly re ised would govern parliamentary procedure The temporary chairman then explained how the actions of lis mvention auld influence important party decisions at subsequent convlntions

-hE~onvention Elected as permanent chairman of the precinct convention

-~ Election of DI~legates and Alternates to the County or State Senatorial DistrictConvention -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 alternats are listed in Exhibit C

5 tesolutions The gtermanent chairr1an 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

sdopted b a mcjority vote are included with these minutes

5 Other Business Ths permanent chairman then asked if there was any other business that shculd properly come before the convention

7 Announcemfnts 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 heshe would officially sign stal 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 (174027c) The chairman announced the time and place for the county or senatorial district cgtnvention

8 Adjournmen t In accordance vli~ha)motion properly moved and seconded and adopted by a majority vote the precinct convention was

ad~ed at iq pm I J fit~ -- ~-ed lZi Aft-t=

ermanent hairman ~ Secretary

Return to y)ur county chairman The permanent chairman should also IOpy and retain a record of all documents

PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

INSTRUCTIONS FOR THE PRECINCT CONVENTIONS

TIMEPLACE 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 700 pm and 900 pm 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 precincts 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 countysenatorial 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 Roberts 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 wwwtexasgoporg and click on the GOP Resources link

PREPARATION OF LIST OF QUALlFIED PARTICIPANTS Attendees must have voted in that precincts 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 heshe takes the chair and oversees the election of the permanent secretary If necessary the chairman and the secretary may be the same person

ANNOUNCEMENTOF COUNTYSENATORIAJ-PI~TRICT COflVENTION The convention will convene on Saturday March 29 th at IcY0cJ ~~ (time) in q76R kAfr-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 countysenatorial 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 countysenatorial 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 countysenatorial 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 countysenatorial 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

PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

Precinct GV gtPage I of -----L EXHIBIT A

Senate District __ List of qualified voters who ATTENDED precinct convention

VOTERCERT PRINT NAME PRINT MAILING ADDRESS CONTACT INFORMATION

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VARGUMENT

The importance of this case

Then the United States Supreme Court in Morse v Republican Party

~11middotImiddotamiddot~~ ()4 29 7 117 TT C 86 1996 ~~d~ m~rle n~ rlJfe----- t ow ~VJ ~uuu 17 - JjJ1 LJJbull l 11 J ~al II II au IV U 11 lC11lC 11 d

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 US Congress See

United States v Clasic 313 US2999

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 US and

Texas Constitutions the Voters Rights Act passed by Congress and the

Election Laws of the State of Texas

And in particular the Relators 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 shy

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 Relators Request for mandamus

Title 10 of the Texas Election Code sect 273061 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 SW2d 86 (Tex 1997)

and 924 SW2d 932 (Tex1996) 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 states 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 OBrien v Brown 409 US 1 92 SCt 271834 LEd2d 1 (1972)

- 5 shy

---shy - ---shy

Party Officer is subject to mandamus

Section 161009 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

163007 also states that these rules are enforceable by writ of mandamus

Section 174027 (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 161004 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 174027 and 161004

allowing access to these documents is the implied duty placed upon Mr

Bertuzzi

- 6 shy

--- shy ~ ----shy - ~~-~ ~----

CONCLUSION

The exhibits attached to this petition provide some evidence that the respondent violated the equal protection clause of the 14th amendment by CAltgttnn noffilal delenatAs ltgtt thAountv nnAntnn ltgtnd lnclurlng thAI~vUll115 UJ v lS t Ul II IlJ vVll V vi ltV J Ul Ul 1 l Ivi

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 PO Box 2641 Corpus Christi Texas 78403 Tel (361) 888-9255 Fax (361) 888-9288

- 7 shy

--- - --- - ---shy- -~-

IN THE SUPREME COURT OF TEXAS

IN RE VANESSA CAHILL

Relator

VERIFlCATION

STATE OF TEXAS sect sect

COUNTY OF NlJECES sect

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 shy

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 shy

~eIT A NUECES COUNTY REPUBLICAN PARTY aD Corpus 4458 South Staples

Christi Texas 78411

(361 ) 994-9317 (361 ) 994-9343 FAX E-Mail ncrpcctxgrandecomnet

Mike Bertuzzi-ehairman Rebecca Bradford---Vice Chairman Aneie 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 Saturday March 29

th 2008 The time is 1000 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 1000

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 am (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 partys 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 Morganmiddot Rd and go toward Leopard St Take a right on Leopard St then take

fJOT tlo Q

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OFFiCE OF THE SECRETARY OF 5T ATE

~Xvi[) A DFAN ITE CAfrrOl_ )~ ~ ro ~-~ fgt( G[)~ 261

~ _ ~ ~ i 1L gt- A S - 1 ~

]url(~ 74 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 Credenshytials 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~ 103 sUbd 1 (V~r~cn Supp 1982)

Tn your letter you inquired hether a crc~denti-ls conrni ttee of (l pol itical pgtty convcT~Ii(Jn could altor lt1 delegation by 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 1334 (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

____- -e~~ ~bull ~Wl -- -middotr ___

Mr Edward M Sullivan Page 2

SUIvl1ARY

Tex Elee Code Ann art 1334 (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 ir

7

~ I~(yfh~__

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 John 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 1334 (Vernon Supp_ 1982) provides

the sale method fer the selection of delegates to county and

state convertions 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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Alex Haupt antoniofratila Robert Lund Benjamin Bernier dmedinaprudent John Falasca Kay Fischer Margaret Fratila Paul Hunt ronpaul-10

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Committee Information from vanessa cahill ltvanessafratilagmailcomgt hide details Mar 6 Beply

to michaeLbertuzzimlcom date Mar 62008411 PM

subject Committee Information mailed-by gmailcom

Mr Bertuzzi

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 soon be able to put a face to the nameas the saying goes

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 what better time to do so than the election season With all of the hype surrounding the Democratic race I think it is important for everyone in our party to get involved so we can retain the White House in November

I am very interested in volunteering my time in any way triat I can I would love to serve on any of the committees as well as attend the meetings of the committees that are already full If at all possible could you send me a list of these committes and the scheduled meeting dates and times In addition could you give me the phone numberslemail addresses of Art Granado and Victor Bird I believe they are heading up the Nominations and Resolutions Committees

Also if my services are also needed at the headquarters feel free to contact me

Thank you for your patience

Sincerely Vanessa 832-816-2944

~ Forward

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Request for Clarification Inbox

w vanessa cahill (Ni jdld Mar 16 Reply

Mr Bertuzzi

I would like to be sure that my recollection of our first telephone conversation is correct(March 6 2008) As per my memory I requested information on the dates 1imes and locations of the Credentials and Nominations Committees for Nueces County You then asked that I send my request in writing which I promptly did via email (March 6 2008) From the email attachment I received from Mike Bergsma (March 132008) I have made the reasonable assumption that you have opened and read my email request for this information

I would also like to clarify the second and last conversation we had over the telephone (March 12 2008) As per my memory you told me that you would not be providing to me the information I was requesting From what I understood your reluctance to provide the requested information to me stemmed from my affiliation with a local meetup group in which a fellow member Chuck Burnett voiced his opinions of local leadership in the Republican Party

I would also like clarification from you on the 14th Rule of the General Rules for All Conventions and Meetings of the Republican Party of Texas which states

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 to that convention

As a voter in the Republican Primary and a delegate in my precinct I would again like to request the dates times and locations for the following committees

Credentials Resolutions Rules and Nominations

In addition I would also like to request a copy of accurate written records (minutes) from every Precinct in Nueces County Please notify me when these copies have been completed and I will pick them up from the Republican Party Headquarters

Thank you for your time

( Newer 29 of 179 Older)

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httomailcooclecommaillui=1ampik=559db3fdOOampview=cvampsearch=sentampth=119c5ce2 5152008

err amp Cause No

VANESSA L CAHILL sect SUPREME COURT OF TEXAS

VS sect sect 201 W 14TH STREET RM 104 sect

NUECESCOUNTY sect AUSTIN TEXAS REPUBLICAN PARTY sect

sect REPUBLICAN PARTY OF TEXAS sect

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 ~~j)~A A it A

~ d i

~fS~~~i LINDA D ZEPEDA f ltJ r~~v Notary Public

~ bull STATE OF TEXAS ~

~~~l My Comm Exp 11262011I LOndo- P~CL~ V V V V

Printed Name

My commission expires 1-clt - 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 IIssrional d rllcctt l number of county Texas met at JMI+td Ge1-e-Ik __amp~ (location) on J-QQ f (date) to hold a precinct convention

1 Call to Order - I (I bull The convention was called to order by temporary chairman J) G( ( 1--~1 I----Th------------__ at 7 s-Opm

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~nelti~I1~911Igirttuen9~importantparjy decisions at subsequentcQnven~ions

3 Election of Permanent Officers The temporary chairman announced that nominations for permanent chairman of this precinct convention woUld be

acceh~~~tIlO~~ tft0ns were nominated as candidates --- shy

The convention elected baf SwtmiddotfI as permanent chairman of the precinct convention The convention elected =na~ 2- SOl r 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 Ill (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 ~ovention

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 beshe 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 reguiredPy Ryle 22 and the Election Code (1740270) 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~pm~_ 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

-i

f1 Precinct fl

0 EXIDBITB E Senate District 20 0 (l) List of DELEGATES elected to County I Senatorial District Convention (J

(J VOTERCERT PRINT NAME PRINT MAILING ADDRESS (l)

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PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

Page of ___

CONTACT INFO~1ATION

1-1 -334--124-2shy

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I

SQT FCause No

VANESSA L CAHILL sect SUPREME COURT OF TEXAS sect

VS sect 201 W 14TH STREET RM 104 sect

NUECESCOUNTY sect AUSTIN TEXAS REPUBLICAN PARTY sect

sect REPUBLICAN PARTY OF TEXAS sect

BUSINESS RECORDS AFFIDAVIT

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

hereto are an exact duplicate of the original

Further affiant sayeth not

~lffmiddotLnL KayLu

SUBSCRIBED AND SWORN TO before me on this May 6 2008 to which I place my

signature and official seal )dQampyM-u J11du~ Signature

dele Jampylt-pound 71LeAJ Printed Name

My commission expires 1 -J-d~tcf Notary Public for the State of Texas

VICKIE JOY VAN MAREN Notary Public

STATE OF TEXAS My Comm Exp 10-05-2008

MINUTES OF THE REPUBLICAN PARTY PRECINCT CONVENTION

CJ3 ed v~ ters a election precinct nymber 5~g senate district numt er congressional district LJmber of ~ county Texas met at -nK~ ~4A-ltj (Jccion) C1 __trh-ltl lcJV L- oog (date) to hold a precinct convent xf

- CI to Order _-~ J r(3-1e ionver-tion as called to order by temporary chairman _dM~1 at ~-pm

P~pararon 0 List of Participants ( -le mpoary cr airmin 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 _ (numJer) 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 P3rty of Texas Rules adopted in accordance with the Election Code Robert Rules of Order current dit en neNly re ised would govern parliamentary procedure The temporary chairman then explained how the actions of lis mvention auld influence important party decisions at subsequent convlntions

-hE~onvention Elected as permanent chairman of the precinct convention

-~ Election of DI~legates and Alternates to the County or State Senatorial DistrictConvention -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 alternats are listed in Exhibit C

5 tesolutions The gtermanent chairr1an 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

sdopted b a mcjority vote are included with these minutes

5 Other Business Ths permanent chairman then asked if there was any other business that shculd properly come before the convention

7 Announcemfnts 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 heshe would officially sign stal 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 (174027c) The chairman announced the time and place for the county or senatorial district cgtnvention

8 Adjournmen t In accordance vli~ha)motion properly moved and seconded and adopted by a majority vote the precinct convention was

ad~ed at iq pm I J fit~ -- ~-ed lZi Aft-t=

ermanent hairman ~ Secretary

Return to y)ur county chairman The permanent chairman should also IOpy and retain a record of all documents

PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

INSTRUCTIONS FOR THE PRECINCT CONVENTIONS

TIMEPLACE 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 700 pm and 900 pm 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 precincts 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 countysenatorial 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 Roberts 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 wwwtexasgoporg and click on the GOP Resources link

PREPARATION OF LIST OF QUALlFIED PARTICIPANTS Attendees must have voted in that precincts 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 heshe takes the chair and oversees the election of the permanent secretary If necessary the chairman and the secretary may be the same person

ANNOUNCEMENTOF COUNTYSENATORIAJ-PI~TRICT COflVENTION The convention will convene on Saturday March 29 th at IcY0cJ ~~ (time) in q76R kAfr-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 countysenatorial 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 countysenatorial 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 countysenatorial 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 countysenatorial 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

PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

Precinct GV gtPage I of -----L EXHIBIT A

Senate District __ List of qualified voters who ATTENDED precinct convention

VOTERCERT PRINT NAME PRINT MAILING ADDRESS CONTACT INFORMATION

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City Zip I E-Mail __1 Last 3 PR()VTnfD BY THE RFPHBUCAN PARTY OF TEXAS

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 Relators Request for mandamus

Title 10 of the Texas Election Code sect 273061 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 SW2d 86 (Tex 1997)

and 924 SW2d 932 (Tex1996) 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 states 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 OBrien v Brown 409 US 1 92 SCt 271834 LEd2d 1 (1972)

- 5 shy

---shy - ---shy

Party Officer is subject to mandamus

Section 161009 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

163007 also states that these rules are enforceable by writ of mandamus

Section 174027 (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 161004 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 174027 and 161004

allowing access to these documents is the implied duty placed upon Mr

Bertuzzi

- 6 shy

--- shy ~ ----shy - ~~-~ ~----

CONCLUSION

The exhibits attached to this petition provide some evidence that the respondent violated the equal protection clause of the 14th amendment by CAltgttnn noffilal delenatAs ltgtt thAountv nnAntnn ltgtnd lnclurlng thAI~vUll115 UJ v lS t Ul II IlJ vVll V vi ltV J Ul Ul 1 l Ivi

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 PO Box 2641 Corpus Christi Texas 78403 Tel (361) 888-9255 Fax (361) 888-9288

- 7 shy

--- - --- - ---shy- -~-

IN THE SUPREME COURT OF TEXAS

IN RE VANESSA CAHILL

Relator

VERIFlCATION

STATE OF TEXAS sect sect

COUNTY OF NlJECES sect

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 shy

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 shy

~eIT A NUECES COUNTY REPUBLICAN PARTY aD Corpus 4458 South Staples

Christi Texas 78411

(361 ) 994-9317 (361 ) 994-9343 FAX E-Mail ncrpcctxgrandecomnet

Mike Bertuzzi-ehairman Rebecca Bradford---Vice Chairman Aneie 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 Saturday March 29

th 2008 The time is 1000 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 1000

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 am (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 partys 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 Morganmiddot Rd and go toward Leopard St Take a right on Leopard St then take

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OFFiCE OF THE SECRETARY OF 5T ATE

~Xvi[) A DFAN ITE CAfrrOl_ )~ ~ ro ~-~ fgt( G[)~ 261

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]url(~ 74 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 Credenshytials 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~ 103 sUbd 1 (V~r~cn Supp 1982)

Tn your letter you inquired hether a crc~denti-ls conrni ttee of (l pol itical pgtty convcT~Ii(Jn could altor lt1 delegation by 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 1334 (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

____- -e~~ ~bull ~Wl -- -middotr ___

Mr Edward M Sullivan Page 2

SUIvl1ARY

Tex Elee Code Ann art 1334 (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 ir

7

~ I~(yfh~__

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 John 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 1334 (Vernon Supp_ 1982) provides

the sale method fer the selection of delegates to county and

state convertions 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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Alex Haupt antoniofratila Robert Lund Benjamin Bernier dmedinaprudent John Falasca Kay Fischer Margaret Fratila Paul Hunt ronpaul-10

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Committee Information from vanessa cahill ltvanessafratilagmailcomgt hide details Mar 6 Beply

to michaeLbertuzzimlcom date Mar 62008411 PM

subject Committee Information mailed-by gmailcom

Mr Bertuzzi

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 soon be able to put a face to the nameas the saying goes

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 what better time to do so than the election season With all of the hype surrounding the Democratic race I think it is important for everyone in our party to get involved so we can retain the White House in November

I am very interested in volunteering my time in any way triat I can I would love to serve on any of the committees as well as attend the meetings of the committees that are already full If at all possible could you send me a list of these committes and the scheduled meeting dates and times In addition could you give me the phone numberslemail addresses of Art Granado and Victor Bird I believe they are heading up the Nominations and Resolutions Committees

Also if my services are also needed at the headquarters feel free to contact me

Thank you for your patience

Sincerely Vanessa 832-816-2944

~ Forward

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Request for Clarification Inbox

w vanessa cahill (Ni jdld Mar 16 Reply

Mr Bertuzzi

I would like to be sure that my recollection of our first telephone conversation is correct(March 6 2008) As per my memory I requested information on the dates 1imes and locations of the Credentials and Nominations Committees for Nueces County You then asked that I send my request in writing which I promptly did via email (March 6 2008) From the email attachment I received from Mike Bergsma (March 132008) I have made the reasonable assumption that you have opened and read my email request for this information

I would also like to clarify the second and last conversation we had over the telephone (March 12 2008) As per my memory you told me that you would not be providing to me the information I was requesting From what I understood your reluctance to provide the requested information to me stemmed from my affiliation with a local meetup group in which a fellow member Chuck Burnett voiced his opinions of local leadership in the Republican Party

I would also like clarification from you on the 14th Rule of the General Rules for All Conventions and Meetings of the Republican Party of Texas which states

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 to that convention

As a voter in the Republican Primary and a delegate in my precinct I would again like to request the dates times and locations for the following committees

Credentials Resolutions Rules and Nominations

In addition I would also like to request a copy of accurate written records (minutes) from every Precinct in Nueces County Please notify me when these copies have been completed and I will pick them up from the Republican Party Headquarters

Thank you for your time

( Newer 29 of 179 Older)

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VANESSA L CAHILL sect SUPREME COURT OF TEXAS

VS sect sect 201 W 14TH STREET RM 104 sect

NUECESCOUNTY sect AUSTIN TEXAS REPUBLICAN PARTY sect

sect REPUBLICAN PARTY OF TEXAS sect

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 ~~j)~A A it A

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~fS~~~i LINDA D ZEPEDA f ltJ r~~v Notary Public

~ bull STATE OF TEXAS ~

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Printed Name

My commission expires 1-clt - 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 IIssrional d rllcctt l number of county Texas met at JMI+td Ge1-e-Ik __amp~ (location) on J-QQ f (date) to hold a precinct convention

1 Call to Order - I (I bull The convention was called to order by temporary chairman J) G( ( 1--~1 I----Th------------__ at 7 s-Opm

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~nelti~I1~911Igirttuen9~importantparjy decisions at subsequentcQnven~ions

3 Election of Permanent Officers The temporary chairman announced that nominations for permanent chairman of this precinct convention woUld be

acceh~~~tIlO~~ tft0ns were nominated as candidates --- shy

The convention elected baf SwtmiddotfI as permanent chairman of the precinct convention The convention elected =na~ 2- SOl r 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 Ill (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 ~ovention

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 beshe 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 reguiredPy Ryle 22 and the Election Code (1740270) 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~pm~_ 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

-i

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0 EXIDBITB E Senate District 20 0 (l) List of DELEGATES elected to County I Senatorial District Convention (J

(J VOTERCERT PRINT NAME PRINT MAILING ADDRESS (l)

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PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

Page of ___

CONTACT INFO~1ATION

1-1 -334--124-2shy

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SQT FCause No

VANESSA L CAHILL sect SUPREME COURT OF TEXAS sect

VS sect 201 W 14TH STREET RM 104 sect

NUECESCOUNTY sect AUSTIN TEXAS REPUBLICAN PARTY sect

sect REPUBLICAN PARTY OF TEXAS sect

BUSINESS RECORDS AFFIDAVIT

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

hereto are an exact duplicate of the original

Further affiant sayeth not

~lffmiddotLnL KayLu

SUBSCRIBED AND SWORN TO before me on this May 6 2008 to which I place my

signature and official seal )dQampyM-u J11du~ Signature

dele Jampylt-pound 71LeAJ Printed Name

My commission expires 1 -J-d~tcf Notary Public for the State of Texas

VICKIE JOY VAN MAREN Notary Public

STATE OF TEXAS My Comm Exp 10-05-2008

MINUTES OF THE REPUBLICAN PARTY PRECINCT CONVENTION

CJ3 ed v~ ters a election precinct nymber 5~g senate district numt er congressional district LJmber of ~ county Texas met at -nK~ ~4A-ltj (Jccion) C1 __trh-ltl lcJV L- oog (date) to hold a precinct convent xf

- CI to Order _-~ J r(3-1e ionver-tion as called to order by temporary chairman _dM~1 at ~-pm

P~pararon 0 List of Participants ( -le mpoary cr airmin 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 _ (numJer) 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 P3rty of Texas Rules adopted in accordance with the Election Code Robert Rules of Order current dit en neNly re ised would govern parliamentary procedure The temporary chairman then explained how the actions of lis mvention auld influence important party decisions at subsequent convlntions

-hE~onvention Elected as permanent chairman of the precinct convention

-~ Election of DI~legates and Alternates to the County or State Senatorial DistrictConvention -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 alternats are listed in Exhibit C

5 tesolutions The gtermanent chairr1an 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

sdopted b a mcjority vote are included with these minutes

5 Other Business Ths permanent chairman then asked if there was any other business that shculd properly come before the convention

7 Announcemfnts 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 heshe would officially sign stal 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 (174027c) The chairman announced the time and place for the county or senatorial district cgtnvention

8 Adjournmen t In accordance vli~ha)motion properly moved and seconded and adopted by a majority vote the precinct convention was

ad~ed at iq pm I J fit~ -- ~-ed lZi Aft-t=

ermanent hairman ~ Secretary

Return to y)ur county chairman The permanent chairman should also IOpy and retain a record of all documents

PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

INSTRUCTIONS FOR THE PRECINCT CONVENTIONS

TIMEPLACE 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 700 pm and 900 pm 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 precincts 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 countysenatorial 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 Roberts 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 wwwtexasgoporg and click on the GOP Resources link

PREPARATION OF LIST OF QUALlFIED PARTICIPANTS Attendees must have voted in that precincts 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 heshe takes the chair and oversees the election of the permanent secretary If necessary the chairman and the secretary may be the same person

ANNOUNCEMENTOF COUNTYSENATORIAJ-PI~TRICT COflVENTION The convention will convene on Saturday March 29 th at IcY0cJ ~~ (time) in q76R kAfr-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 countysenatorial 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 countysenatorial 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 countysenatorial 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 countysenatorial 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

PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

Precinct GV gtPage I of -----L EXHIBIT A

Senate District __ List of qualified voters who ATTENDED precinct convention

VOTERCERT PRINT NAME PRINT MAILING ADDRESS CONTACT INFORMATION

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PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

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First MI Address _____ I Phone

City Zip I E-Mail __1 Last 3 PR()VTnfD BY THE RFPHBUCAN PARTY OF TEXAS

Party Officer is subject to mandamus

Section 161009 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

163007 also states that these rules are enforceable by writ of mandamus

Section 174027 (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 161004 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 174027 and 161004

allowing access to these documents is the implied duty placed upon Mr

Bertuzzi

- 6 shy

--- shy ~ ----shy - ~~-~ ~----

CONCLUSION

The exhibits attached to this petition provide some evidence that the respondent violated the equal protection clause of the 14th amendment by CAltgttnn noffilal delenatAs ltgtt thAountv nnAntnn ltgtnd lnclurlng thAI~vUll115 UJ v lS t Ul II IlJ vVll V vi ltV J Ul Ul 1 l Ivi

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 PO Box 2641 Corpus Christi Texas 78403 Tel (361) 888-9255 Fax (361) 888-9288

- 7 shy

--- - --- - ---shy- -~-

IN THE SUPREME COURT OF TEXAS

IN RE VANESSA CAHILL

Relator

VERIFlCATION

STATE OF TEXAS sect sect

COUNTY OF NlJECES sect

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 shy

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 shy

~eIT A NUECES COUNTY REPUBLICAN PARTY aD Corpus 4458 South Staples

Christi Texas 78411

(361 ) 994-9317 (361 ) 994-9343 FAX E-Mail ncrpcctxgrandecomnet

Mike Bertuzzi-ehairman Rebecca Bradford---Vice Chairman Aneie 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 Saturday March 29

th 2008 The time is 1000 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 1000

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 am (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 partys 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 Morganmiddot Rd and go toward Leopard St Take a right on Leopard St then take

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OFFiCE OF THE SECRETARY OF 5T ATE

~Xvi[) A DFAN ITE CAfrrOl_ )~ ~ ro ~-~ fgt( G[)~ 261

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]url(~ 74 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 Credenshytials 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~ 103 sUbd 1 (V~r~cn Supp 1982)

Tn your letter you inquired hether a crc~denti-ls conrni ttee of (l pol itical pgtty convcT~Ii(Jn could altor lt1 delegation by 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 1334 (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

____- -e~~ ~bull ~Wl -- -middotr ___

Mr Edward M Sullivan Page 2

SUIvl1ARY

Tex Elee Code Ann art 1334 (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 ir

7

~ I~(yfh~__

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 John 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 1334 (Vernon Supp_ 1982) provides

the sale method fer the selection of delegates to county and

state convertions 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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Alex Haupt antoniofratila Robert Lund Benjamin Bernier dmedinaprudent John Falasca Kay Fischer Margaret Fratila Paul Hunt ronpaul-10

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Committee Information from vanessa cahill ltvanessafratilagmailcomgt hide details Mar 6 Beply

to michaeLbertuzzimlcom date Mar 62008411 PM

subject Committee Information mailed-by gmailcom

Mr Bertuzzi

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 soon be able to put a face to the nameas the saying goes

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 what better time to do so than the election season With all of the hype surrounding the Democratic race I think it is important for everyone in our party to get involved so we can retain the White House in November

I am very interested in volunteering my time in any way triat I can I would love to serve on any of the committees as well as attend the meetings of the committees that are already full If at all possible could you send me a list of these committes and the scheduled meeting dates and times In addition could you give me the phone numberslemail addresses of Art Granado and Victor Bird I believe they are heading up the Nominations and Resolutions Committees

Also if my services are also needed at the headquarters feel free to contact me

Thank you for your patience

Sincerely Vanessa 832-816-2944

~ Forward

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Request for Clarification Inbox

w vanessa cahill (Ni jdld Mar 16 Reply

Mr Bertuzzi

I would like to be sure that my recollection of our first telephone conversation is correct(March 6 2008) As per my memory I requested information on the dates 1imes and locations of the Credentials and Nominations Committees for Nueces County You then asked that I send my request in writing which I promptly did via email (March 6 2008) From the email attachment I received from Mike Bergsma (March 132008) I have made the reasonable assumption that you have opened and read my email request for this information

I would also like to clarify the second and last conversation we had over the telephone (March 12 2008) As per my memory you told me that you would not be providing to me the information I was requesting From what I understood your reluctance to provide the requested information to me stemmed from my affiliation with a local meetup group in which a fellow member Chuck Burnett voiced his opinions of local leadership in the Republican Party

I would also like clarification from you on the 14th Rule of the General Rules for All Conventions and Meetings of the Republican Party of Texas which states

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 to that convention

As a voter in the Republican Primary and a delegate in my precinct I would again like to request the dates times and locations for the following committees

Credentials Resolutions Rules and Nominations

In addition I would also like to request a copy of accurate written records (minutes) from every Precinct in Nueces County Please notify me when these copies have been completed and I will pick them up from the Republican Party Headquarters

Thank you for your time

( Newer 29 of 179 Older)

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err amp Cause No

VANESSA L CAHILL sect SUPREME COURT OF TEXAS

VS sect sect 201 W 14TH STREET RM 104 sect

NUECESCOUNTY sect AUSTIN TEXAS REPUBLICAN PARTY sect

sect REPUBLICAN PARTY OF TEXAS sect

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 ~~j)~A A it A

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~fS~~~i LINDA D ZEPEDA f ltJ r~~v Notary Public

~ bull STATE OF TEXAS ~

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Printed Name

My commission expires 1-clt - 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 IIssrional d rllcctt l number of county Texas met at JMI+td Ge1-e-Ik __amp~ (location) on J-QQ f (date) to hold a precinct convention

1 Call to Order - I (I bull The convention was called to order by temporary chairman J) G( ( 1--~1 I----Th------------__ at 7 s-Opm

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~nelti~I1~911Igirttuen9~importantparjy decisions at subsequentcQnven~ions

3 Election of Permanent Officers The temporary chairman announced that nominations for permanent chairman of this precinct convention woUld be

acceh~~~tIlO~~ tft0ns were nominated as candidates --- shy

The convention elected baf SwtmiddotfI as permanent chairman of the precinct convention The convention elected =na~ 2- SOl r 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 Ill (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 ~ovention

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 beshe 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 reguiredPy Ryle 22 and the Election Code (1740270) 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~pm~_ 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

-i

f1 Precinct fl

0 EXIDBITB E Senate District 20 0 (l) List of DELEGATES elected to County I Senatorial District Convention (J

(J VOTERCERT PRINT NAME PRINT MAILING ADDRESS (l)

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First Ed i-~ MI JV1 Address 0 9gt 5~ La kevi t LAJ Pbo~ 30L - 334--lLA-Z- I JD3~3D 2D11 Last Srn ~~~ CitdSXDu5 ChiSt Zip 184-12 E-Mail

(J f (J First 1rL1 Address Pirone-i

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M1 IA~~ Ift~~ Citf Zip EmiddotMlIll

MJ IAdm IPbo Cin Zip E-M81l

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PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

Page of ___

CONTACT INFO~1ATION

1-1 -334--124-2shy

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SQT FCause No

VANESSA L CAHILL sect SUPREME COURT OF TEXAS sect

VS sect 201 W 14TH STREET RM 104 sect

NUECESCOUNTY sect AUSTIN TEXAS REPUBLICAN PARTY sect

sect REPUBLICAN PARTY OF TEXAS sect

BUSINESS RECORDS AFFIDAVIT

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

hereto are an exact duplicate of the original

Further affiant sayeth not

~lffmiddotLnL KayLu

SUBSCRIBED AND SWORN TO before me on this May 6 2008 to which I place my

signature and official seal )dQampyM-u J11du~ Signature

dele Jampylt-pound 71LeAJ Printed Name

My commission expires 1 -J-d~tcf Notary Public for the State of Texas

VICKIE JOY VAN MAREN Notary Public

STATE OF TEXAS My Comm Exp 10-05-2008

MINUTES OF THE REPUBLICAN PARTY PRECINCT CONVENTION

CJ3 ed v~ ters a election precinct nymber 5~g senate district numt er congressional district LJmber of ~ county Texas met at -nK~ ~4A-ltj (Jccion) C1 __trh-ltl lcJV L- oog (date) to hold a precinct convent xf

- CI to Order _-~ J r(3-1e ionver-tion as called to order by temporary chairman _dM~1 at ~-pm

P~pararon 0 List of Participants ( -le mpoary cr airmin 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 _ (numJer) 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 P3rty of Texas Rules adopted in accordance with the Election Code Robert Rules of Order current dit en neNly re ised would govern parliamentary procedure The temporary chairman then explained how the actions of lis mvention auld influence important party decisions at subsequent convlntions

-hE~onvention Elected as permanent chairman of the precinct convention

-~ Election of DI~legates and Alternates to the County or State Senatorial DistrictConvention -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 alternats are listed in Exhibit C

5 tesolutions The gtermanent chairr1an 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

sdopted b a mcjority vote are included with these minutes

5 Other Business Ths permanent chairman then asked if there was any other business that shculd properly come before the convention

7 Announcemfnts 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 heshe would officially sign stal 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 (174027c) The chairman announced the time and place for the county or senatorial district cgtnvention

8 Adjournmen t In accordance vli~ha)motion properly moved and seconded and adopted by a majority vote the precinct convention was

ad~ed at iq pm I J fit~ -- ~-ed lZi Aft-t=

ermanent hairman ~ Secretary

Return to y)ur county chairman The permanent chairman should also IOpy and retain a record of all documents

PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

INSTRUCTIONS FOR THE PRECINCT CONVENTIONS

TIMEPLACE 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 700 pm and 900 pm 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 precincts 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 countysenatorial 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 Roberts 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 wwwtexasgoporg and click on the GOP Resources link

PREPARATION OF LIST OF QUALlFIED PARTICIPANTS Attendees must have voted in that precincts 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 heshe takes the chair and oversees the election of the permanent secretary If necessary the chairman and the secretary may be the same person

ANNOUNCEMENTOF COUNTYSENATORIAJ-PI~TRICT COflVENTION The convention will convene on Saturday March 29 th at IcY0cJ ~~ (time) in q76R kAfr-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 countysenatorial 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 countysenatorial 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 countysenatorial 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 countysenatorial 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

PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

Precinct GV gtPage I of -----L EXHIBIT A

Senate District __ List of qualified voters who ATTENDED precinct convention

VOTERCERT PRINT NAME PRINT MAILING ADDRESS CONTACT INFORMATION

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PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

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City Zip I E-Mail __1 Last 3 PR()VTnfD BY THE RFPHBUCAN PARTY OF TEXAS

CONCLUSION

The exhibits attached to this petition provide some evidence that the respondent violated the equal protection clause of the 14th amendment by CAltgttnn noffilal delenatAs ltgtt thAountv nnAntnn ltgtnd lnclurlng thAI~vUll115 UJ v lS t Ul II IlJ vVll V vi ltV J Ul Ul 1 l Ivi

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 PO Box 2641 Corpus Christi Texas 78403 Tel (361) 888-9255 Fax (361) 888-9288

- 7 shy

--- - --- - ---shy- -~-

IN THE SUPREME COURT OF TEXAS

IN RE VANESSA CAHILL

Relator

VERIFlCATION

STATE OF TEXAS sect sect

COUNTY OF NlJECES sect

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 shy

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 shy

~eIT A NUECES COUNTY REPUBLICAN PARTY aD Corpus 4458 South Staples

Christi Texas 78411

(361 ) 994-9317 (361 ) 994-9343 FAX E-Mail ncrpcctxgrandecomnet

Mike Bertuzzi-ehairman Rebecca Bradford---Vice Chairman Aneie 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 Saturday March 29

th 2008 The time is 1000 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 1000

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 am (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 partys 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 Morganmiddot Rd and go toward Leopard St Take a right on Leopard St then take

fJOT tlo Q

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OFFiCE OF THE SECRETARY OF 5T ATE

~Xvi[) A DFAN ITE CAfrrOl_ )~ ~ ro ~-~ fgt( G[)~ 261

~ _ ~ ~ i 1L gt- A S - 1 ~

]url(~ 74 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 Credenshytials 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~ 103 sUbd 1 (V~r~cn Supp 1982)

Tn your letter you inquired hether a crc~denti-ls conrni ttee of (l pol itical pgtty convcT~Ii(Jn could altor lt1 delegation by 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 1334 (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

____- -e~~ ~bull ~Wl -- -middotr ___

Mr Edward M Sullivan Page 2

SUIvl1ARY

Tex Elee Code Ann art 1334 (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 ir

7

~ I~(yfh~__

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 John 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 1334 (Vernon Supp_ 1982) provides

the sale method fer the selection of delegates to county and

state convertions 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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Alex Haupt antoniofratila Robert Lund Benjamin Bernier dmedinaprudent John Falasca Kay Fischer Margaret Fratila Paul Hunt ronpaul-10

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Committee Information from vanessa cahill ltvanessafratilagmailcomgt hide details Mar 6 Beply

to michaeLbertuzzimlcom date Mar 62008411 PM

subject Committee Information mailed-by gmailcom

Mr Bertuzzi

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 soon be able to put a face to the nameas the saying goes

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 what better time to do so than the election season With all of the hype surrounding the Democratic race I think it is important for everyone in our party to get involved so we can retain the White House in November

I am very interested in volunteering my time in any way triat I can I would love to serve on any of the committees as well as attend the meetings of the committees that are already full If at all possible could you send me a list of these committes and the scheduled meeting dates and times In addition could you give me the phone numberslemail addresses of Art Granado and Victor Bird I believe they are heading up the Nominations and Resolutions Committees

Also if my services are also needed at the headquarters feel free to contact me

Thank you for your patience

Sincerely Vanessa 832-816-2944

~ Forward

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Request for Clarification Inbox

w vanessa cahill (Ni jdld Mar 16 Reply

Mr Bertuzzi

I would like to be sure that my recollection of our first telephone conversation is correct(March 6 2008) As per my memory I requested information on the dates 1imes and locations of the Credentials and Nominations Committees for Nueces County You then asked that I send my request in writing which I promptly did via email (March 6 2008) From the email attachment I received from Mike Bergsma (March 132008) I have made the reasonable assumption that you have opened and read my email request for this information

I would also like to clarify the second and last conversation we had over the telephone (March 12 2008) As per my memory you told me that you would not be providing to me the information I was requesting From what I understood your reluctance to provide the requested information to me stemmed from my affiliation with a local meetup group in which a fellow member Chuck Burnett voiced his opinions of local leadership in the Republican Party

I would also like clarification from you on the 14th Rule of the General Rules for All Conventions and Meetings of the Republican Party of Texas which states

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 to that convention

As a voter in the Republican Primary and a delegate in my precinct I would again like to request the dates times and locations for the following committees

Credentials Resolutions Rules and Nominations

In addition I would also like to request a copy of accurate written records (minutes) from every Precinct in Nueces County Please notify me when these copies have been completed and I will pick them up from the Republican Party Headquarters

Thank you for your time

( Newer 29 of 179 Older)

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err amp Cause No

VANESSA L CAHILL sect SUPREME COURT OF TEXAS

VS sect sect 201 W 14TH STREET RM 104 sect

NUECESCOUNTY sect AUSTIN TEXAS REPUBLICAN PARTY sect

sect REPUBLICAN PARTY OF TEXAS sect

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 ~~j)~A A it A

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~fS~~~i LINDA D ZEPEDA f ltJ r~~v Notary Public

~ bull STATE OF TEXAS ~

~~~l My Comm Exp 11262011I LOndo- P~CL~ V V V V

Printed Name

My commission expires 1-clt - 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 IIssrional d rllcctt l number of county Texas met at JMI+td Ge1-e-Ik __amp~ (location) on J-QQ f (date) to hold a precinct convention

1 Call to Order - I (I bull The convention was called to order by temporary chairman J) G( ( 1--~1 I----Th------------__ at 7 s-Opm

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~nelti~I1~911Igirttuen9~importantparjy decisions at subsequentcQnven~ions

3 Election of Permanent Officers The temporary chairman announced that nominations for permanent chairman of this precinct convention woUld be

acceh~~~tIlO~~ tft0ns were nominated as candidates --- shy

The convention elected baf SwtmiddotfI as permanent chairman of the precinct convention The convention elected =na~ 2- SOl r 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 Ill (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 ~ovention

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 beshe 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 reguiredPy Ryle 22 and the Election Code (1740270) 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~pm~_ 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

-i

f1 Precinct fl

0 EXIDBITB E Senate District 20 0 (l) List of DELEGATES elected to County I Senatorial District Convention (J

(J VOTERCERT PRINT NAME PRINT MAILING ADDRESS (l)

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First Ed i-~ MI JV1 Address 0 9gt 5~ La kevi t LAJ Pbo~ 30L - 334--lLA-Z- I JD3~3D 2D11 Last Srn ~~~ CitdSXDu5 ChiSt Zip 184-12 E-Mail

(J f (J First 1rL1 Address Pirone-i

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M1 IA~~ Ift~~ Citf Zip EmiddotMlIll

MJ IAdm IPbo Cin Zip E-M81l

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M~ 1--- 1-City Zip E-Mail

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PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

Page of ___

CONTACT INFO~1ATION

1-1 -334--124-2shy

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I

SQT FCause No

VANESSA L CAHILL sect SUPREME COURT OF TEXAS sect

VS sect 201 W 14TH STREET RM 104 sect

NUECESCOUNTY sect AUSTIN TEXAS REPUBLICAN PARTY sect

sect REPUBLICAN PARTY OF TEXAS sect

BUSINESS RECORDS AFFIDAVIT

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

hereto are an exact duplicate of the original

Further affiant sayeth not

~lffmiddotLnL KayLu

SUBSCRIBED AND SWORN TO before me on this May 6 2008 to which I place my

signature and official seal )dQampyM-u J11du~ Signature

dele Jampylt-pound 71LeAJ Printed Name

My commission expires 1 -J-d~tcf Notary Public for the State of Texas

VICKIE JOY VAN MAREN Notary Public

STATE OF TEXAS My Comm Exp 10-05-2008

MINUTES OF THE REPUBLICAN PARTY PRECINCT CONVENTION

CJ3 ed v~ ters a election precinct nymber 5~g senate district numt er congressional district LJmber of ~ county Texas met at -nK~ ~4A-ltj (Jccion) C1 __trh-ltl lcJV L- oog (date) to hold a precinct convent xf

- CI to Order _-~ J r(3-1e ionver-tion as called to order by temporary chairman _dM~1 at ~-pm

P~pararon 0 List of Participants ( -le mpoary cr airmin 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 _ (numJer) 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 P3rty of Texas Rules adopted in accordance with the Election Code Robert Rules of Order current dit en neNly re ised would govern parliamentary procedure The temporary chairman then explained how the actions of lis mvention auld influence important party decisions at subsequent convlntions

-hE~onvention Elected as permanent chairman of the precinct convention

-~ Election of DI~legates and Alternates to the County or State Senatorial DistrictConvention -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 alternats are listed in Exhibit C

5 tesolutions The gtermanent chairr1an 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

sdopted b a mcjority vote are included with these minutes

5 Other Business Ths permanent chairman then asked if there was any other business that shculd properly come before the convention

7 Announcemfnts 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 heshe would officially sign stal 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 (174027c) The chairman announced the time and place for the county or senatorial district cgtnvention

8 Adjournmen t In accordance vli~ha)motion properly moved and seconded and adopted by a majority vote the precinct convention was

ad~ed at iq pm I J fit~ -- ~-ed lZi Aft-t=

ermanent hairman ~ Secretary

Return to y)ur county chairman The permanent chairman should also IOpy and retain a record of all documents

PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

INSTRUCTIONS FOR THE PRECINCT CONVENTIONS

TIMEPLACE 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 700 pm and 900 pm 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 precincts 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 countysenatorial 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 Roberts 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 wwwtexasgoporg and click on the GOP Resources link

PREPARATION OF LIST OF QUALlFIED PARTICIPANTS Attendees must have voted in that precincts 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 heshe takes the chair and oversees the election of the permanent secretary If necessary the chairman and the secretary may be the same person

ANNOUNCEMENTOF COUNTYSENATORIAJ-PI~TRICT COflVENTION The convention will convene on Saturday March 29 th at IcY0cJ ~~ (time) in q76R kAfr-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 countysenatorial 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 countysenatorial 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 countysenatorial 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 countysenatorial 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

PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

Precinct GV gtPage I of -----L EXHIBIT A

Senate District __ List of qualified voters who ATTENDED precinct convention

VOTERCERT PRINT NAME PRINT MAILING ADDRESS CONTACT INFORMATION

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PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

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First MI Address _____ I Phone

City Zip I E-Mail __1 Last 3 PR()VTnfD BY THE RFPHBUCAN PARTY OF TEXAS

IN THE SUPREME COURT OF TEXAS

IN RE VANESSA CAHILL

Relator

VERIFlCATION

STATE OF TEXAS sect sect

COUNTY OF NlJECES sect

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 shy

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 shy

~eIT A NUECES COUNTY REPUBLICAN PARTY aD Corpus 4458 South Staples

Christi Texas 78411

(361 ) 994-9317 (361 ) 994-9343 FAX E-Mail ncrpcctxgrandecomnet

Mike Bertuzzi-ehairman Rebecca Bradford---Vice Chairman Aneie 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 Saturday March 29

th 2008 The time is 1000 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 1000

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 am (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 partys 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 Morganmiddot Rd and go toward Leopard St Take a right on Leopard St then take

fJOT tlo Q

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OFFiCE OF THE SECRETARY OF 5T ATE

~Xvi[) A DFAN ITE CAfrrOl_ )~ ~ ro ~-~ fgt( G[)~ 261

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]url(~ 74 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 Credenshytials 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~ 103 sUbd 1 (V~r~cn Supp 1982)

Tn your letter you inquired hether a crc~denti-ls conrni ttee of (l pol itical pgtty convcT~Ii(Jn could altor lt1 delegation by 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 1334 (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

____- -e~~ ~bull ~Wl -- -middotr ___

Mr Edward M Sullivan Page 2

SUIvl1ARY

Tex Elee Code Ann art 1334 (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 ir

7

~ I~(yfh~__

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 John 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 1334 (Vernon Supp_ 1982) provides

the sale method fer the selection of delegates to county and

state convertions 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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Alex Haupt antoniofratila Robert Lund Benjamin Bernier dmedinaprudent John Falasca Kay Fischer Margaret Fratila Paul Hunt ronpaul-10

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Committee Information from vanessa cahill ltvanessafratilagmailcomgt hide details Mar 6 Beply

to michaeLbertuzzimlcom date Mar 62008411 PM

subject Committee Information mailed-by gmailcom

Mr Bertuzzi

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 soon be able to put a face to the nameas the saying goes

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 what better time to do so than the election season With all of the hype surrounding the Democratic race I think it is important for everyone in our party to get involved so we can retain the White House in November

I am very interested in volunteering my time in any way triat I can I would love to serve on any of the committees as well as attend the meetings of the committees that are already full If at all possible could you send me a list of these committes and the scheduled meeting dates and times In addition could you give me the phone numberslemail addresses of Art Granado and Victor Bird I believe they are heading up the Nominations and Resolutions Committees

Also if my services are also needed at the headquarters feel free to contact me

Thank you for your patience

Sincerely Vanessa 832-816-2944

~ Forward

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Request for Clarification Inbox

w vanessa cahill (Ni jdld Mar 16 Reply

Mr Bertuzzi

I would like to be sure that my recollection of our first telephone conversation is correct(March 6 2008) As per my memory I requested information on the dates 1imes and locations of the Credentials and Nominations Committees for Nueces County You then asked that I send my request in writing which I promptly did via email (March 6 2008) From the email attachment I received from Mike Bergsma (March 132008) I have made the reasonable assumption that you have opened and read my email request for this information

I would also like to clarify the second and last conversation we had over the telephone (March 12 2008) As per my memory you told me that you would not be providing to me the information I was requesting From what I understood your reluctance to provide the requested information to me stemmed from my affiliation with a local meetup group in which a fellow member Chuck Burnett voiced his opinions of local leadership in the Republican Party

I would also like clarification from you on the 14th Rule of the General Rules for All Conventions and Meetings of the Republican Party of Texas which states

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 to that convention

As a voter in the Republican Primary and a delegate in my precinct I would again like to request the dates times and locations for the following committees

Credentials Resolutions Rules and Nominations

In addition I would also like to request a copy of accurate written records (minutes) from every Precinct in Nueces County Please notify me when these copies have been completed and I will pick them up from the Republican Party Headquarters

Thank you for your time

( Newer 29 of 179 Older)

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err amp Cause No

VANESSA L CAHILL sect SUPREME COURT OF TEXAS

VS sect sect 201 W 14TH STREET RM 104 sect

NUECESCOUNTY sect AUSTIN TEXAS REPUBLICAN PARTY sect

sect REPUBLICAN PARTY OF TEXAS sect

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 ~~j)~A A it A

~ d i

~fS~~~i LINDA D ZEPEDA f ltJ r~~v Notary Public

~ bull STATE OF TEXAS ~

~~~l My Comm Exp 11262011I LOndo- P~CL~ V V V V

Printed Name

My commission expires 1-clt - 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 IIssrional d rllcctt l number of county Texas met at JMI+td Ge1-e-Ik __amp~ (location) on J-QQ f (date) to hold a precinct convention

1 Call to Order - I (I bull The convention was called to order by temporary chairman J) G( ( 1--~1 I----Th------------__ at 7 s-Opm

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~nelti~I1~911Igirttuen9~importantparjy decisions at subsequentcQnven~ions

3 Election of Permanent Officers The temporary chairman announced that nominations for permanent chairman of this precinct convention woUld be

acceh~~~tIlO~~ tft0ns were nominated as candidates --- shy

The convention elected baf SwtmiddotfI as permanent chairman of the precinct convention The convention elected =na~ 2- SOl r 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 Ill (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 ~ovention

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 beshe 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 reguiredPy Ryle 22 and the Election Code (1740270) 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~pm~_ 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

-i

f1 Precinct fl

0 EXIDBITB E Senate District 20 0 (l) List of DELEGATES elected to County I Senatorial District Convention (J

(J VOTERCERT PRINT NAME PRINT MAILING ADDRESS (l)

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First Ed i-~ MI JV1 Address 0 9gt 5~ La kevi t LAJ Pbo~ 30L - 334--lLA-Z- I JD3~3D 2D11 Last Srn ~~~ CitdSXDu5 ChiSt Zip 184-12 E-Mail

(J f (J First 1rL1 Address Pirone-i

f Lim On ZiD E-Mail11

M1 IA~~ Ift~~ Citf Zip EmiddotMlIll

MJ IAdm IPbo Cin Zip E-M81l

MI IA_ IPh~ Cih~ bull Zip E-II-fail

M~ 1--- 1-City Zip E-Mail

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PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

Page of ___

CONTACT INFO~1ATION

1-1 -334--124-2shy

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SQT FCause No

VANESSA L CAHILL sect SUPREME COURT OF TEXAS sect

VS sect 201 W 14TH STREET RM 104 sect

NUECESCOUNTY sect AUSTIN TEXAS REPUBLICAN PARTY sect

sect REPUBLICAN PARTY OF TEXAS sect

BUSINESS RECORDS AFFIDAVIT

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

hereto are an exact duplicate of the original

Further affiant sayeth not

~lffmiddotLnL KayLu

SUBSCRIBED AND SWORN TO before me on this May 6 2008 to which I place my

signature and official seal )dQampyM-u J11du~ Signature

dele Jampylt-pound 71LeAJ Printed Name

My commission expires 1 -J-d~tcf Notary Public for the State of Texas

VICKIE JOY VAN MAREN Notary Public

STATE OF TEXAS My Comm Exp 10-05-2008

MINUTES OF THE REPUBLICAN PARTY PRECINCT CONVENTION

CJ3 ed v~ ters a election precinct nymber 5~g senate district numt er congressional district LJmber of ~ county Texas met at -nK~ ~4A-ltj (Jccion) C1 __trh-ltl lcJV L- oog (date) to hold a precinct convent xf

- CI to Order _-~ J r(3-1e ionver-tion as called to order by temporary chairman _dM~1 at ~-pm

P~pararon 0 List of Participants ( -le mpoary cr airmin 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 _ (numJer) 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 P3rty of Texas Rules adopted in accordance with the Election Code Robert Rules of Order current dit en neNly re ised would govern parliamentary procedure The temporary chairman then explained how the actions of lis mvention auld influence important party decisions at subsequent convlntions

-hE~onvention Elected as permanent chairman of the precinct convention

-~ Election of DI~legates and Alternates to the County or State Senatorial DistrictConvention -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 alternats are listed in Exhibit C

5 tesolutions The gtermanent chairr1an 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

sdopted b a mcjority vote are included with these minutes

5 Other Business Ths permanent chairman then asked if there was any other business that shculd properly come before the convention

7 Announcemfnts 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 heshe would officially sign stal 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 (174027c) The chairman announced the time and place for the county or senatorial district cgtnvention

8 Adjournmen t In accordance vli~ha)motion properly moved and seconded and adopted by a majority vote the precinct convention was

ad~ed at iq pm I J fit~ -- ~-ed lZi Aft-t=

ermanent hairman ~ Secretary

Return to y)ur county chairman The permanent chairman should also IOpy and retain a record of all documents

PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

INSTRUCTIONS FOR THE PRECINCT CONVENTIONS

TIMEPLACE 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 700 pm and 900 pm 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 precincts 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 countysenatorial 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 Roberts 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 wwwtexasgoporg and click on the GOP Resources link

PREPARATION OF LIST OF QUALlFIED PARTICIPANTS Attendees must have voted in that precincts 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 heshe takes the chair and oversees the election of the permanent secretary If necessary the chairman and the secretary may be the same person

ANNOUNCEMENTOF COUNTYSENATORIAJ-PI~TRICT COflVENTION The convention will convene on Saturday March 29 th at IcY0cJ ~~ (time) in q76R kAfr-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 countysenatorial 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 countysenatorial 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 countysenatorial 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 countysenatorial 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

PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

Precinct GV gtPage I of -----L EXHIBIT A

Senate District __ List of qualified voters who ATTENDED precinct convention

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City Zip I E-Mail __1 Last 3 PR()VTnfD BY THE RFPHBUCAN PARTY OF TEXAS

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 shy

~eIT A NUECES COUNTY REPUBLICAN PARTY aD Corpus 4458 South Staples

Christi Texas 78411

(361 ) 994-9317 (361 ) 994-9343 FAX E-Mail ncrpcctxgrandecomnet

Mike Bertuzzi-ehairman Rebecca Bradford---Vice Chairman Aneie 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 Saturday March 29

th 2008 The time is 1000 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 1000

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 am (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 partys 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 Morganmiddot Rd and go toward Leopard St Take a right on Leopard St then take

fJOT tlo Q

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OFFiCE OF THE SECRETARY OF 5T ATE

~Xvi[) A DFAN ITE CAfrrOl_ )~ ~ ro ~-~ fgt( G[)~ 261

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]url(~ 74 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 Credenshytials 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~ 103 sUbd 1 (V~r~cn Supp 1982)

Tn your letter you inquired hether a crc~denti-ls conrni ttee of (l pol itical pgtty convcT~Ii(Jn could altor lt1 delegation by 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 1334 (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

____- -e~~ ~bull ~Wl -- -middotr ___

Mr Edward M Sullivan Page 2

SUIvl1ARY

Tex Elee Code Ann art 1334 (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 ir

7

~ I~(yfh~__

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 John 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 1334 (Vernon Supp_ 1982) provides

the sale method fer the selection of delegates to county and

state convertions 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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Alex Haupt antoniofratila Robert Lund Benjamin Bernier dmedinaprudent John Falasca Kay Fischer Margaret Fratila Paul Hunt ronpaul-10

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Committee Information from vanessa cahill ltvanessafratilagmailcomgt hide details Mar 6 Beply

to michaeLbertuzzimlcom date Mar 62008411 PM

subject Committee Information mailed-by gmailcom

Mr Bertuzzi

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 soon be able to put a face to the nameas the saying goes

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 what better time to do so than the election season With all of the hype surrounding the Democratic race I think it is important for everyone in our party to get involved so we can retain the White House in November

I am very interested in volunteering my time in any way triat I can I would love to serve on any of the committees as well as attend the meetings of the committees that are already full If at all possible could you send me a list of these committes and the scheduled meeting dates and times In addition could you give me the phone numberslemail addresses of Art Granado and Victor Bird I believe they are heading up the Nominations and Resolutions Committees

Also if my services are also needed at the headquarters feel free to contact me

Thank you for your patience

Sincerely Vanessa 832-816-2944

~ Forward

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Request for Clarification Inbox

w vanessa cahill (Ni jdld Mar 16 Reply

Mr Bertuzzi

I would like to be sure that my recollection of our first telephone conversation is correct(March 6 2008) As per my memory I requested information on the dates 1imes and locations of the Credentials and Nominations Committees for Nueces County You then asked that I send my request in writing which I promptly did via email (March 6 2008) From the email attachment I received from Mike Bergsma (March 132008) I have made the reasonable assumption that you have opened and read my email request for this information

I would also like to clarify the second and last conversation we had over the telephone (March 12 2008) As per my memory you told me that you would not be providing to me the information I was requesting From what I understood your reluctance to provide the requested information to me stemmed from my affiliation with a local meetup group in which a fellow member Chuck Burnett voiced his opinions of local leadership in the Republican Party

I would also like clarification from you on the 14th Rule of the General Rules for All Conventions and Meetings of the Republican Party of Texas which states

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 to that convention

As a voter in the Republican Primary and a delegate in my precinct I would again like to request the dates times and locations for the following committees

Credentials Resolutions Rules and Nominations

In addition I would also like to request a copy of accurate written records (minutes) from every Precinct in Nueces County Please notify me when these copies have been completed and I will pick them up from the Republican Party Headquarters

Thank you for your time

( Newer 29 of 179 Older)

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err amp Cause No

VANESSA L CAHILL sect SUPREME COURT OF TEXAS

VS sect sect 201 W 14TH STREET RM 104 sect

NUECESCOUNTY sect AUSTIN TEXAS REPUBLICAN PARTY sect

sect REPUBLICAN PARTY OF TEXAS sect

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 ~~j)~A A it A

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~fS~~~i LINDA D ZEPEDA f ltJ r~~v Notary Public

~ bull STATE OF TEXAS ~

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Printed Name

My commission expires 1-clt - 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 IIssrional d rllcctt l number of county Texas met at JMI+td Ge1-e-Ik __amp~ (location) on J-QQ f (date) to hold a precinct convention

1 Call to Order - I (I bull The convention was called to order by temporary chairman J) G( ( 1--~1 I----Th------------__ at 7 s-Opm

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~nelti~I1~911Igirttuen9~importantparjy decisions at subsequentcQnven~ions

3 Election of Permanent Officers The temporary chairman announced that nominations for permanent chairman of this precinct convention woUld be

acceh~~~tIlO~~ tft0ns were nominated as candidates --- shy

The convention elected baf SwtmiddotfI as permanent chairman of the precinct convention The convention elected =na~ 2- SOl r 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 Ill (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 ~ovention

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 beshe 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 reguiredPy Ryle 22 and the Election Code (1740270) 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~pm~_ 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

-i

f1 Precinct fl

0 EXIDBITB E Senate District 20 0 (l) List of DELEGATES elected to County I Senatorial District Convention (J

(J VOTERCERT PRINT NAME PRINT MAILING ADDRESS (l)

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First Ed i-~ MI JV1 Address 0 9gt 5~ La kevi t LAJ Pbo~ 30L - 334--lLA-Z- I JD3~3D 2D11 Last Srn ~~~ CitdSXDu5 ChiSt Zip 184-12 E-Mail

(J f (J First 1rL1 Address Pirone-i

f Lim On ZiD E-Mail11

M1 IA~~ Ift~~ Citf Zip EmiddotMlIll

MJ IAdm IPbo Cin Zip E-M81l

MI IA_ IPh~ Cih~ bull Zip E-II-fail

M~ 1--- 1-City Zip E-Mail

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PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

Page of ___

CONTACT INFO~1ATION

1-1 -334--124-2shy

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SQT FCause No

VANESSA L CAHILL sect SUPREME COURT OF TEXAS sect

VS sect 201 W 14TH STREET RM 104 sect

NUECESCOUNTY sect AUSTIN TEXAS REPUBLICAN PARTY sect

sect REPUBLICAN PARTY OF TEXAS sect

BUSINESS RECORDS AFFIDAVIT

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

hereto are an exact duplicate of the original

Further affiant sayeth not

~lffmiddotLnL KayLu

SUBSCRIBED AND SWORN TO before me on this May 6 2008 to which I place my

signature and official seal )dQampyM-u J11du~ Signature

dele Jampylt-pound 71LeAJ Printed Name

My commission expires 1 -J-d~tcf Notary Public for the State of Texas

VICKIE JOY VAN MAREN Notary Public

STATE OF TEXAS My Comm Exp 10-05-2008

MINUTES OF THE REPUBLICAN PARTY PRECINCT CONVENTION

CJ3 ed v~ ters a election precinct nymber 5~g senate district numt er congressional district LJmber of ~ county Texas met at -nK~ ~4A-ltj (Jccion) C1 __trh-ltl lcJV L- oog (date) to hold a precinct convent xf

- CI to Order _-~ J r(3-1e ionver-tion as called to order by temporary chairman _dM~1 at ~-pm

P~pararon 0 List of Participants ( -le mpoary cr airmin 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 _ (numJer) 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 P3rty of Texas Rules adopted in accordance with the Election Code Robert Rules of Order current dit en neNly re ised would govern parliamentary procedure The temporary chairman then explained how the actions of lis mvention auld influence important party decisions at subsequent convlntions

-hE~onvention Elected as permanent chairman of the precinct convention

-~ Election of DI~legates and Alternates to the County or State Senatorial DistrictConvention -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 alternats are listed in Exhibit C

5 tesolutions The gtermanent chairr1an 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

sdopted b a mcjority vote are included with these minutes

5 Other Business Ths permanent chairman then asked if there was any other business that shculd properly come before the convention

7 Announcemfnts 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 heshe would officially sign stal 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 (174027c) The chairman announced the time and place for the county or senatorial district cgtnvention

8 Adjournmen t In accordance vli~ha)motion properly moved and seconded and adopted by a majority vote the precinct convention was

ad~ed at iq pm I J fit~ -- ~-ed lZi Aft-t=

ermanent hairman ~ Secretary

Return to y)ur county chairman The permanent chairman should also IOpy and retain a record of all documents

PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

INSTRUCTIONS FOR THE PRECINCT CONVENTIONS

TIMEPLACE 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 700 pm and 900 pm 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 precincts 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 countysenatorial 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 Roberts 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 wwwtexasgoporg and click on the GOP Resources link

PREPARATION OF LIST OF QUALlFIED PARTICIPANTS Attendees must have voted in that precincts 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 heshe takes the chair and oversees the election of the permanent secretary If necessary the chairman and the secretary may be the same person

ANNOUNCEMENTOF COUNTYSENATORIAJ-PI~TRICT COflVENTION The convention will convene on Saturday March 29 th at IcY0cJ ~~ (time) in q76R kAfr-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 countysenatorial 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 countysenatorial 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 countysenatorial 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 countysenatorial 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

PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

Precinct GV gtPage I of -----L EXHIBIT A

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~eIT A NUECES COUNTY REPUBLICAN PARTY aD Corpus 4458 South Staples

Christi Texas 78411

(361 ) 994-9317 (361 ) 994-9343 FAX E-Mail ncrpcctxgrandecomnet

Mike Bertuzzi-ehairman Rebecca Bradford---Vice Chairman Aneie 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 Saturday March 29

th 2008 The time is 1000 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 1000

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 am (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 partys 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 Morganmiddot Rd and go toward Leopard St Take a right on Leopard St then take

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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 Credenshytials 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~ 103 sUbd 1 (V~r~cn Supp 1982)

Tn your letter you inquired hether a crc~denti-ls conrni ttee of (l pol itical pgtty convcT~Ii(Jn could altor lt1 delegation by 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 1334 (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

____- -e~~ ~bull ~Wl -- -middotr ___

Mr Edward M Sullivan Page 2

SUIvl1ARY

Tex Elee Code Ann art 1334 (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 ir

7

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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 John 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 1334 (Vernon Supp_ 1982) provides

the sale method fer the selection of delegates to county and

state convertions 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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Alex Haupt antoniofratila Robert Lund Benjamin Bernier dmedinaprudent John Falasca Kay Fischer Margaret Fratila Paul Hunt ronpaul-10

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Committee Information from vanessa cahill ltvanessafratilagmailcomgt hide details Mar 6 Beply

to michaeLbertuzzimlcom date Mar 62008411 PM

subject Committee Information mailed-by gmailcom

Mr Bertuzzi

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 soon be able to put a face to the nameas the saying goes

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 what better time to do so than the election season With all of the hype surrounding the Democratic race I think it is important for everyone in our party to get involved so we can retain the White House in November

I am very interested in volunteering my time in any way triat I can I would love to serve on any of the committees as well as attend the meetings of the committees that are already full If at all possible could you send me a list of these committes and the scheduled meeting dates and times In addition could you give me the phone numberslemail addresses of Art Granado and Victor Bird I believe they are heading up the Nominations and Resolutions Committees

Also if my services are also needed at the headquarters feel free to contact me

Thank you for your patience

Sincerely Vanessa 832-816-2944

~ Forward

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Request for Clarification Inbox

w vanessa cahill (Ni jdld Mar 16 Reply

Mr Bertuzzi

I would like to be sure that my recollection of our first telephone conversation is correct(March 6 2008) As per my memory I requested information on the dates 1imes and locations of the Credentials and Nominations Committees for Nueces County You then asked that I send my request in writing which I promptly did via email (March 6 2008) From the email attachment I received from Mike Bergsma (March 132008) I have made the reasonable assumption that you have opened and read my email request for this information

I would also like to clarify the second and last conversation we had over the telephone (March 12 2008) As per my memory you told me that you would not be providing to me the information I was requesting From what I understood your reluctance to provide the requested information to me stemmed from my affiliation with a local meetup group in which a fellow member Chuck Burnett voiced his opinions of local leadership in the Republican Party

I would also like clarification from you on the 14th Rule of the General Rules for All Conventions and Meetings of the Republican Party of Texas which states

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 to that convention

As a voter in the Republican Primary and a delegate in my precinct I would again like to request the dates times and locations for the following committees

Credentials Resolutions Rules and Nominations

In addition I would also like to request a copy of accurate written records (minutes) from every Precinct in Nueces County Please notify me when these copies have been completed and I will pick them up from the Republican Party Headquarters

Thank you for your time

( Newer 29 of 179 Older)

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VANESSA L CAHILL sect SUPREME COURT OF TEXAS

VS sect sect 201 W 14TH STREET RM 104 sect

NUECESCOUNTY sect AUSTIN TEXAS REPUBLICAN PARTY sect

sect REPUBLICAN PARTY OF TEXAS sect

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 ~~j)~A A it A

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~fS~~~i LINDA D ZEPEDA f ltJ r~~v Notary Public

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Printed Name

My commission expires 1-clt - 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 IIssrional d rllcctt l number of county Texas met at JMI+td Ge1-e-Ik __amp~ (location) on J-QQ f (date) to hold a precinct convention

1 Call to Order - I (I bull The convention was called to order by temporary chairman J) G( ( 1--~1 I----Th------------__ at 7 s-Opm

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~nelti~I1~911Igirttuen9~importantparjy decisions at subsequentcQnven~ions

3 Election of Permanent Officers The temporary chairman announced that nominations for permanent chairman of this precinct convention woUld be

acceh~~~tIlO~~ tft0ns were nominated as candidates --- shy

The convention elected baf SwtmiddotfI as permanent chairman of the precinct convention The convention elected =na~ 2- SOl r 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 Ill (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 ~ovention

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 beshe 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 reguiredPy Ryle 22 and the Election Code (1740270) 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~pm~_ 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

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PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

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CONTACT INFO~1ATION

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sect REPUBLICAN PARTY OF TEXAS sect

BUSINESS RECORDS AFFIDAVIT

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

hereto are an exact duplicate of the original

Further affiant sayeth not

~lffmiddotLnL KayLu

SUBSCRIBED AND SWORN TO before me on this May 6 2008 to which I place my

signature and official seal )dQampyM-u J11du~ Signature

dele Jampylt-pound 71LeAJ Printed Name

My commission expires 1 -J-d~tcf Notary Public for the State of Texas

VICKIE JOY VAN MAREN Notary Public

STATE OF TEXAS My Comm Exp 10-05-2008

MINUTES OF THE REPUBLICAN PARTY PRECINCT CONVENTION

CJ3 ed v~ ters a election precinct nymber 5~g senate district numt er congressional district LJmber of ~ county Texas met at -nK~ ~4A-ltj (Jccion) C1 __trh-ltl lcJV L- oog (date) to hold a precinct convent xf

- CI to Order _-~ J r(3-1e ionver-tion as called to order by temporary chairman _dM~1 at ~-pm

P~pararon 0 List of Participants ( -le mpoary cr airmin 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 _ (numJer) 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 P3rty of Texas Rules adopted in accordance with the Election Code Robert Rules of Order current dit en neNly re ised would govern parliamentary procedure The temporary chairman then explained how the actions of lis mvention auld influence important party decisions at subsequent convlntions

-hE~onvention Elected as permanent chairman of the precinct convention

-~ Election of DI~legates and Alternates to the County or State Senatorial DistrictConvention -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 alternats are listed in Exhibit C

5 tesolutions The gtermanent chairr1an 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

sdopted b a mcjority vote are included with these minutes

5 Other Business Ths permanent chairman then asked if there was any other business that shculd properly come before the convention

7 Announcemfnts 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 heshe would officially sign stal 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 (174027c) The chairman announced the time and place for the county or senatorial district cgtnvention

8 Adjournmen t In accordance vli~ha)motion properly moved and seconded and adopted by a majority vote the precinct convention was

ad~ed at iq pm I J fit~ -- ~-ed lZi Aft-t=

ermanent hairman ~ Secretary

Return to y)ur county chairman The permanent chairman should also IOpy and retain a record of all documents

PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

INSTRUCTIONS FOR THE PRECINCT CONVENTIONS

TIMEPLACE 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 700 pm and 900 pm 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 precincts 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 countysenatorial 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 Roberts 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 wwwtexasgoporg and click on the GOP Resources link

PREPARATION OF LIST OF QUALlFIED PARTICIPANTS Attendees must have voted in that precincts 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 heshe takes the chair and oversees the election of the permanent secretary If necessary the chairman and the secretary may be the same person

ANNOUNCEMENTOF COUNTYSENATORIAJ-PI~TRICT COflVENTION The convention will convene on Saturday March 29 th at IcY0cJ ~~ (time) in q76R kAfr-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 countysenatorial 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 countysenatorial 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 countysenatorial 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 countysenatorial 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

PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

Precinct GV gtPage I of -----L EXHIBIT A

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First MI Address _____ I Phone

City Zip I E-Mail __1 Last 3 PR()VTnfD BY THE RFPHBUCAN PARTY OF TEXAS

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 am (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 partys 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 Morganmiddot Rd and go toward Leopard St Take a right on Leopard St then take

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~~

OFFiCE OF THE SECRETARY OF 5T ATE

~Xvi[) A DFAN ITE CAfrrOl_ )~ ~ ro ~-~ fgt( G[)~ 261

~ _ ~ ~ i 1L gt- A S - 1 ~

]url(~ 74 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 Credenshytials 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~ 103 sUbd 1 (V~r~cn Supp 1982)

Tn your letter you inquired hether a crc~denti-ls conrni ttee of (l pol itical pgtty convcT~Ii(Jn could altor lt1 delegation by 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 1334 (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

____- -e~~ ~bull ~Wl -- -middotr ___

Mr Edward M Sullivan Page 2

SUIvl1ARY

Tex Elee Code Ann art 1334 (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 ir

7

~ I~(yfh~__

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 John 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 1334 (Vernon Supp_ 1982) provides

the sale method fer the selection of delegates to county and

state convertions 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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Committee Information from vanessa cahill ltvanessafratilagmailcomgt hide details Mar 6 Beply

to michaeLbertuzzimlcom date Mar 62008411 PM

subject Committee Information mailed-by gmailcom

Mr Bertuzzi

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 soon be able to put a face to the nameas the saying goes

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 what better time to do so than the election season With all of the hype surrounding the Democratic race I think it is important for everyone in our party to get involved so we can retain the White House in November

I am very interested in volunteering my time in any way triat I can I would love to serve on any of the committees as well as attend the meetings of the committees that are already full If at all possible could you send me a list of these committes and the scheduled meeting dates and times In addition could you give me the phone numberslemail addresses of Art Granado and Victor Bird I believe they are heading up the Nominations and Resolutions Committees

Also if my services are also needed at the headquarters feel free to contact me

Thank you for your patience

Sincerely Vanessa 832-816-2944

~ Forward

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Request for Clarification Inbox

w vanessa cahill (Ni jdld Mar 16 Reply

Mr Bertuzzi

I would like to be sure that my recollection of our first telephone conversation is correct(March 6 2008) As per my memory I requested information on the dates 1imes and locations of the Credentials and Nominations Committees for Nueces County You then asked that I send my request in writing which I promptly did via email (March 6 2008) From the email attachment I received from Mike Bergsma (March 132008) I have made the reasonable assumption that you have opened and read my email request for this information

I would also like to clarify the second and last conversation we had over the telephone (March 12 2008) As per my memory you told me that you would not be providing to me the information I was requesting From what I understood your reluctance to provide the requested information to me stemmed from my affiliation with a local meetup group in which a fellow member Chuck Burnett voiced his opinions of local leadership in the Republican Party

I would also like clarification from you on the 14th Rule of the General Rules for All Conventions and Meetings of the Republican Party of Texas which states

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 to that convention

As a voter in the Republican Primary and a delegate in my precinct I would again like to request the dates times and locations for the following committees

Credentials Resolutions Rules and Nominations

In addition I would also like to request a copy of accurate written records (minutes) from every Precinct in Nueces County Please notify me when these copies have been completed and I will pick them up from the Republican Party Headquarters

Thank you for your time

( Newer 29 of 179 Older)

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httomailcooclecommaillui=1ampik=559db3fdOOampview=cvampsearch=sentampth=119c5ce2 5152008

err amp Cause No

VANESSA L CAHILL sect SUPREME COURT OF TEXAS

VS sect sect 201 W 14TH STREET RM 104 sect

NUECESCOUNTY sect AUSTIN TEXAS REPUBLICAN PARTY sect

sect REPUBLICAN PARTY OF TEXAS sect

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 ~~j)~A A it A

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~fS~~~i LINDA D ZEPEDA f ltJ r~~v Notary Public

~ bull STATE OF TEXAS ~

~~~l My Comm Exp 11262011I LOndo- P~CL~ V V V V

Printed Name

My commission expires 1-clt - 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 IIssrional d rllcctt l number of county Texas met at JMI+td Ge1-e-Ik __amp~ (location) on J-QQ f (date) to hold a precinct convention

1 Call to Order - I (I bull The convention was called to order by temporary chairman J) G( ( 1--~1 I----Th------------__ at 7 s-Opm

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~nelti~I1~911Igirttuen9~importantparjy decisions at subsequentcQnven~ions

3 Election of Permanent Officers The temporary chairman announced that nominations for permanent chairman of this precinct convention woUld be

acceh~~~tIlO~~ tft0ns were nominated as candidates --- shy

The convention elected baf SwtmiddotfI as permanent chairman of the precinct convention The convention elected =na~ 2- SOl r 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 Ill (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 ~ovention

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 beshe 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 reguiredPy Ryle 22 and the Election Code (1740270) 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~pm~_ 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

-i

f1 Precinct fl

0 EXIDBITB E Senate District 20 0 (l) List of DELEGATES elected to County I Senatorial District Convention (J

(J VOTERCERT PRINT NAME PRINT MAILING ADDRESS (l)

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First Ed i-~ MI JV1 Address 0 9gt 5~ La kevi t LAJ Pbo~ 30L - 334--lLA-Z- I JD3~3D 2D11 Last Srn ~~~ CitdSXDu5 ChiSt Zip 184-12 E-Mail

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PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

Page of ___

CONTACT INFO~1ATION

1-1 -334--124-2shy

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SQT FCause No

VANESSA L CAHILL sect SUPREME COURT OF TEXAS sect

VS sect 201 W 14TH STREET RM 104 sect

NUECESCOUNTY sect AUSTIN TEXAS REPUBLICAN PARTY sect

sect REPUBLICAN PARTY OF TEXAS sect

BUSINESS RECORDS AFFIDAVIT

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

hereto are an exact duplicate of the original

Further affiant sayeth not

~lffmiddotLnL KayLu

SUBSCRIBED AND SWORN TO before me on this May 6 2008 to which I place my

signature and official seal )dQampyM-u J11du~ Signature

dele Jampylt-pound 71LeAJ Printed Name

My commission expires 1 -J-d~tcf Notary Public for the State of Texas

VICKIE JOY VAN MAREN Notary Public

STATE OF TEXAS My Comm Exp 10-05-2008

MINUTES OF THE REPUBLICAN PARTY PRECINCT CONVENTION

CJ3 ed v~ ters a election precinct nymber 5~g senate district numt er congressional district LJmber of ~ county Texas met at -nK~ ~4A-ltj (Jccion) C1 __trh-ltl lcJV L- oog (date) to hold a precinct convent xf

- CI to Order _-~ J r(3-1e ionver-tion as called to order by temporary chairman _dM~1 at ~-pm

P~pararon 0 List of Participants ( -le mpoary cr airmin 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 _ (numJer) 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 P3rty of Texas Rules adopted in accordance with the Election Code Robert Rules of Order current dit en neNly re ised would govern parliamentary procedure The temporary chairman then explained how the actions of lis mvention auld influence important party decisions at subsequent convlntions

-hE~onvention Elected as permanent chairman of the precinct convention

-~ Election of DI~legates and Alternates to the County or State Senatorial DistrictConvention -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 alternats are listed in Exhibit C

5 tesolutions The gtermanent chairr1an 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

sdopted b a mcjority vote are included with these minutes

5 Other Business Ths permanent chairman then asked if there was any other business that shculd properly come before the convention

7 Announcemfnts 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 heshe would officially sign stal 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 (174027c) The chairman announced the time and place for the county or senatorial district cgtnvention

8 Adjournmen t In accordance vli~ha)motion properly moved and seconded and adopted by a majority vote the precinct convention was

ad~ed at iq pm I J fit~ -- ~-ed lZi Aft-t=

ermanent hairman ~ Secretary

Return to y)ur county chairman The permanent chairman should also IOpy and retain a record of all documents

PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

INSTRUCTIONS FOR THE PRECINCT CONVENTIONS

TIMEPLACE 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 700 pm and 900 pm 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 precincts 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 countysenatorial 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 Roberts 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 wwwtexasgoporg and click on the GOP Resources link

PREPARATION OF LIST OF QUALlFIED PARTICIPANTS Attendees must have voted in that precincts 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 heshe takes the chair and oversees the election of the permanent secretary If necessary the chairman and the secretary may be the same person

ANNOUNCEMENTOF COUNTYSENATORIAJ-PI~TRICT COflVENTION The convention will convene on Saturday March 29 th at IcY0cJ ~~ (time) in q76R kAfr-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 countysenatorial 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 countysenatorial 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 countysenatorial 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 countysenatorial 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

PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

Precinct GV gtPage I of -----L EXHIBIT A

Senate District __ List of qualified voters who ATTENDED precinct convention

VOTERCERT PRINT NAME PRINT MAILING ADDRESS CONTACT INFORMATION

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OFFiCE OF THE SECRETARY OF 5T ATE

~Xvi[) A DFAN ITE CAfrrOl_ )~ ~ ro ~-~ fgt( G[)~ 261

~ _ ~ ~ i 1L gt- A S - 1 ~

]url(~ 74 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 Credenshytials 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~ 103 sUbd 1 (V~r~cn Supp 1982)

Tn your letter you inquired hether a crc~denti-ls conrni ttee of (l pol itical pgtty convcT~Ii(Jn could altor lt1 delegation by 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 1334 (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

____- -e~~ ~bull ~Wl -- -middotr ___

Mr Edward M Sullivan Page 2

SUIvl1ARY

Tex Elee Code Ann art 1334 (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 ir

7

~ I~(yfh~__

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 John 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 1334 (Vernon Supp_ 1982) provides

the sale method fer the selection of delegates to county and

state convertions 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

Gmail Calendar Documents Photos Reader Web more ~ vanessafratilagmailcom I Settings I Help I Sign out

Search Mail Cyen1 I i e~rG ~

Compose Mail

Inbox (67)

Starred U Chats

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Drafts

All Mail

Spam (4)

Trash

Contacts

bull Quick Contacts

fSearchaddcor invit

vanessa cahill Set status here

Alex Haupt antoniofratila Robert Lund Benjamin Bernier dmedinaprudent John Falasca Kay Fischer Margaret Fratila Paul Hunt ronpaul-10

Add Show all contact

bull Labels 6050 Rio Vista Ron Paul Super Bowl 08

Edit labels

bull Invite a friend Give Gmail to

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Committee Information from vanessa cahill ltvanessafratilagmailcomgt hide details Mar 6 Beply

to michaeLbertuzzimlcom date Mar 62008411 PM

subject Committee Information mailed-by gmailcom

Mr Bertuzzi

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 soon be able to put a face to the nameas the saying goes

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 what better time to do so than the election season With all of the hype surrounding the Democratic race I think it is important for everyone in our party to get involved so we can retain the White House in November

I am very interested in volunteering my time in any way triat I can I would love to serve on any of the committees as well as attend the meetings of the committees that are already full If at all possible could you send me a list of these committes and the scheduled meeting dates and times In addition could you give me the phone numberslemail addresses of Art Granado and Victor Bird I believe they are heading up the Nominations and Resolutions Committees

Also if my services are also needed at the headquarters feel free to contact me

Thank you for your patience

Sincerely Vanessa 832-816-2944

~ Forward

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Robert Lund Alex Haupt anton iofratila Bruce C Matzke Debra Medina Dennis Rodenbeck jfalasca John Falasca Kay Fischer Margaret Fratila

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w vanessa cahill (Ni jdld Mar 16 Reply

Mr Bertuzzi

I would like to be sure that my recollection of our first telephone conversation is correct(March 6 2008) As per my memory I requested information on the dates 1imes and locations of the Credentials and Nominations Committees for Nueces County You then asked that I send my request in writing which I promptly did via email (March 6 2008) From the email attachment I received from Mike Bergsma (March 132008) I have made the reasonable assumption that you have opened and read my email request for this information

I would also like to clarify the second and last conversation we had over the telephone (March 12 2008) As per my memory you told me that you would not be providing to me the information I was requesting From what I understood your reluctance to provide the requested information to me stemmed from my affiliation with a local meetup group in which a fellow member Chuck Burnett voiced his opinions of local leadership in the Republican Party

I would also like clarification from you on the 14th Rule of the General Rules for All Conventions and Meetings of the Republican Party of Texas which states

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 to that convention

As a voter in the Republican Primary and a delegate in my precinct I would again like to request the dates times and locations for the following committees

Credentials Resolutions Rules and Nominations

In addition I would also like to request a copy of accurate written records (minutes) from every Precinct in Nueces County Please notify me when these copies have been completed and I will pick them up from the Republican Party Headquarters

Thank you for your time

( Newer 29 of 179 Older)

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About these link

httomailcooclecommaillui=1ampik=559db3fdOOampview=cvampsearch=sentampth=119c5ce2 5152008

err amp Cause No

VANESSA L CAHILL sect SUPREME COURT OF TEXAS

VS sect sect 201 W 14TH STREET RM 104 sect

NUECESCOUNTY sect AUSTIN TEXAS REPUBLICAN PARTY sect

sect REPUBLICAN PARTY OF TEXAS sect

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 ~~j)~A A it A

~ d i

~fS~~~i LINDA D ZEPEDA f ltJ r~~v Notary Public

~ bull STATE OF TEXAS ~

~~~l My Comm Exp 11262011I LOndo- P~CL~ V V V V

Printed Name

My commission expires 1-clt - 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 IIssrional d rllcctt l number of county Texas met at JMI+td Ge1-e-Ik __amp~ (location) on J-QQ f (date) to hold a precinct convention

1 Call to Order - I (I bull The convention was called to order by temporary chairman J) G( ( 1--~1 I----Th------------__ at 7 s-Opm

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~nelti~I1~911Igirttuen9~importantparjy decisions at subsequentcQnven~ions

3 Election of Permanent Officers The temporary chairman announced that nominations for permanent chairman of this precinct convention woUld be

acceh~~~tIlO~~ tft0ns were nominated as candidates --- shy

The convention elected baf SwtmiddotfI as permanent chairman of the precinct convention The convention elected =na~ 2- SOl r 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 Ill (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 ~ovention

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 beshe 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 reguiredPy Ryle 22 and the Election Code (1740270) 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~pm~_ 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

-i

f1 Precinct fl

0 EXIDBITB E Senate District 20 0 (l) List of DELEGATES elected to County I Senatorial District Convention (J

(J VOTERCERT PRINT NAME PRINT MAILING ADDRESS (l)

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PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

Page of ___

CONTACT INFO~1ATION

1-1 -334--124-2shy

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1 ~

I

SQT FCause No

VANESSA L CAHILL sect SUPREME COURT OF TEXAS sect

VS sect 201 W 14TH STREET RM 104 sect

NUECESCOUNTY sect AUSTIN TEXAS REPUBLICAN PARTY sect

sect REPUBLICAN PARTY OF TEXAS sect

BUSINESS RECORDS AFFIDAVIT

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

hereto are an exact duplicate of the original

Further affiant sayeth not

~lffmiddotLnL KayLu

SUBSCRIBED AND SWORN TO before me on this May 6 2008 to which I place my

signature and official seal )dQampyM-u J11du~ Signature

dele Jampylt-pound 71LeAJ Printed Name

My commission expires 1 -J-d~tcf Notary Public for the State of Texas

VICKIE JOY VAN MAREN Notary Public

STATE OF TEXAS My Comm Exp 10-05-2008

MINUTES OF THE REPUBLICAN PARTY PRECINCT CONVENTION

CJ3 ed v~ ters a election precinct nymber 5~g senate district numt er congressional district LJmber of ~ county Texas met at -nK~ ~4A-ltj (Jccion) C1 __trh-ltl lcJV L- oog (date) to hold a precinct convent xf

- CI to Order _-~ J r(3-1e ionver-tion as called to order by temporary chairman _dM~1 at ~-pm

P~pararon 0 List of Participants ( -le mpoary cr airmin 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 _ (numJer) 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 P3rty of Texas Rules adopted in accordance with the Election Code Robert Rules of Order current dit en neNly re ised would govern parliamentary procedure The temporary chairman then explained how the actions of lis mvention auld influence important party decisions at subsequent convlntions

-hE~onvention Elected as permanent chairman of the precinct convention

-~ Election of DI~legates and Alternates to the County or State Senatorial DistrictConvention -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 alternats are listed in Exhibit C

5 tesolutions The gtermanent chairr1an 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

sdopted b a mcjority vote are included with these minutes

5 Other Business Ths permanent chairman then asked if there was any other business that shculd properly come before the convention

7 Announcemfnts 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 heshe would officially sign stal 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 (174027c) The chairman announced the time and place for the county or senatorial district cgtnvention

8 Adjournmen t In accordance vli~ha)motion properly moved and seconded and adopted by a majority vote the precinct convention was

ad~ed at iq pm I J fit~ -- ~-ed lZi Aft-t=

ermanent hairman ~ Secretary

Return to y)ur county chairman The permanent chairman should also IOpy and retain a record of all documents

PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

INSTRUCTIONS FOR THE PRECINCT CONVENTIONS

TIMEPLACE 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 700 pm and 900 pm 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 precincts 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 countysenatorial 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 Roberts 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 wwwtexasgoporg and click on the GOP Resources link

PREPARATION OF LIST OF QUALlFIED PARTICIPANTS Attendees must have voted in that precincts 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 heshe takes the chair and oversees the election of the permanent secretary If necessary the chairman and the secretary may be the same person

ANNOUNCEMENTOF COUNTYSENATORIAJ-PI~TRICT COflVENTION The convention will convene on Saturday March 29 th at IcY0cJ ~~ (time) in q76R kAfr-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 countysenatorial 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 countysenatorial 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 countysenatorial 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 countysenatorial 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

PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

Precinct GV gtPage I of -----L EXHIBIT A

Senate District __ List of qualified voters who ATTENDED precinct convention

VOTERCERT PRINT NAME PRINT MAILING ADDRESS CONTACT INFORMATION

(DY ro3 ofJ1

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MI Phone 1- ff ~-OcJamp g)( ()ft E-Mail

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PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

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First MI Address _____ I Phone

City Zip I E-Mail __1 Last 3 PR()VTnfD BY THE RFPHBUCAN PARTY OF TEXAS

Mr Edward M Sullivan Page 2

SUIvl1ARY

Tex Elee Code Ann art 1334 (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 ir

7

~ I~(yfh~__

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 John 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 1334 (Vernon Supp_ 1982) provides

the sale method fer the selection of delegates to county and

state convertions 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

Gmail Calendar Documents Photos Reader Web more ~ vanessafratilagmailcom I Settings I Help I Sign out

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Alex Haupt antoniofratila Robert Lund Benjamin Bernier dmedinaprudent John Falasca Kay Fischer Margaret Fratila Paul Hunt ronpaul-10

Add Show all contact

bull Labels 6050 Rio Vista Ron Paul Super Bowl 08

Edit labels

bull Invite a friend Give Gmail to

Send Invite Iso left

preview invite

YesWeCanBarack Wristband - wwwyesNecanbraceletscom - Sup Sponsored Link lt gt

laquo Back to Sent Mail More actions ltNewer 71 of 155 Older)

Committee Information from vanessa cahill ltvanessafratilagmailcomgt hide details Mar 6 Beply

to michaeLbertuzzimlcom date Mar 62008411 PM

subject Committee Information mailed-by gmailcom

Mr Bertuzzi

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 soon be able to put a face to the nameas the saying goes

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 what better time to do so than the election season With all of the hype surrounding the Democratic race I think it is important for everyone in our party to get involved so we can retain the White House in November

I am very interested in volunteering my time in any way triat I can I would love to serve on any of the committees as well as attend the meetings of the committees that are already full If at all possible could you send me a list of these committes and the scheduled meeting dates and times In addition could you give me the phone numberslemail addresses of Art Granado and Victor Bird I believe they are heading up the Nominations and Resolutions Committees

Also if my services are also needed at the headquarters feel free to contact me

Thank you for your patience

Sincerely Vanessa 832-816-2944

~ Forward

bull vanessa cahill to jfalasca show details Apr 5 Beply

- Show quoted text shy

Forward~

lf7 i7200R fi42 PM

rage I 01

Gmail Calendar Documents Photos Reader Web more vanessafratilagmailcom I Settings I Help I _ _ _ _ J

I vlJII UUl

earChMailaaT tgtCI~ I Compose Mail

Inbox (94)

Starred C1 Chats lt Sent Mail Drafts (1) All Mail

Spam (4) Trash

Contacts

T Quick Contacts

acid or invlf

vanessa cahill ~-)ct t)t 3 tlcrr

Robert Lund Alex Haupt anton iofratila Bruce C Matzke Debra Medina Dennis Rodenbeck jfalasca John Falasca Kay Fischer Margaret Fratila

T Labels 6050 Rio Vista Ron Paul Super Bowl 08Sh II

Edit I~fjers

T Invite a friend

Give Gmail to

ISend InVi~ 50 left

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Are You Democratic Party - 1001 FunOuizzescomipoiltlcai-party~middot Find out yourpcfliicai

Back to Sent Mail More actions

Request for Clarification Inbox

w vanessa cahill (Ni jdld Mar 16 Reply

Mr Bertuzzi

I would like to be sure that my recollection of our first telephone conversation is correct(March 6 2008) As per my memory I requested information on the dates 1imes and locations of the Credentials and Nominations Committees for Nueces County You then asked that I send my request in writing which I promptly did via email (March 6 2008) From the email attachment I received from Mike Bergsma (March 132008) I have made the reasonable assumption that you have opened and read my email request for this information

I would also like to clarify the second and last conversation we had over the telephone (March 12 2008) As per my memory you told me that you would not be providing to me the information I was requesting From what I understood your reluctance to provide the requested information to me stemmed from my affiliation with a local meetup group in which a fellow member Chuck Burnett voiced his opinions of local leadership in the Republican Party

I would also like clarification from you on the 14th Rule of the General Rules for All Conventions and Meetings of the Republican Party of Texas which states

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 to that convention

As a voter in the Republican Primary and a delegate in my precinct I would again like to request the dates times and locations for the following committees

Credentials Resolutions Rules and Nominations

In addition I would also like to request a copy of accurate written records (minutes) from every Precinct in Nueces County Please notify me when these copies have been completed and I will pick them up from the Republican Party Headquarters

Thank you for your time

( Newer 29 of 179 Older)

Newwindow

l[jJ Print all

ED Expand all

m Forward all

Sponsored Link~

$250K+ 1st year income pc No selling $2K - $9K startu wwwTheFreshFinancialco

100 online executive edul certification Learn more no wwwNotreDameOnlinecor

1 Minute Poll Has he Been a Good Presil Your-VotescomGeorgeWE

SalesPresentation Skills C Call this expert TODAY 72 sheryLcom

Engage successfUlly with C Increase sales success JUI wwwSeIIXLcom

Become the best coach YOL ICF Accredited Life Coach I

wwwiCoachAcademycom

Your personalized system i With expert guidance its si wwwOrganizeYourselfOnli

More about Republican State Conventi( Republican Conferencesraquo Republican Fundraiser Republican National Comm

About these link

httomailcooclecommaillui=1ampik=559db3fdOOampview=cvampsearch=sentampth=119c5ce2 5152008

err amp Cause No

VANESSA L CAHILL sect SUPREME COURT OF TEXAS

VS sect sect 201 W 14TH STREET RM 104 sect

NUECESCOUNTY sect AUSTIN TEXAS REPUBLICAN PARTY sect

sect REPUBLICAN PARTY OF TEXAS sect

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 ~~j)~A A it A

~ d i

~fS~~~i LINDA D ZEPEDA f ltJ r~~v Notary Public

~ bull STATE OF TEXAS ~

~~~l My Comm Exp 11262011I LOndo- P~CL~ V V V V

Printed Name

My commission expires 1-clt - 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 IIssrional d rllcctt l number of county Texas met at JMI+td Ge1-e-Ik __amp~ (location) on J-QQ f (date) to hold a precinct convention

1 Call to Order - I (I bull The convention was called to order by temporary chairman J) G( ( 1--~1 I----Th------------__ at 7 s-Opm

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~nelti~I1~911Igirttuen9~importantparjy decisions at subsequentcQnven~ions

3 Election of Permanent Officers The temporary chairman announced that nominations for permanent chairman of this precinct convention woUld be

acceh~~~tIlO~~ tft0ns were nominated as candidates --- shy

The convention elected baf SwtmiddotfI as permanent chairman of the precinct convention The convention elected =na~ 2- SOl r 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 Ill (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 ~ovention

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 beshe 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 reguiredPy Ryle 22 and the Election Code (1740270) 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~pm~_ 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

-i

f1 Precinct fl

0 EXIDBITB E Senate District 20 0 (l) List of DELEGATES elected to County I Senatorial District Convention (J

(J VOTERCERT PRINT NAME PRINT MAILING ADDRESS (l)

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First Ed i-~ MI JV1 Address 0 9gt 5~ La kevi t LAJ Pbo~ 30L - 334--lLA-Z- I JD3~3D 2D11 Last Srn ~~~ CitdSXDu5 ChiSt Zip 184-12 E-Mail

(J f (J First 1rL1 Address Pirone-i

f Lim On ZiD E-Mail11

M1 IA~~ Ift~~ Citf Zip EmiddotMlIll

MJ IAdm IPbo Cin Zip E-M81l

MI IA_ IPh~ Cih~ bull Zip E-II-fail

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PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

Page of ___

CONTACT INFO~1ATION

1-1 -334--124-2shy

j I I

1 ~

I

SQT FCause No

VANESSA L CAHILL sect SUPREME COURT OF TEXAS sect

VS sect 201 W 14TH STREET RM 104 sect

NUECESCOUNTY sect AUSTIN TEXAS REPUBLICAN PARTY sect

sect REPUBLICAN PARTY OF TEXAS sect

BUSINESS RECORDS AFFIDAVIT

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

hereto are an exact duplicate of the original

Further affiant sayeth not

~lffmiddotLnL KayLu

SUBSCRIBED AND SWORN TO before me on this May 6 2008 to which I place my

signature and official seal )dQampyM-u J11du~ Signature

dele Jampylt-pound 71LeAJ Printed Name

My commission expires 1 -J-d~tcf Notary Public for the State of Texas

VICKIE JOY VAN MAREN Notary Public

STATE OF TEXAS My Comm Exp 10-05-2008

MINUTES OF THE REPUBLICAN PARTY PRECINCT CONVENTION

CJ3 ed v~ ters a election precinct nymber 5~g senate district numt er congressional district LJmber of ~ county Texas met at -nK~ ~4A-ltj (Jccion) C1 __trh-ltl lcJV L- oog (date) to hold a precinct convent xf

- CI to Order _-~ J r(3-1e ionver-tion as called to order by temporary chairman _dM~1 at ~-pm

P~pararon 0 List of Participants ( -le mpoary cr airmin 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 _ (numJer) 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 P3rty of Texas Rules adopted in accordance with the Election Code Robert Rules of Order current dit en neNly re ised would govern parliamentary procedure The temporary chairman then explained how the actions of lis mvention auld influence important party decisions at subsequent convlntions

-hE~onvention Elected as permanent chairman of the precinct convention

-~ Election of DI~legates and Alternates to the County or State Senatorial DistrictConvention -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 alternats are listed in Exhibit C

5 tesolutions The gtermanent chairr1an 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

sdopted b a mcjority vote are included with these minutes

5 Other Business Ths permanent chairman then asked if there was any other business that shculd properly come before the convention

7 Announcemfnts 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 heshe would officially sign stal 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 (174027c) The chairman announced the time and place for the county or senatorial district cgtnvention

8 Adjournmen t In accordance vli~ha)motion properly moved and seconded and adopted by a majority vote the precinct convention was

ad~ed at iq pm I J fit~ -- ~-ed lZi Aft-t=

ermanent hairman ~ Secretary

Return to y)ur county chairman The permanent chairman should also IOpy and retain a record of all documents

PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

INSTRUCTIONS FOR THE PRECINCT CONVENTIONS

TIMEPLACE 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 700 pm and 900 pm 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 precincts 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 countysenatorial 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 Roberts 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 wwwtexasgoporg and click on the GOP Resources link

PREPARATION OF LIST OF QUALlFIED PARTICIPANTS Attendees must have voted in that precincts 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 heshe takes the chair and oversees the election of the permanent secretary If necessary the chairman and the secretary may be the same person

ANNOUNCEMENTOF COUNTYSENATORIAJ-PI~TRICT COflVENTION The convention will convene on Saturday March 29 th at IcY0cJ ~~ (time) in q76R kAfr-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 countysenatorial 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 countysenatorial 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 countysenatorial 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 countysenatorial 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

PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

Precinct GV gtPage I of -----L EXHIBIT A

Senate District __ List of qualified voters who ATTENDED precinct convention

VOTERCERT PRINT NAME PRINT MAILING ADDRESS CONTACT INFORMATION

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PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

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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 1334 (Vernon Supp_ 1982) provides

the sale method fer the selection of delegates to county and

state convertions 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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vanessa cahill Set status here

Alex Haupt antoniofratila Robert Lund Benjamin Bernier dmedinaprudent John Falasca Kay Fischer Margaret Fratila Paul Hunt ronpaul-10

Add Show all contact

bull Labels 6050 Rio Vista Ron Paul Super Bowl 08

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laquo Back to Sent Mail More actions ltNewer 71 of 155 Older)

Committee Information from vanessa cahill ltvanessafratilagmailcomgt hide details Mar 6 Beply

to michaeLbertuzzimlcom date Mar 62008411 PM

subject Committee Information mailed-by gmailcom

Mr Bertuzzi

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 soon be able to put a face to the nameas the saying goes

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 what better time to do so than the election season With all of the hype surrounding the Democratic race I think it is important for everyone in our party to get involved so we can retain the White House in November

I am very interested in volunteering my time in any way triat I can I would love to serve on any of the committees as well as attend the meetings of the committees that are already full If at all possible could you send me a list of these committes and the scheduled meeting dates and times In addition could you give me the phone numberslemail addresses of Art Granado and Victor Bird I believe they are heading up the Nominations and Resolutions Committees

Also if my services are also needed at the headquarters feel free to contact me

Thank you for your patience

Sincerely Vanessa 832-816-2944

~ Forward

bull vanessa cahill to jfalasca show details Apr 5 Beply

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Robert Lund Alex Haupt anton iofratila Bruce C Matzke Debra Medina Dennis Rodenbeck jfalasca John Falasca Kay Fischer Margaret Fratila

T Labels 6050 Rio Vista Ron Paul Super Bowl 08Sh II

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Request for Clarification Inbox

w vanessa cahill (Ni jdld Mar 16 Reply

Mr Bertuzzi

I would like to be sure that my recollection of our first telephone conversation is correct(March 6 2008) As per my memory I requested information on the dates 1imes and locations of the Credentials and Nominations Committees for Nueces County You then asked that I send my request in writing which I promptly did via email (March 6 2008) From the email attachment I received from Mike Bergsma (March 132008) I have made the reasonable assumption that you have opened and read my email request for this information

I would also like to clarify the second and last conversation we had over the telephone (March 12 2008) As per my memory you told me that you would not be providing to me the information I was requesting From what I understood your reluctance to provide the requested information to me stemmed from my affiliation with a local meetup group in which a fellow member Chuck Burnett voiced his opinions of local leadership in the Republican Party

I would also like clarification from you on the 14th Rule of the General Rules for All Conventions and Meetings of the Republican Party of Texas which states

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 to that convention

As a voter in the Republican Primary and a delegate in my precinct I would again like to request the dates times and locations for the following committees

Credentials Resolutions Rules and Nominations

In addition I would also like to request a copy of accurate written records (minutes) from every Precinct in Nueces County Please notify me when these copies have been completed and I will pick them up from the Republican Party Headquarters

Thank you for your time

( Newer 29 of 179 Older)

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httomailcooclecommaillui=1ampik=559db3fdOOampview=cvampsearch=sentampth=119c5ce2 5152008

err amp Cause No

VANESSA L CAHILL sect SUPREME COURT OF TEXAS

VS sect sect 201 W 14TH STREET RM 104 sect

NUECESCOUNTY sect AUSTIN TEXAS REPUBLICAN PARTY sect

sect REPUBLICAN PARTY OF TEXAS sect

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 ~~j)~A A it A

~ d i

~fS~~~i LINDA D ZEPEDA f ltJ r~~v Notary Public

~ bull STATE OF TEXAS ~

~~~l My Comm Exp 11262011I LOndo- P~CL~ V V V V

Printed Name

My commission expires 1-clt - 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 IIssrional d rllcctt l number of county Texas met at JMI+td Ge1-e-Ik __amp~ (location) on J-QQ f (date) to hold a precinct convention

1 Call to Order - I (I bull The convention was called to order by temporary chairman J) G( ( 1--~1 I----Th------------__ at 7 s-Opm

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~nelti~I1~911Igirttuen9~importantparjy decisions at subsequentcQnven~ions

3 Election of Permanent Officers The temporary chairman announced that nominations for permanent chairman of this precinct convention woUld be

acceh~~~tIlO~~ tft0ns were nominated as candidates --- shy

The convention elected baf SwtmiddotfI as permanent chairman of the precinct convention The convention elected =na~ 2- SOl r 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 Ill (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 ~ovention

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 beshe 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 reguiredPy Ryle 22 and the Election Code (1740270) 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~pm~_ 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

-i

f1 Precinct fl

0 EXIDBITB E Senate District 20 0 (l) List of DELEGATES elected to County I Senatorial District Convention (J

(J VOTERCERT PRINT NAME PRINT MAILING ADDRESS (l)

Flm 1)~h1e- MI F Plmnc (J

Ad~b~5~ LakevleuJ~

1039X)lJZ1~LJst5n jJJl shy CilT Cornt15 Lh6 5~t Zip 16412 [-MailIS) I

~ First l)arrv) 5171 MI 1 Add~ 4632 La kEV iev] - ~-9S5-0923 If1l E lzu~9737b9Z lAst 5th 1~ CillLoroUS Ch r is+( ZIp ~ 8412 E-Mail

First Ed i-~ MI JV1 Address 0 9gt 5~ La kevi t LAJ Pbo~ 30L - 334--lLA-Z- I JD3~3D 2D11 Last Srn ~~~ CitdSXDu5 ChiSt Zip 184-12 E-Mail

(J f (J First 1rL1 Address Pirone-i

f Lim On ZiD E-Mail11

M1 IA~~ Ift~~ Citf Zip EmiddotMlIll

MJ IAdm IPbo Cin Zip E-M81l

MI IA_ IPh~ Cih~ bull Zip E-II-fail

M~ 1--- 1-City Zip E-Mail

gtLL 1--- IPh Citf Zip E-Mail

gt~ 1-- 1 Poo~ City Zip E-Mail

-i UJ f1

11

I I~~ Last

a z X ltI I 1-li

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a lk L

PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

Page of ___

CONTACT INFO~1ATION

1-1 -334--124-2shy

j I I

1 ~

I

SQT FCause No

VANESSA L CAHILL sect SUPREME COURT OF TEXAS sect

VS sect 201 W 14TH STREET RM 104 sect

NUECESCOUNTY sect AUSTIN TEXAS REPUBLICAN PARTY sect

sect REPUBLICAN PARTY OF TEXAS sect

BUSINESS RECORDS AFFIDAVIT

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

hereto are an exact duplicate of the original

Further affiant sayeth not

~lffmiddotLnL KayLu

SUBSCRIBED AND SWORN TO before me on this May 6 2008 to which I place my

signature and official seal )dQampyM-u J11du~ Signature

dele Jampylt-pound 71LeAJ Printed Name

My commission expires 1 -J-d~tcf Notary Public for the State of Texas

VICKIE JOY VAN MAREN Notary Public

STATE OF TEXAS My Comm Exp 10-05-2008

MINUTES OF THE REPUBLICAN PARTY PRECINCT CONVENTION

CJ3 ed v~ ters a election precinct nymber 5~g senate district numt er congressional district LJmber of ~ county Texas met at -nK~ ~4A-ltj (Jccion) C1 __trh-ltl lcJV L- oog (date) to hold a precinct convent xf

- CI to Order _-~ J r(3-1e ionver-tion as called to order by temporary chairman _dM~1 at ~-pm

P~pararon 0 List of Participants ( -le mpoary cr airmin 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 _ (numJer) 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 P3rty of Texas Rules adopted in accordance with the Election Code Robert Rules of Order current dit en neNly re ised would govern parliamentary procedure The temporary chairman then explained how the actions of lis mvention auld influence important party decisions at subsequent convlntions

-hE~onvention Elected as permanent chairman of the precinct convention

-~ Election of DI~legates and Alternates to the County or State Senatorial DistrictConvention -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 alternats are listed in Exhibit C

5 tesolutions The gtermanent chairr1an 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

sdopted b a mcjority vote are included with these minutes

5 Other Business Ths permanent chairman then asked if there was any other business that shculd properly come before the convention

7 Announcemfnts 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 heshe would officially sign stal 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 (174027c) The chairman announced the time and place for the county or senatorial district cgtnvention

8 Adjournmen t In accordance vli~ha)motion properly moved and seconded and adopted by a majority vote the precinct convention was

ad~ed at iq pm I J fit~ -- ~-ed lZi Aft-t=

ermanent hairman ~ Secretary

Return to y)ur county chairman The permanent chairman should also IOpy and retain a record of all documents

PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

INSTRUCTIONS FOR THE PRECINCT CONVENTIONS

TIMEPLACE 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 700 pm and 900 pm 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 precincts 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 countysenatorial 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 Roberts 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 wwwtexasgoporg and click on the GOP Resources link

PREPARATION OF LIST OF QUALlFIED PARTICIPANTS Attendees must have voted in that precincts 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 heshe takes the chair and oversees the election of the permanent secretary If necessary the chairman and the secretary may be the same person

ANNOUNCEMENTOF COUNTYSENATORIAJ-PI~TRICT COflVENTION The convention will convene on Saturday March 29 th at IcY0cJ ~~ (time) in q76R kAfr-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 countysenatorial 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 countysenatorial 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 countysenatorial 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 countysenatorial 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

PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

Precinct GV gtPage I of -----L EXHIBIT A

Senate District __ List of qualified voters who ATTENDED precinct convention

VOTERCERT PRINT NAME PRINT MAILING ADDRESS CONTACT INFORMATION

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vanessa cahill Set status here

Alex Haupt antoniofratila Robert Lund Benjamin Bernier dmedinaprudent John Falasca Kay Fischer Margaret Fratila Paul Hunt ronpaul-10

Add Show all contact

bull Labels 6050 Rio Vista Ron Paul Super Bowl 08

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laquo Back to Sent Mail More actions ltNewer 71 of 155 Older)

Committee Information from vanessa cahill ltvanessafratilagmailcomgt hide details Mar 6 Beply

to michaeLbertuzzimlcom date Mar 62008411 PM

subject Committee Information mailed-by gmailcom

Mr Bertuzzi

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 soon be able to put a face to the nameas the saying goes

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 what better time to do so than the election season With all of the hype surrounding the Democratic race I think it is important for everyone in our party to get involved so we can retain the White House in November

I am very interested in volunteering my time in any way triat I can I would love to serve on any of the committees as well as attend the meetings of the committees that are already full If at all possible could you send me a list of these committes and the scheduled meeting dates and times In addition could you give me the phone numberslemail addresses of Art Granado and Victor Bird I believe they are heading up the Nominations and Resolutions Committees

Also if my services are also needed at the headquarters feel free to contact me

Thank you for your patience

Sincerely Vanessa 832-816-2944

~ Forward

bull vanessa cahill to jfalasca show details Apr 5 Beply

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Robert Lund Alex Haupt anton iofratila Bruce C Matzke Debra Medina Dennis Rodenbeck jfalasca John Falasca Kay Fischer Margaret Fratila

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Are You Democratic Party - 1001 FunOuizzescomipoiltlcai-party~middot Find out yourpcfliicai

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Request for Clarification Inbox

w vanessa cahill (Ni jdld Mar 16 Reply

Mr Bertuzzi

I would like to be sure that my recollection of our first telephone conversation is correct(March 6 2008) As per my memory I requested information on the dates 1imes and locations of the Credentials and Nominations Committees for Nueces County You then asked that I send my request in writing which I promptly did via email (March 6 2008) From the email attachment I received from Mike Bergsma (March 132008) I have made the reasonable assumption that you have opened and read my email request for this information

I would also like to clarify the second and last conversation we had over the telephone (March 12 2008) As per my memory you told me that you would not be providing to me the information I was requesting From what I understood your reluctance to provide the requested information to me stemmed from my affiliation with a local meetup group in which a fellow member Chuck Burnett voiced his opinions of local leadership in the Republican Party

I would also like clarification from you on the 14th Rule of the General Rules for All Conventions and Meetings of the Republican Party of Texas which states

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 to that convention

As a voter in the Republican Primary and a delegate in my precinct I would again like to request the dates times and locations for the following committees

Credentials Resolutions Rules and Nominations

In addition I would also like to request a copy of accurate written records (minutes) from every Precinct in Nueces County Please notify me when these copies have been completed and I will pick them up from the Republican Party Headquarters

Thank you for your time

( Newer 29 of 179 Older)

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err amp Cause No

VANESSA L CAHILL sect SUPREME COURT OF TEXAS

VS sect sect 201 W 14TH STREET RM 104 sect

NUECESCOUNTY sect AUSTIN TEXAS REPUBLICAN PARTY sect

sect REPUBLICAN PARTY OF TEXAS sect

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 ~~j)~A A it A

~ d i

~fS~~~i LINDA D ZEPEDA f ltJ r~~v Notary Public

~ bull STATE OF TEXAS ~

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Printed Name

My commission expires 1-clt - 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 IIssrional d rllcctt l number of county Texas met at JMI+td Ge1-e-Ik __amp~ (location) on J-QQ f (date) to hold a precinct convention

1 Call to Order - I (I bull The convention was called to order by temporary chairman J) G( ( 1--~1 I----Th------------__ at 7 s-Opm

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~nelti~I1~911Igirttuen9~importantparjy decisions at subsequentcQnven~ions

3 Election of Permanent Officers The temporary chairman announced that nominations for permanent chairman of this precinct convention woUld be

acceh~~~tIlO~~ tft0ns were nominated as candidates --- shy

The convention elected baf SwtmiddotfI as permanent chairman of the precinct convention The convention elected =na~ 2- SOl r 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 Ill (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 ~ovention

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 beshe 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 reguiredPy Ryle 22 and the Election Code (1740270) 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~pm~_ 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

-i

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0 EXIDBITB E Senate District 20 0 (l) List of DELEGATES elected to County I Senatorial District Convention (J

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Page of ___

CONTACT INFO~1ATION

1-1 -334--124-2shy

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SQT FCause No

VANESSA L CAHILL sect SUPREME COURT OF TEXAS sect

VS sect 201 W 14TH STREET RM 104 sect

NUECESCOUNTY sect AUSTIN TEXAS REPUBLICAN PARTY sect

sect REPUBLICAN PARTY OF TEXAS sect

BUSINESS RECORDS AFFIDAVIT

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

hereto are an exact duplicate of the original

Further affiant sayeth not

~lffmiddotLnL KayLu

SUBSCRIBED AND SWORN TO before me on this May 6 2008 to which I place my

signature and official seal )dQampyM-u J11du~ Signature

dele Jampylt-pound 71LeAJ Printed Name

My commission expires 1 -J-d~tcf Notary Public for the State of Texas

VICKIE JOY VAN MAREN Notary Public

STATE OF TEXAS My Comm Exp 10-05-2008

MINUTES OF THE REPUBLICAN PARTY PRECINCT CONVENTION

CJ3 ed v~ ters a election precinct nymber 5~g senate district numt er congressional district LJmber of ~ county Texas met at -nK~ ~4A-ltj (Jccion) C1 __trh-ltl lcJV L- oog (date) to hold a precinct convent xf

- CI to Order _-~ J r(3-1e ionver-tion as called to order by temporary chairman _dM~1 at ~-pm

P~pararon 0 List of Participants ( -le mpoary cr airmin 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 _ (numJer) 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 P3rty of Texas Rules adopted in accordance with the Election Code Robert Rules of Order current dit en neNly re ised would govern parliamentary procedure The temporary chairman then explained how the actions of lis mvention auld influence important party decisions at subsequent convlntions

-hE~onvention Elected as permanent chairman of the precinct convention

-~ Election of DI~legates and Alternates to the County or State Senatorial DistrictConvention -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 alternats are listed in Exhibit C

5 tesolutions The gtermanent chairr1an 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

sdopted b a mcjority vote are included with these minutes

5 Other Business Ths permanent chairman then asked if there was any other business that shculd properly come before the convention

7 Announcemfnts 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 heshe would officially sign stal 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 (174027c) The chairman announced the time and place for the county or senatorial district cgtnvention

8 Adjournmen t In accordance vli~ha)motion properly moved and seconded and adopted by a majority vote the precinct convention was

ad~ed at iq pm I J fit~ -- ~-ed lZi Aft-t=

ermanent hairman ~ Secretary

Return to y)ur county chairman The permanent chairman should also IOpy and retain a record of all documents

PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

INSTRUCTIONS FOR THE PRECINCT CONVENTIONS

TIMEPLACE 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 700 pm and 900 pm 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 precincts 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 countysenatorial 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 Roberts 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 wwwtexasgoporg and click on the GOP Resources link

PREPARATION OF LIST OF QUALlFIED PARTICIPANTS Attendees must have voted in that precincts 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 heshe takes the chair and oversees the election of the permanent secretary If necessary the chairman and the secretary may be the same person

ANNOUNCEMENTOF COUNTYSENATORIAJ-PI~TRICT COflVENTION The convention will convene on Saturday March 29 th at IcY0cJ ~~ (time) in q76R kAfr-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 countysenatorial 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 countysenatorial 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 countysenatorial 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 countysenatorial 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

PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

Precinct GV gtPage I of -----L EXHIBIT A

Senate District __ List of qualified voters who ATTENDED precinct convention

VOTERCERT PRINT NAME PRINT MAILING ADDRESS CONTACT INFORMATION

(DY ro3 ofJ1

O~9~~ Y1

MI Phone 1- ff ~-OcJamp g)( ()ft E-Mail

~- ~ST- tzs-MI Phone

~7

MIv- First tit rCo Sto 167 7 ~ gt

j I fp v) V I YtLast it1] As

f~ s--- MI Phone ( 1s~o7 3~~ lo~ 03 05 CitAS E-Mail

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Last Cit -

First Phone ( rij-)-3 oz 1~ E-Mail

Phone bull ~V I -- Pltfrshy

I0 3C(rr11 E-Mail

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I I i~a (it Zio _~_ I E-Mail ==I

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Zip E-Mail

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PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

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Request for Clarification Inbox

w vanessa cahill (Ni jdld Mar 16 Reply

Mr Bertuzzi

I would like to be sure that my recollection of our first telephone conversation is correct(March 6 2008) As per my memory I requested information on the dates 1imes and locations of the Credentials and Nominations Committees for Nueces County You then asked that I send my request in writing which I promptly did via email (March 6 2008) From the email attachment I received from Mike Bergsma (March 132008) I have made the reasonable assumption that you have opened and read my email request for this information

I would also like to clarify the second and last conversation we had over the telephone (March 12 2008) As per my memory you told me that you would not be providing to me the information I was requesting From what I understood your reluctance to provide the requested information to me stemmed from my affiliation with a local meetup group in which a fellow member Chuck Burnett voiced his opinions of local leadership in the Republican Party

I would also like clarification from you on the 14th Rule of the General Rules for All Conventions and Meetings of the Republican Party of Texas which states

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 to that convention

As a voter in the Republican Primary and a delegate in my precinct I would again like to request the dates times and locations for the following committees

Credentials Resolutions Rules and Nominations

In addition I would also like to request a copy of accurate written records (minutes) from every Precinct in Nueces County Please notify me when these copies have been completed and I will pick them up from the Republican Party Headquarters

Thank you for your time

( Newer 29 of 179 Older)

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httomailcooclecommaillui=1ampik=559db3fdOOampview=cvampsearch=sentampth=119c5ce2 5152008

err amp Cause No

VANESSA L CAHILL sect SUPREME COURT OF TEXAS

VS sect sect 201 W 14TH STREET RM 104 sect

NUECESCOUNTY sect AUSTIN TEXAS REPUBLICAN PARTY sect

sect REPUBLICAN PARTY OF TEXAS sect

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 ~~j)~A A it A

~ d i

~fS~~~i LINDA D ZEPEDA f ltJ r~~v Notary Public

~ bull STATE OF TEXAS ~

~~~l My Comm Exp 11262011I LOndo- P~CL~ V V V V

Printed Name

My commission expires 1-clt - 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 IIssrional d rllcctt l number of county Texas met at JMI+td Ge1-e-Ik __amp~ (location) on J-QQ f (date) to hold a precinct convention

1 Call to Order - I (I bull The convention was called to order by temporary chairman J) G( ( 1--~1 I----Th------------__ at 7 s-Opm

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~nelti~I1~911Igirttuen9~importantparjy decisions at subsequentcQnven~ions

3 Election of Permanent Officers The temporary chairman announced that nominations for permanent chairman of this precinct convention woUld be

acceh~~~tIlO~~ tft0ns were nominated as candidates --- shy

The convention elected baf SwtmiddotfI as permanent chairman of the precinct convention The convention elected =na~ 2- SOl r 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 Ill (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 ~ovention

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 beshe 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 reguiredPy Ryle 22 and the Election Code (1740270) 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~pm~_ 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

-i

f1 Precinct fl

0 EXIDBITB E Senate District 20 0 (l) List of DELEGATES elected to County I Senatorial District Convention (J

(J VOTERCERT PRINT NAME PRINT MAILING ADDRESS (l)

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First Ed i-~ MI JV1 Address 0 9gt 5~ La kevi t LAJ Pbo~ 30L - 334--lLA-Z- I JD3~3D 2D11 Last Srn ~~~ CitdSXDu5 ChiSt Zip 184-12 E-Mail

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PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

Page of ___

CONTACT INFO~1ATION

1-1 -334--124-2shy

j I I

1 ~

I

SQT FCause No

VANESSA L CAHILL sect SUPREME COURT OF TEXAS sect

VS sect 201 W 14TH STREET RM 104 sect

NUECESCOUNTY sect AUSTIN TEXAS REPUBLICAN PARTY sect

sect REPUBLICAN PARTY OF TEXAS sect

BUSINESS RECORDS AFFIDAVIT

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

hereto are an exact duplicate of the original

Further affiant sayeth not

~lffmiddotLnL KayLu

SUBSCRIBED AND SWORN TO before me on this May 6 2008 to which I place my

signature and official seal )dQampyM-u J11du~ Signature

dele Jampylt-pound 71LeAJ Printed Name

My commission expires 1 -J-d~tcf Notary Public for the State of Texas

VICKIE JOY VAN MAREN Notary Public

STATE OF TEXAS My Comm Exp 10-05-2008

MINUTES OF THE REPUBLICAN PARTY PRECINCT CONVENTION

CJ3 ed v~ ters a election precinct nymber 5~g senate district numt er congressional district LJmber of ~ county Texas met at -nK~ ~4A-ltj (Jccion) C1 __trh-ltl lcJV L- oog (date) to hold a precinct convent xf

- CI to Order _-~ J r(3-1e ionver-tion as called to order by temporary chairman _dM~1 at ~-pm

P~pararon 0 List of Participants ( -le mpoary cr airmin 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 _ (numJer) 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 P3rty of Texas Rules adopted in accordance with the Election Code Robert Rules of Order current dit en neNly re ised would govern parliamentary procedure The temporary chairman then explained how the actions of lis mvention auld influence important party decisions at subsequent convlntions

-hE~onvention Elected as permanent chairman of the precinct convention

-~ Election of DI~legates and Alternates to the County or State Senatorial DistrictConvention -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 alternats are listed in Exhibit C

5 tesolutions The gtermanent chairr1an 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

sdopted b a mcjority vote are included with these minutes

5 Other Business Ths permanent chairman then asked if there was any other business that shculd properly come before the convention

7 Announcemfnts 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 heshe would officially sign stal 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 (174027c) The chairman announced the time and place for the county or senatorial district cgtnvention

8 Adjournmen t In accordance vli~ha)motion properly moved and seconded and adopted by a majority vote the precinct convention was

ad~ed at iq pm I J fit~ -- ~-ed lZi Aft-t=

ermanent hairman ~ Secretary

Return to y)ur county chairman The permanent chairman should also IOpy and retain a record of all documents

PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

INSTRUCTIONS FOR THE PRECINCT CONVENTIONS

TIMEPLACE 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 700 pm and 900 pm 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 precincts 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 countysenatorial 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 Roberts 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 wwwtexasgoporg and click on the GOP Resources link

PREPARATION OF LIST OF QUALlFIED PARTICIPANTS Attendees must have voted in that precincts 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 heshe takes the chair and oversees the election of the permanent secretary If necessary the chairman and the secretary may be the same person

ANNOUNCEMENTOF COUNTYSENATORIAJ-PI~TRICT COflVENTION The convention will convene on Saturday March 29 th at IcY0cJ ~~ (time) in q76R kAfr-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 countysenatorial 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 countysenatorial 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 countysenatorial 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 countysenatorial 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

PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

Precinct GV gtPage I of -----L EXHIBIT A

Senate District __ List of qualified voters who ATTENDED precinct convention

VOTERCERT PRINT NAME PRINT MAILING ADDRESS CONTACT INFORMATION

(DY ro3 ofJ1

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MI Phone 1- ff ~-OcJamp g)( ()ft E-Mail

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Last Cit -

First Phone ( rij-)-3 oz 1~ E-Mail

Phone bull ~V I -- Pltfrshy

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I I MI~- I Add~ I--==Pho=-ncshy

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Zip E-Mail

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PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

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I IFin MI I~dd~ ~ Ph~ I I I Last I U) ~ F-Mml

First MI Address _____ I Phone

City Zip I E-Mail __1 Last 3 PR()VTnfD BY THE RFPHBUCAN PARTY OF TEXAS

err amp Cause No

VANESSA L CAHILL sect SUPREME COURT OF TEXAS

VS sect sect 201 W 14TH STREET RM 104 sect

NUECESCOUNTY sect AUSTIN TEXAS REPUBLICAN PARTY sect

sect REPUBLICAN PARTY OF TEXAS sect

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 ~~j)~A A it A

~ d i

~fS~~~i LINDA D ZEPEDA f ltJ r~~v Notary Public

~ bull STATE OF TEXAS ~

~~~l My Comm Exp 11262011I LOndo- P~CL~ V V V V

Printed Name

My commission expires 1-clt - 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 IIssrional d rllcctt l number of county Texas met at JMI+td Ge1-e-Ik __amp~ (location) on J-QQ f (date) to hold a precinct convention

1 Call to Order - I (I bull The convention was called to order by temporary chairman J) G( ( 1--~1 I----Th------------__ at 7 s-Opm

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~nelti~I1~911Igirttuen9~importantparjy decisions at subsequentcQnven~ions

3 Election of Permanent Officers The temporary chairman announced that nominations for permanent chairman of this precinct convention woUld be

acceh~~~tIlO~~ tft0ns were nominated as candidates --- shy

The convention elected baf SwtmiddotfI as permanent chairman of the precinct convention The convention elected =na~ 2- SOl r 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 Ill (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 ~ovention

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 beshe 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 reguiredPy Ryle 22 and the Election Code (1740270) 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~pm~_ 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

-i

f1 Precinct fl

0 EXIDBITB E Senate District 20 0 (l) List of DELEGATES elected to County I Senatorial District Convention (J

(J VOTERCERT PRINT NAME PRINT MAILING ADDRESS (l)

Flm 1)~h1e- MI F Plmnc (J

Ad~b~5~ LakevleuJ~

1039X)lJZ1~LJst5n jJJl shy CilT Cornt15 Lh6 5~t Zip 16412 [-MailIS) I

~ First l)arrv) 5171 MI 1 Add~ 4632 La kEV iev] - ~-9S5-0923 If1l E lzu~9737b9Z lAst 5th 1~ CillLoroUS Ch r is+( ZIp ~ 8412 E-Mail

First Ed i-~ MI JV1 Address 0 9gt 5~ La kevi t LAJ Pbo~ 30L - 334--lLA-Z- I JD3~3D 2D11 Last Srn ~~~ CitdSXDu5 ChiSt Zip 184-12 E-Mail

(J f (J First 1rL1 Address Pirone-i

f Lim On ZiD E-Mail11

M1 IA~~ Ift~~ Citf Zip EmiddotMlIll

MJ IAdm IPbo Cin Zip E-M81l

MI IA_ IPh~ Cih~ bull Zip E-II-fail

M~ 1--- 1-City Zip E-Mail

gtLL 1--- IPh Citf Zip E-Mail

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PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

Page of ___

CONTACT INFO~1ATION

1-1 -334--124-2shy

j I I

1 ~

I

SQT FCause No

VANESSA L CAHILL sect SUPREME COURT OF TEXAS sect

VS sect 201 W 14TH STREET RM 104 sect

NUECESCOUNTY sect AUSTIN TEXAS REPUBLICAN PARTY sect

sect REPUBLICAN PARTY OF TEXAS sect

BUSINESS RECORDS AFFIDAVIT

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

hereto are an exact duplicate of the original

Further affiant sayeth not

~lffmiddotLnL KayLu

SUBSCRIBED AND SWORN TO before me on this May 6 2008 to which I place my

signature and official seal )dQampyM-u J11du~ Signature

dele Jampylt-pound 71LeAJ Printed Name

My commission expires 1 -J-d~tcf Notary Public for the State of Texas

VICKIE JOY VAN MAREN Notary Public

STATE OF TEXAS My Comm Exp 10-05-2008

MINUTES OF THE REPUBLICAN PARTY PRECINCT CONVENTION

CJ3 ed v~ ters a election precinct nymber 5~g senate district numt er congressional district LJmber of ~ county Texas met at -nK~ ~4A-ltj (Jccion) C1 __trh-ltl lcJV L- oog (date) to hold a precinct convent xf

- CI to Order _-~ J r(3-1e ionver-tion as called to order by temporary chairman _dM~1 at ~-pm

P~pararon 0 List of Participants ( -le mpoary cr airmin 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 _ (numJer) 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 P3rty of Texas Rules adopted in accordance with the Election Code Robert Rules of Order current dit en neNly re ised would govern parliamentary procedure The temporary chairman then explained how the actions of lis mvention auld influence important party decisions at subsequent convlntions

-hE~onvention Elected as permanent chairman of the precinct convention

-~ Election of DI~legates and Alternates to the County or State Senatorial DistrictConvention -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 alternats are listed in Exhibit C

5 tesolutions The gtermanent chairr1an 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

sdopted b a mcjority vote are included with these minutes

5 Other Business Ths permanent chairman then asked if there was any other business that shculd properly come before the convention

7 Announcemfnts 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 heshe would officially sign stal 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 (174027c) The chairman announced the time and place for the county or senatorial district cgtnvention

8 Adjournmen t In accordance vli~ha)motion properly moved and seconded and adopted by a majority vote the precinct convention was

ad~ed at iq pm I J fit~ -- ~-ed lZi Aft-t=

ermanent hairman ~ Secretary

Return to y)ur county chairman The permanent chairman should also IOpy and retain a record of all documents

PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

INSTRUCTIONS FOR THE PRECINCT CONVENTIONS

TIMEPLACE 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 700 pm and 900 pm 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 precincts 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 countysenatorial 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 Roberts 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 wwwtexasgoporg and click on the GOP Resources link

PREPARATION OF LIST OF QUALlFIED PARTICIPANTS Attendees must have voted in that precincts 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 heshe takes the chair and oversees the election of the permanent secretary If necessary the chairman and the secretary may be the same person

ANNOUNCEMENTOF COUNTYSENATORIAJ-PI~TRICT COflVENTION The convention will convene on Saturday March 29 th at IcY0cJ ~~ (time) in q76R kAfr-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 countysenatorial 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 countysenatorial 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 countysenatorial 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 countysenatorial 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

PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

Precinct GV gtPage I of -----L EXHIBIT A

Senate District __ List of qualified voters who ATTENDED precinct convention

VOTERCERT PRINT NAME PRINT MAILING ADDRESS CONTACT INFORMATION

(DY ro3 ofJ1

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MI Phone 1- ff ~-OcJamp g)( ()ft E-Mail

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Iirst kO~t rJIlJ 3amp( LtfO~

Last Cit -

First Phone ( rij-)-3 oz 1~ E-Mail

Phone bull ~V I -- Pltfrshy

I0 3C(rr11 E-Mail

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I I i~a (it Zio _~_ I E-Mail ==I

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Zip E-Mail

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PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

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City Zip I E-Mail __1 Last 3 PR()VTnfD BY THE RFPHBUCAN PARTY 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 IIssrional d rllcctt l number of county Texas met at JMI+td Ge1-e-Ik __amp~ (location) on J-QQ f (date) to hold a precinct convention

1 Call to Order - I (I bull The convention was called to order by temporary chairman J) G( ( 1--~1 I----Th------------__ at 7 s-Opm

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~nelti~I1~911Igirttuen9~importantparjy decisions at subsequentcQnven~ions

3 Election of Permanent Officers The temporary chairman announced that nominations for permanent chairman of this precinct convention woUld be

acceh~~~tIlO~~ tft0ns were nominated as candidates --- shy

The convention elected baf SwtmiddotfI as permanent chairman of the precinct convention The convention elected =na~ 2- SOl r 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 Ill (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 ~ovention

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 beshe 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 reguiredPy Ryle 22 and the Election Code (1740270) 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~pm~_ 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

-i

f1 Precinct fl

0 EXIDBITB E Senate District 20 0 (l) List of DELEGATES elected to County I Senatorial District Convention (J

(J VOTERCERT PRINT NAME PRINT MAILING ADDRESS (l)

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First Ed i-~ MI JV1 Address 0 9gt 5~ La kevi t LAJ Pbo~ 30L - 334--lLA-Z- I JD3~3D 2D11 Last Srn ~~~ CitdSXDu5 ChiSt Zip 184-12 E-Mail

(J f (J First 1rL1 Address Pirone-i

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M1 IA~~ Ift~~ Citf Zip EmiddotMlIll

MJ IAdm IPbo Cin Zip E-M81l

MI IA_ IPh~ Cih~ bull Zip E-II-fail

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PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

Page of ___

CONTACT INFO~1ATION

1-1 -334--124-2shy

j I I

1 ~

I

SQT FCause No

VANESSA L CAHILL sect SUPREME COURT OF TEXAS sect

VS sect 201 W 14TH STREET RM 104 sect

NUECESCOUNTY sect AUSTIN TEXAS REPUBLICAN PARTY sect

sect REPUBLICAN PARTY OF TEXAS sect

BUSINESS RECORDS AFFIDAVIT

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

hereto are an exact duplicate of the original

Further affiant sayeth not

~lffmiddotLnL KayLu

SUBSCRIBED AND SWORN TO before me on this May 6 2008 to which I place my

signature and official seal )dQampyM-u J11du~ Signature

dele Jampylt-pound 71LeAJ Printed Name

My commission expires 1 -J-d~tcf Notary Public for the State of Texas

VICKIE JOY VAN MAREN Notary Public

STATE OF TEXAS My Comm Exp 10-05-2008

MINUTES OF THE REPUBLICAN PARTY PRECINCT CONVENTION

CJ3 ed v~ ters a election precinct nymber 5~g senate district numt er congressional district LJmber of ~ county Texas met at -nK~ ~4A-ltj (Jccion) C1 __trh-ltl lcJV L- oog (date) to hold a precinct convent xf

- CI to Order _-~ J r(3-1e ionver-tion as called to order by temporary chairman _dM~1 at ~-pm

P~pararon 0 List of Participants ( -le mpoary cr airmin 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 _ (numJer) 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 P3rty of Texas Rules adopted in accordance with the Election Code Robert Rules of Order current dit en neNly re ised would govern parliamentary procedure The temporary chairman then explained how the actions of lis mvention auld influence important party decisions at subsequent convlntions

-hE~onvention Elected as permanent chairman of the precinct convention

-~ Election of DI~legates and Alternates to the County or State Senatorial DistrictConvention -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 alternats are listed in Exhibit C

5 tesolutions The gtermanent chairr1an 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

sdopted b a mcjority vote are included with these minutes

5 Other Business Ths permanent chairman then asked if there was any other business that shculd properly come before the convention

7 Announcemfnts 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 heshe would officially sign stal 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 (174027c) The chairman announced the time and place for the county or senatorial district cgtnvention

8 Adjournmen t In accordance vli~ha)motion properly moved and seconded and adopted by a majority vote the precinct convention was

ad~ed at iq pm I J fit~ -- ~-ed lZi Aft-t=

ermanent hairman ~ Secretary

Return to y)ur county chairman The permanent chairman should also IOpy and retain a record of all documents

PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

INSTRUCTIONS FOR THE PRECINCT CONVENTIONS

TIMEPLACE 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 700 pm and 900 pm 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 precincts 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 countysenatorial 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 Roberts 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 wwwtexasgoporg and click on the GOP Resources link

PREPARATION OF LIST OF QUALlFIED PARTICIPANTS Attendees must have voted in that precincts 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 heshe takes the chair and oversees the election of the permanent secretary If necessary the chairman and the secretary may be the same person

ANNOUNCEMENTOF COUNTYSENATORIAJ-PI~TRICT COflVENTION The convention will convene on Saturday March 29 th at IcY0cJ ~~ (time) in q76R kAfr-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 countysenatorial 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 countysenatorial 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 countysenatorial 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 countysenatorial 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

PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

Precinct GV gtPage I of -----L EXHIBIT A

Senate District __ List of qualified voters who ATTENDED precinct convention

VOTERCERT PRINT NAME PRINT MAILING ADDRESS CONTACT INFORMATION

(DY ro3 ofJ1

O~9~~ Y1

MI Phone 1- ff ~-OcJamp g)( ()ft E-Mail

~- ~ST- tzs-MI Phone

~7

MIv- First tit rCo Sto 167 7 ~ gt

j I fp v) V I YtLast it1] As

f~ s--- MI Phone ( 1s~o7 3~~ lo~ 03 05 CitAS E-Mail

~(b f)vcAA DMI Phone ~~r-

vLTshy E-Mail

Iirst kO~t rJIlJ 3amp( LtfO~

Last Cit -

First Phone ( rij-)-3 oz 1~ E-Mail

Phone bull ~V I -- Pltfrshy

I0 3C(rr11 E-Mail

I I MI~- I Add~ I--==Pho=-ncshy

I I i~a (it Zio _~_ I E-Mail ==I

I I

Lasl

~Flrs __gt _ MI

City

I Address gt-----shy

Zip E-Mail

I Phone

PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

I

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Precinct At - --~__- --_- - EXHIBIT ~ j _ it ~ ~ middot~1 ~ bullbull 1LUi~~ Senate District -- List of DELEGATES elected to County I i~~~ ~

lNFORMATIONPRINT MAU~middot J 14IJt middotIil bullbullbullbullbull~ fVOTERCERT

6 t (

Address

City

MI fJ

I v middot I I Addresscr l- L lt_H~v n rIC I V IPhone -Vi

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~e MIT- IAdd~ ]0 ( q)tL6ltgt ~ Ph 3(( J of P-oJH=-I V (0 City (V (J _ -x Zip 7No u E-Mail

I IFin MI I~dd~ ~ Ph~ I I I Last I U) ~ F-Mml

First MI Address _____ I Phone

City Zip I E-Mail __1 Last 3 PR()VTnfD BY THE RFPHBUCAN PARTY OF TEXAS

-i

f1 Precinct fl

0 EXIDBITB E Senate District 20 0 (l) List of DELEGATES elected to County I Senatorial District Convention (J

(J VOTERCERT PRINT NAME PRINT MAILING ADDRESS (l)

Flm 1)~h1e- MI F Plmnc (J

Ad~b~5~ LakevleuJ~

1039X)lJZ1~LJst5n jJJl shy CilT Cornt15 Lh6 5~t Zip 16412 [-MailIS) I

~ First l)arrv) 5171 MI 1 Add~ 4632 La kEV iev] - ~-9S5-0923 If1l E lzu~9737b9Z lAst 5th 1~ CillLoroUS Ch r is+( ZIp ~ 8412 E-Mail

First Ed i-~ MI JV1 Address 0 9gt 5~ La kevi t LAJ Pbo~ 30L - 334--lLA-Z- I JD3~3D 2D11 Last Srn ~~~ CitdSXDu5 ChiSt Zip 184-12 E-Mail

(J f (J First 1rL1 Address Pirone-i

f Lim On ZiD E-Mail11

M1 IA~~ Ift~~ Citf Zip EmiddotMlIll

MJ IAdm IPbo Cin Zip E-M81l

MI IA_ IPh~ Cih~ bull Zip E-II-fail

M~ 1--- 1-City Zip E-Mail

gtLL 1--- IPh Citf Zip E-Mail

gt~ 1-- 1 Poo~ City Zip E-Mail

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PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

Page of ___

CONTACT INFO~1ATION

1-1 -334--124-2shy

j I I

1 ~

I

SQT FCause No

VANESSA L CAHILL sect SUPREME COURT OF TEXAS sect

VS sect 201 W 14TH STREET RM 104 sect

NUECESCOUNTY sect AUSTIN TEXAS REPUBLICAN PARTY sect

sect REPUBLICAN PARTY OF TEXAS sect

BUSINESS RECORDS AFFIDAVIT

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

hereto are an exact duplicate of the original

Further affiant sayeth not

~lffmiddotLnL KayLu

SUBSCRIBED AND SWORN TO before me on this May 6 2008 to which I place my

signature and official seal )dQampyM-u J11du~ Signature

dele Jampylt-pound 71LeAJ Printed Name

My commission expires 1 -J-d~tcf Notary Public for the State of Texas

VICKIE JOY VAN MAREN Notary Public

STATE OF TEXAS My Comm Exp 10-05-2008

MINUTES OF THE REPUBLICAN PARTY PRECINCT CONVENTION

CJ3 ed v~ ters a election precinct nymber 5~g senate district numt er congressional district LJmber of ~ county Texas met at -nK~ ~4A-ltj (Jccion) C1 __trh-ltl lcJV L- oog (date) to hold a precinct convent xf

- CI to Order _-~ J r(3-1e ionver-tion as called to order by temporary chairman _dM~1 at ~-pm

P~pararon 0 List of Participants ( -le mpoary cr airmin 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 _ (numJer) 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 P3rty of Texas Rules adopted in accordance with the Election Code Robert Rules of Order current dit en neNly re ised would govern parliamentary procedure The temporary chairman then explained how the actions of lis mvention auld influence important party decisions at subsequent convlntions

-hE~onvention Elected as permanent chairman of the precinct convention

-~ Election of DI~legates and Alternates to the County or State Senatorial DistrictConvention -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 alternats are listed in Exhibit C

5 tesolutions The gtermanent chairr1an 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

sdopted b a mcjority vote are included with these minutes

5 Other Business Ths permanent chairman then asked if there was any other business that shculd properly come before the convention

7 Announcemfnts 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 heshe would officially sign stal 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 (174027c) The chairman announced the time and place for the county or senatorial district cgtnvention

8 Adjournmen t In accordance vli~ha)motion properly moved and seconded and adopted by a majority vote the precinct convention was

ad~ed at iq pm I J fit~ -- ~-ed lZi Aft-t=

ermanent hairman ~ Secretary

Return to y)ur county chairman The permanent chairman should also IOpy and retain a record of all documents

PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

INSTRUCTIONS FOR THE PRECINCT CONVENTIONS

TIMEPLACE 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 700 pm and 900 pm 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 precincts 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 countysenatorial 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 Roberts 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 wwwtexasgoporg and click on the GOP Resources link

PREPARATION OF LIST OF QUALlFIED PARTICIPANTS Attendees must have voted in that precincts 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 heshe takes the chair and oversees the election of the permanent secretary If necessary the chairman and the secretary may be the same person

ANNOUNCEMENTOF COUNTYSENATORIAJ-PI~TRICT COflVENTION The convention will convene on Saturday March 29 th at IcY0cJ ~~ (time) in q76R kAfr-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 countysenatorial 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 countysenatorial 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 countysenatorial 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 countysenatorial 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

PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

Precinct GV gtPage I of -----L EXHIBIT A

Senate District __ List of qualified voters who ATTENDED precinct convention

VOTERCERT PRINT NAME PRINT MAILING ADDRESS CONTACT INFORMATION

(DY ro3 ofJ1

O~9~~ Y1

MI Phone 1- ff ~-OcJamp g)( ()ft E-Mail

~- ~ST- tzs-MI Phone

~7

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j I fp v) V I YtLast it1] As

f~ s--- MI Phone ( 1s~o7 3~~ lo~ 03 05 CitAS E-Mail

~(b f)vcAA DMI Phone ~~r-

vLTshy E-Mail

Iirst kO~t rJIlJ 3amp( LtfO~

Last Cit -

First Phone ( rij-)-3 oz 1~ E-Mail

Phone bull ~V I -- Pltfrshy

I0 3C(rr11 E-Mail

I I MI~- I Add~ I--==Pho=-ncshy

I I i~a (it Zio _~_ I E-Mail ==I

I I

Lasl

~Flrs __gt _ MI

City

I Address gt-----shy

Zip E-Mail

I Phone

PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

I

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First MI Address _____ I Phone

City Zip I E-Mail __1 Last 3 PR()VTnfD BY THE RFPHBUCAN PARTY OF TEXAS

SQT FCause No

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VS sect 201 W 14TH STREET RM 104 sect

NUECESCOUNTY sect AUSTIN TEXAS REPUBLICAN PARTY sect

sect REPUBLICAN PARTY OF TEXAS sect

BUSINESS RECORDS AFFIDAVIT

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

hereto are an exact duplicate of the original

Further affiant sayeth not

~lffmiddotLnL KayLu

SUBSCRIBED AND SWORN TO before me on this May 6 2008 to which I place my

signature and official seal )dQampyM-u J11du~ Signature

dele Jampylt-pound 71LeAJ Printed Name

My commission expires 1 -J-d~tcf Notary Public for the State of Texas

VICKIE JOY VAN MAREN Notary Public

STATE OF TEXAS My Comm Exp 10-05-2008

MINUTES OF THE REPUBLICAN PARTY PRECINCT CONVENTION

CJ3 ed v~ ters a election precinct nymber 5~g senate district numt er congressional district LJmber of ~ county Texas met at -nK~ ~4A-ltj (Jccion) C1 __trh-ltl lcJV L- oog (date) to hold a precinct convent xf

- CI to Order _-~ J r(3-1e ionver-tion as called to order by temporary chairman _dM~1 at ~-pm

P~pararon 0 List of Participants ( -le mpoary cr airmin 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 _ (numJer) 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 P3rty of Texas Rules adopted in accordance with the Election Code Robert Rules of Order current dit en neNly re ised would govern parliamentary procedure The temporary chairman then explained how the actions of lis mvention auld influence important party decisions at subsequent convlntions

-hE~onvention Elected as permanent chairman of the precinct convention

-~ Election of DI~legates and Alternates to the County or State Senatorial DistrictConvention -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 alternats are listed in Exhibit C

5 tesolutions The gtermanent chairr1an 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

sdopted b a mcjority vote are included with these minutes

5 Other Business Ths permanent chairman then asked if there was any other business that shculd properly come before the convention

7 Announcemfnts 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 heshe would officially sign stal 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 (174027c) The chairman announced the time and place for the county or senatorial district cgtnvention

8 Adjournmen t In accordance vli~ha)motion properly moved and seconded and adopted by a majority vote the precinct convention was

ad~ed at iq pm I J fit~ -- ~-ed lZi Aft-t=

ermanent hairman ~ Secretary

Return to y)ur county chairman The permanent chairman should also IOpy and retain a record of all documents

PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

INSTRUCTIONS FOR THE PRECINCT CONVENTIONS

TIMEPLACE 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 700 pm and 900 pm 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 precincts 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 countysenatorial 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 Roberts 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 wwwtexasgoporg and click on the GOP Resources link

PREPARATION OF LIST OF QUALlFIED PARTICIPANTS Attendees must have voted in that precincts 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 heshe takes the chair and oversees the election of the permanent secretary If necessary the chairman and the secretary may be the same person

ANNOUNCEMENTOF COUNTYSENATORIAJ-PI~TRICT COflVENTION The convention will convene on Saturday March 29 th at IcY0cJ ~~ (time) in q76R kAfr-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 countysenatorial 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 countysenatorial 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 countysenatorial 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 countysenatorial 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

PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

Precinct GV gtPage I of -----L EXHIBIT A

Senate District __ List of qualified voters who ATTENDED precinct convention

VOTERCERT PRINT NAME PRINT MAILING ADDRESS CONTACT INFORMATION

(DY ro3 ofJ1

O~9~~ Y1

MI Phone 1- ff ~-OcJamp g)( ()ft E-Mail

~- ~ST- tzs-MI Phone

~7

MIv- First tit rCo Sto 167 7 ~ gt

j I fp v) V I YtLast it1] As

f~ s--- MI Phone ( 1s~o7 3~~ lo~ 03 05 CitAS E-Mail

~(b f)vcAA DMI Phone ~~r-

vLTshy E-Mail

Iirst kO~t rJIlJ 3amp( LtfO~

Last Cit -

First Phone ( rij-)-3 oz 1~ E-Mail

Phone bull ~V I -- Pltfrshy

I0 3C(rr11 E-Mail

I I MI~- I Add~ I--==Pho=-ncshy

I I i~a (it Zio _~_ I E-Mail ==I

I I

Lasl

~Flrs __gt _ MI

City

I Address gt-----shy

Zip E-Mail

I Phone

PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

I

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) bull V bullbullubull bullAt of j~Sgt l )- 1 (J c)middotmiddotmiddot )L ( - i bull middot middotmiddot bull~rbullbullbullbullbullbullbull C tlio

Precinct At - --~__- --_- - EXHIBIT ~ j _ it ~ ~ middot~1 ~ bullbull 1LUi~~ Senate District -- List of DELEGATES elected to County I i~~~ ~

lNFORMATIONPRINT MAU~middot J 14IJt middotIil bullbullbullbullbull~ fVOTERCERT

6 t (

Address

City

MI fJ

I v middot I I Addresscr l- L lt_H~v n rIC I V IPhone -Vi

First

First

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Last

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IcAr MI Address _ tw bull bull(L ~ ~~]1 ~~~ bullbull~ - C ~~FtJii cu

~

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i0 j CJ (p Ltg () ~rlrst j~middot1 -f7 0 1 I

~S- -(Po lt~ I ML M Ph~ 3(p I ZC-s--)3(

E-Mail

MI ft 7ampS-~93igt I

IFirst Jlt1r-0 g-~7 -)P 2shy

E-Mail

~e MIT- IAdd~ ]0 ( q)tL6ltgt ~ Ph 3(( J of P-oJH=-I V (0 City (V (J _ -x Zip 7No u E-Mail

I IFin MI I~dd~ ~ Ph~ I I I Last I U) ~ F-Mml

First MI Address _____ I Phone

City Zip I E-Mail __1 Last 3 PR()VTnfD BY THE RFPHBUCAN PARTY OF TEXAS

MINUTES OF THE REPUBLICAN PARTY PRECINCT CONVENTION

CJ3 ed v~ ters a election precinct nymber 5~g senate district numt er congressional district LJmber of ~ county Texas met at -nK~ ~4A-ltj (Jccion) C1 __trh-ltl lcJV L- oog (date) to hold a precinct convent xf

- CI to Order _-~ J r(3-1e ionver-tion as called to order by temporary chairman _dM~1 at ~-pm

P~pararon 0 List of Participants ( -le mpoary cr airmin 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 _ (numJer) 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 P3rty of Texas Rules adopted in accordance with the Election Code Robert Rules of Order current dit en neNly re ised would govern parliamentary procedure The temporary chairman then explained how the actions of lis mvention auld influence important party decisions at subsequent convlntions

-hE~onvention Elected as permanent chairman of the precinct convention

-~ Election of DI~legates and Alternates to the County or State Senatorial DistrictConvention -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 alternats are listed in Exhibit C

5 tesolutions The gtermanent chairr1an 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

sdopted b a mcjority vote are included with these minutes

5 Other Business Ths permanent chairman then asked if there was any other business that shculd properly come before the convention

7 Announcemfnts 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 heshe would officially sign stal 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 (174027c) The chairman announced the time and place for the county or senatorial district cgtnvention

8 Adjournmen t In accordance vli~ha)motion properly moved and seconded and adopted by a majority vote the precinct convention was

ad~ed at iq pm I J fit~ -- ~-ed lZi Aft-t=

ermanent hairman ~ Secretary

Return to y)ur county chairman The permanent chairman should also IOpy and retain a record of all documents

PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

INSTRUCTIONS FOR THE PRECINCT CONVENTIONS

TIMEPLACE 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 700 pm and 900 pm 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 precincts 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 countysenatorial 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 Roberts 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 wwwtexasgoporg and click on the GOP Resources link

PREPARATION OF LIST OF QUALlFIED PARTICIPANTS Attendees must have voted in that precincts 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 heshe takes the chair and oversees the election of the permanent secretary If necessary the chairman and the secretary may be the same person

ANNOUNCEMENTOF COUNTYSENATORIAJ-PI~TRICT COflVENTION The convention will convene on Saturday March 29 th at IcY0cJ ~~ (time) in q76R kAfr-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 countysenatorial 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 countysenatorial 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 countysenatorial 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 countysenatorial 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

PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

Precinct GV gtPage I of -----L EXHIBIT A

Senate District __ List of qualified voters who ATTENDED precinct convention

VOTERCERT PRINT NAME PRINT MAILING ADDRESS CONTACT INFORMATION

(DY ro3 ofJ1

O~9~~ Y1

MI Phone 1- ff ~-OcJamp g)( ()ft E-Mail

~- ~ST- tzs-MI Phone

~7

MIv- First tit rCo Sto 167 7 ~ gt

j I fp v) V I YtLast it1] As

f~ s--- MI Phone ( 1s~o7 3~~ lo~ 03 05 CitAS E-Mail

~(b f)vcAA DMI Phone ~~r-

vLTshy E-Mail

Iirst kO~t rJIlJ 3amp( LtfO~

Last Cit -

First Phone ( rij-)-3 oz 1~ E-Mail

Phone bull ~V I -- Pltfrshy

I0 3C(rr11 E-Mail

I I MI~- I Add~ I--==Pho=-ncshy

I I i~a (it Zio _~_ I E-Mail ==I

I I

Lasl

~Flrs __gt _ MI

City

I Address gt-----shy

Zip E-Mail

I Phone

PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

I

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) bull V bullbullubull bullAt of j~Sgt l )- 1 (J c)middotmiddotmiddot )L ( - i bull middot middotmiddot bull~rbullbullbullbullbullbullbull C tlio

Precinct At - --~__- --_- - EXHIBIT ~ j _ it ~ ~ middot~1 ~ bullbull 1LUi~~ Senate District -- List of DELEGATES elected to County I i~~~ ~

lNFORMATIONPRINT MAU~middot J 14IJt middotIil bullbullbullbullbull~ fVOTERCERT

6 t (

Address

City

MI fJ

I v middot I I Addresscr l- L lt_H~v n rIC I V IPhone -Vi

First

First

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Last

Last

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IcAr MI Address _ tw bull bull(L ~ ~~]1 ~~~ bullbull~ - C ~~FtJii cu

~

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i0 j CJ (p Ltg () ~rlrst j~middot1 -f7 0 1 I

~S- -(Po lt~ I ML M Ph~ 3(p I ZC-s--)3(

E-Mail

MI ft 7ampS-~93igt I

IFirst Jlt1r-0 g-~7 -)P 2shy

E-Mail

~e MIT- IAdd~ ]0 ( q)tL6ltgt ~ Ph 3(( J of P-oJH=-I V (0 City (V (J _ -x Zip 7No u E-Mail

I IFin MI I~dd~ ~ Ph~ I I I Last I U) ~ F-Mml

First MI Address _____ I Phone

City Zip I E-Mail __1 Last 3 PR()VTnfD BY THE RFPHBUCAN PARTY OF TEXAS

INSTRUCTIONS FOR THE PRECINCT CONVENTIONS

TIMEPLACE 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 700 pm and 900 pm 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 precincts 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 countysenatorial 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 Roberts 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 wwwtexasgoporg and click on the GOP Resources link

PREPARATION OF LIST OF QUALlFIED PARTICIPANTS Attendees must have voted in that precincts 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 heshe takes the chair and oversees the election of the permanent secretary If necessary the chairman and the secretary may be the same person

ANNOUNCEMENTOF COUNTYSENATORIAJ-PI~TRICT COflVENTION The convention will convene on Saturday March 29 th at IcY0cJ ~~ (time) in q76R kAfr-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 countysenatorial 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 countysenatorial 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 countysenatorial 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 countysenatorial 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

PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

Precinct GV gtPage I of -----L EXHIBIT A

Senate District __ List of qualified voters who ATTENDED precinct convention

VOTERCERT PRINT NAME PRINT MAILING ADDRESS CONTACT INFORMATION

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exttIIMT (i Cause No

VANESSA L CAHILL sect SUPREME COURT OF TEXAS sect

VS sect 201 W 14TH STREET RM 104 sect

NUECES COUNTY sect AUSTIN TEXAS REPUBLICAN PARTY sect

sect REPUBLICAN PARTY OF TEXAS sect

BUSINESS RECORDS AFFIDAVIT

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

affidavit and personally acquainted with the facts stated herein

I am Chairman of precinct 70 In my capacity as precinct chainnan I have access

to and am familiar with the attached pages ofaccurate written minutesTrom precinct 70 Such

records were made at the precinct convention held on March 42008 The records attached

hereto are an exact duplicate of the original

Further affiant sayeth not

ricCd I i c itL C I Maria Angela Hultgren U

SUBSCRIBED AND SWORN TO before me on this May 6 2008 to which I place my

signature and official seal c j~

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NORMA J ALANIZ NOlOIV PtlllC Stote 01 Texas

My CQrnmIssIon EJPlres JoNJOIV 1S 200Q

L I[UL ~

A)J Z-IJ) 1 f I-iet~ j Printed Name

My commission expires SKYP) -IS J 1 () V 9 Notary Public for the State of texas

MINUTES OF THE REPUBLICAN PARTY PRECINCT CONVENTION

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-midu1ClI mlckH e ~bo) (location) on 3 Lf I 2ClOB (date) to hold a precinct convention -

1 Call to Order The convention was called to order by temporary chairman (a(j 6 Amiddot kh )l+Qre () at 757pm

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 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 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 permanent chairman then announced that heshe 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 (174027cl The chairman announced 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

adjourned at 8 pm f bull

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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

Precinct 1Q Page I of 3 Senate District 2Q EXHIBIT A

List of qualified voters who ATTENDED precinct convention

VOTERCERT PRINT NAME PRINT MAILING ADDRESS CONTACTINFO~TION

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PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

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VOTERCERT PRINT MAILING ADDRESS

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PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

March 4th 2008

r acknowledge that I am a registered voter living in Nucces County Precinct 7 J _ and that I have voted in the March 4th

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 500PM Fnday Marcb7th 2008) J c~I

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(JtVtA N 1

exalr HCause No

VANESSA L CAHILL sect SUPREME COURT OF TEXAS sect

VS sect 201 W 14TH STREET RM 104 sect

NUECES COUNTY sect AUSTIN TEXAS REPUBLICAN PARTY sect

sect REPUBLICAN PARTY OF TEXAS sect

BUSINESS RECORDS AFFIDAVIT

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

affidavit and personally acquainted with the facts stated herein

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 42008 The

records attached hereto are an exact duplicate of the original

Further affiant sayeth not

J

()i~middot6g~ 7 BenJa n BernIer

SUBSCRIBED AND SWORN TO before me on this May 6 2008 to which I place my

signature and official seal C_ -

~~~t~~I~~~~ NORMA J ALANIZ ~~o~~ ~Notary PIdc Stole 01 relICsiJ~)j My Commission fJlllJes ~~~ bullbull O January 15 2009-~~1 ~~~llJt J- HC rtll 2

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My commission expires 04-70 I r2l)OCjI

Notary Public for the State of Texas

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List of ALTERNATES elected to County Senatorial Ditrict COllcntiol1

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PROVIDED BY THE REPlBLlCA PARTY OF TEXAS

MINUTES OF THE REPUBLICAN PARTY PRECINCT CONVENTION

Oualified voters of election precinct number ~~ senate district number ---------__ number ___ of~_ county Texas met at shy bull ifocation) on (date) to hold a precinct convention

congressional district

1 Call to Order Tr1e convention was called to order by temporalV chairman Z-- at plil

2 Preparation of List of Participants The temporary churnwn prepared a list of al qualified members present The list was shown to those presetl and IS

attClched 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 Offimiddotcers The temporary chairman announced that nominations for permanent chairman of this precinct convention would be accepted The foilowll1g persons were nominated as candidates _77Ay~~12 ~_- ~~Zlt ---- rA_~~L~ __~_

The convention elected ~~ pound~ 1 ~-F ~L_ as permanent chairman of the precllct convention u

The convention elected- _)-r i ~j~ as secretary of the precllct 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 [gt (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 explalling 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 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 permanent chairman then announced that heshe 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 (174027c) The chairman announced the time and place for the county or senatorial district convention

8 Adjournment In accordance Ifth a motion properly moved and seconded and adoPt~Jfa majority vote the precinct convention was adjo)Jfned at rt Db pm -1

I l Pc U~

erm nent hairman~ ----- Perman nt SeCretary shy

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

etttIeaTX Cause No

VANESSA L CAHILL sect SUPREME COURT OF TEXAS

VS sect sect 201 W 14TH STREET lUll 104 sect

NUECES C01J~TY sect AUSTll~ TEXAS REPUBLICAN PARTY sect

sect REPUBLICAN PARTY OF TEXAS sect

BUSINESS RECORDS AFFIDAVIT

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

SUBSCRIBED AND SWORN TO before me on this May 6 2008 to which I place my

signature and official seal

~~Jk~=--------My commission expires tmiddotO ~ 0008

Notary Public for the State of Texas

April 26 2008

Wm Paul Hunt 137 Tropical Lane Corpus Christi TX 78408

Via US Mail CERTIFIED RETURN RECEIPT 70062760000405214509

Mr Michael Bertuzzi County Chairman Nueces County Republican Party 4458 South Staples Corpus Christi TX 78411

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) ExhibitA 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 12008 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 gl ma n

[i 11~ ~j g ~ m ~ ~2 gja 0 ~ ~ ~ sect ~ b h~ u - j5

Sincere~IY~~ ~)~~ I UU~ ~ t~-J l~ ~ ~g ~2middot ~ 5 4J i P~ 1 ~ ~- ~ n S $3~~ 2amp~ 1 I ro 0 CD 00 m t~

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Corpus 4458 South Staples Christi Texas 78411

(361 ) 994-9317 (361) 994-9343 FAX E-Mail ncrpcctxgrandecomnet

Mike Bertuzzi-ehairman Rebecca Bradford-Vice Chairman Aneie Flores- Secretary Bill Payne-Treasurer ~bull

April 29 2008

- middotf)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

County Chairman Nueces County Republican Party

Michael A Bertuzzi

~err IeTo Whom It May Concern

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 committees 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 No1 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 132008 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 years 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 172008 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 161004 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 No27 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

bull anessa Cahill

Delegate Pct 65

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(onferenCt (infoCjopconferencecorn) lebL)Ieuro we~I ((lttwet(iviI 10 ((Il DeltlIlll V(IIO (dhiri rpII ~Ie 0 I ~

I)(olilna Gelaek (workfutureaolcom) Dr Robin rT1stong (roli1rl1i1r(cilwtmailcom) Davie (iLl (dave 1181 S2aolrolll) Doris White ((Jorsjwniteyahoo laquol ielli a ntill1 (juclgienr lej Utltrildlw() cnr i

I~Cley HoJtclli50n Campaign (infOlexansforkaycol1l Krystal ~lfVIr) mfO[)1l1Qonvbrnqcom) I(lll i~vlr)iJn (texilsvolunteersglllclllcom) Becky I(an pe (beckyki)nlpelaquodasslatelxu~) ]riH1

middotIMI inez (imartineznetnetwebcom) William IJ Dodge JII (wdiilrlc1cirjdqciilrr1sn(nn) Nick JIIIClCZ (lditorcalercom)

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I I ~-()ITy 011(5 that Margaret Fratila has involved you in her bromide djCllnst our County Chairman Miilt) Ekrtu middot1 I ii~ ~av that she is not a reliable source of information I am atlachinq two cJocuments fOm It) dauqhler 1)lt Ij ijnltts t11lt11 something else is involved It appears tl1t some of tile F~Cin FJaul foiks arE tryin~J to Iltlke Olr tI( iii r( callil1g our county leadership Marxist Fascist and warrnonqers This is a pathetic (JIGtrcion f(()rn (jeH ~ j~iilr fltilelin rEHdected and adding to our numb(rs In other office~

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MINUTES OF THE REPUBLICAN PARTY PRECINCT CONVENTION

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-midu1ClI mlckH e ~bo) (location) on 3 Lf I 2ClOB (date) to hold a precinct convention -

1 Call to Order The convention was called to order by temporary chairman (a(j 6 Amiddot kh )l+Qre () at 757pm

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 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 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 permanent chairman then announced that heshe 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 (174027cl The chairman announced 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

adjourned at 8 pm f bull

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~a ~( ~LL -lmiddot~Permanent Chairman Permanent 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

Precinct 1Q Page I of 3 Senate District 2Q EXHIBIT A

List of qualified voters who ATTENDED precinct convention

VOTERCERT PRINT NAME PRINT MAILING ADDRESS CONTACTINFO~TION

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PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

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Precinct 10 middotPage L of ~ EXHIBITB

Senate District 2D List of DELEGATES elected to County Senatorial District COllvention

VOTERCERT PRINT MAILING ADDRESS

E-Mail

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PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

March 4th 2008

r acknowledge that I am a registered voter living in Nucces County Precinct 7 J _ and that I have voted in the March 4th

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 500PM Fnday Marcb7th 2008) J c~I

PRINTED NAMEJ~1a(a Itmiddot I-lv i-M (e (L C-J~~Jj )) V( ~ L )

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(JtVtA N 1

exalr HCause No

VANESSA L CAHILL sect SUPREME COURT OF TEXAS sect

VS sect 201 W 14TH STREET RM 104 sect

NUECES COUNTY sect AUSTIN TEXAS REPUBLICAN PARTY sect

sect REPUBLICAN PARTY OF TEXAS sect

BUSINESS RECORDS AFFIDAVIT

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

affidavit and personally acquainted with the facts stated herein

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 42008 The

records attached hereto are an exact duplicate of the original

Further affiant sayeth not

J

()i~middot6g~ 7 BenJa n BernIer

SUBSCRIBED AND SWORN TO before me on this May 6 2008 to which I place my

signature and official seal C_ -

~~~t~~I~~~~ NORMA J ALANIZ ~~o~~ ~Notary PIdc Stole 01 relICsiJ~)j My Commission fJlllJes ~~~ bullbull O January 15 2009-~~1 ~~~llJt J- HC rtll 2

Printed Narne

My commission expires 04-70 I r2l)OCjI

Notary Public for the State of Texas

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EXHIBIT C Senate District -2 2

List of ALTERNATES elected to County Senatorial Ditrict COllcntiol1

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PROVIDED BY THE REPlBLlCA PARTY OF TEXAS

MINUTES OF THE REPUBLICAN PARTY PRECINCT CONVENTION

Oualified voters of election precinct number ~~ senate district number ---------__ number ___ of~_ county Texas met at shy bull ifocation) on (date) to hold a precinct convention

congressional district

1 Call to Order Tr1e convention was called to order by temporalV chairman Z-- at plil

2 Preparation of List of Participants The temporary churnwn prepared a list of al qualified members present The list was shown to those presetl and IS

attClched 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 Offimiddotcers The temporary chairman announced that nominations for permanent chairman of this precinct convention would be accepted The foilowll1g persons were nominated as candidates _77Ay~~12 ~_- ~~Zlt ---- rA_~~L~ __~_

The convention elected ~~ pound~ 1 ~-F ~L_ as permanent chairman of the precllct convention u

The convention elected- _)-r i ~j~ as secretary of the precllct 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 [gt (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 explalling 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 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 permanent chairman then announced that heshe 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 (174027c) The chairman announced the time and place for the county or senatorial district convention

8 Adjournment In accordance Ifth a motion properly moved and seconded and adoPt~Jfa majority vote the precinct convention was adjo)Jfned at rt Db pm -1

I l Pc U~

erm nent hairman~ ----- Perman nt SeCretary shy

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

etttIeaTX Cause No

VANESSA L CAHILL sect SUPREME COURT OF TEXAS

VS sect sect 201 W 14TH STREET lUll 104 sect

NUECES C01J~TY sect AUSTll~ TEXAS REPUBLICAN PARTY sect

sect REPUBLICAN PARTY OF TEXAS sect

BUSINESS RECORDS AFFIDAVIT

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

SUBSCRIBED AND SWORN TO before me on this May 6 2008 to which I place my

signature and official seal

~~Jk~=--------My commission expires tmiddotO ~ 0008

Notary Public for the State of Texas

April 26 2008

Wm Paul Hunt 137 Tropical Lane Corpus Christi TX 78408

Via US Mail CERTIFIED RETURN RECEIPT 70062760000405214509

Mr Michael Bertuzzi County Chairman Nueces County Republican Party 4458 South Staples Corpus Christi TX 78411

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) ExhibitA 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 12008 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 gl ma n

[i 11~ ~j g ~ m ~ ~2 gja 0 ~ ~ ~ sect ~ b h~ u - j5

Sincere~IY~~ ~)~~ I UU~ ~ t~-J l~ ~ ~g ~2middot ~ 5 4J i P~ 1 ~ ~- ~ n S $3~~ 2amp~ 1 I ro 0 CD 00 m t~

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eattetr if NUECES COUNTY REPUBLICAN PARTY

Corpus 4458 South Staples Christi Texas 78411

(361 ) 994-9317 (361) 994-9343 FAX E-Mail ncrpcctxgrandecomnet

Mike Bertuzzi-ehairman Rebecca Bradford-Vice Chairman Aneie Flores- Secretary Bill Payne-Treasurer ~bull

April 29 2008

- middotf)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

County Chairman Nueces County Republican Party

Michael A Bertuzzi

~err IeTo Whom It May Concern

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 committees 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 No1 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 132008 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 years 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 172008 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 161004 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 No27 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

bull anessa Cahill

Delegate Pct 65

1111lWS LIve Hotmail C I (i

JqU~rr ( iii(CIlling Margaret Fratilas email CMike Bergsma (bergsmaconsultingdavlinnetl

[lUI 1308258 pre frlC Von Wade (encllonwadeholmailcom) Bol) Jlt)n~s (IJol)Jonlt14101(F~YS0jYiJhOO ((10) VCtn~~)

dllill (cahiilvanessaC0hotmallcom) Tx Fed of Rorjol1lan (ctgolclltmUl(iltIocorn) middotNallJCli1i Rq)JIJ n i c (oll1mitlee (womenlaquo)gop5enatorscom) Cliff la5Icl (cliffilISy lt~)(11 1() PRC CTS [~iiii

1lIIA (ilfrillila(jjforceS5invcom) Setty an(J AI CerJera (hcercJll Iwslor(pnITfcorn) rilld I (i gt~

)iCCW (ldodgecalallenk12lxusj bobbie anderson (ilnderslaw(tiln corn) Ana Cooper ((jna((lu(LIio Jlld (uJelunClcaolcom)Cilll1ie Adams (cathieadalllslexnceaJ eej et1MJ 11 linnks RepJIJUni llylIIiil

(onferenCt (infoCjopconferencecorn) lebL)Ieuro we~I ((lttwet(iviI 10 ((Il DeltlIlll V(IIO (dhiri rpII ~Ie 0 I ~

I)(olilna Gelaek (workfutureaolcom) Dr Robin rT1stong (roli1rl1i1r(cilwtmailcom) Davie (iLl (dave 1181 S2aolrolll) Doris White ((Jorsjwniteyahoo laquol ielli a ntill1 (juclgienr lej Utltrildlw() cnr i

I~Cley HoJtclli50n Campaign (infOlexansforkaycol1l Krystal ~lfVIr) mfO[)1l1Qonvbrnqcom) I(lll i~vlr)iJn (texilsvolunteersglllclllcom) Becky I(an pe (beckyki)nlpelaquodasslatelxu~) ]riH1

middotIMI inez (imartineznetnetwebcom) William IJ Dodge JII (wdiilrlc1cirjdqciilrr1sn(nn) Nick JIIIClCZ (lditorcalercom)

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I I ~-()ITy 011(5 that Margaret Fratila has involved you in her bromide djCllnst our County Chairman Miilt) Ekrtu middot1 I ii~ ~av that she is not a reliable source of information I am atlachinq two cJocuments fOm It) dauqhler 1)lt Ij ijnltts t11lt11 something else is involved It appears tl1t some of tile F~Cin FJaul foiks arE tryin~J to Iltlke Olr tI( iii r( callil1g our county leadership Marxist Fascist and warrnonqers This is a pathetic (JIGtrcion f(()rn (jeH ~ j~iilr fltilelin rEHdected and adding to our numb(rs In other office~

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Precinct 1Q Page I of 3 Senate District 2Q EXHIBIT A

List of qualified voters who ATTENDED precinct convention

VOTERCERT PRINT NAME PRINT MAILING ADDRESS CONTACTINFO~TION

1J4qampz~qD First n1nr i( Ml n Address J)()I alUT~~~l 0bull Phone (3(nl crPD - =-J-1(0(

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First 111 Address Phone

Last City ZIn E-Mail

First MI Address Phone

Last Cltv Zip E-Mail

iFirst Ml Address Phone I Last Cltv ZIJ) E-MailI I I z I First MI

Last

First MI

Last

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Address Phone

City Zip E-Mail

Address Phone

City Zip EmiddotMall

I -_ City Zip EmiddotMallI I J First MI Address Phone

Last City Zip E-Mail

I I MI I Address I00 I Last City Zip -=E=-MaIIc-shy _

PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

I

Precinct 10 middotPage L of ~ EXHIBITB

Senate District 2D List of DELEGATES elected to County Senatorial District COllvention

VOTERCERT PRINT MAILING ADDRESS

E-Mail

PhoneMI

PRINT NAME

Last

First114Qt173C13

First MI Address Phone

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PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

March 4th 2008

r acknowledge that I am a registered voter living in Nucces County Precinct 7 J _ and that I have voted in the March 4th

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 500PM Fnday Marcb7th 2008) J c~I

PRINTED NAMEJ~1a(a Itmiddot I-lv i-M (e (L C-J~~Jj )) V( ~ L )

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r bull I - ~-J -~ bull (p ~ Vi)rELEPHoNE~~7~I~B~ 77~~~~ ~ ) w~ ~ SIGNATURE4i~ lt-ltf (Jtd_JL)t- YI(t AP Please sign and giv~ this receipt bac[~o the Eleoli011 J~dge bull i I t f IfYOlI are the ElectIOn Judge please SIgn and return thIs receipt WIth your election supplies JiJ

(JtVtA N 1

exalr HCause No

VANESSA L CAHILL sect SUPREME COURT OF TEXAS sect

VS sect 201 W 14TH STREET RM 104 sect

NUECES COUNTY sect AUSTIN TEXAS REPUBLICAN PARTY sect

sect REPUBLICAN PARTY OF TEXAS sect

BUSINESS RECORDS AFFIDAVIT

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

affidavit and personally acquainted with the facts stated herein

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 42008 The

records attached hereto are an exact duplicate of the original

Further affiant sayeth not

J

()i~middot6g~ 7 BenJa n BernIer

SUBSCRIBED AND SWORN TO before me on this May 6 2008 to which I place my

signature and official seal C_ -

~~~t~~I~~~~ NORMA J ALANIZ ~~o~~ ~Notary PIdc Stole 01 relICsiJ~)j My Commission fJlllJes ~~~ bullbull O January 15 2009-~~1 ~~~llJt J- HC rtll 2

Printed Narne

My commission expires 04-70 I r2l)OCjI

Notary Public for the State of Texas

i

I

Pnxil1ct Z i Pd~~C __~ (1[ _

EXHIBIT C Senate District -2 2

List of ALTERNATES elected to County Senatorial Ditrict COllcntiol1

VOTER CERT PRIlT NAME PRINT MAILING ADDRESS COITACT INFORMA1ION -- -~ l ~~ shy_j bull

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PROVIDED BY THE REPlBLlCA PARTY OF TEXAS

MINUTES OF THE REPUBLICAN PARTY PRECINCT CONVENTION

Oualified voters of election precinct number ~~ senate district number ---------__ number ___ of~_ county Texas met at shy bull ifocation) on (date) to hold a precinct convention

congressional district

1 Call to Order Tr1e convention was called to order by temporalV chairman Z-- at plil

2 Preparation of List of Participants The temporary churnwn prepared a list of al qualified members present The list was shown to those presetl and IS

attClched 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 Offimiddotcers The temporary chairman announced that nominations for permanent chairman of this precinct convention would be accepted The foilowll1g persons were nominated as candidates _77Ay~~12 ~_- ~~Zlt ---- rA_~~L~ __~_

The convention elected ~~ pound~ 1 ~-F ~L_ as permanent chairman of the precllct convention u

The convention elected- _)-r i ~j~ as secretary of the precllct 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 [gt (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 explalling 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 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 permanent chairman then announced that heshe 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 (174027c) The chairman announced the time and place for the county or senatorial district convention

8 Adjournment In accordance Ifth a motion properly moved and seconded and adoPt~Jfa majority vote the precinct convention was adjo)Jfned at rt Db pm -1

I l Pc U~

erm nent hairman~ ----- Perman nt SeCretary shy

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

etttIeaTX Cause No

VANESSA L CAHILL sect SUPREME COURT OF TEXAS

VS sect sect 201 W 14TH STREET lUll 104 sect

NUECES C01J~TY sect AUSTll~ TEXAS REPUBLICAN PARTY sect

sect REPUBLICAN PARTY OF TEXAS sect

BUSINESS RECORDS AFFIDAVIT

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

SUBSCRIBED AND SWORN TO before me on this May 6 2008 to which I place my

signature and official seal

~~Jk~=--------My commission expires tmiddotO ~ 0008

Notary Public for the State of Texas

April 26 2008

Wm Paul Hunt 137 Tropical Lane Corpus Christi TX 78408

Via US Mail CERTIFIED RETURN RECEIPT 70062760000405214509

Mr Michael Bertuzzi County Chairman Nueces County Republican Party 4458 South Staples Corpus Christi TX 78411

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) ExhibitA 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 12008 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 gl ma n

[i 11~ ~j g ~ m ~ ~2 gja 0 ~ ~ ~ sect ~ b h~ u - j5

Sincere~IY~~ ~)~~ I UU~ ~ t~-J l~ ~ ~g ~2middot ~ 5 4J i P~ 1 ~ ~- ~ n S $3~~ 2amp~ 1 I ro 0 CD 00 m t~

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Corpus 4458 South Staples Christi Texas 78411

(361 ) 994-9317 (361) 994-9343 FAX E-Mail ncrpcctxgrandecomnet

Mike Bertuzzi-ehairman Rebecca Bradford-Vice Chairman Aneie Flores- Secretary Bill Payne-Treasurer ~bull

April 29 2008

- middotf)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

County Chairman Nueces County Republican Party

Michael A Bertuzzi

~err IeTo Whom It May Concern

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 committees 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 No1 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 132008 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 years 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 172008 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 161004 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 No27 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

bull anessa Cahill

Delegate Pct 65

1111lWS LIve Hotmail C I (i

JqU~rr ( iii(CIlling Margaret Fratilas email CMike Bergsma (bergsmaconsultingdavlinnetl

[lUI 1308258 pre frlC Von Wade (encllonwadeholmailcom) Bol) Jlt)n~s (IJol)Jonlt14101(F~YS0jYiJhOO ((10) VCtn~~)

dllill (cahiilvanessaC0hotmallcom) Tx Fed of Rorjol1lan (ctgolclltmUl(iltIocorn) middotNallJCli1i Rq)JIJ n i c (oll1mitlee (womenlaquo)gop5enatorscom) Cliff la5Icl (cliffilISy lt~)(11 1() PRC CTS [~iiii

1lIIA (ilfrillila(jjforceS5invcom) Setty an(J AI CerJera (hcercJll Iwslor(pnITfcorn) rilld I (i gt~

)iCCW (ldodgecalallenk12lxusj bobbie anderson (ilnderslaw(tiln corn) Ana Cooper ((jna((lu(LIio Jlld (uJelunClcaolcom)Cilll1ie Adams (cathieadalllslexnceaJ eej et1MJ 11 linnks RepJIJUni llylIIiil

(onferenCt (infoCjopconferencecorn) lebL)Ieuro we~I ((lttwet(iviI 10 ((Il DeltlIlll V(IIO (dhiri rpII ~Ie 0 I ~

I)(olilna Gelaek (workfutureaolcom) Dr Robin rT1stong (roli1rl1i1r(cilwtmailcom) Davie (iLl (dave 1181 S2aolrolll) Doris White ((Jorsjwniteyahoo laquol ielli a ntill1 (juclgienr lej Utltrildlw() cnr i

I~Cley HoJtclli50n Campaign (infOlexansforkaycol1l Krystal ~lfVIr) mfO[)1l1Qonvbrnqcom) I(lll i~vlr)iJn (texilsvolunteersglllclllcom) Becky I(an pe (beckyki)nlpelaquodasslatelxu~) ]riH1

middotIMI inez (imartineznetnetwebcom) William IJ Dodge JII (wdiilrlc1cirjdqciilrr1sn(nn) Nick JIIIClCZ (lditorcalercom)

li~ i 1 ( ( t (1 1 ) 1 KI ) ( ltIi k f ~l rmiddot~ Et-H ~

I I ~-()ITy 011(5 that Margaret Fratila has involved you in her bromide djCllnst our County Chairman Miilt) Ekrtu middot1 I ii~ ~av that she is not a reliable source of information I am atlachinq two cJocuments fOm It) dauqhler 1)lt Ij ijnltts t11lt11 something else is involved It appears tl1t some of tile F~Cin FJaul foiks arE tryin~J to Iltlke Olr tI( iii r( callil1g our county leadership Marxist Fascist and warrnonqers This is a pathetic (JIGtrcion f(()rn (jeH ~ j~iilr fltilelin rEHdected and adding to our numb(rs In other office~

Vi I Cd1 cali lYlE about this is you would like at 537696j~

i laquo a(d~)

111 I HrrCjsma

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Precinct 10 middotPage L of ~ EXHIBITB

Senate District 2D List of DELEGATES elected to County Senatorial District COllvention

VOTERCERT PRINT MAILING ADDRESS

E-Mail

PhoneMI

PRINT NAME

Last

First114Qt173C13

First MI Address Phone

Last I City Zln I E-Mail

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Last

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Ml I~= City Zip

MI IAddress

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PROVIDED BY THE REPUBLICAN PARTY OF TEXAS

March 4th 2008

r acknowledge that I am a registered voter living in Nucces County Precinct 7 J _ and that I have voted in the March 4th

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 500PM Fnday Marcb7th 2008) J c~I

PRINTED NAMEJ~1a(a Itmiddot I-lv i-M (e (L C-J~~Jj )) V( ~ L )

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ri) ~j L) V 1f1It - J

r bull I - ~-J -~ bull (p ~ Vi)rELEPHoNE~~7~I~B~ 77~~~~ ~ ) w~ ~ SIGNATURE4i~ lt-ltf (Jtd_JL)t- YI(t AP Please sign and giv~ this receipt bac[~o the Eleoli011 J~dge bull i I t f IfYOlI are the ElectIOn Judge please SIgn and return thIs receipt WIth your election supplies JiJ

(JtVtA N 1

exalr HCause No

VANESSA L CAHILL sect SUPREME COURT OF TEXAS sect

VS sect 201 W 14TH STREET RM 104 sect

NUECES COUNTY sect AUSTIN TEXAS REPUBLICAN PARTY sect

sect REPUBLICAN PARTY OF TEXAS sect

BUSINESS RECORDS AFFIDAVIT

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

affidavit and personally acquainted with the facts stated herein

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 42008 The

records attached hereto are an exact duplicate of the original

Further affiant sayeth not

J

()i~middot6g~ 7 BenJa n BernIer

SUBSCRIBED AND SWORN TO before me on this May 6 2008 to which I place my

signature and official seal C_ -

~~~t~~I~~~~ NORMA J ALANIZ ~~o~~ ~Notary PIdc Stole 01 relICsiJ~)j My Commission fJlllJes ~~~ bullbull O January 15 2009-~~1 ~~~llJt J- HC rtll 2

Printed Narne

My commission expires 04-70 I r2l)OCjI

Notary Public for the State of Texas

i

I

Pnxil1ct Z i Pd~~C __~ (1[ _

EXHIBIT C Senate District -2 2

List of ALTERNATES elected to County Senatorial Ditrict COllcntiol1

VOTER CERT PRIlT NAME PRINT MAILING ADDRESS COITACT INFORMA1ION -- -~ l ~~ shy_j bull

J- ~ I 1 I I ddr ~ lt f r ) ( ( First - -t- I Ilwnl~_~

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IJpound~__-+- Cli) cl pr_f ~ 0 t i )( _

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0386 9919 ~tia 1 H I dltl tj vgt elnnAu(0lt ~ ( I~) g~I- amp ---1 I I I Last ~egg - RlVenx_ I(Ill CJniiLAS C hnst fX Zip 7lt2 =t Ii Eilail~1 H V2jo (0 0-1 CC(ccl2 Lom bull net I

VVIf)J~] 970J-5-- ~ -I3~ Idgt ~J L - Ode 16) ~~If fVe( 1k l 1 7-- ~ Pllonl~ 3-fs~c jgt(~--- l ~============~L=a~=l=~ C-k 4- I c- __ ~___ (it~ C(y ~S LllJS ~_k_v-J- I 1-llIild l (l lt Camp 6-~lL0- ou [0 ~]

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PROVIDED BY THE REPlBLlCA PARTY OF TEXAS

MINUTES OF THE REPUBLICAN PARTY PRECINCT CONVENTION

Oualified voters of election precinct number ~~ senate district number ---------__ number ___ of~_ county Texas met at shy bull ifocation) on (date) to hold a precinct convention

congressional district

1 Call to Order Tr1e convention was called to order by temporalV chairman Z-- at plil

2 Preparation of List of Participants The temporary churnwn prepared a list of al qualified members present The list was shown to those presetl and IS

attClched 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 Offimiddotcers The temporary chairman announced that nominations for permanent chairman of this precinct convention would be accepted The foilowll1g persons were nominated as candidates _77Ay~~12 ~_- ~~Zlt ---- rA_~~L~ __~_

The convention elected ~~ pound~ 1 ~-F ~L_ as permanent chairman of the precllct convention u

The convention elected- _)-r i ~j~ as secretary of the precllct 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 [gt (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 explalling 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 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 permanent chairman then announced that heshe 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 (174027c) The chairman announced the time and place for the county or senatorial district convention

8 Adjournment In accordance Ifth a motion properly moved and seconded and adoPt~Jfa majority vote the precinct convention was adjo)Jfned at rt Db pm -1

I l Pc U~

erm nent hairman~ ----- Perman nt SeCretary shy

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

etttIeaTX Cause No

VANESSA L CAHILL sect SUPREME COURT OF TEXAS

VS sect sect 201 W 14TH STREET lUll 104 sect

NUECES C01J~TY sect AUSTll~ TEXAS REPUBLICAN PARTY sect

sect REPUBLICAN PARTY OF TEXAS sect

BUSINESS RECORDS AFFIDAVIT

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

SUBSCRIBED AND SWORN TO before me on this May 6 2008 to which I place my

signature and official seal

~~Jk~=--------My commission expires tmiddotO ~ 0008

Notary Public for the State of Texas

April 26 2008

Wm Paul Hunt 137 Tropical Lane Corpus Christi TX 78408

Via US Mail CERTIFIED RETURN RECEIPT 70062760000405214509

Mr Michael Bertuzzi County Chairman Nueces County Republican Party 4458 South Staples Corpus Christi TX 78411

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) ExhibitA 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 12008 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 gl ma n

[i 11~ ~j g ~ m ~ ~2 gja 0 ~ ~ ~ sect ~ b h~ u - j5

Sincere~IY~~ ~)~~ I UU~ ~ t~-J l~ ~ ~g ~2middot ~ 5 4J i P~ 1 ~ ~- ~ n S $3~~ 2amp~ 1 I ro 0 CD 00 m t~

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eattetr if NUECES COUNTY REPUBLICAN PARTY

Corpus 4458 South Staples Christi Texas 78411

(361 ) 994-9317 (361) 994-9343 FAX E-Mail ncrpcctxgrandecomnet

Mike Bertuzzi-ehairman Rebecca Bradford-Vice Chairman Aneie Flores- Secretary Bill Payne-Treasurer ~bull

April 29 2008

- middotf)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

County Chairman Nueces County Republican Party

Michael A Bertuzzi

~err IeTo Whom It May Concern

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 committees 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 No1 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 132008 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 years 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 172008 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 161004 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 No27 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

bull anessa Cahill

Delegate Pct 65

1111lWS LIve Hotmail C I (i

JqU~rr ( iii(CIlling Margaret Fratilas email CMike Bergsma (bergsmaconsultingdavlinnetl

[lUI 1308258 pre frlC Von Wade (encllonwadeholmailcom) Bol) Jlt)n~s (IJol)Jonlt14101(F~YS0jYiJhOO ((10) VCtn~~)

dllill (cahiilvanessaC0hotmallcom) Tx Fed of Rorjol1lan (ctgolclltmUl(iltIocorn) middotNallJCli1i Rq)JIJ n i c (oll1mitlee (womenlaquo)gop5enatorscom) Cliff la5Icl (cliffilISy lt~)(11 1() PRC CTS [~iiii

1lIIA (ilfrillila(jjforceS5invcom) Setty an(J AI CerJera (hcercJll Iwslor(pnITfcorn) rilld I (i gt~

)iCCW (ldodgecalallenk12lxusj bobbie anderson (ilnderslaw(tiln corn) Ana Cooper ((jna((lu(LIio Jlld (uJelunClcaolcom)Cilll1ie Adams (cathieadalllslexnceaJ eej et1MJ 11 linnks RepJIJUni llylIIiil

(onferenCt (infoCjopconferencecorn) lebL)Ieuro we~I ((lttwet(iviI 10 ((Il DeltlIlll V(IIO (dhiri rpII ~Ie 0 I ~

I)(olilna Gelaek (workfutureaolcom) Dr Robin rT1stong (roli1rl1i1r(cilwtmailcom) Davie (iLl (dave 1181 S2aolrolll) Doris White ((Jorsjwniteyahoo laquol ielli a ntill1 (juclgienr lej Utltrildlw() cnr i

I~Cley HoJtclli50n Campaign (infOlexansforkaycol1l Krystal ~lfVIr) mfO[)1l1Qonvbrnqcom) I(lll i~vlr)iJn (texilsvolunteersglllclllcom) Becky I(an pe (beckyki)nlpelaquodasslatelxu~) ]riH1

middotIMI inez (imartineznetnetwebcom) William IJ Dodge JII (wdiilrlc1cirjdqciilrr1sn(nn) Nick JIIIClCZ (lditorcalercom)

li~ i 1 ( ( t (1 1 ) 1 KI ) ( ltIi k f ~l rmiddot~ Et-H ~

I I ~-()ITy 011(5 that Margaret Fratila has involved you in her bromide djCllnst our County Chairman Miilt) Ekrtu middot1 I ii~ ~av that she is not a reliable source of information I am atlachinq two cJocuments fOm It) dauqhler 1)lt Ij ijnltts t11lt11 something else is involved It appears tl1t some of tile F~Cin FJaul foiks arE tryin~J to Iltlke Olr tI( iii r( callil1g our county leadership Marxist Fascist and warrnonqers This is a pathetic (JIGtrcion f(()rn (jeH ~ j~iilr fltilelin rEHdected and adding to our numb(rs In other office~

Vi I Cd1 cali lYlE about this is you would like at 537696j~

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11) ell r 07vblu 107mailJivecommaiIReadMessageLightaspxAction==MarkAsNorJunkampFoJder[OcO 3 OOk

March 4th 2008

r acknowledge that I am a registered voter living in Nucces County Precinct 7 J _ and that I have voted in the March 4th

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 500PM Fnday Marcb7th 2008) J c~I

PRINTED NAMEJ~1a(a Itmiddot I-lv i-M (e (L C-J~~Jj )) V( ~ L )

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r bull I - ~-J -~ bull (p ~ Vi)rELEPHoNE~~7~I~B~ 77~~~~ ~ ) w~ ~ SIGNATURE4i~ lt-ltf (Jtd_JL)t- YI(t AP Please sign and giv~ this receipt bac[~o the Eleoli011 J~dge bull i I t f IfYOlI are the ElectIOn Judge please SIgn and return thIs receipt WIth your election supplies JiJ

(JtVtA N 1

exalr HCause No

VANESSA L CAHILL sect SUPREME COURT OF TEXAS sect

VS sect 201 W 14TH STREET RM 104 sect

NUECES COUNTY sect AUSTIN TEXAS REPUBLICAN PARTY sect

sect REPUBLICAN PARTY OF TEXAS sect

BUSINESS RECORDS AFFIDAVIT

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

affidavit and personally acquainted with the facts stated herein

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 42008 The

records attached hereto are an exact duplicate of the original

Further affiant sayeth not

J

()i~middot6g~ 7 BenJa n BernIer

SUBSCRIBED AND SWORN TO before me on this May 6 2008 to which I place my

signature and official seal C_ -

~~~t~~I~~~~ NORMA J ALANIZ ~~o~~ ~Notary PIdc Stole 01 relICsiJ~)j My Commission fJlllJes ~~~ bullbull O January 15 2009-~~1 ~~~llJt J- HC rtll 2

Printed Narne

My commission expires 04-70 I r2l)OCjI

Notary Public for the State of Texas

i

I

Pnxil1ct Z i Pd~~C __~ (1[ _

EXHIBIT C Senate District -2 2

List of ALTERNATES elected to County Senatorial Ditrict COllcntiol1

VOTER CERT PRIlT NAME PRINT MAILING ADDRESS COITACT INFORMA1ION -- -~ l ~~ shy_j bull

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VVIf)J~] 970J-5-- ~ -I3~ Idgt ~J L - Ode 16) ~~If fVe( 1k l 1 7-- ~ Pllonl~ 3-fs~c jgt(~--- l ~============~L=a~=l=~ C-k 4- I c- __ ~___ (it~ C(y ~S LllJS ~_k_v-J- I 1-llIild l (l lt Camp 6-~lL0- ou [0 ~]

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PROVIDED BY THE REPlBLlCA PARTY OF TEXAS

MINUTES OF THE REPUBLICAN PARTY PRECINCT CONVENTION

Oualified voters of election precinct number ~~ senate district number ---------__ number ___ of~_ county Texas met at shy bull ifocation) on (date) to hold a precinct convention

congressional district

1 Call to Order Tr1e convention was called to order by temporalV chairman Z-- at plil

2 Preparation of List of Participants The temporary churnwn prepared a list of al qualified members present The list was shown to those presetl and IS

attClched 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 Offimiddotcers The temporary chairman announced that nominations for permanent chairman of this precinct convention would be accepted The foilowll1g persons were nominated as candidates _77Ay~~12 ~_- ~~Zlt ---- rA_~~L~ __~_

The convention elected ~~ pound~ 1 ~-F ~L_ as permanent chairman of the precllct convention u

The convention elected- _)-r i ~j~ as secretary of the precllct 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 [gt (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 explalling 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 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 permanent chairman then announced that heshe 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 (174027c) The chairman announced the time and place for the county or senatorial district convention

8 Adjournment In accordance Ifth a motion properly moved and seconded and adoPt~Jfa majority vote the precinct convention was adjo)Jfned at rt Db pm -1

I l Pc U~

erm nent hairman~ ----- Perman nt SeCretary shy

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

etttIeaTX Cause No

VANESSA L CAHILL sect SUPREME COURT OF TEXAS

VS sect sect 201 W 14TH STREET lUll 104 sect

NUECES C01J~TY sect AUSTll~ TEXAS REPUBLICAN PARTY sect

sect REPUBLICAN PARTY OF TEXAS sect

BUSINESS RECORDS AFFIDAVIT

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

SUBSCRIBED AND SWORN TO before me on this May 6 2008 to which I place my

signature and official seal

~~Jk~=--------My commission expires tmiddotO ~ 0008

Notary Public for the State of Texas

April 26 2008

Wm Paul Hunt 137 Tropical Lane Corpus Christi TX 78408

Via US Mail CERTIFIED RETURN RECEIPT 70062760000405214509

Mr Michael Bertuzzi County Chairman Nueces County Republican Party 4458 South Staples Corpus Christi TX 78411

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) ExhibitA 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 12008 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 gl ma n

[i 11~ ~j g ~ m ~ ~2 gja 0 ~ ~ ~ sect ~ b h~ u - j5

Sincere~IY~~ ~)~~ I UU~ ~ t~-J l~ ~ ~g ~2middot ~ 5 4J i P~ 1 ~ ~- ~ n S $3~~ 2amp~ 1 I ro 0 CD 00 m t~

~ - - 1 (~ _o _0 CD Q (f)

f~ i I fljWmP Hunt ~V1 L~Q I I ~) I

f 1~ i i lt ~

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iflo l~ i c------------- shy

iiJ~ j ~ rP i~ 8 ~ ~ - 0 - i~ _ 0

Vi 8 rg _ ~ CD ~ 3 ~ I I f) ~

~ ~

~I

eattetr if NUECES COUNTY REPUBLICAN PARTY

Corpus 4458 South Staples Christi Texas 78411

(361 ) 994-9317 (361) 994-9343 FAX E-Mail ncrpcctxgrandecomnet

Mike Bertuzzi-ehairman Rebecca Bradford-Vice Chairman Aneie Flores- Secretary Bill Payne-Treasurer ~bull

April 29 2008

- middotf)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

County Chairman Nueces County Republican Party

Michael A Bertuzzi

~err IeTo Whom It May Concern

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 committees 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 No1 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 132008 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 years 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 172008 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 161004 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 No27 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

bull anessa Cahill

Delegate Pct 65

1111lWS LIve Hotmail C I (i

JqU~rr ( iii(CIlling Margaret Fratilas email CMike Bergsma (bergsmaconsultingdavlinnetl

[lUI 1308258 pre frlC Von Wade (encllonwadeholmailcom) Bol) Jlt)n~s (IJol)Jonlt14101(F~YS0jYiJhOO ((10) VCtn~~)

dllill (cahiilvanessaC0hotmallcom) Tx Fed of Rorjol1lan (ctgolclltmUl(iltIocorn) middotNallJCli1i Rq)JIJ n i c (oll1mitlee (womenlaquo)gop5enatorscom) Cliff la5Icl (cliffilISy lt~)(11 1() PRC CTS [~iiii

1lIIA (ilfrillila(jjforceS5invcom) Setty an(J AI CerJera (hcercJll Iwslor(pnITfcorn) rilld I (i gt~

)iCCW (ldodgecalallenk12lxusj bobbie anderson (ilnderslaw(tiln corn) Ana Cooper ((jna((lu(LIio Jlld (uJelunClcaolcom)Cilll1ie Adams (cathieadalllslexnceaJ eej et1MJ 11 linnks RepJIJUni llylIIiil

(onferenCt (infoCjopconferencecorn) lebL)Ieuro we~I ((lttwet(iviI 10 ((Il DeltlIlll V(IIO (dhiri rpII ~Ie 0 I ~

I)(olilna Gelaek (workfutureaolcom) Dr Robin rT1stong (roli1rl1i1r(cilwtmailcom) Davie (iLl (dave 1181 S2aolrolll) Doris White ((Jorsjwniteyahoo laquol ielli a ntill1 (juclgienr lej Utltrildlw() cnr i

I~Cley HoJtclli50n Campaign (infOlexansforkaycol1l Krystal ~lfVIr) mfO[)1l1Qonvbrnqcom) I(lll i~vlr)iJn (texilsvolunteersglllclllcom) Becky I(an pe (beckyki)nlpelaquodasslatelxu~) ]riH1

middotIMI inez (imartineznetnetwebcom) William IJ Dodge JII (wdiilrlc1cirjdqciilrr1sn(nn) Nick JIIIClCZ (lditorcalercom)

li~ i 1 ( ( t (1 1 ) 1 KI ) ( ltIi k f ~l rmiddot~ Et-H ~

I I ~-()ITy 011(5 that Margaret Fratila has involved you in her bromide djCllnst our County Chairman Miilt) Ekrtu middot1 I ii~ ~av that she is not a reliable source of information I am atlachinq two cJocuments fOm It) dauqhler 1)lt Ij ijnltts t11lt11 something else is involved It appears tl1t some of tile F~Cin FJaul foiks arE tryin~J to Iltlke Olr tI( iii r( callil1g our county leadership Marxist Fascist and warrnonqers This is a pathetic (JIGtrcion f(()rn (jeH ~ j~iilr fltilelin rEHdected and adding to our numb(rs In other office~

Vi I Cd1 cali lYlE about this is you would like at 537696j~

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11) ell r 07vblu 107mailJivecommaiIReadMessageLightaspxAction==MarkAsNorJunkampFoJder[OcO 3 OOk

exalr HCause No

VANESSA L CAHILL sect SUPREME COURT OF TEXAS sect

VS sect 201 W 14TH STREET RM 104 sect

NUECES COUNTY sect AUSTIN TEXAS REPUBLICAN PARTY sect

sect REPUBLICAN PARTY OF TEXAS sect

BUSINESS RECORDS AFFIDAVIT

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

affidavit and personally acquainted with the facts stated herein

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 42008 The

records attached hereto are an exact duplicate of the original

Further affiant sayeth not

J

()i~middot6g~ 7 BenJa n BernIer

SUBSCRIBED AND SWORN TO before me on this May 6 2008 to which I place my

signature and official seal C_ -

~~~t~~I~~~~ NORMA J ALANIZ ~~o~~ ~Notary PIdc Stole 01 relICsiJ~)j My Commission fJlllJes ~~~ bullbull O January 15 2009-~~1 ~~~llJt J- HC rtll 2

Printed Narne

My commission expires 04-70 I r2l)OCjI

Notary Public for the State of Texas

i

I

Pnxil1ct Z i Pd~~C __~ (1[ _

EXHIBIT C Senate District -2 2

List of ALTERNATES elected to County Senatorial Ditrict COllcntiol1

VOTER CERT PRIlT NAME PRINT MAILING ADDRESS COITACT INFORMA1ION -- -~ l ~~ shy_j bull

J- ~ I 1 I I ddr ~ lt f r ) ( ( First - -t- I Ilwnl~_~

~ ~1 I er~i- ~ 7 I r 1f- ~ i Cill ~~~) l ~ - j lt ~fI 1shyjLast t -- ~

IJpound~__-+- Cli) cl pr_f ~ 0 t i )( _

IFirst i3cnJd rYllvj 11 i-r-ddn Lf~)J- joVj dl-)v dS 1) V- _- Phoill 3f t f3 - CO 7S G 1D3 780J~ b ______~ I Bu ~ c r c(oc res L ~s-r Zip I 11) I11 b cmiddot bU I fi PD Ju el

0386 9919 ~tia 1 H I dltl tj vgt elnnAu(0lt ~ ( I~) g~I- amp ---1 I I I Last ~egg - RlVenx_ I(Ill CJniiLAS C hnst fX Zip 7lt2 =t Ii Eilail~1 H V2jo (0 0-1 CC(ccl2 Lom bull net I

VVIf)J~] 970J-5-- ~ -I3~ Idgt ~J L - Ode 16) ~~If fVe( 1k l 1 7-- ~ Pllonl~ 3-fs~c jgt(~--- l ~============~L=a~=l=~ C-k 4- I c- __ ~___ (it~ C(y ~S LllJS ~_k_v-J- I 1-llIild l (l lt Camp 6-~lL0- ou [0 ~]

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PROVIDED BY THE REPlBLlCA PARTY OF TEXAS

MINUTES OF THE REPUBLICAN PARTY PRECINCT CONVENTION

Oualified voters of election precinct number ~~ senate district number ---------__ number ___ of~_ county Texas met at shy bull ifocation) on (date) to hold a precinct convention

congressional district

1 Call to Order Tr1e convention was called to order by temporalV chairman Z-- at plil

2 Preparation of List of Participants The temporary churnwn prepared a list of al qualified members present The list was shown to those presetl and IS

attClched 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 Offimiddotcers The temporary chairman announced that nominations for permanent chairman of this precinct convention would be accepted The foilowll1g persons were nominated as candidates _77Ay~~12 ~_- ~~Zlt ---- rA_~~L~ __~_

The convention elected ~~ pound~ 1 ~-F ~L_ as permanent chairman of the precllct convention u

The convention elected- _)-r i ~j~ as secretary of the precllct 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 [gt (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 explalling 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 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 permanent chairman then announced that heshe 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 (174027c) The chairman announced the time and place for the county or senatorial district convention

8 Adjournment In accordance Ifth a motion properly moved and seconded and adoPt~Jfa majority vote the precinct convention was adjo)Jfned at rt Db pm -1

I l Pc U~

erm nent hairman~ ----- Perman nt SeCretary shy

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

etttIeaTX Cause No

VANESSA L CAHILL sect SUPREME COURT OF TEXAS

VS sect sect 201 W 14TH STREET lUll 104 sect

NUECES C01J~TY sect AUSTll~ TEXAS REPUBLICAN PARTY sect

sect REPUBLICAN PARTY OF TEXAS sect

BUSINESS RECORDS AFFIDAVIT

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

SUBSCRIBED AND SWORN TO before me on this May 6 2008 to which I place my

signature and official seal

~~Jk~=--------My commission expires tmiddotO ~ 0008

Notary Public for the State of Texas

April 26 2008

Wm Paul Hunt 137 Tropical Lane Corpus Christi TX 78408

Via US Mail CERTIFIED RETURN RECEIPT 70062760000405214509

Mr Michael Bertuzzi County Chairman Nueces County Republican Party 4458 South Staples Corpus Christi TX 78411

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) ExhibitA 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 12008 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 gl ma n

[i 11~ ~j g ~ m ~ ~2 gja 0 ~ ~ ~ sect ~ b h~ u - j5

Sincere~IY~~ ~)~~ I UU~ ~ t~-J l~ ~ ~g ~2middot ~ 5 4J i P~ 1 ~ ~- ~ n S $3~~ 2amp~ 1 I ro 0 CD 00 m t~

~ - - 1 (~ _o _0 CD Q (f)

f~ i I fljWmP Hunt ~V1 L~Q I I ~) I

f 1~ i i lt ~

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eattetr if NUECES COUNTY REPUBLICAN PARTY

Corpus 4458 South Staples Christi Texas 78411

(361 ) 994-9317 (361) 994-9343 FAX E-Mail ncrpcctxgrandecomnet

Mike Bertuzzi-ehairman Rebecca Bradford-Vice Chairman Aneie Flores- Secretary Bill Payne-Treasurer ~bull

April 29 2008

- middotf)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

County Chairman Nueces County Republican Party

Michael A Bertuzzi

~err IeTo Whom It May Concern

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 committees 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 No1 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 132008 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 years 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 172008 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 161004 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 No27 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

bull anessa Cahill

Delegate Pct 65

1111lWS LIve Hotmail C I (i

JqU~rr ( iii(CIlling Margaret Fratilas email CMike Bergsma (bergsmaconsultingdavlinnetl

[lUI 1308258 pre frlC Von Wade (encllonwadeholmailcom) Bol) Jlt)n~s (IJol)Jonlt14101(F~YS0jYiJhOO ((10) VCtn~~)

dllill (cahiilvanessaC0hotmallcom) Tx Fed of Rorjol1lan (ctgolclltmUl(iltIocorn) middotNallJCli1i Rq)JIJ n i c (oll1mitlee (womenlaquo)gop5enatorscom) Cliff la5Icl (cliffilISy lt~)(11 1() PRC CTS [~iiii

1lIIA (ilfrillila(jjforceS5invcom) Setty an(J AI CerJera (hcercJll Iwslor(pnITfcorn) rilld I (i gt~

)iCCW (ldodgecalallenk12lxusj bobbie anderson (ilnderslaw(tiln corn) Ana Cooper ((jna((lu(LIio Jlld (uJelunClcaolcom)Cilll1ie Adams (cathieadalllslexnceaJ eej et1MJ 11 linnks RepJIJUni llylIIiil

(onferenCt (infoCjopconferencecorn) lebL)Ieuro we~I ((lttwet(iviI 10 ((Il DeltlIlll V(IIO (dhiri rpII ~Ie 0 I ~

I)(olilna Gelaek (workfutureaolcom) Dr Robin rT1stong (roli1rl1i1r(cilwtmailcom) Davie (iLl (dave 1181 S2aolrolll) Doris White ((Jorsjwniteyahoo laquol ielli a ntill1 (juclgienr lej Utltrildlw() cnr i

I~Cley HoJtclli50n Campaign (infOlexansforkaycol1l Krystal ~lfVIr) mfO[)1l1Qonvbrnqcom) I(lll i~vlr)iJn (texilsvolunteersglllclllcom) Becky I(an pe (beckyki)nlpelaquodasslatelxu~) ]riH1

middotIMI inez (imartineznetnetwebcom) William IJ Dodge JII (wdiilrlc1cirjdqciilrr1sn(nn) Nick JIIIClCZ (lditorcalercom)

li~ i 1 ( ( t (1 1 ) 1 KI ) ( ltIi k f ~l rmiddot~ Et-H ~

I I ~-()ITy 011(5 that Margaret Fratila has involved you in her bromide djCllnst our County Chairman Miilt) Ekrtu middot1 I ii~ ~av that she is not a reliable source of information I am atlachinq two cJocuments fOm It) dauqhler 1)lt Ij ijnltts t11lt11 something else is involved It appears tl1t some of tile F~Cin FJaul foiks arE tryin~J to Iltlke Olr tI( iii r( callil1g our county leadership Marxist Fascist and warrnonqers This is a pathetic (JIGtrcion f(()rn (jeH ~ j~iilr fltilelin rEHdected and adding to our numb(rs In other office~

Vi I Cd1 cali lYlE about this is you would like at 537696j~

i laquo a(d~)

111 I HrrCjsma

poundtJA1L ~DM

~~MA

11) ell r 07vblu 107mailJivecommaiIReadMessageLightaspxAction==MarkAsNorJunkampFoJder[OcO 3 OOk

i

I

Pnxil1ct Z i Pd~~C __~ (1[ _

EXHIBIT C Senate District -2 2

List of ALTERNATES elected to County Senatorial Ditrict COllcntiol1

VOTER CERT PRIlT NAME PRINT MAILING ADDRESS COITACT INFORMA1ION -- -~ l ~~ shy_j bull

J- ~ I 1 I I ddr ~ lt f r ) ( ( First - -t- I Ilwnl~_~

~ ~1 I er~i- ~ 7 I r 1f- ~ i Cill ~~~) l ~ - j lt ~fI 1shyjLast t -- ~

IJpound~__-+- Cli) cl pr_f ~ 0 t i )( _

IFirst i3cnJd rYllvj 11 i-r-ddn Lf~)J- joVj dl-)v dS 1) V- _- Phoill 3f t f3 - CO 7S G 1D3 780J~ b ______~ I Bu ~ c r c(oc res L ~s-r Zip I 11) I11 b cmiddot bU I fi PD Ju el

0386 9919 ~tia 1 H I dltl tj vgt elnnAu(0lt ~ ( I~) g~I- amp ---1 I I I Last ~egg - RlVenx_ I(Ill CJniiLAS C hnst fX Zip 7lt2 =t Ii Eilail~1 H V2jo (0 0-1 CC(ccl2 Lom bull net I

VVIf)J~] 970J-5-- ~ -I3~ Idgt ~J L - Ode 16) ~~If fVe( 1k l 1 7-- ~ Pllonl~ 3-fs~c jgt(~--- l ~============~L=a~=l=~ C-k 4- I c- __ ~___ (it~ C(y ~S LllJS ~_k_v-J- I 1-llIild l (l lt Camp 6-~lL0- ou [0 ~]

~i ltldnmiddot ----- ----- W 1111gt11( - -- shy l --11011_ (ity pound_ I-middotIail _I - J

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I 11 ---- shy~-- - shy FiN

I c[ G I ~~-C -- IFI

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--

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------_ _ shy _------ shy

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(jh Iip

11110111

lmiddotlail

PROVIDED BY THE REPlBLlCA PARTY OF TEXAS

MINUTES OF THE REPUBLICAN PARTY PRECINCT CONVENTION

Oualified voters of election precinct number ~~ senate district number ---------__ number ___ of~_ county Texas met at shy bull ifocation) on (date) to hold a precinct convention

congressional district

1 Call to Order Tr1e convention was called to order by temporalV chairman Z-- at plil

2 Preparation of List of Participants The temporary churnwn prepared a list of al qualified members present The list was shown to those presetl and IS

attClched 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 Offimiddotcers The temporary chairman announced that nominations for permanent chairman of this precinct convention would be accepted The foilowll1g persons were nominated as candidates _77Ay~~12 ~_- ~~Zlt ---- rA_~~L~ __~_

The convention elected ~~ pound~ 1 ~-F ~L_ as permanent chairman of the precllct convention u

The convention elected- _)-r i ~j~ as secretary of the precllct 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 [gt (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 explalling 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 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 permanent chairman then announced that heshe 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 (174027c) The chairman announced the time and place for the county or senatorial district convention

8 Adjournment In accordance Ifth a motion properly moved and seconded and adoPt~Jfa majority vote the precinct convention was adjo)Jfned at rt Db pm -1

I l Pc U~

erm nent hairman~ ----- Perman nt SeCretary shy

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

etttIeaTX Cause No

VANESSA L CAHILL sect SUPREME COURT OF TEXAS

VS sect sect 201 W 14TH STREET lUll 104 sect

NUECES C01J~TY sect AUSTll~ TEXAS REPUBLICAN PARTY sect

sect REPUBLICAN PARTY OF TEXAS sect

BUSINESS RECORDS AFFIDAVIT

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

SUBSCRIBED AND SWORN TO before me on this May 6 2008 to which I place my

signature and official seal

~~Jk~=--------My commission expires tmiddotO ~ 0008

Notary Public for the State of Texas

April 26 2008

Wm Paul Hunt 137 Tropical Lane Corpus Christi TX 78408

Via US Mail CERTIFIED RETURN RECEIPT 70062760000405214509

Mr Michael Bertuzzi County Chairman Nueces County Republican Party 4458 South Staples Corpus Christi TX 78411

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) ExhibitA 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 12008 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 gl ma n

[i 11~ ~j g ~ m ~ ~2 gja 0 ~ ~ ~ sect ~ b h~ u - j5

Sincere~IY~~ ~)~~ I UU~ ~ t~-J l~ ~ ~g ~2middot ~ 5 4J i P~ 1 ~ ~- ~ n S $3~~ 2amp~ 1 I ro 0 CD 00 m t~

~ - - 1 (~ _o _0 CD Q (f)

f~ i I fljWmP Hunt ~V1 L~Q I I ~) I

f 1~ i i lt ~

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iiJ~ j ~ rP i~ 8 ~ ~ - 0 - i~ _ 0

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~ ~

~I

eattetr if NUECES COUNTY REPUBLICAN PARTY

Corpus 4458 South Staples Christi Texas 78411

(361 ) 994-9317 (361) 994-9343 FAX E-Mail ncrpcctxgrandecomnet

Mike Bertuzzi-ehairman Rebecca Bradford-Vice Chairman Aneie Flores- Secretary Bill Payne-Treasurer ~bull

April 29 2008

- middotf)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

County Chairman Nueces County Republican Party

Michael A Bertuzzi

~err IeTo Whom It May Concern

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 committees 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 No1 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 132008 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 years 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 172008 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 161004 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 No27 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

bull anessa Cahill

Delegate Pct 65

1111lWS LIve Hotmail C I (i

JqU~rr ( iii(CIlling Margaret Fratilas email CMike Bergsma (bergsmaconsultingdavlinnetl

[lUI 1308258 pre frlC Von Wade (encllonwadeholmailcom) Bol) Jlt)n~s (IJol)Jonlt14101(F~YS0jYiJhOO ((10) VCtn~~)

dllill (cahiilvanessaC0hotmallcom) Tx Fed of Rorjol1lan (ctgolclltmUl(iltIocorn) middotNallJCli1i Rq)JIJ n i c (oll1mitlee (womenlaquo)gop5enatorscom) Cliff la5Icl (cliffilISy lt~)(11 1() PRC CTS [~iiii

1lIIA (ilfrillila(jjforceS5invcom) Setty an(J AI CerJera (hcercJll Iwslor(pnITfcorn) rilld I (i gt~

)iCCW (ldodgecalallenk12lxusj bobbie anderson (ilnderslaw(tiln corn) Ana Cooper ((jna((lu(LIio Jlld (uJelunClcaolcom)Cilll1ie Adams (cathieadalllslexnceaJ eej et1MJ 11 linnks RepJIJUni llylIIiil

(onferenCt (infoCjopconferencecorn) lebL)Ieuro we~I ((lttwet(iviI 10 ((Il DeltlIlll V(IIO (dhiri rpII ~Ie 0 I ~

I)(olilna Gelaek (workfutureaolcom) Dr Robin rT1stong (roli1rl1i1r(cilwtmailcom) Davie (iLl (dave 1181 S2aolrolll) Doris White ((Jorsjwniteyahoo laquol ielli a ntill1 (juclgienr lej Utltrildlw() cnr i

I~Cley HoJtclli50n Campaign (infOlexansforkaycol1l Krystal ~lfVIr) mfO[)1l1Qonvbrnqcom) I(lll i~vlr)iJn (texilsvolunteersglllclllcom) Becky I(an pe (beckyki)nlpelaquodasslatelxu~) ]riH1

middotIMI inez (imartineznetnetwebcom) William IJ Dodge JII (wdiilrlc1cirjdqciilrr1sn(nn) Nick JIIIClCZ (lditorcalercom)

li~ i 1 ( ( t (1 1 ) 1 KI ) ( ltIi k f ~l rmiddot~ Et-H ~

I I ~-()ITy 011(5 that Margaret Fratila has involved you in her bromide djCllnst our County Chairman Miilt) Ekrtu middot1 I ii~ ~av that she is not a reliable source of information I am atlachinq two cJocuments fOm It) dauqhler 1)lt Ij ijnltts t11lt11 something else is involved It appears tl1t some of tile F~Cin FJaul foiks arE tryin~J to Iltlke Olr tI( iii r( callil1g our county leadership Marxist Fascist and warrnonqers This is a pathetic (JIGtrcion f(()rn (jeH ~ j~iilr fltilelin rEHdected and adding to our numb(rs In other office~

Vi I Cd1 cali lYlE about this is you would like at 537696j~

i laquo a(d~)

111 I HrrCjsma

poundtJA1L ~DM

~~MA

11) ell r 07vblu 107mailJivecommaiIReadMessageLightaspxAction==MarkAsNorJunkampFoJder[OcO 3 OOk

MINUTES OF THE REPUBLICAN PARTY PRECINCT CONVENTION

Oualified voters of election precinct number ~~ senate district number ---------__ number ___ of~_ county Texas met at shy bull ifocation) on (date) to hold a precinct convention

congressional district

1 Call to Order Tr1e convention was called to order by temporalV chairman Z-- at plil

2 Preparation of List of Participants The temporary churnwn prepared a list of al qualified members present The list was shown to those presetl and IS

attClched 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 Offimiddotcers The temporary chairman announced that nominations for permanent chairman of this precinct convention would be accepted The foilowll1g persons were nominated as candidates _77Ay~~12 ~_- ~~Zlt ---- rA_~~L~ __~_

The convention elected ~~ pound~ 1 ~-F ~L_ as permanent chairman of the precllct convention u

The convention elected- _)-r i ~j~ as secretary of the precllct 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 [gt (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 explalling 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 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 permanent chairman then announced that heshe 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 (174027c) The chairman announced the time and place for the county or senatorial district convention

8 Adjournment In accordance Ifth a motion properly moved and seconded and adoPt~Jfa majority vote the precinct convention was adjo)Jfned at rt Db pm -1

I l Pc U~

erm nent hairman~ ----- Perman nt SeCretary shy

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

etttIeaTX Cause No

VANESSA L CAHILL sect SUPREME COURT OF TEXAS

VS sect sect 201 W 14TH STREET lUll 104 sect

NUECES C01J~TY sect AUSTll~ TEXAS REPUBLICAN PARTY sect

sect REPUBLICAN PARTY OF TEXAS sect

BUSINESS RECORDS AFFIDAVIT

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

SUBSCRIBED AND SWORN TO before me on this May 6 2008 to which I place my

signature and official seal

~~Jk~=--------My commission expires tmiddotO ~ 0008

Notary Public for the State of Texas

April 26 2008

Wm Paul Hunt 137 Tropical Lane Corpus Christi TX 78408

Via US Mail CERTIFIED RETURN RECEIPT 70062760000405214509

Mr Michael Bertuzzi County Chairman Nueces County Republican Party 4458 South Staples Corpus Christi TX 78411

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) ExhibitA 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 12008 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 gl ma n

[i 11~ ~j g ~ m ~ ~2 gja 0 ~ ~ ~ sect ~ b h~ u - j5

Sincere~IY~~ ~)~~ I UU~ ~ t~-J l~ ~ ~g ~2middot ~ 5 4J i P~ 1 ~ ~- ~ n S $3~~ 2amp~ 1 I ro 0 CD 00 m t~

~ - - 1 (~ _o _0 CD Q (f)

f~ i I fljWmP Hunt ~V1 L~Q I I ~) I

f 1~ i i lt ~

~I~ l~ 1 t ~ ~ ~ ~1t I~~ bull_ s foOolo i r-ll 6 l amp - L ) clgt ciT UI

iflo l~ i c------------- shy

iiJ~ j ~ rP i~ 8 ~ ~ - 0 - i~ _ 0

Vi 8 rg _ ~ CD ~ 3 ~ I I f) ~

~ ~

~I

eattetr if NUECES COUNTY REPUBLICAN PARTY

Corpus 4458 South Staples Christi Texas 78411

(361 ) 994-9317 (361) 994-9343 FAX E-Mail ncrpcctxgrandecomnet

Mike Bertuzzi-ehairman Rebecca Bradford-Vice Chairman Aneie Flores- Secretary Bill Payne-Treasurer ~bull

April 29 2008

- middotf)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

County Chairman Nueces County Republican Party

Michael A Bertuzzi

~err IeTo Whom It May Concern

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 committees 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 No1 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 132008 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 years 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 172008 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 161004 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 No27 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

bull anessa Cahill

Delegate Pct 65

1111lWS LIve Hotmail C I (i

JqU~rr ( iii(CIlling Margaret Fratilas email CMike Bergsma (bergsmaconsultingdavlinnetl

[lUI 1308258 pre frlC Von Wade (encllonwadeholmailcom) Bol) Jlt)n~s (IJol)Jonlt14101(F~YS0jYiJhOO ((10) VCtn~~)

dllill (cahiilvanessaC0hotmallcom) Tx Fed of Rorjol1lan (ctgolclltmUl(iltIocorn) middotNallJCli1i Rq)JIJ n i c (oll1mitlee (womenlaquo)gop5enatorscom) Cliff la5Icl (cliffilISy lt~)(11 1() PRC CTS [~iiii

1lIIA (ilfrillila(jjforceS5invcom) Setty an(J AI CerJera (hcercJll Iwslor(pnITfcorn) rilld I (i gt~

)iCCW (ldodgecalallenk12lxusj bobbie anderson (ilnderslaw(tiln corn) Ana Cooper ((jna((lu(LIio Jlld (uJelunClcaolcom)Cilll1ie Adams (cathieadalllslexnceaJ eej et1MJ 11 linnks RepJIJUni llylIIiil

(onferenCt (infoCjopconferencecorn) lebL)Ieuro we~I ((lttwet(iviI 10 ((Il DeltlIlll V(IIO (dhiri rpII ~Ie 0 I ~

I)(olilna Gelaek (workfutureaolcom) Dr Robin rT1stong (roli1rl1i1r(cilwtmailcom) Davie (iLl (dave 1181 S2aolrolll) Doris White ((Jorsjwniteyahoo laquol ielli a ntill1 (juclgienr lej Utltrildlw() cnr i

I~Cley HoJtclli50n Campaign (infOlexansforkaycol1l Krystal ~lfVIr) mfO[)1l1Qonvbrnqcom) I(lll i~vlr)iJn (texilsvolunteersglllclllcom) Becky I(an pe (beckyki)nlpelaquodasslatelxu~) ]riH1

middotIMI inez (imartineznetnetwebcom) William IJ Dodge JII (wdiilrlc1cirjdqciilrr1sn(nn) Nick JIIIClCZ (lditorcalercom)

li~ i 1 ( ( t (1 1 ) 1 KI ) ( ltIi k f ~l rmiddot~ Et-H ~

I I ~-()ITy 011(5 that Margaret Fratila has involved you in her bromide djCllnst our County Chairman Miilt) Ekrtu middot1 I ii~ ~av that she is not a reliable source of information I am atlachinq two cJocuments fOm It) dauqhler 1)lt Ij ijnltts t11lt11 something else is involved It appears tl1t some of tile F~Cin FJaul foiks arE tryin~J to Iltlke Olr tI( iii r( callil1g our county leadership Marxist Fascist and warrnonqers This is a pathetic (JIGtrcion f(()rn (jeH ~ j~iilr fltilelin rEHdected and adding to our numb(rs In other office~

Vi I Cd1 cali lYlE about this is you would like at 537696j~

i laquo a(d~)

111 I HrrCjsma

poundtJA1L ~DM

~~MA

11) ell r 07vblu 107mailJivecommaiIReadMessageLightaspxAction==MarkAsNorJunkampFoJder[OcO 3 OOk

etttIeaTX Cause No

VANESSA L CAHILL sect SUPREME COURT OF TEXAS

VS sect sect 201 W 14TH STREET lUll 104 sect

NUECES C01J~TY sect AUSTll~ TEXAS REPUBLICAN PARTY sect

sect REPUBLICAN PARTY OF TEXAS sect

BUSINESS RECORDS AFFIDAVIT

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

SUBSCRIBED AND SWORN TO before me on this May 6 2008 to which I place my

signature and official seal

~~Jk~=--------My commission expires tmiddotO ~ 0008

Notary Public for the State of Texas

April 26 2008

Wm Paul Hunt 137 Tropical Lane Corpus Christi TX 78408

Via US Mail CERTIFIED RETURN RECEIPT 70062760000405214509

Mr Michael Bertuzzi County Chairman Nueces County Republican Party 4458 South Staples Corpus Christi TX 78411

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) ExhibitA 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 12008 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 gl ma n

[i 11~ ~j g ~ m ~ ~2 gja 0 ~ ~ ~ sect ~ b h~ u - j5

Sincere~IY~~ ~)~~ I UU~ ~ t~-J l~ ~ ~g ~2middot ~ 5 4J i P~ 1 ~ ~- ~ n S $3~~ 2amp~ 1 I ro 0 CD 00 m t~

~ - - 1 (~ _o _0 CD Q (f)

f~ i I fljWmP Hunt ~V1 L~Q I I ~) I

f 1~ i i lt ~

~I~ l~ 1 t ~ ~ ~ ~1t I~~ bull_ s foOolo i r-ll 6 l amp - L ) clgt ciT UI

iflo l~ i c------------- shy

iiJ~ j ~ rP i~ 8 ~ ~ - 0 - i~ _ 0

Vi 8 rg _ ~ CD ~ 3 ~ I I f) ~

~ ~

~I

eattetr if NUECES COUNTY REPUBLICAN PARTY

Corpus 4458 South Staples Christi Texas 78411

(361 ) 994-9317 (361) 994-9343 FAX E-Mail ncrpcctxgrandecomnet

Mike Bertuzzi-ehairman Rebecca Bradford-Vice Chairman Aneie Flores- Secretary Bill Payne-Treasurer ~bull

April 29 2008

- middotf)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

County Chairman Nueces County Republican Party

Michael A Bertuzzi

~err IeTo Whom It May Concern

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 committees 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 No1 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 132008 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 years 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 172008 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 161004 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 No27 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

bull anessa Cahill

Delegate Pct 65

1111lWS LIve Hotmail C I (i

JqU~rr ( iii(CIlling Margaret Fratilas email CMike Bergsma (bergsmaconsultingdavlinnetl

[lUI 1308258 pre frlC Von Wade (encllonwadeholmailcom) Bol) Jlt)n~s (IJol)Jonlt14101(F~YS0jYiJhOO ((10) VCtn~~)

dllill (cahiilvanessaC0hotmallcom) Tx Fed of Rorjol1lan (ctgolclltmUl(iltIocorn) middotNallJCli1i Rq)JIJ n i c (oll1mitlee (womenlaquo)gop5enatorscom) Cliff la5Icl (cliffilISy lt~)(11 1() PRC CTS [~iiii

1lIIA (ilfrillila(jjforceS5invcom) Setty an(J AI CerJera (hcercJll Iwslor(pnITfcorn) rilld I (i gt~

)iCCW (ldodgecalallenk12lxusj bobbie anderson (ilnderslaw(tiln corn) Ana Cooper ((jna((lu(LIio Jlld (uJelunClcaolcom)Cilll1ie Adams (cathieadalllslexnceaJ eej et1MJ 11 linnks RepJIJUni llylIIiil

(onferenCt (infoCjopconferencecorn) lebL)Ieuro we~I ((lttwet(iviI 10 ((Il DeltlIlll V(IIO (dhiri rpII ~Ie 0 I ~

I)(olilna Gelaek (workfutureaolcom) Dr Robin rT1stong (roli1rl1i1r(cilwtmailcom) Davie (iLl (dave 1181 S2aolrolll) Doris White ((Jorsjwniteyahoo laquol ielli a ntill1 (juclgienr lej Utltrildlw() cnr i

I~Cley HoJtclli50n Campaign (infOlexansforkaycol1l Krystal ~lfVIr) mfO[)1l1Qonvbrnqcom) I(lll i~vlr)iJn (texilsvolunteersglllclllcom) Becky I(an pe (beckyki)nlpelaquodasslatelxu~) ]riH1

middotIMI inez (imartineznetnetwebcom) William IJ Dodge JII (wdiilrlc1cirjdqciilrr1sn(nn) Nick JIIIClCZ (lditorcalercom)

li~ i 1 ( ( t (1 1 ) 1 KI ) ( ltIi k f ~l rmiddot~ Et-H ~

I I ~-()ITy 011(5 that Margaret Fratila has involved you in her bromide djCllnst our County Chairman Miilt) Ekrtu middot1 I ii~ ~av that she is not a reliable source of information I am atlachinq two cJocuments fOm It) dauqhler 1)lt Ij ijnltts t11lt11 something else is involved It appears tl1t some of tile F~Cin FJaul foiks arE tryin~J to Iltlke Olr tI( iii r( callil1g our county leadership Marxist Fascist and warrnonqers This is a pathetic (JIGtrcion f(()rn (jeH ~ j~iilr fltilelin rEHdected and adding to our numb(rs In other office~

Vi I Cd1 cali lYlE about this is you would like at 537696j~

i laquo a(d~)

111 I HrrCjsma

poundtJA1L ~DM

~~MA

11) ell r 07vblu 107mailJivecommaiIReadMessageLightaspxAction==MarkAsNorJunkampFoJder[OcO 3 OOk

April 26 2008

Wm Paul Hunt 137 Tropical Lane Corpus Christi TX 78408

Via US Mail CERTIFIED RETURN RECEIPT 70062760000405214509

Mr Michael Bertuzzi County Chairman Nueces County Republican Party 4458 South Staples Corpus Christi TX 78411

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) ExhibitA 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 12008 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 gl ma n

[i 11~ ~j g ~ m ~ ~2 gja 0 ~ ~ ~ sect ~ b h~ u - j5

Sincere~IY~~ ~)~~ I UU~ ~ t~-J l~ ~ ~g ~2middot ~ 5 4J i P~ 1 ~ ~- ~ n S $3~~ 2amp~ 1 I ro 0 CD 00 m t~

~ - - 1 (~ _o _0 CD Q (f)

f~ i I fljWmP Hunt ~V1 L~Q I I ~) I

f 1~ i i lt ~

~I~ l~ 1 t ~ ~ ~ ~1t I~~ bull_ s foOolo i r-ll 6 l amp - L ) clgt ciT UI

iflo l~ i c------------- shy

iiJ~ j ~ rP i~ 8 ~ ~ - 0 - i~ _ 0

Vi 8 rg _ ~ CD ~ 3 ~ I I f) ~

~ ~

~I

eattetr if NUECES COUNTY REPUBLICAN PARTY

Corpus 4458 South Staples Christi Texas 78411

(361 ) 994-9317 (361) 994-9343 FAX E-Mail ncrpcctxgrandecomnet

Mike Bertuzzi-ehairman Rebecca Bradford-Vice Chairman Aneie Flores- Secretary Bill Payne-Treasurer ~bull

April 29 2008

- middotf)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

County Chairman Nueces County Republican Party

Michael A Bertuzzi

~err IeTo Whom It May Concern

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 committees 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 No1 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 132008 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 years 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 172008 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 161004 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 No27 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

bull anessa Cahill

Delegate Pct 65

1111lWS LIve Hotmail C I (i

JqU~rr ( iii(CIlling Margaret Fratilas email CMike Bergsma (bergsmaconsultingdavlinnetl

[lUI 1308258 pre frlC Von Wade (encllonwadeholmailcom) Bol) Jlt)n~s (IJol)Jonlt14101(F~YS0jYiJhOO ((10) VCtn~~)

dllill (cahiilvanessaC0hotmallcom) Tx Fed of Rorjol1lan (ctgolclltmUl(iltIocorn) middotNallJCli1i Rq)JIJ n i c (oll1mitlee (womenlaquo)gop5enatorscom) Cliff la5Icl (cliffilISy lt~)(11 1() PRC CTS [~iiii

1lIIA (ilfrillila(jjforceS5invcom) Setty an(J AI CerJera (hcercJll Iwslor(pnITfcorn) rilld I (i gt~

)iCCW (ldodgecalallenk12lxusj bobbie anderson (ilnderslaw(tiln corn) Ana Cooper ((jna((lu(LIio Jlld (uJelunClcaolcom)Cilll1ie Adams (cathieadalllslexnceaJ eej et1MJ 11 linnks RepJIJUni llylIIiil

(onferenCt (infoCjopconferencecorn) lebL)Ieuro we~I ((lttwet(iviI 10 ((Il DeltlIlll V(IIO (dhiri rpII ~Ie 0 I ~

I)(olilna Gelaek (workfutureaolcom) Dr Robin rT1stong (roli1rl1i1r(cilwtmailcom) Davie (iLl (dave 1181 S2aolrolll) Doris White ((Jorsjwniteyahoo laquol ielli a ntill1 (juclgienr lej Utltrildlw() cnr i

I~Cley HoJtclli50n Campaign (infOlexansforkaycol1l Krystal ~lfVIr) mfO[)1l1Qonvbrnqcom) I(lll i~vlr)iJn (texilsvolunteersglllclllcom) Becky I(an pe (beckyki)nlpelaquodasslatelxu~) ]riH1

middotIMI inez (imartineznetnetwebcom) William IJ Dodge JII (wdiilrlc1cirjdqciilrr1sn(nn) Nick JIIIClCZ (lditorcalercom)

li~ i 1 ( ( t (1 1 ) 1 KI ) ( ltIi k f ~l rmiddot~ Et-H ~

I I ~-()ITy 011(5 that Margaret Fratila has involved you in her bromide djCllnst our County Chairman Miilt) Ekrtu middot1 I ii~ ~av that she is not a reliable source of information I am atlachinq two cJocuments fOm It) dauqhler 1)lt Ij ijnltts t11lt11 something else is involved It appears tl1t some of tile F~Cin FJaul foiks arE tryin~J to Iltlke Olr tI( iii r( callil1g our county leadership Marxist Fascist and warrnonqers This is a pathetic (JIGtrcion f(()rn (jeH ~ j~iilr fltilelin rEHdected and adding to our numb(rs In other office~

Vi I Cd1 cali lYlE about this is you would like at 537696j~

i laquo a(d~)

111 I HrrCjsma

poundtJA1L ~DM

~~MA

11) ell r 07vblu 107mailJivecommaiIReadMessageLightaspxAction==MarkAsNorJunkampFoJder[OcO 3 OOk

eattetr if NUECES COUNTY REPUBLICAN PARTY

Corpus 4458 South Staples Christi Texas 78411

(361 ) 994-9317 (361) 994-9343 FAX E-Mail ncrpcctxgrandecomnet

Mike Bertuzzi-ehairman Rebecca Bradford-Vice Chairman Aneie Flores- Secretary Bill Payne-Treasurer ~bull

April 29 2008

- middotf)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

County Chairman Nueces County Republican Party

Michael A Bertuzzi

~err IeTo Whom It May Concern

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 committees 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 No1 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 132008 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 years 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 172008 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 161004 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 No27 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

bull anessa Cahill

Delegate Pct 65

1111lWS LIve Hotmail C I (i

JqU~rr ( iii(CIlling Margaret Fratilas email CMike Bergsma (bergsmaconsultingdavlinnetl

[lUI 1308258 pre frlC Von Wade (encllonwadeholmailcom) Bol) Jlt)n~s (IJol)Jonlt14101(F~YS0jYiJhOO ((10) VCtn~~)

dllill (cahiilvanessaC0hotmallcom) Tx Fed of Rorjol1lan (ctgolclltmUl(iltIocorn) middotNallJCli1i Rq)JIJ n i c (oll1mitlee (womenlaquo)gop5enatorscom) Cliff la5Icl (cliffilISy lt~)(11 1() PRC CTS [~iiii

1lIIA (ilfrillila(jjforceS5invcom) Setty an(J AI CerJera (hcercJll Iwslor(pnITfcorn) rilld I (i gt~

)iCCW (ldodgecalallenk12lxusj bobbie anderson (ilnderslaw(tiln corn) Ana Cooper ((jna((lu(LIio Jlld (uJelunClcaolcom)Cilll1ie Adams (cathieadalllslexnceaJ eej et1MJ 11 linnks RepJIJUni llylIIiil

(onferenCt (infoCjopconferencecorn) lebL)Ieuro we~I ((lttwet(iviI 10 ((Il DeltlIlll V(IIO (dhiri rpII ~Ie 0 I ~

I)(olilna Gelaek (workfutureaolcom) Dr Robin rT1stong (roli1rl1i1r(cilwtmailcom) Davie (iLl (dave 1181 S2aolrolll) Doris White ((Jorsjwniteyahoo laquol ielli a ntill1 (juclgienr lej Utltrildlw() cnr i

I~Cley HoJtclli50n Campaign (infOlexansforkaycol1l Krystal ~lfVIr) mfO[)1l1Qonvbrnqcom) I(lll i~vlr)iJn (texilsvolunteersglllclllcom) Becky I(an pe (beckyki)nlpelaquodasslatelxu~) ]riH1

middotIMI inez (imartineznetnetwebcom) William IJ Dodge JII (wdiilrlc1cirjdqciilrr1sn(nn) Nick JIIIClCZ (lditorcalercom)

li~ i 1 ( ( t (1 1 ) 1 KI ) ( ltIi k f ~l rmiddot~ Et-H ~

I I ~-()ITy 011(5 that Margaret Fratila has involved you in her bromide djCllnst our County Chairman Miilt) Ekrtu middot1 I ii~ ~av that she is not a reliable source of information I am atlachinq two cJocuments fOm It) dauqhler 1)lt Ij ijnltts t11lt11 something else is involved It appears tl1t some of tile F~Cin FJaul foiks arE tryin~J to Iltlke Olr tI( iii r( callil1g our county leadership Marxist Fascist and warrnonqers This is a pathetic (JIGtrcion f(()rn (jeH ~ j~iilr fltilelin rEHdected and adding to our numb(rs In other office~

Vi I Cd1 cali lYlE about this is you would like at 537696j~

i laquo a(d~)

111 I HrrCjsma

poundtJA1L ~DM

~~MA

11) ell r 07vblu 107mailJivecommaiIReadMessageLightaspxAction==MarkAsNorJunkampFoJder[OcO 3 OOk

~err IeTo Whom It May Concern

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 committees 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 No1 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 132008 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 years 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 172008 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 161004 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 No27 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

bull anessa Cahill

Delegate Pct 65

1111lWS LIve Hotmail C I (i

JqU~rr ( iii(CIlling Margaret Fratilas email CMike Bergsma (bergsmaconsultingdavlinnetl

[lUI 1308258 pre frlC Von Wade (encllonwadeholmailcom) Bol) Jlt)n~s (IJol)Jonlt14101(F~YS0jYiJhOO ((10) VCtn~~)

dllill (cahiilvanessaC0hotmallcom) Tx Fed of Rorjol1lan (ctgolclltmUl(iltIocorn) middotNallJCli1i Rq)JIJ n i c (oll1mitlee (womenlaquo)gop5enatorscom) Cliff la5Icl (cliffilISy lt~)(11 1() PRC CTS [~iiii

1lIIA (ilfrillila(jjforceS5invcom) Setty an(J AI CerJera (hcercJll Iwslor(pnITfcorn) rilld I (i gt~

)iCCW (ldodgecalallenk12lxusj bobbie anderson (ilnderslaw(tiln corn) Ana Cooper ((jna((lu(LIio Jlld (uJelunClcaolcom)Cilll1ie Adams (cathieadalllslexnceaJ eej et1MJ 11 linnks RepJIJUni llylIIiil

(onferenCt (infoCjopconferencecorn) lebL)Ieuro we~I ((lttwet(iviI 10 ((Il DeltlIlll V(IIO (dhiri rpII ~Ie 0 I ~

I)(olilna Gelaek (workfutureaolcom) Dr Robin rT1stong (roli1rl1i1r(cilwtmailcom) Davie (iLl (dave 1181 S2aolrolll) Doris White ((Jorsjwniteyahoo laquol ielli a ntill1 (juclgienr lej Utltrildlw() cnr i

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middotIMI inez (imartineznetnetwebcom) William IJ Dodge JII (wdiilrlc1cirjdqciilrr1sn(nn) Nick JIIIClCZ (lditorcalercom)

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I I ~-()ITy 011(5 that Margaret Fratila has involved you in her bromide djCllnst our County Chairman Miilt) Ekrtu middot1 I ii~ ~av that she is not a reliable source of information I am atlachinq two cJocuments fOm It) dauqhler 1)lt Ij ijnltts t11lt11 something else is involved It appears tl1t some of tile F~Cin FJaul foiks arE tryin~J to Iltlke Olr tI( iii r( callil1g our county leadership Marxist Fascist and warrnonqers This is a pathetic (JIGtrcion f(()rn (jeH ~ j~iilr fltilelin rEHdected and adding to our numb(rs In other office~

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until the end of that years 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 172008 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 161004 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 No27 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

bull anessa Cahill

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I I ~-()ITy 011(5 that Margaret Fratila has involved you in her bromide djCllnst our County Chairman Miilt) Ekrtu middot1 I ii~ ~av that she is not a reliable source of information I am atlachinq two cJocuments fOm It) dauqhler 1)lt Ij ijnltts t11lt11 something else is involved It appears tl1t some of tile F~Cin FJaul foiks arE tryin~J to Iltlke Olr tI( iii r( callil1g our county leadership Marxist Fascist and warrnonqers This is a pathetic (JIGtrcion f(()rn (jeH ~ j~iilr fltilelin rEHdected and adding to our numb(rs In other office~

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I I ~-()ITy 011(5 that Margaret Fratila has involved you in her bromide djCllnst our County Chairman Miilt) Ekrtu middot1 I ii~ ~av that she is not a reliable source of information I am atlachinq two cJocuments fOm It) dauqhler 1)lt Ij ijnltts t11lt11 something else is involved It appears tl1t some of tile F~Cin FJaul foiks arE tryin~J to Iltlke Olr tI( iii r( callil1g our county leadership Marxist Fascist and warrnonqers This is a pathetic (JIGtrcion f(()rn (jeH ~ j~iilr fltilelin rEHdected and adding to our numb(rs In other office~

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From vanessa cahill [vanessafratilagmailcomJ

SfFIt Thursday March 06 200B 3 12 PM

ro Bertuzzi Michael A(CORPUS CHRISTI CU 532)

SUbject Committee Intonnation

1 hnnzzi

~t pJl~asant talking viith you this afternoon rVfy n1otJer-in~aV1 1argaret Fraltlal speaks very highly of t HI -J itmiddot (lod ll finally gel a chance to meet J hope we will soon he C3ble to put a fan to the nameas the saying goc-

ly 11lIsbilJ1d Antonio and 1just moved back to Corpus Christi this past summer Margaret has heen encouragi rill

) hClIHllC more involved in the Republican Party and wlat b(tler t1ll1C to do so than the election ~ca~nnl Vilh If hI ill( iulTounding the Democratic race think it is important for everyone in our pltlrty to gel If1vohd iU Wl [1

Lull 111lt White House in November

am llY interested in volunteering lUY time in any way that I can I would love to serve on any of the cornmill as ell i atllnd the meetings of the committees that arc already fuJI lfal all possible could you send me a list qf c omn Ilte and the scheduled meeting dates and times In addition could you give me the phone numbers email ddnscs uf Art Granado and Victor Bird I believe they are heading up the Nominations and Reiolulions ltr11Illlkcs

I hl1 i r my services are also needed at th(~ headquarters f~el free to contact me

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I would like to be sure thaI my rncollectlor If Ollr fll$t telephone conversation IS cOrect (Vr As per my memory I requested Informatin 01 tile dates times and locations of the Credent Nominations Committees for ieces COl)n1y You len asked that I send my request in WIII promptly did via email (Marcil 6 7000) Frorn the email attachment I receiverJ frOm J1ike Bp 132008) I have made the remonable asiIJnption tlla you have opened anc eoc Y1y erai i

thiS Information

I would also ItI~e to clarify the u~cond and Ipound1Sl ulrversation we had over the telephone (Mel -

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from what I understood your rduclance C rrowie tbe requested InforlT1ati~n 10 me stemrw affiliation with a local meetup woup In wch J fellGw rnember~ClllJCI Bppt voiced hitgt op leadersJ1ip in the Republican Fcrty

I would also like clarification fOil you 011 1I1e 14th RIJoe of the General Rules for AI Convr Meetings of the RepUblican Party of Tll~lU~ W11C states

All meetings of any COmmiHoIe or sub-(ommlttee of any convention whether it I)e i111 permanent organization shull be open ~o ~ly dl)legat~ 011 altl1lrnate to that convention

As a voter in the Republican Fnmary and 8 elelAq2tA in my precinct I wouid again like 10 (f~Cj dates times and locations tor ne (ollowing cOfT1ytces

Credentials Resolutions Rules and NominatJOns

In addition I would also like to request a copy of accurate written records (minuesi from elf~ Nueces County Please notify me when tJ)eSI~ copies have been completed and i j Jlckior the Republican Party Headquarters

Thank you for your time

Sincerely Vanessa

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Ms Sally Hunt 137 Tropical Lane Corpus Cluisti TX 78408

Dear Ms Hunt

Per your request enclosed are the Minutes 11001 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

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GOP RULeI GENERAL RULES FOR ALL CONVENTIONS

AND MEETINGS

Rule No1 - Adoption and Amendment of Rules Clarification These Rules having been filed with the Secretary of State ofTexas together with the stltltutes rules and bylaws adopted by reference shall constitute the Rules of the Republican Party of Texas

Rule No4 - Adoption of Reference - US 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 No5 - Parliamentary Authority Unless otherwise provided for by the United States Constitution Texas Constitution United States and Texas statutes or these Rules the current edition of Roberts Rules o(Order Ncvdv shyRelised 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 ie 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 - Chairmans 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 years 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 sect 161004 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 sect 1 efT Jan 1 1986

sect 161009 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 sect 1 eff Jan 1 1986

sect 163002 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 ch211 sect 1 eff Jan 11986

sect 163007 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 sect 1 eff Jan 1 1986

sect 174021 SELECTION OF DELEGATES TO COUNTY AND SENATORIAL DISTRICT CONVENTIONS The delegates to a political partys 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 sect I eff Jan I 1986

sect 174027 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 174025(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 sect I eff Jan 1 1986 Amended by Acts 1987 70th Leg ch 472 sect 47 eff Sept I 1987 Acts 1987 70th Leg ch 499 sect I eff Sept I 1987 Acts 1997 75th Leg ch 864 sect 179 eff Sept I 1997

sect 273061 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

sect 273063 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 sect 15(c) eff Sept 11987

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I would like to be sure thaI my rncollectlor If Ollr fll$t telephone conversation IS cOrect (Vr As per my memory I requested Informatin 01 tile dates times and locations of the Credent Nominations Committees for ieces COl)n1y You len asked that I send my request in WIII promptly did via email (Marcil 6 7000) Frorn the email attachment I receiverJ frOm J1ike Bp 132008) I have made the remonable asiIJnption tlla you have opened anc eoc Y1y erai i

thiS Information

I would also ItI~e to clarify the u~cond and Ipound1Sl ulrversation we had over the telephone (Mel -

As per my memory you tolcl TIC tllat ymJ Nould noll)e provIjlng to me tile idormation I WB bull

from what I understood your rduclance C rrowie tbe requested InforlT1ati~n 10 me stemrw affiliation with a local meetup woup In wch J fellGw rnember~ClllJCI Bppt voiced hitgt op leadersJ1ip in the Republican Fcrty

I would also like clarification fOil you 011 1I1e 14th RIJoe of the General Rules for AI Convr Meetings of the RepUblican Party of Tll~lU~ W11C states

All meetings of any COmmiHoIe or sub-(ommlttee of any convention whether it I)e i111 permanent organization shull be open ~o ~ly dl)legat~ 011 altl1lrnate to that convention

As a voter in the Republican Fnmary and 8 elelAq2tA in my precinct I wouid again like 10 (f~Cj dates times and locations tor ne (ollowing cOfT1ytces

Credentials Resolutions Rules and NominatJOns

In addition I would also like to request a copy of accurate written records (minuesi from elf~ Nueces County Please notify me when tJ)eSI~ copies have been completed and i j Jlckior the Republican Party Headquarters

Thank you for your time

Sincerely Vanessa

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April 18 2008

Ms Sally Hunt 137 Tropical Lane Corpus Cluisti TX 78408

Dear Ms Hunt

Per your request enclosed are the Minutes 11001 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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65 IBertuzzi Caroline I

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GOP RULeI GENERAL RULES FOR ALL CONVENTIONS

AND MEETINGS

Rule No1 - Adoption and Amendment of Rules Clarification These Rules having been filed with the Secretary of State ofTexas together with the stltltutes rules and bylaws adopted by reference shall constitute the Rules of the Republican Party of Texas

Rule No4 - Adoption of Reference - US 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 No5 - Parliamentary Authority Unless otherwise provided for by the United States Constitution Texas Constitution United States and Texas statutes or these Rules the current edition of Roberts Rules o(Order Ncvdv shyRelised 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 ie 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 - Chairmans 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 years 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 sect 161004 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 sect 1 efT Jan 1 1986

sect 161009 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 sect 1 eff Jan 1 1986

sect 163002 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 ch211 sect 1 eff Jan 11986

sect 163007 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 sect 1 eff Jan 1 1986

sect 174021 SELECTION OF DELEGATES TO COUNTY AND SENATORIAL DISTRICT CONVENTIONS The delegates to a political partys 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 sect I eff Jan I 1986

sect 174027 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 174025(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 sect I eff Jan 1 1986 Amended by Acts 1987 70th Leg ch 472 sect 47 eff Sept I 1987 Acts 1987 70th Leg ch 499 sect I eff Sept I 1987 Acts 1997 75th Leg ch 864 sect 179 eff Sept I 1997

sect 273061 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

sect 273063 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 sect 15(c) eff Sept 11987

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~ ~i ~- ishy ~ L middotTinaJ BenhserC9p1r fl0

April 18 2008

Ms Sally Hunt 137 Tropical Lane Corpus Cluisti TX 78408

Dear Ms Hunt

Per your request enclosed are the Minutes 11001 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

gt~~~ xmiddot-middotmiddotmiddotmiddot ~~

(

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Pet j Last First ML i SIGN INI 1 - - I

65 (Anderson Amy B I

65 IAnderson Shane D I ----- -~_- I

65 iBailes Rebecca _-+--i_--+---shy

65 IBertuzzi Caroline I

-651Sertuzzi Michael I 65 iCahill ~rf( Vanessa 65 iCheetham Gerald 65 Collins-- Mrs Bruce 65 Eigueda Maria I

RECEiVEO APR (I 4 Lu08

i~8 r =-~ 1I~ ~ C~ ~ t ~ ~ iltc ~ ~ ~ tlt9 ~ Y~j

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65 iSeama_~ Eugene J _65 JSheldon yen- Jean

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65 (Webster IDean I 4tU0 t iJ~

65 jWebster L I 7JJ~1Mary 6~ IWhitt Betty I ~JIr~

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(bl G ~Cllid~ I Av+shyPRECINCT 167 i I

Pctlf-----Last~ tlt~-~~~ I First i ML i SIGN IN 67 f Burger CJ))J~ ~ Gary R~

61 iY~ung Christopher P ~ t

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GOP RULeI GENERAL RULES FOR ALL CONVENTIONS

AND MEETINGS

Rule No1 - Adoption and Amendment of Rules Clarification These Rules having been filed with the Secretary of State ofTexas together with the stltltutes rules and bylaws adopted by reference shall constitute the Rules of the Republican Party of Texas

Rule No4 - Adoption of Reference - US 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 No5 - Parliamentary Authority Unless otherwise provided for by the United States Constitution Texas Constitution United States and Texas statutes or these Rules the current edition of Roberts Rules o(Order Ncvdv shyRelised 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 ie 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 - Chairmans 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 years 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 sect 161004 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 sect 1 efT Jan 1 1986

sect 161009 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 sect 1 eff Jan 1 1986

sect 163002 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 ch211 sect 1 eff Jan 11986

sect 163007 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 sect 1 eff Jan 1 1986

sect 174021 SELECTION OF DELEGATES TO COUNTY AND SENATORIAL DISTRICT CONVENTIONS The delegates to a political partys 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 sect I eff Jan I 1986

sect 174027 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 174025(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 sect I eff Jan 1 1986 Amended by Acts 1987 70th Leg ch 472 sect 47 eff Sept I 1987 Acts 1987 70th Leg ch 499 sect I eff Sept I 1987 Acts 1997 75th Leg ch 864 sect 179 eff Sept I 1997

sect 273061 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

sect 273063 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 sect 15(c) eff Sept 11987

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Fax 51248001)9 wwwtexasgoptrg

~ ~i ~- ishy ~ L middotTinaJ BenhserC9p1r fl0

April 18 2008

Ms Sally Hunt 137 Tropical Lane Corpus Cluisti TX 78408

Dear Ms Hunt

Per your request enclosed are the Minutes 11001 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

gt~~~ xmiddot-middotmiddotmiddotmiddot ~~

(

gY~-e-Pl~ Execu( e rector

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L

Pet j Last First ML i SIGN INI 1 - - I

65 (Anderson Amy B I

65 IAnderson Shane D I ----- -~_- I

65 iBailes Rebecca _-+--i_--+---shy

65 IBertuzzi Caroline I

-651Sertuzzi Michael I 65 iCahill ~rf( Vanessa 65 iCheetham Gerald 65 Collins-- Mrs Bruce 65 Eigueda Maria I

RECEiVEO APR (I 4 Lu08

i~8 r =-~ 1I~ ~ C~ ~ t ~ ~ iltc ~ ~ ~ tlt9 ~ Y~j

Pet i Last First

i ML SIGN IN ~5 IFratila P - A~toniO--tiS IGonzalez Nllza

A

65 Moore Richard R A100 I]-Y~65 IPrice Paul D 65 ISchroeder K Mike

I

65 Seaman F- Ellen v~

65 iSeama_~ Eugene J _65 JSheldon yen- Jean

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RECEiVED APR 042008

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65 (Webster IDean I 4tU0 t iJ~

65 jWebster L I 7JJ~1Mary 6~ IWhitt Betty I ~JIr~

~

(bl G ~Cllid~ I Av+shyPRECINCT 167 i I

Pctlf-----Last~ tlt~-~~~ I First i ML i SIGN IN 67 f Burger CJ))J~ ~ Gary R~

61 iY~ung Christopher P ~ t

~

GOP RULeI GENERAL RULES FOR ALL CONVENTIONS

AND MEETINGS

Rule No1 - Adoption and Amendment of Rules Clarification These Rules having been filed with the Secretary of State ofTexas together with the stltltutes rules and bylaws adopted by reference shall constitute the Rules of the Republican Party of Texas

Rule No4 - Adoption of Reference - US 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 No5 - Parliamentary Authority Unless otherwise provided for by the United States Constitution Texas Constitution United States and Texas statutes or these Rules the current edition of Roberts Rules o(Order Ncvdv shyRelised 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 ie 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 - Chairmans 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 years 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 sect 161004 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 sect 1 efT Jan 1 1986

sect 161009 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 sect 1 eff Jan 1 1986

sect 163002 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 ch211 sect 1 eff Jan 11986

sect 163007 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 sect 1 eff Jan 1 1986

sect 174021 SELECTION OF DELEGATES TO COUNTY AND SENATORIAL DISTRICT CONVENTIONS The delegates to a political partys 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 sect I eff Jan I 1986

sect 174027 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 174025(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 sect I eff Jan 1 1986 Amended by Acts 1987 70th Leg ch 472 sect 47 eff Sept I 1987 Acts 1987 70th Leg ch 499 sect I eff Sept I 1987 Acts 1997 75th Leg ch 864 sect 179 eff Sept I 1997

sect 273061 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

sect 273063 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 sect 15(c) eff Sept 11987

900 Congress Avenue Suite ~H 10ectfterr L Austin TX 787 I) Phone 51247798gt1

Fax 51248001)9 wwwtexasgoptrg

~ ~i ~- ishy ~ L middotTinaJ BenhserC9p1r fl0

April 18 2008

Ms Sally Hunt 137 Tropical Lane Corpus Cluisti TX 78408

Dear Ms Hunt

Per your request enclosed are the Minutes 11001 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

gt~~~ xmiddot-middotmiddotmiddotmiddot ~~

(

gY~-e-Pl~ Execu( e rector

14v amp u- ~~_I

_

I I~~~Z

RfeE if CtPR 04 2uaa

- - --PR~r~l~jj~~rJ h~i ~ i ]l~YilJl~~ $ T

I I ----------------------Iic~T-------Last-----L-First---iML i - _ SIGN IN

~~ IShirley IRobert bullIP I6Jcl Jt~ 04 IStephens iCarol i 64 IStruve Joe ---+-1----+I-l------yen--middotr

I I II ~I gt) ~- tU

CtQ J- -rt]~lJ--1 -i C~f1 teflS e l~fb6 --LL PRECINCT 165 I U--

L

Pet j Last First ML i SIGN INI 1 - - I

65 (Anderson Amy B I

65 IAnderson Shane D I ----- -~_- I

65 iBailes Rebecca _-+--i_--+---shy

65 IBertuzzi Caroline I

-651Sertuzzi Michael I 65 iCahill ~rf( Vanessa 65 iCheetham Gerald 65 Collins-- Mrs Bruce 65 Eigueda Maria I

RECEiVEO APR (I 4 Lu08

i~8 r =-~ 1I~ ~ C~ ~ t ~ ~ iltc ~ ~ ~ tlt9 ~ Y~j

Pet i Last First

i ML SIGN IN ~5 IFratila P - A~toniO--tiS IGonzalez Nllza

A

65 Moore Richard R A100 I]-Y~65 IPrice Paul D 65 ISchroeder K Mike

I

65 Seaman F- Ellen v~

65 iSeama_~ Eugene J _65 JSheldon yen- Jean

L

-J

~ ~J bull

RECEiVED APR 042008

jJ~1 iff ~il= P 814 -c -er 6 ~ j~1 hg iF ~j tf ( -

ofj f1 i ~- ~=J ] ~ I~ 4d i t ~

ECt b ~Lasi---- _--~ -F-irs-t-middot--MLI ___ SIGN 711~ 65 ISlattery Q IChantal jSendtoCredentiills

65 (Webster IDean I 4tU0 t iJ~

65 jWebster L I 7JJ~1Mary 6~ IWhitt Betty I ~JIr~

~

(bl G ~Cllid~ I Av+shyPRECINCT 167 i I

Pctlf-----Last~ tlt~-~~~ I First i ML i SIGN IN 67 f Burger CJ))J~ ~ Gary R~

61 iY~ung Christopher P ~ t

~

GOP RULeI GENERAL RULES FOR ALL CONVENTIONS

AND MEETINGS

Rule No1 - Adoption and Amendment of Rules Clarification These Rules having been filed with the Secretary of State ofTexas together with the stltltutes rules and bylaws adopted by reference shall constitute the Rules of the Republican Party of Texas

Rule No4 - Adoption of Reference - US 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 No5 - Parliamentary Authority Unless otherwise provided for by the United States Constitution Texas Constitution United States and Texas statutes or these Rules the current edition of Roberts Rules o(Order Ncvdv shyRelised 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 ie 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 - Chairmans 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 years 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 sect 161004 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 sect 1 efT Jan 1 1986

sect 161009 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 sect 1 eff Jan 1 1986

sect 163002 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 ch211 sect 1 eff Jan 11986

sect 163007 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 sect 1 eff Jan 1 1986

sect 174021 SELECTION OF DELEGATES TO COUNTY AND SENATORIAL DISTRICT CONVENTIONS The delegates to a political partys 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 sect I eff Jan I 1986

sect 174027 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 174025(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 sect I eff Jan 1 1986 Amended by Acts 1987 70th Leg ch 472 sect 47 eff Sept I 1987 Acts 1987 70th Leg ch 499 sect I eff Sept I 1987 Acts 1997 75th Leg ch 864 sect 179 eff Sept I 1997

sect 273061 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

sect 273063 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 sect 15(c) eff Sept 11987

14v amp u- ~~_I

_

I I~~~Z

RfeE if CtPR 04 2uaa

- - --PR~r~l~jj~~rJ h~i ~ i ]l~YilJl~~ $ T

I I ----------------------Iic~T-------Last-----L-First---iML i - _ SIGN IN

~~ IShirley IRobert bullIP I6Jcl Jt~ 04 IStephens iCarol i 64 IStruve Joe ---+-1----+I-l------yen--middotr

I I II ~I gt) ~- tU

CtQ J- -rt]~lJ--1 -i C~f1 teflS e l~fb6 --LL PRECINCT 165 I U--

L

Pet j Last First ML i SIGN INI 1 - - I

65 (Anderson Amy B I

65 IAnderson Shane D I ----- -~_- I

65 iBailes Rebecca _-+--i_--+---shy

65 IBertuzzi Caroline I

-651Sertuzzi Michael I 65 iCahill ~rf( Vanessa 65 iCheetham Gerald 65 Collins-- Mrs Bruce 65 Eigueda Maria I

RECEiVEO APR (I 4 Lu08

i~8 r =-~ 1I~ ~ C~ ~ t ~ ~ iltc ~ ~ ~ tlt9 ~ Y~j

Pet i Last First

i ML SIGN IN ~5 IFratila P - A~toniO--tiS IGonzalez Nllza

A

65 Moore Richard R A100 I]-Y~65 IPrice Paul D 65 ISchroeder K Mike

I

65 Seaman F- Ellen v~

65 iSeama_~ Eugene J _65 JSheldon yen- Jean

L

-J

~ ~J bull

RECEiVED APR 042008

jJ~1 iff ~il= P 814 -c -er 6 ~ j~1 hg iF ~j tf ( -

ofj f1 i ~- ~=J ] ~ I~ 4d i t ~

ECt b ~Lasi---- _--~ -F-irs-t-middot--MLI ___ SIGN 711~ 65 ISlattery Q IChantal jSendtoCredentiills

65 (Webster IDean I 4tU0 t iJ~

65 jWebster L I 7JJ~1Mary 6~ IWhitt Betty I ~JIr~

~

(bl G ~Cllid~ I Av+shyPRECINCT 167 i I

Pctlf-----Last~ tlt~-~~~ I First i ML i SIGN IN 67 f Burger CJ))J~ ~ Gary R~

61 iY~ung Christopher P ~ t

~

GOP RULeI GENERAL RULES FOR ALL CONVENTIONS

AND MEETINGS

Rule No1 - Adoption and Amendment of Rules Clarification These Rules having been filed with the Secretary of State ofTexas together with the stltltutes rules and bylaws adopted by reference shall constitute the Rules of the Republican Party of Texas

Rule No4 - Adoption of Reference - US 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 No5 - Parliamentary Authority Unless otherwise provided for by the United States Constitution Texas Constitution United States and Texas statutes or these Rules the current edition of Roberts Rules o(Order Ncvdv shyRelised 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 ie 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 - Chairmans 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 years 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 sect 161004 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 sect 1 efT Jan 1 1986

sect 161009 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 sect 1 eff Jan 1 1986

sect 163002 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 ch211 sect 1 eff Jan 11986

sect 163007 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 sect 1 eff Jan 1 1986

sect 174021 SELECTION OF DELEGATES TO COUNTY AND SENATORIAL DISTRICT CONVENTIONS The delegates to a political partys 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 sect I eff Jan I 1986

sect 174027 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 174025(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 sect I eff Jan 1 1986 Amended by Acts 1987 70th Leg ch 472 sect 47 eff Sept I 1987 Acts 1987 70th Leg ch 499 sect I eff Sept I 1987 Acts 1997 75th Leg ch 864 sect 179 eff Sept I 1997

sect 273061 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

sect 273063 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 sect 15(c) eff Sept 11987

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GOP RULeI GENERAL RULES FOR ALL CONVENTIONS

AND MEETINGS

Rule No1 - Adoption and Amendment of Rules Clarification These Rules having been filed with the Secretary of State ofTexas together with the stltltutes rules and bylaws adopted by reference shall constitute the Rules of the Republican Party of Texas

Rule No4 - Adoption of Reference - US 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 No5 - Parliamentary Authority Unless otherwise provided for by the United States Constitution Texas Constitution United States and Texas statutes or these Rules the current edition of Roberts Rules o(Order Ncvdv shyRelised 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 ie 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 - Chairmans 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 years 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 sect 161004 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 sect 1 efT Jan 1 1986

sect 161009 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 sect 1 eff Jan 1 1986

sect 163002 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 ch211 sect 1 eff Jan 11986

sect 163007 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 sect 1 eff Jan 1 1986

sect 174021 SELECTION OF DELEGATES TO COUNTY AND SENATORIAL DISTRICT CONVENTIONS The delegates to a political partys 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 sect I eff Jan I 1986

sect 174027 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 174025(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 sect I eff Jan 1 1986 Amended by Acts 1987 70th Leg ch 472 sect 47 eff Sept I 1987 Acts 1987 70th Leg ch 499 sect I eff Sept I 1987 Acts 1997 75th Leg ch 864 sect 179 eff Sept I 1997

sect 273061 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

sect 273063 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 sect 15(c) eff Sept 11987

RECEiVED APR 042008

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ECt b ~Lasi---- _--~ -F-irs-t-middot--MLI ___ SIGN 711~ 65 ISlattery Q IChantal jSendtoCredentiills

65 (Webster IDean I 4tU0 t iJ~

65 jWebster L I 7JJ~1Mary 6~ IWhitt Betty I ~JIr~

~

(bl G ~Cllid~ I Av+shyPRECINCT 167 i I

Pctlf-----Last~ tlt~-~~~ I First i ML i SIGN IN 67 f Burger CJ))J~ ~ Gary R~

61 iY~ung Christopher P ~ t

~

GOP RULeI GENERAL RULES FOR ALL CONVENTIONS

AND MEETINGS

Rule No1 - Adoption and Amendment of Rules Clarification These Rules having been filed with the Secretary of State ofTexas together with the stltltutes rules and bylaws adopted by reference shall constitute the Rules of the Republican Party of Texas

Rule No4 - Adoption of Reference - US 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 No5 - Parliamentary Authority Unless otherwise provided for by the United States Constitution Texas Constitution United States and Texas statutes or these Rules the current edition of Roberts Rules o(Order Ncvdv shyRelised 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 ie 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 - Chairmans 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 years 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 sect 161004 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 sect 1 efT Jan 1 1986

sect 161009 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 sect 1 eff Jan 1 1986

sect 163002 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 ch211 sect 1 eff Jan 11986

sect 163007 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 sect 1 eff Jan 1 1986

sect 174021 SELECTION OF DELEGATES TO COUNTY AND SENATORIAL DISTRICT CONVENTIONS The delegates to a political partys 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 sect I eff Jan I 1986

sect 174027 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 174025(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 sect I eff Jan 1 1986 Amended by Acts 1987 70th Leg ch 472 sect 47 eff Sept I 1987 Acts 1987 70th Leg ch 499 sect I eff Sept I 1987 Acts 1997 75th Leg ch 864 sect 179 eff Sept I 1997

sect 273061 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

sect 273063 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 sect 15(c) eff Sept 11987

GOP RULeI GENERAL RULES FOR ALL CONVENTIONS

AND MEETINGS

Rule No1 - Adoption and Amendment of Rules Clarification These Rules having been filed with the Secretary of State ofTexas together with the stltltutes rules and bylaws adopted by reference shall constitute the Rules of the Republican Party of Texas

Rule No4 - Adoption of Reference - US 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 No5 - Parliamentary Authority Unless otherwise provided for by the United States Constitution Texas Constitution United States and Texas statutes or these Rules the current edition of Roberts Rules o(Order Ncvdv shyRelised 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 ie 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 - Chairmans 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 years 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 sect 161004 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 sect 1 efT Jan 1 1986

sect 161009 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 sect 1 eff Jan 1 1986

sect 163002 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 ch211 sect 1 eff Jan 11986

sect 163007 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 sect 1 eff Jan 1 1986

sect 174021 SELECTION OF DELEGATES TO COUNTY AND SENATORIAL DISTRICT CONVENTIONS The delegates to a political partys 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 sect I eff Jan I 1986

sect 174027 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 174025(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 sect I eff Jan 1 1986 Amended by Acts 1987 70th Leg ch 472 sect 47 eff Sept I 1987 Acts 1987 70th Leg ch 499 sect I eff Sept I 1987 Acts 1997 75th Leg ch 864 sect 179 eff Sept I 1997

sect 273061 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

sect 273063 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 sect 15(c) eff Sept 11987

etec4 CMc sect 161004 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 sect 1 efT Jan 1 1986

sect 161009 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 sect 1 eff Jan 1 1986

sect 163002 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 ch211 sect 1 eff Jan 11986

sect 163007 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 sect 1 eff Jan 1 1986

sect 174021 SELECTION OF DELEGATES TO COUNTY AND SENATORIAL DISTRICT CONVENTIONS The delegates to a political partys 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 sect I eff Jan I 1986

sect 174027 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 174025(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 sect I eff Jan 1 1986 Amended by Acts 1987 70th Leg ch 472 sect 47 eff Sept I 1987 Acts 1987 70th Leg ch 499 sect I eff Sept I 1987 Acts 1997 75th Leg ch 864 sect 179 eff Sept I 1997

sect 273061 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

sect 273063 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 sect 15(c) eff Sept 11987

sect 273061 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

sect 273063 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 sect 15(c) eff Sept 11987