IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT …...Bartlit Beck Herman Palenchar & Scott LLP...

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

STATE OF TEXAS, Plaintiff, v. ERIC H. HOLDER, JR., in his official capacity as Attorney General of the United States, Defendant. ERIC KENNIE, et al., Defendant-Intervenors, TEXAS STATE CONFERENCE OF NAACP BRANCHES, et al., Defendant-Intervenors, TEXAS LEAGUE OF YOUNG VOTERS EDUCATION FUND, et al., Defendant-Intervenors. TEXAS LEGISLATIVE BLACK CAUCUS, et al., Defendant-Intervenors, VICTORIA RODRIGUEZ, et al., Defendant-Intervenors.

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CASE NO. 1:12-CV-00128 (RMC-DST-RLW) Three-Judge Court

ATTORNEY GENERAL’S MOTION TO COMPEL THE

PRODUCTION OF TES DOCUMENTS

Pursuant to Federal Rule of Civil Procedure 37, and pursuant to the briefing schedule set

out in this Court’s Order of May 21, 2012 (Doc. 128), Defendant Eric H. Holder Jr. respectfully

Case 1:12-cv-00128-RMC-DST-RLW Document 152 Filed 05/25/12 Page 1 of 5

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moves for an order compelling the production of documents that the State of Texas has

improperly withheld from discovery. For the reasons set out in the Attorney General’s

Memorandum of Points and Authorities, the State has misapplied three categories of privilege:

the state legislative privilege, the attorney-client privilege, and the deliberative process privilege.

The Attorney General therefore respectfully requests that the Court enter the attached Proposed

Order Compelling the Production of Documents.

Date: May 25, 2012 Respectfully submitted, RONALD C. MACHEN, JR. THOMAS E. PEREZ United States Attorney Assistant Attorney General District of Columbia Civil Rights Division

/s/ Daniel J. Freeman T. CHRISTIAN HERREN, JR. MEREDITH BELL-PLATTS ELIZABETH S. WESTFALL BRUCE I. GEAR JENNIFER L. MARANZANO RISA BERKOWER DANIEL J. FREEMAN Attorneys Voting Section, Civil Rights Division U.S. Department of Justice 950 Pennsylvania Avenue, N.W. Washington, D.C. 20530 (800) 253-3931


CERTIFICATE OF CONFERRAL

I hereby certify that on May 21, 2012, I met and conferred with counsel for the State of Texas in an effort to obtain the requested discovery without court intervention.

/s/ Elizabeth S. Westfall ELIZABETH S. WESTFALL U.S. Department of Justice 950 Pennsylvania Avenue, N.W. Washington, D.C. 20530 [email protected]


CERTIFICATE OF SERVICE

I hereby certify that on May 25, 2012, I served a true and correct copy of the foregoing via the Court’s ECF system on the following counsel of record:

Jonathan Franklin Mitchell Adam W. Aston Matthew Hamilton Frederick Patrick Kinney Sweeten Office of the Attorney General of Texas [email protected] [email protected] [email protected] [email protected] Adam K. Mortara John M. Hughes Bartlit Beck Herman Palenchar & Scott LLP [email protected] [email protected] Counsel for Plaintiff John Tanner [email protected] Nancy G. Abudu M. Laughlin McDonald Katie O’Connor Arthur B. Spitzer American Civil Liberties Union [email protected] [email protected] [email protected] [email protected] Counsel Texas Legislative Black Caucus Intervenors

Debo P. Adegbile Leah C. Aden Elise C. Boddie Ryan Haygood Dale E. Ho Natasha Korgaonkar NAACP Legal Defense and Education Fund [email protected] [email protected] [email protected] [email protected] [email protected] [email protected] Michael Birney de Leeuw Douglas H. Flaum Adam M. Harris Fried, Frank, Harris, Shriver & Jacobson [email protected] [email protected] [email protected] Counsel for Texas League of Young Voters Intervenors


Jon M. Greenbaum Mark A. Posner Lawyers’ Committee for Civil Rights [email protected] [email protected] Ezra David Rosenberg Michelle Hart Yeary Dechert LLP [email protected] [email protected] Robert Stephen Notzon [email protected] Gary L. Bledsoe Law Office of Gary L. Bledsoe and Associates [email protected] Myrna Perez Wendy Robin Weiser Ian Arthur Vandewalker The Brennan Center for Justice [email protected] [email protected] [email protected] Counsel for NAACP Intervenors

Nina Perales Amy Pederson Mexican American Legal Defense & Educational Fund, Inc. [email protected] [email protected] Counsel for Rodriguez Intervenors J. Gerald Hebert [email protected] Chad W. Dunn Brazil & Dunn [email protected] Counsel for Kennie Intervenors

s/ Daniel J. Freeman DANIEL J. FREEMAN Attorney, Voting Section Civil Rights Division U.S. Department of Justice 950 Pennsylvania Avenue, N.W. Washington, D.C. 20530




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MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF

THE ATTORNEY GENERAL’S MOTION TO COMPEL

The Attorney General seeks discovery concerning the State of Texas’s (“Texas” or “the

State”) claim that Texas’s photographic voter identification law, Senate Bill 14 (2011) (“SB

Case 1:12-cv-00128-RMC-DST-RLW Document 152-1 Filed 05/25/12 Page 1 of 14

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14”), “neither has the purpose nor will have the effect of denying or abridging the right to vote

on account of race or color,” or language minority status in violation of Section 5 of the Voting

Rights Act, 42 U.S.C. § 1973c. The State of Texas’s overbroad assertions of numerous

evidentiary privileges – in a manner that overlaps nearly completely with relevance to the

purpose prong of Section 5 – yet again requires the Attorney General to seek from this Court an

order compelling discovery.

I. THE ATTORNEY GENERAL IS ENTITLED TO AN ORDER COMPELLING THE PRODUCTION OF DOCUMENTS.

The instant motion addresses the two supplemental privilege logs produced by the State

in response to this Court’s May 21, 2012 order, which gave Texas an additional chance to

establish the application of privileges to documents that the State has withheld from discovery.

See Order at 6-7 (Doc. 128). The first of these privilege logs is 196 pages long and asserts the

legislative privilege, deliberative process privilege, attorney-client privilege, and attorney work

product doctrine over hundreds of documents. See Revised Privilege Log (May 23, 2012) (Ex.

1) [hereinafter OOG Log].1

1 The Attorney General does not challenge the State’s assertions of the attorney work product doctrine.

The second is 181 pages long and asserts the legislative privilege

and attorney-client privilege over an even greater number of documents. See Texas Legislative

Council Second Revised Privilege Log (May 23, 2012) (Ex. 2) [hereinafter TLC Log]. Once

again the State’s claims of legislative privilege extend far beyond the possible scope of any

recognized legislative privilege. And once again, the State asserts the attorney-client privilege

over numerous documents that do not meet the well-established prerequisites for such protection.

Finally, although the State has heeded the Court’s advice and articulated the elements of the

deliberative process privilege with regard to each document withheld on that ground, see Order


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at 3-4 (Doc. 128), this privilege is also qualified and must yield with regard to critical

documents.2

The Attorney General is entitled to an order compelling the production of testimony and

documents over which the State has improperly asserted the state legislative privilege, attorney-

client privilege, and the deliberative process privilege. “A party seeking discovery may move for

an order compelling . . . production[] or inspection . . . if a party fails to respond that inspection

will be permitted – or fails to permit inspection – as requested under Rule 34.” Fed. R. Civ. P.

37(a)(3)(B)(iv). While a party moving to compel discovery bears the initial burden to prove that

the materials sought are relevant, the burden of demonstrating facts sufficient to establish a

privilege’s applicability rests on the proponent of a privilege. See In re Subpoena Duces Tecum,

439 F.3d 740, 750 (D.C. Cir. 2006); Alexander v. FBI, 192 F.R.D. 32, 33-34 (D.D.C. 2000). The

“basis of privilege” must be “adequately established in the record,” Liberty Lobby, Inc. v. Dow

Jones & Co., Inc., 838 F.2d 1287, 1303 (D.C. Cir. 1988), through evidence sufficient to establish

the privilege “with reasonable certainty,” FTC v. TRW, Inc., 628 F.2d 207, 213 (D.C. Cir. 1980).

For the reasons that follow, the State has failed to carry its burden with regard to each of the

privileges at issue.

2 The Attorney General incorporates by reference all of the arguments against Texas’s assertions of privilege presented in opposition to the State’s motion for a protective order, see Defendant’s Response in Opposition to Plaintiff’s Motion for a Protective Order (Doc. 57); United States’ Statement in Support of Its Request to Depose and Seek Documents from State Legislators and Staff (Doc. 69), in support of the Attorney General’s resolved motion to compel, see Memorandum of Points and Authorities in Support of the Attorney General’s Motion to Compel (Doc. 93-1); Reply Memorandum in Support of the Attorney General’s Motion to Compel (Doc. 104), and in support of the Attorney General’s pending motion to compel, see Memorandum of Points and Authorities in Support of the Attorney General’s Motion to Compel (Doc. 136-1).


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II. THE STATE HAS IMPROPERLY WITHHELD DOCUMENTS IN THE CUSTODY OF THE OFFICE OF THE GOVERNOR.

The State of Texas continues to withhold hundreds of admittedly relevant documents in

the possession of the Office of the Governor on the basis of the state legislative privilege, the

attorney-client privilege, and the deliberative process privilege. The latest iteration of the Office

of the Governor’s privilege log succeeds in establishing valid privilege claims over some of these

documents. However, for the reasons that follow, Texas has misapplied some basic principles

concerning the legislative privilege and attorney-client privilege. In addition, the State’s

invocation of the deliberative process privilege must yield with regard to documents that may

contain vital evidence of a discriminatory purpose.

A. The State Cannot Assert a Legislative Privilege over Documents in the Custody of the Office of the Governor.

The State of Texas has withheld three documents in the possession of the Office of the

Governor on the basis of the state legislative privilege. See Office of the Governor Contested

Document Index at 1 (Ex. 3) [hereinafter OOG Index]. However, for the reasons explained at

length in the Attorney General’s April 25, 2012 motion to compel the production of documents

and privilege logs, documents in the possession of executive agencies cannot be subject to a

legislative privilege. See Memorandum of Points and Authorities in Support of the Attorney

General’s Motion to Compel at 9-14 (Doc. 93-1); Reply Memorandum in Support of the

Attorney General’s Motion to Compel at 7-9 (Doc. 104). Moreover, the documents at issue are

quintessential instances of legislative lobbying of the executive branch. See, e.g., OOG Log at 1

(“Letter from State Representative Betty Brown regarding actions the Governor could take to

advance the legislative enactment of a voter ID law.”). Such documents are not protected by any

form of legislative privilege. See Doe v. McMillan, 412 U.S. 306, 313 (1973) (“Members of


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Congress may frequently be in touch with and seek to influence the Executive Branch of

Government, but this conduct ‘though generally done, is not protected legislative activity.’”

(quoting Gravel v. United States, 408 U.S. 606, 625 (1972))). Therefore these documents are

subject to immediate production.

B. The State Has Not Established Requisite Elements of the Attorney-Client Privilege.

The State of Texas appears to have claimed an attorney-client privilege over every

document in the possession of the Office of the Governor where an attorney was a party to the

conversation. See OOG Log at 1-190. However it is a basic hornbook law that the mere

presence of an attorney does not place communications under the aegis of the attorney-client

privilege. See, e.g., In re Lindsey, 158 F.3d 1263, 1270 (D.C. Cir. 1998) (citing 8 John Henry

Wigmore, Evidence in Trials at Common Law § 2292, at 554 (McNaughton rev. 1961))); see

also United States v. Brown, 478 F.2d 1038, 1040 (7th Cir. 1973). Rather, a party asserting the

attorney-client privilege “must conclusively prove each element of the privilege.” In re Lindsey,

148 F.3d 1100, 1106 (D.C. Cir. 1998); see also Coastal States Gas Corp. v. Dep’t of Energy, 617

F.2d 854, 863 (D.C. Cir. 1980).

The privilege applies only if (1) the asserted holder of the privilege is or sought to become a client; (2) the person to whom the communication was made (a) is a member of the bar of a court or his subordinate and (b) in connection with this communication is acting as a lawyer; (3) the communication relates to a fact of which the attorney was informed (a) by his client (b) without the presence of strangers (c) for the purpose of securing primarily either (i) an opinion on law or (ii) legal services or (iii) assistance in some legal proceeding, and not (d) for the purpose of committing a crime or tort; and (4) the privilege has been (a) claimed and (b) not waived by the client.


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In re Sealed Case, 737 F.2d 94, 98-99 (D.C. Cir. 1984) (quoting United States v. United Shoe

Machinery Corp., 89 F. Supp. 357, 358-59 (D. Mass. 1950)).3

First and foremost, the state has yet again failed to provide an adequate description of some

documents over which it continues to assert an attorney-client privilege. A description of a

document as “Confidential communications between Governor’s Office Attorneys and staff sent

for the purpose of seeking or providing legal advice regarding Voter ID,” OOG Log at 5-6, does

no more than articulate the legal standard and the subject matter of this case. This Court has

found a similar privilege log to “fall woefully short of what is required to permit this court to

determine whether a particular privilege was properly asserted.” See Alexander v. FBI, 186

F.R.D. 102, 107 (D.D.C. 1998) Thus documents for which the State has provided insufficient

information in its privilege log should be disclosed or provided to the Court for in camera review.

See OOG Index at 1.

Critically to this case, a

government attorneys’ advice on “political, strategic, or policy issues . . . would not be shielded from

disclosure by the attorney-client privilege.” In re Lindsey, 148 F.3d 1100, 1106 (D.C. Cir. 1998) (per

curiam).

The weakness of Texas’s privilege claims is evinced by the numerous communications

between officials that each communication with an attorney is subject to the attorney-client privilege

is belied by a sampling of the privilege log. For example, the State has asserted an attorney client

privilege over communications between the Chief of Staff of the Office of the Governor – who

3 In addition, communications from an attorney to a client are shielded only if “they rest on confidential information obtained from the client.” Id. at 99 (citing Mead Data Central, Inc. v. U.S. Dep’t of Air Force, 566 F.2d 242, 254 (D.C. Cir. 1977). Finally, “when an attorney conveys to his client facts acquired from other persons or sources, those facts are not privileged.” Id. (citing Brinton v. Dep’t of State, 636 F.2d 600, 604 (D.C. Cir. 1980)). See generally In re Lindsey, 158 F.3dd 1263, 1272 (D.C. Cir. 1998) (“[T]he attorney-client privilege must be strictly confined within the narrowest possible limits consistent with the logic of its principle.” (internal citations and quotation marks omitted)).


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happens to be an attorney – and the press staff of the Office of the Governor, providing edits to drafts

of public statements. E.g., OOG Log at 157-58.4

Moreover, the State has again asserted an attorney-client privilege across different agencies

of the State. For example, the State has asserted attorneys from the Office of the Governor and the

Office of the Secretary of State share an attorney-client privilege. See OOG Log at 14. These two

offices serve independent constitutional actors who are separately elected, see Tex. Const. art. IV, §§

1-2, and Texas law provides no basis for a privileged relationship between them. Cf. Tex. Gov’t

Code § 402.021 (providing for the Attorney General to “prosecute and defend all actions in which

the state is interested before the supreme court and courts of appeals”). The mere existence of a

shared policy preference between multiple attorneys cannot create an attorney-client relationship.

Because the State of Texas did not implement a litigation hold until the filing of its complaint in

early 2012, it cannot assert a common-interest privilege before that date. See United States v.

AT&T Co., 642 F.2d 1285, 1299 (D.C. Cir. 1980) (limiting the common interest privilege to

instances in which the “transferor and transferee anticipate litigation against a common adversary

on the same issue or issues”). Therefore the State must produce all communications between the

Office of the Secretary of State and the Office of the Governor over which the State has claimed an

attorney-client privilege. See OOG Index at 1; see also Order at 7 (Doc. 128) (requiring the

Similarly, the State has claimed an attorney-client

privilege over a draft of the Governor’s 2011 State of the State speech, based on the inclusion of the

Governor’s chief of staff to the communication. See OOG Log at 10-11. In sum, Texas has not

carried its burden to establish that documents superficially labeled as legal guidance are not in fact

political, strategic, or policy advice. See OOG Index at 1.

4 Cf. In re Sealed Case, 737 F.2d 94, 99 (D.C. Cir. 1984) (“We are mindful, however, that C was a Company vice president, and had certain responsibilities outside the lawyer’s sphere.”).


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production of documents withheld on the basis of attorney-client privilege between TLC attorneys

and Secretary of State Staff).

C. Any Deliberative Process Privilege Predating the Enactment of SB 14 Must Yield.

On May 7, the Court provided the State of Texas with an additional opportunity to

establish the deliberative process privilege and set out the necessary elements of such a privilege

claim. See Order at 3-4 (Doc. 128).5

5 As noted in the memorandum in support of the May 21 motion to compel, the Attorney General respectfully disagrees with the conclusion that Section 5 is not “directed at . . . the purpose or motivation of individual actors.” Order at 3 (Doc. 128). While the ultimate inquiry in a Section 5 preclearance case is of course the purpose of the legislation at issue, under Arlington Heights, contemporaneous statements constitute a critical category of relevant circumstantial evidence. See 429 U.S. at 268. Thus the court’s inquiry in Busbee v. Smith hinged on the racially charged statements of Georgia House Redistricting Chairman Joe Mack Wilson. See 549 F. Supp. at 500. In the broader context of discrimination law, “courts often must inquire into the motives of legislators and other government actors.” Grossbaum v. Indianapolis-Marion County Bldg. Auth., 100 F.3d 1287, 1292 (7th Cir. 1996); see also id. at 1292 n.3 (noting “the inquiry that courts occasionally make into the subjective ‘intent,’ ‘motive,’ or ‘actual purpose’ of government actors” and the analytical distinction from the broader purpose inquiry). In the analogous Establishment Clause context, the Court has inferred purpose from the detailed public comments of a statute’s sponsor. See Edwards v. Aguillard, 482 U.S. 578, 586-88 (1987); see also McCreary County v. ACLU of Kentucky, 545 U.S. 844, 861-63 (2005) (describing the contours of a practical purpose inquiry). To the extent that the Court determines that the deliberative process privilege need not otherwise yield with regard to the most probative subset of documents, the Attorney General requests that the Court reconsider its order in light of these precedents.

Although Texas has now belatedly set out the elements of

the deliberative process privilege with regard to each such privilege claim, see OOG Log 1-196,

the deliberative process privilege is merely qualified and rests on, as the State itself recognizes,

“considerations of competing policy claims.” Response in Opposition to Defendant and

Defendant-Intervenors’ Motions to Compel at 5 (Doc. 148). “Each time the deliberative process

privilege is asserted the district court must undertake a fresh balancing of the competing

interests, taking into account factors such as the relevance of the evidence, the availability of

other evidence, the seriousness of the litigation, the role of the government, and the possibility of


9

future timidity by government employees.” In re Sealed Case, 121 F.3d 729, 737-38 (D.C. Cir.

1997) (internal modifications and quotation marks omitted).

In light of the qualified nature of the deliberative process privilege, this Court should

hold that the importance of disclosure outweighs the need for the privilege as to the subset of

withheld documents that relate to the Governor’s contemporaneous understanding of the purpose

and likely effect of SB 14. Not only are these contemporaneous statements highly relevant

evidence of the actual purpose of SB 14, see Reno v. Bossier Parish Sch. Bd. (Bossier Parish I),

520 U.S. 471, 489 (1997) (quoting Vill. of Arlington Heights v. Metro. Housing Dev. Corp., 429

U.S. 252, 266-68 (1977)), but they may be entirely distinct from officials’ public

pronouncements. See, e.g., Smith v. Clarkton, 682 F.2d 1055, 1064 (4th Cir. 1982) (noting that

“officials . . . seldom, if ever, announce on the record that they are pursuing a particular course of

action because of their desire to discriminate against a racial minority”). Thus expression of the

Governor’s understanding of the likely effect of SB 14 on minority voters in the context of the

deliberations is highly relevant to the purpose inquiry. Nor are these vital deliberations available to

the Attorney General in other forms. Cf. United States v. Nixon, 418 U.S. 683, 700-702 (1974)

(overcoming qualified privilege based on unavailability of recordings from any other source).

Finally, any chilling effect brought on by the disclosure of a possible purpose to reduce minority

voter turnout must be outweighed by the vital rights at issue and the seriousness of the Attorney

General’s enforcement of the Voting Rights Act. Thus the deliberative process privilege fails to

justify the further non-disclosure of these documents.


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III. THE STATE HAS IMPROPERLY WITHHELD DOCUMENTS IN THE CUSTODY OF THE TEXAS LEGISLATIVE COUNCIL.

The State of Texas also continues to withhold hundreds of admittedly relevant documents

in the possession of the Texas Legislative Council on the basis of the state legislative privilege

and attorney-client privilege. The Legislative Council’s newly produced privilege log reasserts

the attorney-client privilege claim that has been rejected by this court. See Texas v. United States

(Texas II), 279 F.R.D. 24, 34 (D.D.C. 2012), vacated after production of disputed documents,

No. 1:11-cv-1303, 2012 WL 1578390 (D.D.C. Jan. 6, 2012). Moreover, despite the Court’s prior

rebuke against the State’s invocation of legislative privilege on behalf of absent legislators, see

Order at 6 (Doc. 128), the State again asserts legislative privilege over communications with the

leading opponents of SB 14. However, for the reasons that follow, Texas has misapplied some

basic principles applicable to the legislative privilege and attorney-client privilege. In addition,

the State’s invocation of the deliberative process privilege must yield with regard to documents

that may contain vital evidence of a discriminatory purpose.

A. The Texas Legislative Council Does Not Maintain an Attorney-Client Relationship with Individual Legislators and Legislative Staff.

The State of Texas has once again asserted an attorney-client privilege over all

communications between the legal department of the Texas Legislative Council and Texas

legislators and staff. See TLC Log at 1-181; See Texas Legislative Council Contested Document

Index at 1 (Ex. 4) [hereinafter TLC Index]. As the Attorney General set out in previous briefing,

no such attorney-client relationship exists between these parties. See Memorandum of Points

and Authorities in Support of the Attorney General’s Motion to Compel at 17-21 (Doc. 93-1);

Reply Memorandum in Support of the Attorney General’s Motion to Compel at 9-14 (Doc. 104).

Although Texas has now remedied most of the fundamental flaws in its privilege logs that the


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Court had previously identified, see Order at 5 (Doc. 128), the State has not explained how an

attorney-client relationship has been established between legislators and the Legislative Council

in the absence of state statutory authorization. See Tex. Gov. Code § 323.006 (listing functions);

see also Texas II, 279 F.R.D. at 34 (“The Texas Government Code expresses no such

relationship or expectation.”). Nor has the State explained whether attorneys employed by the

Texas Legislative Council provide anything more than “neutral, objective analysis” of the

legality of proposed actions. See Tax Analysts v. IRS, 117 F.3d 607, 619 (D.C. Cir. 1997); see

also Coastal States Gas, 617 F.2d at 863 (distinguishing governmental inquiries into legal

principles or the legality of potential state action from a “private party seeking advice to protect

personal interests”). Finally, even if an attorney-client relationship attaches to communications

between individual legislators and the Legislative Council, logically waiver must occur if

Council attorneys share legal advice among multiple legislators. See, e.g., TLC Log at 60.6

B. The State of Texas Cannot Assert a Legislative Privilege Belonging Solely to Legislators.

In its May 21 Order, the Court directed the State to produce “all documents withheld on the

basis of legislative privilege where . . . . the specific legislators identified have not asserted a

legislative privilege.” Order at 6 (Doc. 128). Two days later, the State produced a privilege log

asserting legislative privilege on behalf of opponents of SB 14, such as Representative Roberto

Alonzo. See TLC Log at 48-51, 53, 55, 94, 118-119, 128, 158; see also Waivers (Doc. 136-18)

6 The possibility of waiver also raises the concern that varying and often opposing alignments of legislative interest among different legislators would create an untenable ethical conflict for an attorney if he or she were to form individual attorney-client relationships with each and every member of the Texas Legislator. Cf. Tex. Disciplinary R. of Prof’l Conduct 1.06, cmt. 16 (noting that representation of both a board and individual directors may create a “material risk that the dual role will compromise the lawyer’s independence of professional judgment”). This further weighs against recognition of an attorney-client privilege.


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(expressly waiving privilege). The right to assert a legislative privilege belongs solely to legislators.

See Gravel, 408 U.S. at 621-22 & n.13; Miller v. Transamerican Press, Inc., 709 F.2d 524, 530 (9th

Cir. 1983) (citing Gravel, 408 U.S. at 616-19). Nevertheless, the State of Texas appears to have

appropriated this power to the Office of the Attorney General with regard to legislators who had not

communicated waiver directly to the State. The State has no basis to continue to withhold documents

reflecting communications with legislators who expressly waived legislative privilege, along with

those who have not expressly asserted the privilege. See TLC Index at 1.

C. Any Legislative Privilege Concerning the Drafting of SB 14 Must Yield.

The State of Texas has also asserted a state legislative privilege over nearly the full range

of responsive documents in the possession of the Texas Legislative Council. See TLC Log at 1-8

(setting out consecutive bates ranges). The Attorney General does not dispute that these TLC

documents reflect “legislative acts” subject to the state legislative privilege recognized by this

Court. However the Supreme Court has held that this privilege is merely qualified, see United

States v. Gillock, 445 U.S. 360, 368-69 (1980), and numerous district courts have followed this

command to apply multifactor balancing tests. See Comm. for a Fair & Balanced Map v. Ill. State

Bd. of Elections, No. 11 C 5065, 2011 WL 4837508, at *7 (N.D. Ill. Oct. 12, 2011); Rodriguez v.

Pataki, 280 F. Supp. 2d 89, 100-01 (S.D.N.Y. 2003), aff’d, 293 F. Supp. 2d 302 (S.D.N.Y. 2003);

United States v. Irvin, 127 F.R.D. 169, 173 (C.D. Cal. 1989); Baldus v. Members of the Wis. Gov’t

Accountability Bd., No. 11-cv-562, 2011 WL 6122542, at *2 (E.D. Wis. Dec. 8, 2011) (three-judge

court). Moreover, any language in Arlington Heights concerning state legislative privilege is

limited to “[p]lacing a decisionmaker on the stand”; even this dicta does not require

“extraordinary circumstances” to require the production of otherwise discoverable documents.

See 429 U.S. at 268.


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For the reasons set out in the Attorney General’s May 21 motion to compel, any state

legislative privilege should yield in this extraordinary litigation. See Memorandum of Points and

Authorities in Support of the Attorney General’s Motion to Compel at 10-26 (Doc. 136-1).

However one category of documents in the possession of the Texas Legislative Council is

particularly probative of legislative purpose: drafting files concerning the bill itself. See TLC

Index at 1-2. As Texas legislators and staff have explained, legislators often provide the purpose

and rough contours of legislative proposals to the Legislative Council, which then provides

technical bill-drafting support. See Beuck Dep. at 50:11-23, May 14, 2012 (Doc. 136-3); Harless

Dep. at 61:10-13, May 15, 2012 (Doc. 136-5). Thus instructions to the Texas Legislative

Council and related inquiries are highly probative of the purpose of legislation, rather than

legislators’ mental impressions. With respect to this limited universe of documents, the factors

used to assess a qualified privilege overwhelming favor disclosure.

IV. CONCLUSION

For the reasons set out above, this Court should grant the Attorney General’s motion to

compel the production of documents and enter the proposed order attached to the instant motion.


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Date: May 25, 2012 Respectfully submitted, RONALD C. MACHEN, JR. THOMAS E. PEREZ United States Attorney Assistant Attorney General District of Columbia Civil Rights Division

/s/ Daniel J. Freeman T. CHRISTIAN HERREN, JR. MEREDITH BELL-PLATTS ELIZABETH S. WESTFALL BRUCE I. GEAR JENNIFER L. MARANZANO RISA BERKOWER DANIEL J. FREEMAN Attorneys Voting Section, Civil Rights Division U.S. Department of Justice 950 Pennsylvania Avenue, N.W. Washington, D.C. 20530




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[PROPOSED] ORDER COMPELLING THE

PRODUCTION OF DOCUMENTS

Upon consideration of the Attorney General’s motion to compel the production of

testimony and documents (Doc. __), the State of Texas’s response thereto (Doc. ___), and the


Attorney General’s reply in further support (Doc. __), it is hereby ORDERED that:

1. The Attorney General’s motion to compel is GRANTED.

2. The State of Texas shall produce all relevant documents in the possession of the Texas

Legislative Council within two days of the date of this order.

3. The State of Texas shall produce within two days of the date of this order, all relevant

documents in the possession of the Office of the Governor not subject to a valid assertion

of the attorney-client privilege, as set out in Exhibit 3 to Attorney General’s Motion to

Compel (Doc. __-__).

SO ORDERED. Date: June ____, 2012

___________________________ DAVID S. TATEL United States Circuit Judge ___________________________ ROSEMARY M. COLLYER United States District Judge ___________________________ ROBERT L. WILKINS United States District Judge


State of Texas v. Eric Holder, Jr., Attorney General of the United States Case No. 1:12-cv-00128

United States District Court for the District of Columbia

REVISED PRIVILEGE LOG May 23, 2012

Beginning Document

End Document Recipient Sender/Author Issues Attynotes Date Sources

TX_00034902

TX_00034902

Governor Rick Perry

Representative Betty Brown

Legislative Privilege

Letter from State Representative Betty Brown regarding actions the Governor could take to advance the legislative enactment of a voter ID law. 6/18/2009

GOVERNOR PART 2

TX_00037744

TX_00037744

Governor Rick Perry

Rep. Doug Miller


Letter from State representative Doug Miller to Governor Perry regarding actions the Governor could take to advance the legislative enactment of a voter ID law. 6/26/2009

GOVERNOR PART 2

TX_00038291

TX_00038291

Beverley Wooley Rick Perry


Letter from Representative Beverley Wooley to Governor Rick Perry regarding actions that Governor Perry could take to advance the enactment of the 2009 voter ID bill. 6/15/2009

GOVERNOR PART 2

TX_00057287

TX_00057288

Governor Perry Greg Davidson

DNP - ATTY CLIENT;DELIBERATIVE PROCESS

Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 82nd Legislature. This document consists of 5/18/2011

GOVERNOR PART 3


1


PRIVILEGE

an in-depth analysis of SB 14. The document contains the advice, opinion, and recommendations of the author regarding legislation addressing economic development. The document was created to assist the Governor and his staff in deciding whether to support or oppose SB14. The Governor personally reviewed this document. Ultimately, the document was used to advise the Governor on whether to sign or veto SB 14. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor taff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00057289

TX_00057289 Jeff Boyd David Morales

DNP - ATTY CLIENT

Confidential e-mail from Governor's General Counsel to Governor's Chief of Staff sent for purposes of providing legal advice regarding SB 14 preclearance. 9/23/2011

GOVERNOR PART 3

TX_00057290

TX_00057290 Jeff Boyd David Morales

DNP - ATTY CLIENT

Attachment to above confidential attorney-client copmmunication (TX_00057289) sent for purposes of providing legal advice regardign SB 14 preclearance 9/23/2011

GOVERNOR PART 3

TX_00057 TX_00057 Jeff Boyd David Morales DNP - Attachment to above confidential 9/23/2011 GOVERN


2


291 293 ATTY CLIENT

attorney-client copmmunication (TX_00057289) sent for purposes of providing legal advice regardign SB 14 preclearance

OR PART 3

TX_00057294

TX_00057308

General Counsel~Budget Planning and Policy~Executive

General Counsel's Office

DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE

Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 79th Legislature.~~This document consists of bill summaries and bill tracking of bills from the 79th legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the 00/00/2005

GOVERNOR PART 3


3


document cannot be produced in a redacted form without disclosing privileged information.

TX_00057309

TX_00057309

Coby Shorter~Jimmy Blacklock~Daniel Hodge~Ken Armbrister Jeff Boyd

DNP - ATTY CLIENT

Confidential e-mail from Governor's Chief of Staff to Secretary of State Director, OAG Attorneys, and Governor's staff sent for purposes of seeking legal advice regarding SB 14 preclearance submission 1/12/2012

GOVERNOR PART 3

TX_00057310

TX_00057319

Coby Shorter~Jimmy Blacklock~Daniel Hodge~Ken Armbrister Jeff Boyd

DNP - ATTY CLIENT

Attachment to above confidential attorney-client communication (TX_00057309) sent for purpose of seeking legal advice regarding SB 14 preclearance submission 1/12/2012

GOVERNOR PART 3

TX_00057320

TX_00057320

Jeff Boyd~Blaine Brunsen Daniel Hodge

DNP - ATTY CLIENT

Confidential communications from OAG First Assistant Attorney General to Governor Chief of Staff and Lt. Governor Chief of Staff sent for the purposes of providing legal advice regarding Voter ID 12/23/2011

GOVERNOR PART 3

TX_00057321

TX_00057321

Press Office~Jeff Boyd~Matthew Thompson~Konathan Hurst~Ken Armbrister~Mike Allison Castle

DNP - DELIBERATIVE PROCESS PRIVILEGE;DNP - ATTY CLIENT

Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 82nd Legislature.~~This document transmits a draft press release regarding bills from the 82nd legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding 8/31/2011

GOVERNOR PART 3


4


Morrissey certain legislation. Jeff Boyd is an attorney recipient of the document. The document was created to assist the Governor in formulating a policy announcement on legislation from the 82nd legislature. Ultimately, the document was used to advise the Governor on his decision on which policy positions the Governor should take. The document is a draft and was created prior to a final decision by the Governor on a policy statement. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00057322

TX_00057323

Press Office~Jeff Boyd~Matthew Thompson~Konathan Hurst~Ken Armbrister~Mike Morrissey Allison Castle


Draft press release attachment to above privileged communication (TX_00057322) and privileged for the same reasons as the email to which it was attached. 8/31/2011

GOVERNOR PART 3

TX_00057324

TX_00057324

Jeff Boyd, Marty Brandy Colin Parish

DNP - ATTY CLIENT

Confidential communications between Governor's Office Attorneys and staff sent for the purpose of seeking or 5/6/2011

GOVERNOR PART 3


5


providing legal advice regarding Voter ID

TX_00057325

TX_00057356

Jeff Boyd, David Morales, Stacy Napier,~David, Schenck,~Jimmy Blacklock, Jonathan Mitchell,~Michael Schofield, Daniel Hodge,Ken Armbrister, Sarah Floerke, David Eichler, Ray Sullivan,~Brandy Marty, Mike Vitris,~Press Office, EBM_Cooridnators, Senior Staff, BPP 4th, General Counsel,

Daniel Hodge, David Morales,~Jeff Boyd,~ Stacy Napier~Colin Parrish,~BPP Advisors,~GC Lawyers, Gregg Davidson,


Confidential communication between Governor Office Attorneys and Staff sent for purposes of seeking or providing legal advice regarding Voter ID.~~This document contains and solicits legal advice on the constitutionality of Section 5. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor in formulating a policy on bills in 82nd legislature that might trigger a preclearance obligation under Section 5. Ultimately, the document was used to advise the Governor on whether to support or oppose certain legislation. The document was created prior to a final decision by the Governor whether to support or oppose legislation that might require preclearance. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information. 3/21/2011

GOVERNOR PART 3


6


ATLAS Analysts, Legislative, Blake Bell, Logan Jack

TX_00057357

TX_00057358

Jonathan Hurst~Press Office~Jeff Boyd~Ken Armbrister~Mike Morrissey Steffany Duke


Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 82nd Legislature.~~This document transmits a draft press release regarding bills from the 82nd legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. Jeff Boyd is an attorney recipient of the document. The document was created to assist the Governor in formulating a policy announcement on legislation from the 82nd legislature. Ultimately, the document was used to advise the Governor on his decision on which policy positions the Governor should take. The document is a draft and was created prior to a final decision by the Governoron a policy statement. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the 8/30/2011

GOVERNOR PART 3


7


public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00057359

TX_00057360



Draft press release attachment to above confidential attorney-client, deliberative process privileged communication (TX_00057357), and privileged for the same reasons. 8/31/2011

GOVERNOR PART 3

TX_00057361

TX_00057362

Lucy Nashed~Batherine Frazier~Jeff Boyd~Matthew Thompson~Jonathan Hurst~Press Office~Ken Armbrister~Mike Morrissey~Kethy Walt Steffany Duke


Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 82nd Legislature.~~This document transmits a draft press release regarding bills from the 82nd legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. Jeff Boyd is an attorney recipient of the document. The document was created to assist the Governor in formulating a policy announcement on legislation from the 82nd legislature. Ultimately, the document was used to advise the Governor on his decision on which policy positions the Governor should take. The document is a draft and was created prior to a final decision by the Governoron a policy statement. As such, the document does not memorialize or 8/31/2011

GOVERNOR PART 3


8


evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00057363

TX_00057364

Lucy Nashed~Batherine Frazier~Jeff Boyd~Matthew Thompson~Jonathan Hurst~Press Office~Ken Armbrister~Mike Morrissey~Kethy Walt Steffany Duke


Draft press release attachment to above attorney-client, deliberative process privileged communication (TX_00057362) and privileged for the same reasons as the email attaching it. 8/31/2011

GOVERNOR PART 3

TX_00057365

TX_00057366

Press Office~Jonathan hurst~Jeff Boyd~Ken Armbrister~Mike Morrissey Steffany Duke


Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 82nd Legislature.~~This document transmits a draft press release regarding bills from the 82nd legislative session that were deemed important by the Governor's policy advisers. The document contains 8/30/2011

GOVERNOR PART 3


9


the advice, opinion, and recommendations of the author regarding certain legislation. Jeff Boyd is an attorney recipient of the document. The document was created to assist the Governor in formulating a policy announcement on legislation from the 82nd legislature. Ultimately, the document was used to advise the Governor on his decision on which policy positions the Governor should take. The document is a draft and was created prior to a final decision by the Governoron a policy statement. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00057367

TX_00057368

Press Office~Jonathan hurst~Jeff Boyd~Ken Armbrister~Mike Morrissey Steffany Duke


Draft press release attachment to above confidential attorney-client, deliberative process privileged document (TX_00057365) and privileged for the same reasons as the email to which it is attached. 8/30/2011

GOVERNOR PART 3

TX_00057369

TX_00057414

Lisa Ried, Jeff Boyd, ~Press Offfice,

Andrew Barlow

DNP - ATTY CLIENT;DNP -

Confidential communication between Governor Office Attorneys and Staff sent for purposes of seeking or providing legal advice regarding Voter ID and numerous 2/7/2011

GOVERNOR PART 3


10


Ray Sullivan, Rob Johnson, Marty Brandy, Ken Armbrister, Mike Morrissey

DELIBERATIVE PROCESS PRIVILEGE

other laws and policy initiatives.~~This document transmits a draft State of the State" speech discussing numerous issues that were deemed important by the Governor's policy advisers, including Voter ID. The document contains the advice, opinion, and recommendations of the author regarding numerous pieces of legislation and various policy statements. Jeff Boyd is an attorney recipient of the document. The document was created to assist the Governor in formulating a policy announcement on legislation from the 82nd legislature. Ultimately, the document was used to advise the Governor on his decision on which policy positions the Governor should take. The document is a draft and was created prior to a final decision by the Governor on which policy statement he would publicly adopt. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information."

TX_00057415

TX_00057415

Allison Castle~Stephanie Duke~Jonathan Hurst~Kathy Walt Jeff Boyd

DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS

Confidential communication between Governor Office Attorneys and Staff sent for purposes of seeking or providing legal advice regarding Voter ID and several other bills from the 82nd legislative session.~~This document edits a draft press release regarding bills from the 8/30/2011

GOVERNOR PART 3


11


PRIVILEGE

82nd legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. Jeff Boyd is an attorney recipient of the document. The document was created to assist the Governor in formulating a policy announcement on legislation from the 82nd legislature. Ultimately, the document was used to advise the Governor on his decision on which policy positions the Governor should take. The document is a draft and was created prior to a final decision by the Governoro n a policy statement. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00057416

TX_00057417

Allison Castle~Stephanie Duke~Jonathan Hurst~Kathy Walt Jeff Boyd


Attachment to above confidential attorney-client, deliberative process privileged document (TX_00057415) and privileged for the same reasons as the email to which it is attached. 8/30/2011

GOVERNOR PART 3

TX_00057418

TX_00057450 Jeff Boyd Colin Parrish

DNP - DELIBERA

Confidential email communication and attachments involving Governor's 5/6/2011

GOVERNOR PART


12


TIVE PROCESS PRIVILEGE;DNP - ATTY CLIENT

General Counsel and Governor's Staff sent for purposes of providing legal advice regarding SB 14.~~This document transmits committee reports and other materials on SB 14 that were deemed important by the Governor's policy and advisers. The document reflects the advice, opinion, and recommendations of the author regarding certain legislation. Jeff Boyd is an attorney recipient of the document. The document was created to assist the Governor in deciding whether to support or oppose voter ID. Ultimately, the document was used to advise the Governor on his decision on which policy positions the Governor should take. The document was created prior to a final decision by the Governoron a policy statement. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

3

TX_00057451

TX_00057455

Jeff Boyd, Brandy Marty, Colin Parish Amando Saenz

Colin Parrish~Amando Saenz


Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of giving or receiving legal advice regarding SB 14.~~This document is an email string among Governor Staff and Governor Counsel sent for the purpose of collecting information about SB 14. The document contains the advice, opinion, 3/30/2011

GOVERNOR PART 3


13


and recommendations of the author regarding whom the Governor should contact and consult regarding SB 14. Jeff Boyd is an attorney recipient and author of several emails in the email string. The document was created to assist the Governor in deciding whether to veto or sign SB 14. Ultimately, the document was used to advise the Governor on his decision on whether to veto or sign SB 14. The document was created prior to a final decision by the Governor on whether to sign or veto SB 14. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00057456

TX_00057475

Travis Richmond Jeff Boyd John Sepehri AnnMcGeehan Erik Wilson Paul Miles Elizabeth Winn

John Sepehri~Elizabeth Winn

DNP - ATTY CLIENT

Confidential communication between Governor Office Attorneys and SOS General Counsel sent for purposes of seeking or providing legal advice regarding SB 14 preclearance submission 7/22/2011

GOVERNOR PART 3

TX_00057476

TX_00057511

Travis Richmond Jeff Boyd

John Sepehri~Ann McGeehan

DNP - ATTY CLIENT

Confidential communication between Governor Office Attorneys, SOS General Counsel, and OAG Attorneys sent for 7/26/2011

GOVERNOR PART 3


14


John Sepehri Erik Wilson Paul Miles Elizabeth Winn Jay Dyer~Jimmy Blacklock David Schenck Stacy Napier Reed Clay

purposes of seeking or providing legal advice regarding SB 14 preclearance submission

TX_00057512

TX_00057518

Jeff Boyd ~David Morales

Jay Dyer~David Morales

DNP - ATTY CLIENT

Confidential communication between Governor Office Attorneys and Staff sent for purposes of seeking or providing legal advice regarding Voter ID, containing advice, opinions, and deliberations that precede a final decision relating to voter ID implementation 9/23/2011

GOVERNOR PART 3

TX_00057519

TX_00057537

Jeff Boyd~Travis Richmondf~Jay Dyer~John Sepehri

John Sepehri~Jimmy Blacklock

DNP - ATTY CLIENT

Confidential communication among OAG Attorneys, SOS General Counsel, Governor Office Attorneys and Staff sent for purposes of seeking or providing legal advice regarding Voter ID. 7/20/2011

GOVERNOR PART 3

TX_00057538

TX_00057539 Jeff Boyd Colin Parrish


Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of giving or receiving legal advice regarding SB 14.~~This document is an email string among Governor Staff and Governor Counsel sent for the purpose of 5/13/2011

GOVERNOR PART 3


15


PRIVILEGE

collecting information about SB 14. The document contains the advice, opinion, and recommendations of the author regarding whom the Governor should contact and consult regarding SB 14. Jeff Boyd is an attorney recipient of emails in the email string. The document was created to assist the Governor in deciding whether to veto or sign SB 14. Ultimately, the document was used to advise the Governor on his decision on whether to veto or sign SB 14. The document was created prior to a final decision by the Governor on whether to sign or veto SB 14. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00057540

TX_00057546 Jeff Boyd Lisa Reid

DNP - ATTY CLIENT

Confidential communication between Governor Office Attorneys and Staff sent for purposes of seeking or providing legal advice regarding Voter ID 9/2/2011

GOVERNOR PART 3

TX_00057547

TX_00057562

Ann McGeehan,~Elizabeth Winn~Erik Wilson~Esperanza Andrade~ John Sepehri

DNP - ATTY CLIENT

Confidential communications between Governor Office Attorneys and Staff sent for purposes of seeking or providing legal advice. 7/22/2011

GOVERNOR PART 3


16


Coby Shorter~Jeff Boyd~Travis Richmond

TX_00057563

TX_00057564 Jeff Boyd Lisa Ried

DNP - ATTY CLIENT

Confidential communication between Governor Office Attorney and Staff sent for purposes of seeking or providing legal advice regarding Voter ID 5/6/2011

GOVERNOR PART 3

TX_00057565

TX_00057566

Lucy Nashed~Jeff Boyd~Mary Anne Wiley~Kathy Wall~Josh Havens~Matthew Thompson~Ken Armbrister~Jonathan Hurst~Steffany Duke Allison Castle


Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of giving or receiving legal advice regarding SB 14.~~This document is an email string among Governor Staff and Governor Counsel sent for the purpose of responding to media inquiries about SB 14. The document contains the advice, opinion, and recommendations of the author regarding the public policy positions that the Governor would adopt on SB 14. Jeff Boyd is an attorney recipient. The document was created to assist the Governor in deciding whether which public positions, if any, he would take on SB 14. Ultimately, the document was used to advise the Governor on his decision on policy positions relating to SB 14. The document was created prior to a final decision by the Governor on which public policy positions he should take as to SB 14. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. 9/14/2011

GOVERNOR PART 3


17


The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00057567

TX_00057568

Steffany Duke~Press Office~Jeff Boyd~Ken Armbrister~Mike Morrissey

Jonathan Hurst


Confidential communication between Governor Office Attorneys and Staff sent for purposes of seeking or providing legal advice regarding Voter ID and several other bills from the 82nd legislative session.~~This document edits a draft press release regarding bills from the 82nd legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. Jeff Boyd is an attorney recipient of the document. The document was created to assist the Governor in formulating a policy announcement on legislation from the 82nd legislature. Ultimately, the document was used to advise the Governor on his decision on which policy positions the Governor should take. The document is a draft and was created prior to a final decision by the Governoro n a policy statement. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information. 8/30/2011

GOVERNOR PART 3


18


TX_00057569

TX_00057570


DNP - ATTY CLIENT;DNP - WORK PRODUCT

Confidential communications between Governor Office Attorneys and Staff sent for purposes of seeking or providing legal advice regarding Voter ID, containing advice, opinions, and deliberations that precede a final decision relating to voter ID implementation 8/31/2011

GOVERNOR PART 3

TX_00057571

TX_00057572

Steffany Duke~Lucy Nashed~Catherine Frazier~Jeff Boyd~Jonathan Hurst~Press Office~Ken Armbrister~Mike Morrissey~Kathy Walt

Matthew Thompson


Confidential communication between Governor Office Attorneys and Staff sent for purposes of seeking or providing legal advice regarding Voter ID and several other bills from the 82nd legislative session.~~This document edits a draft press release regarding bills from the 82nd legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. Jeff Boyd is an attorney recipient of the document. The document was created to assist the Governor in formulating a policy announcement on legislation from the 82nd legislature. Ultimately, the document was used to advise the Governor on his decision on which policy positions the Governor should take. The document is a draft and was created prior to a final decision by the Governoro n a policy statement. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor 8/31/2011

GOVERNOR PART 3


19


staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00057573

TX_00057574

Steffany Duke~Lucy Nashed~Catherine Frazier~Jeff Boyd~Jonathan Hurst~Press Office~Ken Armbrister~Mike Morrissey~Kathy Walt

Matthew Thompson



GOVERNOR PART 3

TX_00057575

TX_00057577

Jeff Boyd~Steffany Duke~Matthew Thompson~Jonathan Hurst~Press Office~Ken Armbrister~Mike

Catherine Frazier


Confidential communication between Governor Office Attorneys and Staff sent for purposes of seeking or providing legal advice regarding Voter ID and several other bills from the 82nd legislative session.~~This document edits a draft press release regarding bills from the 82nd legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. Jeff Boyd is an attorney recipient of the document. The 8/31/2011

GOVERNOR PART 3


20


Morrissey~Kathy Walt

document was created to assist the Governor in formulating a policy announcement on legislation from the 82nd legislature. Ultimately, the document was used to advise the Governor on his decision on which policy positions the Governor should take. The document is a draft and was created prior to a final decision by the Governoro n a policy statement. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00057578

TX_00057579

Jeff Boyd~Steffany Duke~Matthew Thompson~Jonathan Hurst~Press Office~Ken Armbrister~Mike Morrissey~Kathy Walt

Catherine Frazier

DNP - DELIBERATIVE PROCESS PRIVILEGE


GOVERNOR PART 3

TX_00057 TX_00057 Catherine Lucy Nached DNP - Confidential communication between 8/31/2011 GOVERN


21


580 582 Frazier~Jeff Boyd~Steffany Duke~Matthew Thompson~Jonathan Hurst~Press Office~Ken Armbrister~Mike Morrisey~Kathy Walt

ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE

Governor Office Attorneys and Staff sent for purposes of seeking or providing legal advice regarding Voter ID and several other bills from the 82nd legislative session.~~This document edits a draft press release regarding bills from the 82nd legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. Jeff Boyd is an attorney recipient of the document. The document was created to assist the Governor in formulating a policy announcement on legislation from the 82nd legislature. Ultimately, the document was used to advise the Governor on his decision on which policy positions the Governor should take. The document is a draft and was created prior to a final decision by the Governoro n a policy statement. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

OR PART 3

TX_00057583

TX_00057584

Catherine Frazier~Jeff Boyd~Steffany Lucy Nached

DNP - DELIBERATIVE PROCESS PRIVILEG

Draft press release attachment to above confidential attorney-client, deliberative process privileged document (TX_00057580) and privileged for the same reason as the email to which it is 8/31/2011

GOVERNOR PART 3


22


Duke~Matthew Thompson~Jonathan Hurst~Press Office~Ken Armbrister~Mike Morrisey~Kathy Walt

E;DNP - ATTY CLIENT

attached.

TX_00057585

TX_00057587

Steffany Duke~Matthew Thompson~Jonathan Hurst~Press Office~Ken Armbrister~Mike Morrissey Jeff Boyd


Confidential communication between Governor Office Attorneys and Staff sent for purposes of seeking or providing legal advice regarding Voter ID and several other bills from the 82nd legislative session.~~This document edits a draft press release regarding bills from the 82nd legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. Jeff Boyd is an attorney author of the document. The document was created to assist the Governor in formulating a policy announcement on legislation from the 82nd legislature. Ultimately, the document was used to advise the Governor on his decision on which policy positions the Governor should take. The document is a draft and was created prior to a final decision by the Governor on a policy statement. As such, the 8/31/2011

GOVERNOR PART 3


23


document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00057588

TX_00057589

Steffany Duke~Matthew Thompson~Jonathan Hurst~Press Office~Ken Armbrister~Mike Morrissey Jeff Boyd


Draft press release attachment to above confidential attorney-client, deliberative process privileged documents (TX_00057585) and privileged for the same reasons as the email to which it was originally attached. 8/31/2011

GOVERNOR PART 3

TX_00057590

TX_00057591

Matthew Thompson~Steffany Duke~Press Office~Jeff Boyd~Ken Armbrister~Mike Morrissey

Jonathan Hurst


Confidential communication between Governor Office Attorneys and Staff sent for purposes of seeking or providing legal advice regarding Voter ID and several other bills from the 82nd legislative session.~~This document edits a draft press release regarding bills from the 82nd legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. Jeff Boyd is an attorney recipient of the document. The document was created to assist the 8/30/2011

GOVERNOR PART 3


24


Governor in formulating a policy announcement on legislation from the 82nd legislature. Ultimately, the document was used to advise the Governor on his decision on which policy positions the Governor should take. The document is a draft and was created prior to a final decision by the Governoro n a policy statement. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00057592

TX_00057593

Matthew Thompson~Jonathan Hurst~Press Office~Jeff Boyd~Ken Armbrister~Mike Morrissey Steffany Duke


Confidential communication between Governor Office Attorneys and Staff sent for purposes of seeking or providing legal advice regarding Voter ID and several other bills from the 82nd legislative session.~~This document edits a draft press release regarding bills from the 82nd legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. Jeff Boyd is an attorney recipient of the document. The document was created to assist the Governor in formulating a policy announcement on legislation from the 82nd legislature. Ultimately, the document was used to advise the 8/30/2011

GOVERNOR PART 3


25


Governor on his decision on which policy positions the Governor should take. The document is a draft and was created prior to a final decision by the Governoro n a policy statement. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00057594

TX_00057595

Jonathan Hurst~Steffany Duke~Press Office~Jeff Boyd~Ken Armbrister

Matthew Thompson


Confidential communication between Governor Office Attorneys and Staff sent for purposes of seeking or providing legal advice regarding Voter ID and several other bills from the 82nd legislative session.~~This document edits a draft press release regarding bills from the 82nd legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. Jeff Boyd is an attorney recipient of the document. The document was created to assist the Governor in formulating a policy announcement on legislation from the 82nd legislature. Ultimately, the document was used to advise the Governor on his decision on which policy positions the Governor should take. The document is a draft and was created prior to a final decision by the Governoro 8/30/2011

GOVERNOR PART 3


26


n a policy statement. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00057596

TX_00057597

Steffany Duke~Press Office~Jeff Boyd~Ken Armbrister~Mike Morrissey

Jonathan Hurst


Confidential communication between Governor Office Attorneys and Staff sent for purposes of seeking or providing legal advice regarding Voter ID and several other bills from the 82nd legislative session.~~This document edits a draft press release regarding bills from the 82nd legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. Jeff Boyd is an attorney recipient of the document. The document was created to assist the Governor in formulating a policy announcement on legislation from the 82nd legislature. Ultimately, the document was used to advise the Governor on his decision on which policy positions the Governor should take. The document is a draft and was created prior to a final decision by the Governoro n a policy statement. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed 8/30/2011

GOVERNOR PART 3


27


and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00057598

TX_00057599

Lucy Nashed~Catherine Frazier~Jeff Boyd~Matthew Thompson~Jonathan Hurst~Press Office~Ken Armbrister~Mike Morrissey~Kathy Walt Steffany Duke


Confidential communication between Governor Office Attorneys and Staff sent for purposes of seeking or providing legal advice regarding Voter ID and several other bills from the 82nd legislative session.~~This document edits a draft press release regarding bills from the 82nd legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. Jeff Boyd is an attorney recipient of the document. The document was created to assist the Governor in formulating a policy announcement on legislation from the 82nd legislature. Ultimately, the document was used to advise the Governor on his decision on which policy positions the Governor should take. The document is a draft and was created prior to a final decision by the Governoro n a policy statement. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the 8/31/2011

GOVERNOR PART 3


28



TX_00057600

TX_00057601

Lucy Nashed~Catherine Frazier~Jeff Boyd~Matthew Thompson~Jonathan Hurst~Press Office~Ken Armbrister~Mike Morrissey~Kathy Walt Steffany Duke


Draft press release attachment to above confidential attorney-client, deliberative process privileged documents (TX_00057598) and privileged for the same reasons as the original email to which it is attached. 8/31/2011

GOVERNOR PART 3

TX_00057602

TX_00057603

Allison Castle~Lucy Nashed~Mary Anne Wiley~Kathy Walt~Josh Havens~Matthew Thompson~Ken Armbrister~Jonat Jeff Boyd


Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of giving or receiving legal advice regarding SB 14.~~This document is an email string among Governor Staff and Governor Counsel sent for the purpose of responding to media inquiries about SB 14. The document contains the advice, opinion, and recommendations of the author regarding the public policy positions that the Governor would adopt on SB 14. Jeff Boyd is an attorney author and recipient of emails in this email string. The document was created to assist the Governor in deciding 9/14/2011

GOVERNOR PART 3


29


hen Hurst~Steffany Duke

whether which public positions, if any, he would take on SB 14. Ultimately, the document was used to advise the Governor on his decision on policy positions relating to SB 14. The document was created prior to a final decision by the Governor on which public policy positions he should take as to SB 14. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00057604

TX_00057605

Allison Castle~Lucy Nashed~Mary Anne Wiley~Kathy Walt~Josh Havens~Matthew Thompson~Ken Armbrister~Jonathen Hurst~Steffany Duke

Jonathan Hurst~Allison Castle


Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of giving or receiving legal advice regarding SB 14.~~This document is an email string among Governor Staff and Governor Counsel sent for the purpose of responding to media inquiries about SB 14. The document contains the advice, opinion, and recommendations of the author regarding the public policy positions that the Governor would adopt on SB 14. Jeff Boyd is an attorney recipient of emails in the email string. The document was created to assist the Governor in deciding whether which public positions, if any, he would take on SB 14. Ultimately, the document was used to advise the Governor on his decision on policy positions relating to SB 9/14/2011

GOVERNOR PART 3


30


14. The document was created prior to a final decision by the Governor on which public policy positions he should take as to SB 14. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00057606

TX_00057607

Becky Dean~Lucy Nashed~Allison Castle~Jeff Boyd~Press Office~Mary Anne Wiley Steffany Duke


Confidential communication between Governor Office Attorneys and Staff sent for purposes of seeking or providing legal advice regarding Voter ID and several other bills from the 82nd legislative session.~~This document edits a draft press release regarding bills from the 82nd legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. Jeff Boyd is an attorney recipient of the document. The document was created to assist the Governor in formulating a policy announcement on legislation from the 82nd legislature. Ultimately, the document was used to advise the Governor on his decision on which policy positions the Governor should take. The document is a draft and was created prior to a final decision by the Governoro n a policy statement. As such, the document does not memorialize or 8/31/2011

GOVERNOR PART 3


31



TX_00057608

TX_00057609

Becky Dean~Lucy Nashed~Allison Castle~Jeff Boyd~Press Office~Mary Anne Wiley Steffany Duke


Attachment to above confidential attorney-client, delibertaive process privileged document (TX_00057606) and privileged for the same reasons as the email to which it is attached. 8/31/2011

GOVERNOR PART 3

TX_00057610

TX_00057626

Colin Parrish~Brandy Marty

Jeff Boyd~Colin Parrish


Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of giving or receiving legal advice regarding SB 14.~~This document is an email string among Governor Staff and Governor Counsel sent for the purpose of collecting information about SB 14. The document contains the advice, opinion, and recommendations of the author regarding whom the Governor should contact and consult regarding SB 14. Jeff Boyd is an attorney recipient and author of emails in the email string. The document was created to assist the Governor in deciding whether to veto or sign SB 14. Ultimately, the document 3/29/2011

GOVERNOR PART 3


32


was used to advise the Governor on his decision on whether to veto or sign SB 14. The document was created prior to a final decision by the Governor on whether to sign or veto SB 14. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00057627

TX_00057644

Jeff Boyd ~Michael Schofield~Rep Anchia~Deirdre Delisi

Michael Schoenfiled~Jeff Boyd~Rep. Anchia

DNP - DELIBERATIVE PROCESS PRIVILEGE;DNP - ATTY CLIENT;DNP - LEGISLATIVE PRIVILEGE

Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of giving or receiving legal advice regarding SB 14.~~This document is an email string among Governor Staff and Governor Counsel sent for the purpose of collecting information about SB 14. The document contains the advice, opinion, and recommendations of the author regarding whom the Governor should contact and consult regarding SB 14. Jeff Boyd is an attorney recipient of emails in the email string. The document was created to assist the Governor in deciding whether to veto or sign SB 14. Ultimately, the document was used to advise the Governor on his decision on whether to veto or sign SB 14. The document was created prior to a final decision by the Governor on whether to sign or veto SB 14. As such, the document does not memorialize or 5/6/2011

GOVERNOR PART 3


33



TX_00057645

TX_00057678

Collin Parrish~Michael Schofield~Brandy Marty Jeff Boyd


Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of giving or receiving legal advice regarding SB 14.~~This document is an email string among Governor Staff and Governor Counsel sent for the purpose of collecting information about SB 14. The document contains the advice, opinion, and recommendations of the author regarding whom the Governor should contact and consult regarding SB 14. Jeff Boyd is an attorney author and recipient of emails in the email string. The document was created to assist the Governor in deciding whether to veto or sign SB 14. Ultimately, the document was used to advise the Governor on his decision on whether to veto or sign SB 14. The document was created prior to a final decision by the Governor on whether to sign or veto SB 14. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the 4/16/2011

GOVERNOR PART 3


34



TX_00057679

TX_00057695

John Sepehri~Keff Boyd

Travis Richmond

DNP - ATTY CLIENT

Confidential communications between Governor Office Attorneys and SOS General Counsel sent for purposes of seeking or providing legal advice regarding SB 14 preclearance submission 7/25/2011

GOVERNOR PART 3

TX_00057696

TX_00057698

Katherine Cesinger~Michael Schofield Jeff Boyd


Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of giving or receiving legal advice regarding SB 14.~~This document is an email string among Governor Staff and Governor Counsel sent for the purpose of discussing preclearance of SB 14. The document contains the advice, opinion, and recommendations of the author regarding the Governor's role, if any, in the preclearance of SB 14. Jeff Boyd is an attorney author and recipient of emails in the email string. The document was created to assist the Governor in deciding his post-enactment role in the preclearance of SB 14. Ultimately, the document was used to advise the Governor on his decision on his post-enactment role in the preclearance of SB 14. The document was created prior to a final decision by the Governor on what role he would play in the preclearance of SB 14. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The 6/7/2011

GOVERNOR PART 3


35


document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00057699

TX_00057718

John Sepehri~Jeff Boyd

Travis Richmond

DNP - ATTY CLIENT

Confidential comunication between Governor's Office Attorneys and SOS General Counsel sent for purposes of providing or seeking legal advice regarding SB 14 preclearance submission 7/21/2011

GOVERNOR PART 3

TX_00057719

TX_00057743

Travis Richmond~Jeff Boyd John Sepehri

DNP - ATTY CLIENT


GOVERNOR PART 3

TX_00057744

TX_00057746

Travis Richmond~Jeff Boyd John Sepehri

DNP - ATTY CLIENT


GOVERNOR PART 3

TX_00057747

TX_00057753

Colin Parrish~Brandy Marty Jeff Boyd

DNP - ATTY CLIENT

Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of giving or receiving legal advice regarding SB 14.~~This document is an email string among Governor Staff and Governor Counsel sent for the purpose of collecting information about the fiscal impact of SB 14. The document contains the advice, opinion, and recommendations of the author regarding the fiscal impact of SB 14. Jeff Boyd is an attorney recipient and author of emails in the email string. The document was created to assist the Governor in making a final policy determination on whether the fiscal impact of SB 14 has constitutional or other legal implications. 5/6/2011

GOVERNOR PART 3


36


TX_00057754

TX_00057755 Jeff Boyd

Travis Richmond


Confidential communication from Governor's General Counsel attorneys sent for purposes of giving or receiving legal advice regarding SB 14.~~This document is an email string among Governor's Counsel attorneys opining on the legality and constitutionality of SB 14. The document contains the advice, opinion, and recommendations of the author regarding the legality and constitutionality of SB 14. Jeff Boyd is an attorney recipient and author of emails in string. The document was created to assist the Governor in deciding whether to veto or sign SB 14. Ultimately, the document was used to advise the Governor on his decision on whether to veto or sign SB 14. The document was created prior to a final decision by the Governor on whether to sign or veto SB 14. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information. 1/28/2011

GOVERNOR PART 3

TX_00057756

TX_00057759

Allison Castle~Lucy Nashed~Mary Anne Wiley~Ka Jeff Boyd


Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of giving or receiving legal advice regarding SB 14.~~This document is an email string among Governor Staff and Governor Counsel sent for the purpose of 9/14/2011

GOVERNOR PART 3


37


thy Walt~Josh Havens~Matthew thompson~Ken Armbrister~Konathan Hurst

PRIVILEGE

responding to media inquiries about SB 14. The document contains the advice, opinion, and recommendations of the author regarding the public policy positions that the Governor would adopt on SB 14. Jeff Boyd is an attorney recipient. The document was created to assist the Governor in deciding whether which public positions, if any, he would take on SB 14. Ultimately, the document was used to advise the Governor on his decision on policy positions relating to SB 14. The document was created prior to a final decision by the Governor on which public policy positions he should take as to SB 14. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00057760

TX_00057779

Jimmy Blacklock~Jay Dyer~Stacey Napier~Devid Schenck~Reed Clay~Jeff Boyd~Travis Richmond John Sepehri

DNP - ATTY CLIENT

Confidential e-mail from SOS General Counsel to OAG Attorneys and Governor's Office Attorneys sent for purpose of providing or seeking legal advice regarding SB 14 preclearance submission 7/21/2011

GOVERNOR PART 3


38


~Ann McGeehan~Elizabeth Winn

TX_00057780

TX_00057781 Jeff Boyd Ray Sullivan


Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of giving or receiving legal advice regarding SB 14.~~This document is an email string among Governor Staff and Governor Counsel sent for the purpose of discussing preclearance of SB 14 and relating legal advice from the Office of the Attorney General. The document contains the advice, opinion, and recommendations of the author regarding the Governor's role, if any, in the preclearance of SB 14. Jeff Boyd is an attorney author and recipient of emails in the email string. The document was created to assist the Governor in deciding his post-enactment role in the preclearance of SB 14. Ultimately, the document was used to advise the Governor on his decision on his post-enactment role in the preclearance of SB 14. The document was created prior to a final decision by the Governor on what role he would play in the preclearance of SB 14. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without 7/14/2011

GOVERNOR PART 3


39


disclosing privileged information.

TX_00057782

TX_00057803

Jimmy Blacklock~Jeff Boyd~Travis Richmond~David Schenck~Jay Dyer John Sepehri

DNP - ATTY CLIENT

Confidential communication between SOS General Counsel, OAG Attorneys, and Governor's Office Attorneys sent for purposes of seeking or providing legal advice regarding SB 14 preclearance submission 7/20/2011

GOVERNOR PART 3

TX_00057804

TX_00057806

Daniel Hodge~Reed Clay Jeff Boyd

DNP - ATTY CLIENT

Confidential communication between Governor's Office Attorney and OAG Attorneys sent for purpose of providing or seeking legal advice regarding SB 14 preclearance 7/11/2011

GOVERNOR PART 3

TX_00057807

TX_00057999

Press Office~Jonathan Hurst~Jeff Boyd~Ken Armbrister~Mike Morrissey Steffany Duke


Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 82nd Legislature.~~This document transmits a draft press release regarding bills from the 82nd legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. Jeff Boyd is an attorney recipient of the document. The document was created to assist the Governor in formulating a policy announcement on legislation from the 82nd legislature. Ultimately, the document was used to advise the Governor on his decision on which policy positions the Governor should take. The document is a draft and was created prior to a final decision by the 8/30/2011

GOVERNOR PART 3


40


Governoron a policy statement. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00058000


Travis Richmond


Confidential communication from Governor's General Counsel attorneys sent for purposes of giving or receiving legal advice regarding SB 14.~~This document is an email string among Governor's Counsel attorneys opining on the legality and constitutionality of SB 14. The document contains the advice, opinion, and recommendations of the author regarding the legality and constitutionality of SB 14. Jeff Boyd is an attorney recipient and author of emails in string. The document was created to assist the Governor in deciding whether to veto or sign SB 14. Ultimately, the document was used to advise the Governor on his decision on whether to veto or sign SB 14. The document was created prior to a final decision by the Governor on whether to sign or veto SB 14. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The 1/27/2011

GOVERNOR PART 3


41


document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00058001

TX_00058036

Executive~Budget, Planning, and Policy Press Office


This document transmits a draft State of the State" speech discussing numerous issues that were deemed important by the Governor's policy advisers, including Voter ID. The document contains the advice, opinion, and recommendations of the author regarding numerous pieces of legislation and various policy statements. Jeff Boyd is an attorney recipient of the document. The document was created to assist the Governor in formulating a policy announcement on legislation from the 82nd legislature. Ultimately, the document was used to advise the Governor on his decision on which policy positions the Governor should take. The document is a draft and was created prior to a final decision by the Governor on which policy statement he would publicly adopt. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information." 2/8/2011

GOVERNOR PART 3

TX_00058037

TX_00058038

General Counsel~Press Office~Ex Press Office

DNP - DELIBERATIVE PROCESS

This document is a draft press release explaining the Governor's policies behind signing SB 14. The document contains the advice, opinion, and 5/27/2011

GOVERNOR PART 3


42


ecutive PRIVILEGE

recommendations of the author regarding certain SB 14. The document was created to assist the Governor in formulating a policy announcement on legislation from the 82nd legislature. Ultimately, the document was used to advise the Governor on his decision on which policy positions the Governor should take. The document is a draft and was created prior to a final decision by the Governor on a policy statement. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00058039

TX_00058069

Budget, Planning, and Policy~Executive~General Counsel~Legislative

Governor's Legislative Division


This document was created to assist the Office of the Governor employee in providing analyses, opinions, and recommendations to Office of the Governor policy-making staff. The content of the document reveals analyses, opinions, and recommendations that were ultimately communicated to Office of the Governor policy-making staff. The analyses, opinions, and recommendations contain legal and policy advice. The document was created prior to an ultimate decision by the Governor on whether to sign or veto bills pending in the House. It cannot be redacted in a manner that would preclude the disclosure of privileged information. It 5/8/2007

GOVERNOR PART 3


43


also does not memorialize or evidence the Office of the Governor's final decision on the matters identified in the document. It was not shared with the public.

TX_00058070

TX_00058143


Michael Schofield


Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice bills from the 81st Legislature.~~This document consists of bill summaries and bill tracking of bills from the 81st legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor taff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a 8/13/2008

GOVERNOR PART 3


44


redacted form without disclosing privileged information.

TX_00058144

TX_00058150



This document was created to assist the Office of the Governor employee in providing analyses, opinions, and recommendations to Office of the Governor policy-making staff. The content of the document reveals analyses, opinions, and recommendations that were ultimately communicated to Office of the Governor policy-making staff. The document was created prior to an ultimate decision by the Governor on whether to sign or veto bills pending in the House. It cannot be redacted in a manner that would preclude the disclosure of privileged information. It also does not memorialize or evidence the Office of the Governor's final decision on the matters identified in the document. It was not shared with the public. 00/00/2009

GOVERNOR PART 3

TX_00058151

TX_00058234


Michael Schofield


This document consists of bill summaries and bill tracking of bills from the 81st legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the 00/00/2009

GOVERNOR PART 3


45


document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00058235

TX_00058298


Michael Schofield


Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice bills from the 82nd Legislature.~~This document consists of bill summaries and bill tracking of bills from the 82nd legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of 8/13/2008

GOVERNOR PART 3


46


the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00058299

TX_00058304


This document was created to assist the Office of the Governor employee in providing analyses, opinions, and recommendations to Office of the Governor policy-making staff. The content of the document reveals analyses, opinions, and recommendations that were ultimately communicated to Office of the Governor policy-making staff. The document was created prior to an ultimate decision by the Governor on whether to sign or veto bills pending in the House. It cannot be redacted in a manner that would preclude the disclosure of privileged information. It also does not memorialize or evidence the Office of the Governor's final decision on the matters identified in the document. It was not shared with the public. 00/00/2011

GOVERNOR PART 3

TX_00058305

TX_00058308

Michael Schofield Legislative


This document consists of bill summaries, bill tracking, and recommendations for bills from the 82nd legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of 00/00/2011

GOVERNOR PART 3


47


the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00058309

TX_00058310


This document consists of a policy outline on the features that a Texas Voter ID bill should have if the legislature were to consider such a bill. The document contains the advice, opinion, and recommendations of the author regarding Voter ID. The document was created to assist the Governor and his staff in deciding whether to support or oppose Voter ID legislation. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created 00/00/2010

GOVERNOR PART 3


48


prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. This document reflects analyses, opinions, and recommendations that were ultimately communicated to Office of the Governor policy-making staff. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00058311

TX_00058330


This document consists of bill summaries, bill tracking, and recommendations for bills from the 82nd legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied 00/00/2009

GOVERNOR PART 3


49


upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00058331

TX_00058332


Michael Schofield


This document consists of bill analyses of a Voter ID bill. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation. Ultimately, the document was used to advise the Governor on his decision whether to support or oppose a bill. The document was created prior to a final decision by the Governor whether to support or oppose the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information. 00/00/2007

GOVERNOR PART 3

TX_00058334

TX_00058336

Ryan Brannan

Jonathan Hurst

DNP - DELIBERATIVE

Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of 3/22/2012

GOVERNOR PART 3


50


PROCESS PRIVILEGE;DNP - ATTY CLIENT;DNP - WORK PRODUCT

giving or receiving legal advice regarding SB 14.~~This document is an email string among Governor Staff and Governor Counsel sent for the purpose of responding to media inquiries about SB 14. The document contains the advice, opinion, and recommendations of the author regarding the public policy positions that the Governor would adopt on SB 14. Jeff Boyd is an attorney author and recipient of emails in this email string. The document was created to assist the Governor in deciding whether which public positions, if any, he would take on SB 14. Ultimately, the document was used to advise the Governor on his decision on policy positions relating to SB 14. The document was created prior to a final decision by the Governor on which public policy positions he should take as to SB 14. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00058337

TX_00058342


This document is a copy of DOJ preclearance rejection letter sent to the Texas SOS with handwritten notes.~The document contains the advice, opinion, and recommendations of the author regarding the what the Governor's legal and policy positions should be on 3/12/2012

GOVERNOR PART 3


51


preclearance of SB 14. The document was created to assist the Governor in deciding what the Governor's legal and policy positions should be on preclearance of SB 14. Ultimately, the document was used to advise the Governor on his decision on what the Governor's legal and policy positions should be on preclearance of SB 14. The document was created prior to a final decision by the Governor on what role he would play in the preclearance of SB 14. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00058343

TX_00058343

Budget, Planning, and Policy~Executive~General Counsel Ryan Brannan


This document contains handwritten notes on the preclearance of SB 14.~The document contains the advice, opinion, and recommendations of the author regarding the what the Governor's legal and policy positions should be on preclearance of SB 14. The document was created to assist the Governor in deciding what the Governor's legal and policy positions should be on preclearance of SB 14. Ultimately, the document was used to advise the Governor on his decision on what the Governor's legal and policy positions should be on preclearance of SB 14. The document was created prior to a final 00/00/2011

GOVERNOR PART 3


52


decision by the Governor on what role he would play in the preclearance of SB 14. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. It was stored in files available to internal Governor staff, but it document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00058344

TX_00058345 Executive

Ray Sullivan (Executive)


This document is a draft constituent communication to a prominent business leader.~The document contains the advice, opinion, and recommendations of the author regarding the what the Governor's public stated policy positions should be on Voter ID. The document was created to assist the Governor in deciding public stated policy positions should be on Voter ID. Ultimately, the document was used to advise the Governor on his decision on public stated policy positions should be on Voter ID. The document was created prior to a final decision by the Governor on public stated policy positions should be on Voter ID. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. It was stored in files available to internal Governor staff, but it document was not 00/00/2011

GOVERNOR PART 3


53


shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00058346

TX_00058352

Communication Division.

Ashton Morgan (Communication Division)


This document is a legislative communication plan prepared by the Governor's staff on a variety of topics.~The document contains the advice, opinion, and recommendations of the author regarding the what the Governor's public stated policy positions should be on a variety of policies. The document was created to assist the Governor in deciding public stated policy positions should be on a variety of policies. Ultimately, the document was used to advise the Governor on his decision on public stated policy positions should be on a variety of issues and other policies as well as whether he should sign or veto certain bills. The document was created prior to a final decision by the Governor on public stated policy positions on a variety of issues. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. It was stored in files available to internal Governor staff, but it document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

GOVERNOR PART 3

TX_00058353

TX_00058377

Budget, Planning,

Governor's Legislative

DNP - ATTY

Confidential communication from Governor's General Counsel to 4/6/2009

GOVERNOR PART


54


and Policy~General Counsel

Division CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE

Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 81st Legislature.~~This document consists of bill summaries, bill tracking, and recommendations for bills from the 81st legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

3

TX_00058378

TX_00058405

Budget, Planning, and


DNP - DELIBERATIVE

Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of 4/7/2009

GOVERNOR PART 3


55


Policy~General Counsel

PROCESS PRIVILEGE

providing legal advice regarding engrossed bills from the 81st Legislature.~~This document consists of bill summaries, bill tracking, and recommendations for bills from the 81st legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00058406

TX_00058545

Executive~Budget, Planning, and



Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding 3/5/2009

GOVERNOR PART 3


56


Policy~General Counsel~Legislative Counsel


engrossed bills from the 81st Legislature.~~This document consists of bill summaries, bill tracking, and recommendations for bills from the 81st legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00058546

TX_00058783

Executive~Budget, Planning, and Policy~Ge


DNP - ATTY CLIENT;DNP - DELIBERA

Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 81st 4/6/2009

GOVERNOR PART 3


57


neral Counsel~Legislative Counsel

TIVE PROCESS PRIVILEGE

Legislature.~~This document consists of bill summaries, bill tracking, and recommendations for bills from the 81st legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00058784

TX_00058791

Governor's Communications/Scheduling Division.

Governor's Communications/Scheduling Division.


This document contains a list of persons and organizations from whom the Governor solicited , or to whom the Governor provided, information regarding a variety of bills pending before the 82nd Legislature. It reflects

GOVERNOR PART 3


58


the Office of the Governor's internal deliberations regarding which individuals and groups can contribute policy advice on a variety of issues, including Voter ID. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was made prior to a final decision on whether to sign or veto the legislation identified in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00058792

TX_00058811

Executive~Budget, Planning, and Policy~General Counsel~Legislative Counsel

Governor's Budget, Planning, and Policy Division


Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 82nd Legislature.~~This document consists of bill summaries, bill tracking, and recommendations for bills from the 82nd legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the 02/00/2011

GOVERNOR PART 3


59


Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00058812

TX_00058829




Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 82nd Legislature.~~This document consists of bill summaries, bill tracking, and recommendations for bills from the 82nd legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding 1/24/2011

GOVERNOR PART 3


60


whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00058830

TX_00059449




Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 82nd Legislature.~~This document consists of bill summaries, bill tracking, and recommendations for bills from the 82nd legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the 2/18/2009

GOVERNOR PART 3


61


legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00059450

TX_00059703




Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 82nd Legislature.~~This document consists of bill summaries, bill tracking, and recommendations for bills from the 82nd legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. 00/00/2011

GOVERNOR PART 3


62


Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00059714

TX_00059716

Legislative Division Jordan Root


Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 82nd Legislature.~~This document consists of bill summaries, bill tracking, and recommendations for bills from the 82nd legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to 00/00/2011

GOVERNOR PART 3


63


advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00059717

TX_00059956




Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 82nd Legislature.~~This document consists of bill summaries, bill tracking, and recommendations for bills from the 82nd legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision 00/00/2011

GOVERNOR PART 3


64


whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00059957

TX_00060257




Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 82nd Legislature.~~This document consists of bill summaries, bill tracking, and recommendations for bills from the 82nd legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The 00/00/2011

GOVERNOR PART 3


65


document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00060258

TX_00060258

Kimberly Snyder~Kristy French~Ray Sullivan~Clint Harp~Ken Armbrister~David Eichler~Sarah Floerke Sarah Floerke


Confidential e-mail between Governor's Office Attorneys and Staff sent for purposes of seeking or providing legal advice regarding Voter ID and numerous other items.~~This email consists of bill tracking and summaries regarding the procedural posture of pending bills from the 81st legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to 3/22/2011

GOVERNOR PART 3


66


veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor taff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00060259

TX_00060559


Governor's Legislative Staff


Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 82nd Legislature.~~This document consists of bill summaries, bill tracking, and recommendations for bills from the 82nd legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the 00/00/2011

GOVERNOR PART 3


67



TX_00060560


Executive~Budget, Planning, and Policy Division


This document consists of bill tracking and summaries regarding the procedural posture of pending bills from the 81st legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff.

GOVERNOR PART 3


68


The document was reviewed and relied upon by Office of the Governor taff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00060561

TX_00060561


This document was created to assist the Office of the Governor employee in providing analyses, opinions, and recommendations to Office of the Governor policy-making staff. The content of the document reveals analyses, opinions, and recommendations that were ultimately communicated to Office of the Governor policy-making staff. The document was created prior to an ultimate decision by the Governor on whether to sign or veto bills pending in the House. It cannot be redacted in a manner that would preclude the disclosure of privileged information. It also does not memorialize or evidence the Office of the Governor's final decision on the matters identified in the document. It was not shared with the public.

GOVERNOR PART 3

TX_00060562

TX_00060563

Governor's Staff



This document consists of a list of Governor policy priorities. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation affecting the policy priorities identified. Ultimately, the document was used to advise the Governor on his decision whether to veto

GOVERNOR PART 3


69


or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor taff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00060564

TX_00060565

Governor's Budget, Planning, and Policy Division Greg Stein


This document consists of a list of Governor policy priorities. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation affecting the policy priorities identified. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor taff as part of the Office of the Governor's decision-making process. The document 2/3/2009

GOVERNOR PART 3


70


was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00060566

TX_00060566




This document consists of bill analyses for HB 2194. The document contains a summary of the bill as well as advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

GOVERNOR PART 3

TX_00060567

TX_00060569

Executive~Budget, Planning, and Policy~General



This document consists of bill analyses for HB 16. The document contains a summary of the bill as well as advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the 12/21/2010

GOVERNOR PART 3


71


Counsel~Legislative Counsel

Governor and his staff in deciding whether to support or oppose the legislation. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00060570

TX_00060571




This document consists of bill analyses for HB 101. The document contains a summary of the bill as well as advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of

GOVERNOR PART 3


72


the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00060572

TX_00060573




This document consists of bill analyses for HB 112. The document contains a summary of the bill as well as advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a 12/21/2010

GOVERNOR PART 3


73


redacted form without disclosing privileged information.

TX_00060574

TX_00060577




This document consists of bill analyses for HB 125. The document contains a summary of the bill as well as advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

GOVERNOR PART 3

TX_00060578

TX_00060579

Executive~Budget, Planning, and Policy~General Counsel~Legislativ



This document consists of bill analyses for HB 186. The document contains a summary of the bill as well as advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the 12/21/2010

GOVERNOR PART 3


74


e Counsel legislation. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00060580

TX_00060582




This document consists of bill analyses for HB 218. The document contains a summary of the bill as well as advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared 2/22/2007

GOVERNOR PART 3


75


internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00060583

TX_00060583



GOVERNOR PART 3

TX_00060584

TX_00060585




This document consists of bill analyses for HB 373. The document contains a summary of the bill as well as advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation. Ultimately, the document

GOVERNOR PART 3


76


was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00060586

TX_00060587




This document consists of bill analyses for HB 401. The document contains a summary of the bill as well as advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive 12/21/2010

GOVERNOR PART 3


77


and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00060588

TX_00060589




This document consists of bill analyses for HB 539. The document contains a summary of the bill as well as advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information. 1/7/2011

GOVERNOR PART 3

TX_00060 TX_00060 Executive Governor's DNP - This document consists of bill analyses 3/7/2005 GOVERN


78


590 591 ~Budget, Planning, and Policy~General Counsel~Legislative Counsel

Budget, Planning, and Policy Division


for a 2005 Voter ID bill. The document contains a summary of the bill as well as advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

OR PART 3

TX_00060592

TX_00060593




This document consists of bill analyses for a HB 1726 bill. The document contains a summary of the bill as well as advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill.

GOVERNOR PART 3


79


The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00060594

TX_00060595




This document consists of bill analyses for a HB 1882 bill. The document contains a summary of the bill as well as advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied

GOVERNOR PART 3


80


upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00060596

TX_00060598




This document consists of bill analyses for HB 2194. The document contains a summary of the bill as well as advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information. 4/17/2011

GOVERNOR PART 3

TX_00060599

TX_00060600

Executive~Budget, Planning,

Governor's Budget, Planning, and

DNP - DELIBERATIVE

This document consists of bill analyses for HB 3556. The document contains a summary of the bill as well as advice,

GOVERNOR PART 3


81


and Policy~General Counsel~Legislative Counsel

Policy Division PROCESS PRIVILEGE

opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00060601

TX_00060602




This document consists of bill analyses for HB 3901 The document contains a summary of the bill as well as advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to

GOVERNOR PART 3


82


veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00060603

TX_00060604




This document consists of bill analyses for HB 3902 The document contains a summary of the bill as well as advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's

GOVERNOR PART 3


83


decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00060605

TX_00060606




This document consists of bill analyses for HB 3948 The document contains a summary of the bill as well as advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

GOVERNOR PART 3

TX_00060607

TX_00060608

Executive~Budget, Planning, and Policy~Ge



This document consists of bill analyses for HB 1351 The document contains a summary of the bill as well as advice, opinion, and recommendations of the author regarding certain legislation. The

GOVERNOR PART 3


84


neral Counsel~Legislative Counsel

E document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00060609


Ray Sullivan (Executive)


This document is a draft constituent communication to a prominent business leader.~The document contains the advice, opinion, and recommendations of the author regarding the what the Governor's public stated policy positions should be on Voter ID. The document was created to assist the Governor in deciding public stated policy positions should be on Voter ID. Ultimately, the document was used to advise the Governor on his decision on public stated policy positions should be on Voter ID. The document was created prior to a final decision by the Governor on public

GOVERNOR PART 3


85


stated policy positions should be on Voter ID. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00060618

TX_00060640

Governor's Staff


GOV - Deliberative Process Privilege

Confidential communications between Governor Staff containing advice, opinions, and deliberations that precede a final decision relating to voter ID and other policies.

GOVERNOR PART 3

TX_00060641

TX_00060686




Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 80th Legislature.~~This document consists of bill summaries, bill tracking, and recommendations for bills from the 80th legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision

GOVERNOR PART 3


86


whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00060687

TX_00060706




Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 80th Legislature.~~This document consists of bill summaries, bill tracking, and recommendations for bills from the 80th legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The

GOVERNOR PART 3


87


document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00060707

TX_00060814




Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 80th Legislature.~~This document consists of bill summaries, bill tracking, and recommendations for bills from the 80th legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final

GOVERNOR PART 3


88


decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00060815

TX_00060932




Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 80th Legislature.~~This document consists of bill summaries, bill tracking, and recommendations for bills from the 80th legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto

GOVERNOR PART 3


89


or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00060933

TX_00061396




Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 81st Legislature.~~This document consists of bill summaries, bill tracking, and recommendations for bills from the 81st legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the

GOVERNOR PART 3


90



TX_00061397

TX_00062024




Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 81st Legislature.~~This document consists of bill summaries, bill tracking, and recommendations for bills from the 81st legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does

GOVERNOR PART 3


91


not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00062025

TX_00062984




Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 81st Legislature.~~This document consists of bill summaries, bill tracking, and recommendations for bills from the 81st legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of

GOVERNOR PART 3


92


the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00062985

TX_00064428




Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 81st Legislature.~~This document consists of bill summaries, bill tracking, and recommendations for bills from the 81st legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The

GOVERNOR PART 3


93


document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00064429

TX_00065892




Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 81st Legislature.~~This document consists of bill summaries, bill tracking, and recommendations for bills from the 81st legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared

GOVERNOR PART 3


94


internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00065893

TX_00067976




Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 81st Legislature.~~This document consists of bill summaries, bill tracking, and recommendations for bills from the 81st legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive

GOVERNOR PART 3


95


and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00067977

TX_00069906




Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 81st Legislature.~~This document consists of bill summaries, bill tracking, and recommendations for bills from the 81st legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff.

GOVERNOR PART 3


96


The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00069907

TX_00071582




Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 81st Legislature.~~This document consists of bill summaries, bill tracking, and recommendations for bills from the 81st legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied

GOVERNOR PART 3


97



TX_00071583

TX_00073582




Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 81st Legislature.~~This document consists of bill summaries, bill tracking, and recommendations for bills from the 81st legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as

GOVERNOR PART 3


98


part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00073583

TX_00073584

Mark Miner,~Ken Armbrister,~Steve McGraw,~Mary Katherine, Stout~Jim Harrison,~Kyle Mitchell, Brandy Marty,~David Eichler,~Allison Castle, RuthAnn Nicholson

Amanda Arriaga


This document consists a list of studies that the Governor's policy advisers deemed important on the policy issues of immigration/border issues. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation affecting the policy priorities identified. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor taff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

GOVERNOR PART 3

TX_00073 TX_00073 Executive Governor's DNP - Confidential communication from GOVERN


99


585 604 ~Budget, Planning, and Policy~General Counsel~Legislative Counsel

Legislative Division


Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 81st Legislature.~~This document consists of bill summaries, bill tracking, and recommendations for bills from the 81st legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

OR PART 3

TX_00073605

TX_00073613

Executive~Budget,


DNP - DELIBERA

This document consists of a list of Governor legislative priorities for the 5/24/2011

GOVERNOR PART


100


Planning, and Policy~General Counsel~Legislative Counsel

Division TIVE PROCESS PRIVILEGE

82nd Legislature and the procedural posture of bills addressing these priorities. The document was prepared by the Governor's staff. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation affecting the policy priorities identified. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor taff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

3

TX_00073614

TX_00073627

Executive~Budget, Planning, and Policy~General Counsel~Legislativ


DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEG

Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 81st Legislature.~~This document consists of bill summaries, bill tracking, and recommendations for bills from the 81st

GOVERNOR PART 3


101


e E legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00073628

TX_00073633

Executive~Budget, Planning, and Policy~General Counsel~Legislative



This document consists of a list of Governor policy priorities on border security entitled Priority Issues: Texas Border Security Plan." The document contains the advice, opinion, and recommendations of the author regarding legislation addressing the border security priorities identified in the document. The document was created to assist the

GOVERNOR PART 3


102


Governor and his staff in deciding whether to support or oppose the legislation affecting the policy priorities identified. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor taff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information."

TX_00073634

TX_00073707

Executive~Budget, Planning, and Policy

Governor's Budget, Planning, and Policy Division & Communications Division


This document consists of a list of Governor policy priorities on economic development entitled Economic Development and Job Creation" The document contains the advice, opinion, and recommendations of the author regarding legislation addressing economic development. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation affecting the policy priorities identified. Ultimately, the document was used to advise the Governor on which publicly stated policy positions he would take on economic

GOVERNOR PART 3


103


development issues. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor taff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information."

TX_00073708

TX_00073708


This email consists of a discussion on the public policy positions that the Governor should take on DOJ's denial of administrative preclearance of SB 14. The document contains the advice, opinion, and recommendations of the author regarding legislation addressing economic development. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation affecting the policy priorities identified. Ultimately, the document was used to advise the Governor on which publicly stated policy positions he would take on economic development issues. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's 3/12/2012

GOVERNOR PART 3


104


final policy. The document was reviewed and relied upon by Office of the Governor taff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00073709

TX_00073709




This document consists of an in-depth analysis of SB 14. The document contains the advice, opinion, and recommendations of the author regarding legislation addressing economic development. The document was created to assist the Governor and his staff in deciding whether to support or oppose SB14. Ultimately, the document was used to advise the Governor on whether to sign or veto SB 14. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor taff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

GOVERNOR PART 3

TX_00073710

TX_00073712



DNP - DELIBERATIVE

This document consists of bill analyses for a Voter ID Bill. The document contains a summary of the bill as well as 1/14/2011

GOVERNOR PART 3


105


and Policy~General Counsel~Legislative


advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00073716

TX_00073717




This document consists of bill analyses for SB 14. The document contains a summary of the bill as well as advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to 1/14/2011

GOVERNOR PART 3


106



TX_00073718

TX_00073722




This document consists of amendment analyses and tracking as well as recommendations for SB 14. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied 3/21/2011

GOVERNOR PART 3


107



TX_00073742

TX_00073744




This document consists of bill analyses for SB 178 The document contains a summary of the bill as well as advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

GOVERNOR PART 3

TX_00073764

TX_00073766



DNP - DELIBERATIVE

This document consists of bill analyses for a voter ID bill. The document contains a summary of the bill as well as

GOVERNOR PART 3


108


and Policy~General Counsel~Legislative


advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00073767

TX_00073769




This document consists of bill analyses for a voter ID bill. The document contains a summary of the bill as well as advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to

GOVERNOR PART 3


109



TX_00073770

TX_00073773




This document consists of bill analyses for a voter ID bill. The document contains a summary of the bill as well as advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's

GOVERNOR PART 3


110


decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00073774

TX_00073775



GOVERNOR PART 3

TX_00073776

TX_00073777


This document consists of a bill comparison for two voter ID bills--SB 362 and HB125. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's

GOVERNOR PART 3


111


final policy. The content of this document was ultimately communicated to the Governor's policy-making staff. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00073796

TX_00073799




This document consists of bill analyses for SB 1647. The document contains a summary of the bill as well as advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing

GOVERNOR PART 3


112


privileged information.

TX_00073800

TX_00073860




Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 80th Legislature.~~This document consists of bill summaries, bill tracking, and recommendations for bills from the 80th legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

GOVERNOR PART 3


113


TX_00073861

TX_00073866




Confidential communication from Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 80th Legislature.~~This document consists of bill summaries, bill tracking, and recommendations for bills from the 80th legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

GOVERNOR PART 3

TX_00073 TX_00073 Executive Governor's DNP - Confidential communication from GOVERN


114


867 878 ~Budget, Planning, and Policy~General Counsel~Legislative

Legislative Division


Governor's General Counsel to Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 80th Legislature.~~This document consists of bill summaries, bill tracking, and recommendations for bills from the 80th legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

OR PART 3

TX_00073879

TX_00074003

Executive~Budget,


DNP - ATTY

Confidential communication from Governor's General Counsel to

GOVERNOR PART


115


Planning, and Policy~General Counsel~Legislative

Division CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE

Governor's Staff sent for purposes of providing legal advice regarding engrossed bills from the 80th Legislature.~~This document consists of bill summaries, bill tracking, and recommendations for bills from the 80th legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

3

TX_00074010

TX_00074011

Michael Schofield

Budget, Planning, and Policy

DNP - DELIBERATIVE

This document consists of document describing how SB 14 will work. The document contains advice, opinion, and

GOVERNOR PART 3


116


PROCESS PRIVILEGE

recommendations of the author regarding SB 14. The document was created to assist the Governor and his staff in deciding the public policy position that the Governor would take on SB 14. Ultimately, the document was used to advise the Governor on his decision the public policy position his office would take on SB 14. The document was created prior to a final decision by the Governor on the public policy grounds supporting SB 14. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00074012

TX_00074012

Press Office,~Brandy Marty,~Jeff Boyd

Catherine Frazier


This email consists of a discussion on the public policy positions that the Governor should take on DOJ's denial of administrative preclearance of SB 14. The document contains the advice, opinion, and recommendations of the author regarding legislation addressing potential responses to the decision to deny preclearance of SB 14. The document was created to assist the Governor and his staff in deciding the proper policy response to denial of preclearance. Ultimately, the document 3/12/2012

GOVERNOR PART 3


117


was used to advise the Governor on which publicly stated policy positions he would take on the denial of preclearance. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00074031

TX_00074046

GCPD (Governor's Committee on People with Disabilities) Mail Drop

GCPD Mail Drop


This document consists of bill summaries, bill tracking, and recommendations for bills from the 82nd legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied 1/21/2011

GOVERNOR PART 3


118



TX_00074047

TX_00074071

GCPD Mail Drop

Angela English


This document consists of bill summaries, bill tracking, and recommendations for bills from the 82nd legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing 1/28/2011

GOVERNOR PART 3


119


privileged information.

TX_00074072

TX_00074113

GCPD Mail Drop

Angela English


This document consists of bill summaries, bill tracking, and recommendations for bills from the 82nd legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information. 2/25/2011

GOVERNOR PART 3

TX_00074114

TX_00074136

GCPD Mail Drop

GCPD Mail Drop


This document consists of bill summaries, bill tracking, and recommendations for bills from the 82nd legislative session that were deemed important by the Governor's policy 2/18/2011

GOVERNOR PART 3


120


E advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00074137

TX_00074149

Tammy Tatom

GCPD Mail Drop


This document consists of bill summaries, bill tracking, and recommendations for bills from the 82nd legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the 6/20/2011

GOVERNOR PART 3


121


legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00074150

TX_00074175

Tammy Tatom

GCPD Mail Drop


This document consists of bill summaries, bill tracking, and recommendations for bills from the 82nd legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto 5/27/2011

GOVERNOR PART 3


122


or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00074176

TX_00074225

GCPD Mail Drop

GCPD Mail Drop


This document consists of bill summaries, bill tracking, and recommendations for bills from the 82nd legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive 5/20/2011

GOVERNOR PART 3


123


and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00074226

TX_00074227

Executive~Communications Division

Communications Division


This document is a draft press release explaining the Governor's policies behind signing SB 14. The document contains the advice, opinion, and recommendations of the author regarding certain SB 14. The document was created to assist the Governor in formulating a policy announcement on legislation from the 82nd legislature. Ultimately, the document was used to advise the Governor on his decision on which policy positions the Governor should take. The document is a draft and was created prior to a final decision by the Governor on a policy statement. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information. 5/27/2011

GOVERNOR PART 3

TX_00074 TX_00074 GCPD GCPD DNP - This document is a draft press release 11/28/2011 GOVERN


124


228 234 DELIBERATIVE PROCESS PRIVILEGE

explaining the Governor's policies relating to disabled Texans. The document contains the advice, opinion, and recommendations of the author regarding the Governor's policy priorities for disabled Texans. The document was created to assist the Governor in formulating a policy announcement on legislation from the 82nd legislature. Ultimately, the document was used to advise the Governor on his decision on which policy positions the Governor should take. The document is a draft and was created prior to a final decision by the Governor on a policy statement. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

OR PART 3

TX_00074235

TX_00074235

Communications Division Josh Havens


This email consists of a discussion on the public policy positions that the Governor should take on the administrative preclearance of SB 14. The document contains the advice, opinion, and recommendations of the author regarding legislation addressing potential responses to administrative preclearance of SB 14. The document was created to assist the Governor and his staff in 9/22/2011

GOVERNOR PART 3


125


deciding the proper policy seeking administrative preclearance. Ultimately, the document was used to advise the Governor on which publicly stated policy positions he would take on administrative preclearance. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00074236

TX_00074236


This document is a draft constituent communication to a prominent business leader.~The document contains the advice, opinion, and recommendations of the author regarding the what the Governor's public stated policy positions should be on Voter ID. The document was created to assist the Governor in deciding public stated policy positions should be on Voter ID. Ultimately, the document was used to advise the Governor on his decision on public stated policy positions should be on Voter ID. The document was created prior to a final decision by the Governor on public stated policy positions should be on Voter ID. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office. The document was reviewed and relied 3/21/2011

GOVERNOR PART 3


126



TX_00074237

TX_00074237

Matthew Thompson~Allison Castle~Josh Havens Lucy Nashed


This email consists of a discussion on the public policy positions that the Governor should take on the administrative preclearance of SB 14. The document contains the advice, opinion, and recommendations of the author regarding the administrative preclearance of SB 14.. The document was created to assist the Governor and his staff in deciding the proper policy seeking administrative preclearance. Ultimately, the document was used to advise the Governor on which publicly stated policy positions he would take on administrative preclearance. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information. 9/14/2011

GOVERNOR PART 3

TX_00074238

TX_00074238

Allison Castle~Lucy Nashed~Josh Havens

Matthew Thompson


This email consists of a discussion on the public policy positions that the Governor should take on the administrative preclearance of SB 14. The document contains the advice, opinion, and recommendations of the author regarding 9/14/2011

GOVERNOR PART 3


127


the administrative preclearance of SB 14.. The document was created to assist the Governor and his staff in deciding the proper policy seeking administrative preclearance. Ultimately, the document was used to advise the Governor on which publicly stated policy positions he would take on administrative preclearance. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00074239

TX_00074242

Jeff Boyd,~Press Office

Kalese Hammonds


This is a draft press release on school finance lawsuits. The document contains the advice, opinion, and recommendations of the author regarding school finance lawsuits. The document was created to assist the Governor and his staff in deciding the proper policy on school finance lawsuits. Ultimately, the document was used to advise the Governor on which publicly stated policy positions he would take on school finance lawsuits. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be

GOVERNOR PART 3


128


produced in a redacted form without disclosing privileged information.

TX_00074243

TX_00074705

Budget, Planning, and Policy Division,~General Counsel

Legislative~Division


This document consists of bill summaries, bill tracking, and recommendations for bills from the 80th legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information. 5/5/2009

GOVERNOR PART 3"|"|"|"|"|"|463"

TX_00074706

TX_00075089

Budget, Planning, and Policy

Legislative~Division

DNP - DELIBERATIVE PROCESS

This document consists of bill summaries, bill tracking, and recommendations for bills from the 80th legislative session that were deemed

GOVERNOR PART 3"|"|"|"|"|"|384"


129


Division,~General Counsel

PRIVILEGE

important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00075090

TX_00075153

Julie Johnson Pat Pound


This document consists of bill summaries, bill tracking, and recommendations for bills from the 80th legislative session that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding

GOVERNOR PART 3"|"|"|"|"|"|64"


130


whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00089058

TX_00089059 Jeff Boyd Ray Sullivan


This email discusses a new SEC investment adviser rule and the preclearance obligations related to eliminating elected offices. The document contains the advice, opinion, and recommendations of the author regarding the new SEC rule and the elimination of elected offices. The document was created to assist the Governor and his staff in deciding whether to support or oppose legislation relating to the elimination of elected offices. The emails also discuss the effect of the SEC rule on the appointee process. Ultimately, the document was used to advise the Governor on his decision on 3/24/2011

OOG STAFF ELECTRONIC RECORDS


131


legislation and the appointee process. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document and how to proceed on appointing political appointees. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.~~The email also forwards legal advice from the office of the attorney general sent for the purpose of giving or receiving legal advice on preclearance obligations relating to the the elimination of elected offices. Jeff Boyd is also an attorney-recipient of the document.

TX_00089060

TX_00089061

David Zimmerman Jeff Boyd


This email discusses a new SEC investment adviser rule and the preclearance obligations related to eliminating elected offices. The document contains the advice, opinion, and recommendations of the author regarding the new SEC rule and the elimination of elected offices. The document was created to assist the Governor and his staff in deciding whether to support or oppose legislation relating to the elimination of elected offices. The emails also discuss the effect of the SEC rule on the appointee process. Ultimately, the document was used to 3/24/2011



132


advise the Governor on his decision on legislation and the appointee process. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.~~The email also forwards legal advice from the office of the attorney general sent for the purpose of giving or receiving legal advice on preclearance obligations relating to the the elimination of elected offices. Jeff Boyd is also an attorney-author of the document.

TX_00089062

TX_00089063

Ray Sullivan Jeff Boyd


This email discusses a new SEC investment adviser rule and the preclearance obligations related to eliminating elected offices. The document contains the advice, opinion, and recommendations of the author regarding the new SEC rule and the elimination of elected offices. The document was created to assist the Governor and his staff in deciding whether to support or oppose legislation relating to the elimination of elected offices. The emails also discuss the effect of the SEC rule on the appointee process. Ultimately, the document was used to 3/24/2011



133


advise the Governor on his decision on legislation and the appointee process. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.~~The email also forwards legal advice from the office of the attorney general sent for the purpose of giving or receiving legal advice on preclearance obligations relating to the the elimination of elected offices. Jeff Boyd is also an attorney-author of the document.

TX_00089064

TX_00089066

Collin Parish~Brandy Marty Jeff Boyd


This email discusses a request for information relating to SB 14 from Representative Anchia's office to an executive agency that reports to the Governor--TxDOT. The document contains the advice, opinion, and recommendations of the author regarding potential responses to Representative Anchia's request. The document was created to assist the Governor and his staff in deciding how to respond to Representative Anchia's request. Ultimately, the document was used to advise the Governor's Office on the proper response to Representative 3/29/2011



134


Anchia's request. The document was created prior to a final decision by the Governor on how to respond. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.~~The email also contains legal advice from Governor's General Counsel attorneys to the Governor's staff sent for the purpose of giving or receiving legal advice on SB 14 and DPS statistics relating to the bill.

TX_00089067

TX_00089067

Jeff Boyd~Brandy Marty Colin Parrish


This email transmits information collected from DPS and relating to SB 14. The document reflects the information that the Governor's office considered pertinent in its review of SB 14. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. 3/30/2011



135


The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00089068

TX_00089068

Amadeo Saenz James Bass


This email transmits information collected from DPS and relating to SB 14. The document reflects the information that the Governor's office considered pertinent in its review of SB 14. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation. Ultimately, the document was used to advise the Governor on his decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information. 3/29/2011


TX_00089069

TX_00089069


DNP - DELIBERA

Charts attached to document TX_00089068 and privileged for the same 3/29/2011

OOG STAFF


136



reasons as the email to which the charts are attached.

ELECTRONIC RECORDS

TX_00089070

TX_00089070



Charts attached to document TX_00089068 and privileged for the same reasons as the email to which the charts are attached. 3/29/2011


TX_00089072

TX_00089075

Collin Parrish~Michael Schofield,~Brandy Marty Jeff Boyd


This email discusses a free election IDs in SB 14. The document contains the advice, opinion, and recommendations of the author regarding the free election IDs. The document was created to assist the Governor and his staff in deciding whether to support or oppose SB 14. Ultimately, the document was used to advise the Governor on his decision to sign or veto SB 14. The document was created prior to a final decision by the Governor whether to veto or sign Sb 14. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.~~The email also relates legal advice from the office of the attorney general sent for the purpose of giving or receiving legal advice on free election IDs. Jeff Boyd is also an attorney-author of the document. 4/15/2011


TX_00089 TX_00089 Brandy Chip Roy DNP - This email fo discusses Section 5 in the 6/1/2011 OOG


137


076 078 Marty,~Travis Richmond,~Jeff Boyd


context of redistricting. The document contains reflections of the author regarding the free election IDs. The document was created to assist the Governor and his staff in deciding on a final policy position regarding preclearance litigation. Ultimately, the document was used to advise the Governor on his final policy decisions on preclearance. The document was created prior to a final decision on the Governor's public position on preclearance . As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.~~The email also relates a request for attorney review of applicable Section 5 standards. Jeff Boyd and Travis Richmond are also attorney recipients of the document.

STAFF ELECTRONIC RECORDS

TX_00089079

TX_00089079 Jeff Boyd John Sepehri


This email transmits and discusses a draft administrative preclearance submission prepared by attorneys in the Secretay of State office--an executive agency of the State. The document contains reflections of the author regarding the preclearance. The document was created to assist the Governor and his staff in deciding on a final policy position regarding preclearance. Ultimately, the document was used to advise the Governor on his 7/19/2011



138


final policy decisions on preclearance. The document was created prior to a final decision on the Governor's public position on preclearance . As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.~~The email also relates legal advice on administrative preclearance from a Secretary of State attorney to other executive attorneys. Attorney John Sepehri is the attorney author and Jeff Boyd is the attorney recipient.

TX_00089080

TX_00089095 Jeff Boyd John Sepehri


Draft preclearance submission attachment to TX-00089079 and privileged for the same reasons as the email to which it is attached. 7/19/2011


TX_00089096

TX_00089097

Jimmy Blacklock, Jeff Boyd, Travis Richmond, David Schenck, Jay Dyer, John Sepehri


This email discusses a draft administrative preclearance submission prepared by attorneys in the Secretay of State office--an executive agency of the State. The document contains reflections of the author regarding the preclearance. The document was created to assist the Governor and his staff in deciding on a final policy position regarding 7/20/2011



139


Stacey Napier

preclearance. Ultimately, the document was used to advise the Governor on his final policy decisions on preclearance. The document was created prior to a final decision on the Governor's public position on preclearance . As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.~~The email also relates legal advice on administrative preclearance from Secretary of State, Attorney General, and Office of the Governor attorneys. Attorney John Sepehri is the attorney author and attorneys from the Governor's Office and Office of the Attorney General are recipients.

TX_00089098

TX_00089098

Jeff Boyd~Travis Richmond John Sepehri


This email transmits and discusses a draft administrative preclearance submission prepared by attorneys in the Secretay of State office--an executive agency of the State. The document contains reflections of the author regarding the preclearance. The document was created to assist the Governor and his staff in deciding on a final policy position regarding preclearance. Ultimately, the document was used to advise the Governor on his final policy decisions on preclearance. The document was created prior to a 7/20/2011



140


final decision on the Governor's public position on preclearance . As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.~~The email also relates legal advice on administrative preclearance from Secretary of State and Attorney General attorneys. Attorney John Sepehri is the attorney author and attorneys from the Governor's Office are recipients.

TX_00089099

TX_00089113

Jeff Boyd~Travis Richmond John Sepehri


Attachment to TX-00089098 and privileged for the same reasons as the email to which it is attached. 7/20/2011


TX_00089114

TX_00089114

Jimmy Blacklock,~Jay Dyer, Stacey Napier, David Schenck, Reed Clay, Jeff Boyd, John Sepehri


This email discusses a draft administrative preclearance submission prepared by attorneys in the Secretay of State office--an executive agency of the State. The document contains reflections of the author regarding preclearance. The document was created to assist the Governor and his staff in deciding on a final policy position regarding preclearance. Ultimately, the document was used to advise the Governor on his 7/21/2011



141


Travis Richmond, Ann McGeehan, Elizabeth Winn

final policy decisions on preclearance. The document was created prior to a final decision on the Governor's public position on preclearance . As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.~~The email also relates legal advice on administrative preclearance from Secretary of State, Attorney General, and Office of the Governor attorneys. Attorney John Sepehri is the attorney author and attorneys from the Governor's Office, Secretary of State, and Office of the Attorney General are recipients.

TX_00089115

TX_00089129

Jimmy Blacklock,~Jay Dyer, Stacey Napier, David Schenck, Reed Clay, Jeff Boyd, Travis Richmond, Ann McGeehan, John Sepehri





142


Elizabeth Winn

TX_00089130

TX_00089130

John Sepehri,~Jeff Boyd

Travis Richmond


This email discusses a draft administrative preclearance submission prepared by attorneys in the Secretay of State office--an executive agency of the State. The document contains reflections of the author regarding preclearance. The document was created to assist the Governor and his staff in deciding on a final policy position regarding preclearance. Ultimately, the document was used to advise the Governor on his final policy decisions on preclearance. The document was created prior to a final decision on the Governor's public position on preclearance . As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.~~The email also relates legal advice on administrative preclearance from Secretary of State, Attorney General, and Office of the Governor attorneys. Attorney Travis Richmond is the attorney author and attorneys from the Governor's Office and Secretary of State are recipients. 7/21/2011


TX_00089131

TX_00089145


Travis Richmond

DNP - ATTY CLIENT;D

Draft preclearance submission attachment to TX-00089131 and privileged for the same reasons as the 7/21/2011

OOG STAFF ELECTRO


143


NP - DELIBERATIVE PROCESS PRIVILEGE

email to which it is attached. NIC RECORDS

TX_00089146

TX_00089146

Ann McGeehan, Elizabeth Winn, Erik Wilson, Esperanza Andrade, Coby Shorter, Jeff Boyd, Travis Richmond John Sepehri


This email discusses a draft administrative preclearance submission prepared by attorneys in the Secretay of State office--an executive agency of the State. The document contains reflections of the author regarding preclearance. The document was created to assist the Governor and his staff in deciding on a final policy position regarding preclearance. Ultimately, the document was used to advise the Governor on his final policy decisions on preclearance. The document was created prior to a final decision on the Governor's public position on preclearance . As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.~~The email also relates legal advice on administrative preclearance from Secretary of State, Attorney General, and Office of the Governor attorneys. Attorney John Sepehri is the attorney author and attorneys and staff from the Governor's Office and Secretary of State 7/22/2011



144


are recipients.

TX_00089147

TX_00089161

Ann McGeehan, Elizabeth Winn, Erik Wilson, Esperanza Andrade, Coby Shorter, Jeff Boyd, Travis Richmond John Sepehri




TX_00089162

TX_00089166

Travis Richmond,~Jeff Boyd John Sepehri


This email discusses a draft administrative preclearance submission prepared by attorneys in the Secretay of State office--an executive agency of the State. The document contains reflections of the author regarding preclearance. The document was created to assist the Governor and his staff in deciding on a final policy position regarding preclearance. Ultimately, the document was used to advise the Governor on his final policy decisions on preclearance. The document was created prior to a final decision on the Governor's public position on preclearance . As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the 7/22/2011



145


public, and the document cannot be produced in a redacted form without disclosing privileged information.~~The email also relates legal advice on administrative preclearance from Secretary of State, Attorney General, and Office of the Governor attorneys. Attorney John Sepehri is the attorney author and attorneys from the Governor's Office are recipients.

TX_00089167

TX_00089181

Travis Richmond,~Jeff Boyd John Sepehri




TX_00089182

TX_00089187


Travis Richmond


This email discusses a draft administrative preclearance submission prepared by attorneys in the Secretay of State office--an executive agency of the State. The document contains reflections of the author regarding preclearance. The document was created to assist the Governor and his staff in deciding on a final policy position regarding preclearance. Ultimately, the document was used to advise the Governor on his final policy decisions on preclearance. The document was created prior to a final decision on the Governor's public position on preclearance . As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor 7/25/2011



146


Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.~~The email also relates legal advice on administrative preclearance from Secretary of State, Attorney General, and Office of the Governor attorneys. Attorney Travis Richmond is the attorney author and attorneys from the Governor's Office and Secretary of State are recipients.

TX_00089188

TX_00089189

Travis Richmond,~Jeff Boyd,~Jimmy Blacklock,~Jay Dyer,~Stacey Napier,~David Schenck,~Reed Clay John Sepehri


This email discusses the final administrative preclearance submission prepared by attorneys in the Secretay of State office--an executive agency of the State. The document contains reflections of the author regarding preclearance. The document was created to assist the Governor and his staff in deciding on a final policy position regarding preclearance. Ultimately, the document was used to advise the Governor on his final policy decisions on preclearance. The document was created after a final decision, but contains numerous pre-decision deliberations throughout the email string on preclearance . As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be 7/26/2011



147


produced in a redacted form without disclosing privileged information.~~The email also relates legal advice on administrative preclearance from Secretary of State, Attorney General, and Office of the Governor attorneys. Attorney John Sepehri is the attorney author and attorneys from the Governor's Office, Office of the Attorney General, and Secretary of State are recipients.

TX_00089224

TX_00089225

Jeff Boyd,~Denise Davis,~Blaine Brunson Daniel Hodge


This email discusses the constitutionality of Section 5. The document contains reflections of the author regarding Section 5's constitutionality. The document was created to assist the Governor and his staff in deciding on a final policy position regarding preclearance. Ultimately, the document was used to advise the Governor on his final policy decisions on preclearance. The document was created prior to a final decision on the Governor's public position on preclearance . As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.~~The email also relates legal advice on the constitutionality of Section 5. Attorney Daniel Hodge from the Attorney General's Office is the author. 8/26/2011


TX_00089 TX_00089 Jeff Boyd John Sepehri DNP - This email discusses the administrative 8/29/2011 OOG


148


226 227 ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE

preclearance process. The document contains reflections of the author regarding Section 5's constitutionality. The document was created to assist the Governor and his staff in deciding on a final policy position regarding preclearance. Ultimately, the document was used to advise the Governor on his final policy decisions on preclearance. The document was created prior to a final decision on the Governor's public position on preclearance . As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.~~The email also relates legal advice on administrative preclearance. Attorney John Sepehri from the Secretary of State's office is the author and Jeff Boyd is the recipient.


TX_00089229

TX_00089229

Jay Dyer,~John Sepehri,~Richard Parsons

Ann McGeehan

DNP - ATTY CLIENT

This document is an email sent for the purpose of giving or seeking legal advice on the progress of the administrative preclearance process. Attorney Ann McGeehan of the Secretary of State's office is the author of the email and attorneys Jay Dyer and John Sepehri of the Office of the Attorney General and Secretary of State's office are among the recipients. 9/23/2011


TX_00089 TX_00089 David Daniel Hodge DNP - This document is an email sent for the 11/8/2011 OOG


149


233 233 Morales, Jeff Boyd, Doug Davis, Denise Davis, Blaine Brunson.

ATTY CLIENT

purpose of giving or seeking legal advice on the progress of the administrative preclearance process. Attorney Daniel Hodge of the Attorney General is the author of the email.


TX_00089234

TX_00089235

Coby Shorter,~Kathy Walt Jeff Boyd


This email discusses the MOVE Act requirements. The document contains opinions, advice, and reflections of the author regarding MOVE Act requirements. The document was created to assist the Governor and his staff in deciding on actions it must take to facilitate MOVE act compliance. Ultimately, the document was used to advise the Governor on his final policy decisions on MOVE Act Compliance. The document was created prior to a final decision on MOVE Act Compliance . As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.~~The email also relates legal advice on Move Act Compliance. Attorney Jeff Boyd to Coby Shorter and Kathy Walt. 12/2/2011


TX_00089236


Blaine Brunson


This email discusses the Texas primaries. The document contains opinions, advice, and reflections of the author regarding bifurcated primaries. 12/13/2011

OOG STAFF ELECTRONIC


150



The document was created to assist the Governor and his staff in deciding its position on bifurcated primaries. Ultimately, the document was used to advise the Governor on his final policy decisions on bifurcated primaries The document was created prior to a final decision on bifurcated primaries . As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.~~The email also relates legal advice on bifurcated primaries. Blaine Brunson is the author and attorney Jeff Boyd is the recipient.

RECORDS

TX_00089239

TX_00089239

Jeff Boyd,~Blaine Brunson, Daniel Hodge


This email discusses the administrative preclearance process. The document contains reflections of the author regarding Section 5's constitutionality. The document was created to assist the Governor and his staff in deciding on a final policy position regarding preclearance. Ultimately, the document was used to advise the Governor on his final policy decisions on preclearance. The document was created prior to a final decision on the Governor's public position on preclearance . As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed 12/23/2011



151


and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.~~The email also relates legal advice on administrative preclearance. Attorney Daniel Hodge is the author of the email

TX_00089240

TX_00089240

Coby Shorter, Jimmy Blacklock, Daniel Hodge, Ken Armbrister Jeff Boyd


This email discusses the administrative preclearance process. The document contains reflections of the author regarding Section 5's constitutionality. The document was created to assist the Governor and his staff in deciding on a final policy position regarding preclearance. Ultimately, the document was used to advise the Governor on his final policy decisions on preclearance. The document was created prior to a final decision on the Governor's public position on preclearance . As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was reviewed and relied upon by Office of the Governor Staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.~~The email also relates legal advice on administrative preclearance. Attorney Jeff Boyd is the author of the email 1/12/2012


TX_00089241

TX_00089250

DNP - ATTY

Attachment to TX_0089240 containing edits to an email responsive to a DOJ 1/12/2012

OOG STAFF


152


CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE

request for information and privileged for the same reasons as the email to which it is attached.

ELECTRONIC RECORDS

TX_00089251

TX_00089252

OOG Press Office; Jonathan Hurst; Jeff Boyd; Ken Armbrister; Mike Morrissey Steffany Duke


Confidential e-mail communication between OOG Press staff and OOG Chief of Staff and Attorney Jeff Boyd sent for the purposes of seeking legal advice regarding legislative summaries and effective dates.~~This document consists of an e-mail communication between OOG Press Assistant Steffany Duke and OOG Executives and Press Office staff regarding the drafting of a press statement summarizing legislation going into effect from the 82nd legislature that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding suggested edits to the Press Release. The document was created to assist the Governor and his staff in formulating a Press Release summarizing important legislation passed during the 82nd legislature. Ultimately, the document was used to advise the Governor's Press Office in formulating a final press release summarizing important legislation passed during the 82nd legislature and the effective dates of each. The document was created prior to creation and issuance of a final press release issued by the Governor's Office. As such,



153


the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00089253

TX_00089254

OOG Press Office; Jonathan Hurst; Jeff Boyd; Ken Armbrister; Mike Morrissey Steffany Duke


Attachment to above confidential attorne-client e-mail communication (TX_00089251) sent for the purposes of seeking legal advice legislative summaries and effective dates.~~This document consists of a draft press release prepared by OOG Press Assistant Steffany Duke summarizing notable legislation passed during 82nd legislature that was deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding the format and substance of the Press Statement. The document was created to assist the Governor and his staff in formulating a Press Release summarizing important legislation passed during the 82nd legislature. Ultimately, the document was used to advise the Governor's Press Office in formulating a final press release summarizing important legislation passed during the 82nd legislature and the effective dates of each. The



154


document was created prior to creation and issuance of a final press release issued by the Governor's Office. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00089255

TX_00089256

Steffany Duke; OOG Office staff; Jeff Boyd; Ken Armbrister; Mike Morrissey

Jonathan Hurst


Confidential e-mail communication between OOG Director and OOG Chief of Staff and Attorney Jeff Boyd sent for purposes of seeking legal advice regarding legislative summaries and effective dates.~~This document consists of e-mail communications between OOG Director Jonathan Hurst and OOG Executives and Press Office staff regarding edits to a draft Press Release summarizing legislation passed during the 82nd legislature that was deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding suggested edits to the Press Release. The document was created to assist the Governor and his staff in formulating a Press Release summarizing important legislation passed during the 82nd legislature. Ultimately, the document was used to



155


advise the Governor's Press Office in formulating a final press release summarizing important legislation passed during the 82nd legislature and the effective dates of each. The document was created prior to creation and issuance of a final Press Release from the Governor's Office regarding the legislation addressed in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00089257

TX_00089258

Jonathan Hurst; Steffany Duke; OOG Press Office; Jeff Boyd; Ken Armbrister; Mike Morrissey

Matthew Thompson


Confidential e-mail communication between OOG Speechwriter and OOG Chief of Staff and Attorney Jeff Boyd sent for the purposes of seeking legal advice regarding implementation of SB 14.~~This document consists of an e-mail communication between OOG Speechwriter Matthew thompson and OOG Chief of Staff, Executives and Press Office staff regarding the drafting of a Press Release summarizing legislation going into effect from the 82nd legislature that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author



156


regarding suggested edits to the Press Release and the legislation summarized therein. The document was created to assist the Governor and his staff in formulating a Press Release summarizing important legislation passed during the 82nd legislature. Ultimately, the document was used to advise the Governor's Press Office in formulating a final press release summarizing important legislation passed during the 82nd legislature and the effective dates of each. The document was created prior to creation and issuance of a final press release issued by the Governor's Office. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00089259

TX_00089261

Matthew Thompson; Jonathan Jurst; OOG Press Office; Jeff Boyd; Steffany Duke


Confidential e-mail communication between OOG Press staff and OOG Chief of Staff and Attorney Jeff Boyd sent for the purposes of seeking legal advice regarding implementation of SB 14.~~This document consists of an e-mail communication between OOG Press staff Steffany Duke and OOG Chief of Staff, Executives and Press Office staff



157


Ken Armbrister; Mike Morrissey

regarding the drafting of a Press Release summarizing legislation going into effect from the 82nd legislature that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding suggested edits to the Press Release and the legislation summarized therein. The document was created to assist the Governor and his staff in formulating a Press Release summarizing important legislation passed during the 82nd legislature. Ultimately, the document was used to advise the Governor's Press Office in formulating a final press release summarizing important legislation passed during the 82nd legislature and the effective dates of each. The document was created prior to creation and issuance of a final press release issued by the Governor's Office. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00089262

TX_00089264

Matthew Thompson;

Jonathan Hurst

DNP - ATTY CLIENT;D

Confidential e-mail communication between OOG Director of Budget, Planning and Policy Jonathan Hurst and

OOG STAFF ELECTRO


158


Steffany Duke; OOG Press Office; Jeff Boyd; Ken Armbrister; Mike Morrissey

NP - DELIBERATIVE PROCESS PRIVILEGE

OOG Chief of Staff and Attorney Jeff Boyd sent for the purposes of seeking legal advice regarding the implementation of SB 14.~~This document consists of an e-mail communication between OOG Director Jonathan Hurst and OOG Chief of Staff, Executives and Press Office staff regarding the drafting of a Press Release summarizing legislation going into effect from the 82nd legislature that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding suggested edits to the Press Release and the legislation summarized therein. The document was created to assist the Governor and his staff in formulating a Press Release summarizing important legislation passed during the 82nd legislature. Ultimately, the document was used to advise the Governor's Press Office in formulating a final press release summarizing important legislation passed during the 82nd legislature and the effective dates of each. The document was created prior to creation and issuance of a final press release issued by the Governor's Office. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the

NIC RECORDS


159


Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00089265

TX_00089266

Jonathan Hurst; OOG Press Office; Jeff Boyd; Ken Armbrister; Mike Morrissey Steffany Duke


Confidential e-mail communication between OOG Press Office staffer Steffany Duke and OOG Chief of Staff and Attorney Jeff Boyd sent for the purposes of seeking legal advice regarding legislative summaries and effective dates.~~This document consists of an e-mail communication between OOG Press staff and OOG Chief of Staff, Executives and Press Office staff regarding the drafting of a Press Release summarizing legislation going into effect from the 82nd legislature that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding suggested edits to the Press Release and the legislation summarized therein. The document was created to assist the Governor and his staff in formulating a Press Release summarizing important legislation passed during the 82nd legislature. Ultimately, the document was used to advise the Governor's Press Office in formulating a final press release summarizing important legislation passed during the 82nd legislature and the effective dates of each. The document was created prior to creation and issuance of a final press release issued by the Governor's Office. As such, the document does not memorialize or



160


evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00089267

TX_00089268



Attachment to above confidential attorney-client communication (TX_00089265) between OOG Press Staff and OOG CHief of Staff and Attorney Jeff Boyd sent for the purposes of seeking legal advice regarding legislative summaries and effective dates.~~This document consists of a draft Press Release prepared by OOG Press Office staffer Steffany Duke summarizing legislation passed during 82nd legislature that was deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding suggested edits to the Press Release and the legislation summarized therein. The document was created to assist the Governor and his staff in formulating a Press Release summarizing important legislation passed during the 82nd legislature. Ultimately, the document was used to advise the Governor's Press Office in formulating a final press release summarizing important legislation



161


passed during the 82nd legislature and the effective dates of each. The document was created prior to creation and issuance of a final press release issued by the Governor's Office. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00089269

TX_00089270

Steffany Duke; OOG Press Office; Jeff Boyd; Ken Armbrister; Mike Morrissey

Jonathan Hurst


Confidential e-mail communication between OOG Director of Budget, Planning and Policy Jonathan Hurst and OOG Chief of Staff and Attorney Jeff Boyd sent for the purposes of seeking legal advice regarding legislative summaries and effective dates.~~This document consists of an e-mail communication between OOG Director Jonathan Hurst and OOG Chief of Staff, Executives and Press Office staff regarding the drafting of a Press Release summarizing legislation going into effect from the 82nd legislature that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding suggested edits to the Press Release and the legislation summarized therein. The



162


document was created to assist the Governor and his staff in formulating a Press Release summarizing important legislation passed during the 82nd legislature. Ultimately, the document was used to advise the Governor's Press Office in formulating a final press release summarizing important legislation passed during the 82nd legislature and the effective dates of each. The document was created prior to creation and issuance of a final press release issued by the Governor's Office. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00089271

TX_00089271

Allison Castle; Stephanie Duke; Jonathan Hurst; Kathy Walt Jeff Boyd


Confidential e-mail communication from OOG Chief of Staff and Attorney Jeff Boyd to OOG Executives and Press Office Staff sent for the purposes of providing legal advice regarding legislative summaries and effective dates.~~This document consists of an e-mail communication between OOG Chief of Staff Jeff Boyd and OOG Executives and Press Office staff regarding the drafting of a Press Release summarizing legislation going into effect from the 82nd



163


legislature that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding suggested edits to the Press Release and the legislation summarized therein. The document was created to assist the Governor and his staff in formulating a Press Release summarizing important legislation passed during the 82nd legislature. Ultimately, the document was used to advise the Governor's Press Office in formulating a final press release summarizing important legislation passed during the 82nd legislature and the effective dates of each. The document was created prior to creation and issuance of a final press release issued by the Governor's Office. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00089272

TX_00089273

Allison Castle; Stephanie Duke; Jonathan Jeff Boyd

DNP - ATTY CLIENT;DNP - DELIBERA

Attachment to above confidential attorney-client communication (TX_00089271) between OOG Chief of Staff and Attorney Jeff Boyd and OOG Executives and Press Office staff sent for



164


Hurst; Kathy Walt


the purposes of seeking legal advice regarding legislative summaries and effective dates.~~This document consists of a draft Press Release prepared by OOG Press Office staffer Steffany Duke summarizing legislation passed during 82nd legislature that was deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding suggested edits to the Press Release and the legislation summarized therein. The document was created to assist the Governor and his staff in formulating a Press Release summarizing important legislation passed during the 82nd legislature. Ultimately, the document was used to advise the Governor's Press Office in formulating a final press release summarizing important legislation passed during the 82nd legislature and the effective dates of each. The document was created prior to creation and issuance of a final press release issued by the Governor's Office. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without


165


disclosing privileged information.

TX_00089274

TX_00089276

Steffany Duke; Matthew Thompson; Jonathan Hurst; OOG Press Office; Ken Armbrister; Mike Morrissey; Kathy Walt Jeff Boyd


Confidential e-mail communication from OOG Chief of Staff and Attorney Jeff Boyd to OOG Executives and Press Office Staff sent for the purposes of providing legal advice regarding legislative summaries and effective dates.~~This document consists of an e-mail communication between OOG Chief of Staff Jeff Boyd and OOG Executives and Press Office staff regarding the drafting of a Press Release summarizing legislation going into effect from the 82nd legislature that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding suggested edits to the Press Release and the legislation summarized therein. The document was created to assist the Governor and his staff in formulating a Press Release summarizing important legislation passed during the 82nd legislature. Ultimately, the document was used to advise the Governor's Press Office in formulating a final press release summarizing important legislation passed during the 82nd legislature and the effective dates of each. The document was created prior to creation and issuance of a final press release issued by the Governor's Office. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the



166


Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00089277

TX_00089278

Steffany Duke; Matthew Thompson; Jonathan Hurst; OOG Press Office; Ken Armbrister; Mike Morrissey; Kathy Walt Jeff Boyd


Attachment to above confidential attorney-client communication (TX_00089274) from OOG Chief of Staff and Attorney Jeff Boyd to OOG Executives and Pres Office staff sent for the purposes of providing legal advice regarding legislative summaries and effective dates.~~This document consists of a draft Press Release prepared by OOG Chief of Staff Jeff Boyd summarizing legislation passed during 82nd legislature that was deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding suggested edits to the Press Release and the legislation summarized therein. The document was created to assist the Governor and his staff in formulating a Press Release summarizing important legislation passed during the 82nd legislature. Ultimately, the document was used to advise the Governor's Press Office in formulating a final press release summarizing important legislation passed during the 82nd legislature and the effective dates of each. The document was created prior to creation and issuance of a final press release



167


issued by the Governor's Office. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00089279

TX_00089280



Confidential e-mail communication between OOG Press Office staff Steffany Duke and OOG Chief of Staff and Attorney Jeff Boyd sent for the purposes of seeking legal advice regarding legislative summaries and effective dates.~~This document consists of an e-mail communication between OOG Press Office Staffer Steffany Duke and OOG Chief of Staff, Executives and Press Office staff regarding the drafting of a Press Release summarizing legislation going into effect from the 82nd legislature that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding suggested edits to the Press Release and the legislation summarized therein. The document was created to assist the Governor and his staff in formulating a Press Release summarizing important legislation passed during the 82nd legislature.



168


Ultimately, the document was used to advise the Governor's Press Office in formulating a final press release summarizing important legislation passed during the 82nd legislature and the effective dates of each. The document was created prior to creation and issuance of a final press release issued by the Governor's Office. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00089281

TX_00089283

Jeff Boyd; Steffany Duke; Matthew Thompson; Jonathan Hurst; OOG Press Office; Ken Armbrister; Mike Morrissey; Kathy

Catherine Frazier


Confidential e-mail communication between OOG Press Secretary Catherine Frazier and OOG Chief of Staff and Attorney Jeff Boyd sent for the purposes of seeking legal advice regarding legislative summaries and effective dates.~~This document consists of an e-mail communication between OOG Press Secretary Catherine Frazier and OOG Chief of Staff, Executives and Press Office staff regarding the drafting of a Press Release summarizing legislation going into effect from the 82nd legislature that were deemed important by the Governor's policy advisers. The document contains the advice, opinion,



169


Walt and recommendations of the author regarding suggested edits to the Press Release and the legislation summarized therein. The document was created to assist the Governor and his staff in formulating a Press Release summarizing important legislation passed during the 82nd legislature. Ultimately, the document was used to advise the Governor's Press Office in formulating a final press release summarizing important legislation passed during the 82nd legislature and the effective dates of each. The document was created prior to creation and issuance of a final press release issued by the Governor's Office. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00089284

TX_00089285

Jeff Boyd; Steffany Duke; Matthew Thompson; Jonathan Hurst;

Catherine Frazier

DNP - ATTY CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEG

Attachment to above confidential attorney-client communication (TX_00089281) from by OOG Press Secretary Catherine Frazier to OOG Chief of Staff and Attorney Jeff Boyd sent for the purposes of seeking legal advice regarding legislative summaries and effective dates.~~This document



170


OOG Press Office; Ken Armbrister; Mike Morrissey; Kathy Walt

E consists of a draft Press Release prepared by OOG Press Secretary Catherine Frazier summarizing legislation passed during 82nd legislature that was deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding suggested edits to the Press Release and the legislation summarized therein. The document was created to assist the Governor and his staff in formulating a Press Release summarizing important legislation passed during the 82nd legislature. Ultimately, the document was used to advise the Governor's Press Office in formulating a final press release summarizing important legislation passed during the 82nd legislature and the effective dates of each. The document was created prior to creation and issuance of a final press release issued by the Governor's Office. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00089286

TX_00089288

Catherine Frazier; Lucy Nashed

DNP - ATTY

Confidential e-mail communication between OOG Deputy Press Secretary

OOG STAFF


171


Jeff Boyd; Steffany Duke; Matthew Thompson; Jonathan Hurst; OOG Press Office; Kem Arbrister; Mike Morrissey; Kathy Walt

CLIENT;DNP - DELIBERATIVE PROCESS PRIVILEGE

Lucy Nashed and OOG Chief of Staff and Attorney Jeff Boyd sent for the purposes of seeking legal advice regarding legislative summaries and effective dates.~~This document consists of an e-mail communication between OOG Deputy Press Secretary Lucy Nashed and OOG Chief of Staff, Executives and Press Office staff regarding the drafting of a Press Release summarizing legislation going into effect from the 82nd legislature that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding suggested edits to the Press Release and the legislation summarized therein. The document was created to assist the Governor and his staff in formulating a Press Release summarizing important legislation passed during the 82nd legislature. Ultimately, the document was used to advise the Governor's Press Office in formulating a final press release summarizing important legislation passed during the 82nd legislature and the effective dates of each. The document was created prior to creation and issuance of a final press release issued by the Governor's Office. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the

ELECTRONIC RECORDS


172


Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00089289

TX_00089290

Catherine Frazier; Jeff Boyd; Steffany Duke; Matthew Thompson; Jonathan Hurst; OOG Press Office; Kem Arbrister; Mike Morrissey; Kathy Walt Lucy Nashed


Attachment to above confidential attorney-client communication (TX_00089286) between OOG Deputy Press Secretary Lucy Nashed and OOG Chief of Staff and Attorney Jeff Boyd sent for the purposes of seeking legal advice regarding legislative summaries and effective dates.~~This document consists of a draft Press Release prepared by OOG Deputy Press Secretary Lucy Nashed summarizing legislation passed during 82nd legislature that was deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding suggested edits to the Press Release and the legislation summarized therein. The document was created to assist the Governor and his staff in formulating a Press Release summarizing important legislation passed during the 82nd legislature. Ultimately, the document was used to advise the Governor's Press Office in formulating a final press release summarizing important legislation passed during the 82nd legislature and the effective dates of each. The document was created prior to creation and issuance of a final press release issued by the Governor's Office. As such, the document does not memorialize



173


or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00089291

TX_00089292

Lucy Nashed; Catherine Frazier; Jeff Boyd; Matthew Thompson; Jonathan Hurst; OOG Press Office, Ken Armbrister; Mike Morrissey; Kathy Walt Steffany Duke


Confidential e-mail communication between OOG Press Office staff Steffany Duke and OOG Chief of Staff and Attorney Jeff Boyd sent for the purposes of seeking legal advice regarding legislative summaries and effective dates.~~This document consists of an e-mail communication between OOG Press Office Staffer Steffany Duke and OOG Chief of Staff, Executives and Press Office staff regarding the drafting of a Press Release summarizing legislation going into effect from the 82nd legislature that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding suggested edits to the Press Release and the legislation summarized therein. The document was created to assist the Governor and his staff in formulating a Press Release summarizing important legislation passed during the 82nd legislature. Ultimately, the document was used to advise the Governor's Press Office in



174


formulating a final press release summarizing important legislation passed during the 82nd legislature and the effective dates of each. The document was created prior to creation and issuance of a final press release issued by the Governor's Office. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00089293

TX_00089294

Lucy Nashed; Catherine Frazier; Jeff Boyd; Matthew Thompson; Jonathan Hurst; OOG Press Office, Ken Armbrister; Mike Morrissey; Kathy

Stephany Duke


Attachment to above confidential attorney-client communication (TX_00089291) between OOG Press Staffer Steffany Duke and OOG Chief of Staff and Attorney Jeff Boyd sent for the purposes of seeking legal advice regarding legislative summaries and effective dates.~~This document consists of a draft Press Release prepared by OOG Press Office staffer Steffany Duke summarizing legislation passed during 82nd legislature that was deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding suggested edits to the Press Release and the legislation summarized therein. The document was



175


Walt created to assist the Governor and his staff in formulating a Press Release summarizing important legislation passed during the 82nd legislature. Ultimately, the document was used to advise the Governor's Press Office in formulating a final press release summarizing important legislation passed during the 82nd legislature and the effective dates of each. The document was created prior to creation and issuance of a final press release issued by the Governor's Office. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00089295

TX_00089296

Lucy Nashed; Catherine Frazier; Jeff Boyd; Matthew Thompson; Jonathan Hurst; OOG Press Steffany Duke


Confidential e-mail communication between OOG Press Office staff Steffany Duke and OOG Chief of Staff and Attorney Jeff Boyd sent for the purposes of seeking legal advice regarding legislative summaries and effective dates.~~This document consists of an e-mail communication between OOG Press Office Staffer Steffany Duke and OOG Chief of Staff, Executives and Press Office staff regarding the drafting of a Press Release summarizing legislation



176


Office; Ken Armbrister; Mike Morrissey; Kathy Walt

going into effect from the 82nd legislature that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding suggested edits to the Press Release and the legislation summarized therein. The document was created to assist the Governor and his staff in formulating a Press Release summarizing important legislation passed during the 82nd legislature. Ultimately, the document was used to advise the Governor's Press Office in formulating a final press release summarizing important legislation passed during the 82nd legislature and the effective dates of each. The document was created prior to creation and issuance of a final press release issued by the Governor's Office. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00089297

TX_00089298

Lucy Nashed; Catherine Frazier; Steffany Duke


Attachment to above confidential attorney-client communication (TX_00089295) from by OOG Chief of Staff and Attorney Jeff Boyd to OOG

OOG STAFF ELECTRONIC


177


Jeff Boyd; Matthew Thompson; Jonathan Hurst; OOG Press Office; Ken Armbrister; Mike Morrissey; Kathy Walt


Executives and Pres Office staff sent for the purposes of providing legal advice regarding legislative summaries and effective dates.~~This document consists of a draft Press Release prepared by OOG Chief of Staff Jeff Boyd summarizing legislation passed during 82nd legislature that was deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding suggested edits to the Press Release and the legislation summarized therein. The document was created to assist the Governor and his staff in formulating a Press Release summarizing important legislation passed during the 82nd legislature. Ultimately, the document was used to advise the Governor's Press Office in formulating a final press release summarizing important legislation passed during the 82nd legislature and the effective dates of each. The document was created prior to creation and issuance of a final press release issued by the Governor's Office. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be

RECORDS


178


produced in a redacted form without disclosing privileged information.

TX_00089299

TX_00089300

Steffany Duke; Lucy Nashed; Catherine Frazier; Jeff Boyd; Jonathan Hurst; OOG Press Office; Ken Armbrister; Mike Morrissey; Kathy Walt

Matthew Thompson


Confidential e-mail communication between OOG Speechwriter Matthew Thompson and OOG Chief of Staff and Attorney Jeff Boyd sent for the purposes of seeking legal advice regarding legislative summaries and effective dates.~~This document consists of e-mail communications between OOG Speechwriter Matthew Thompson and OOG Press Office staff, OOG Director of Comunications, and OOG Deputy Press Secretaries regarding the drafting of a press statement summarizing legislation passed during the 82nd legislature that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding suggested edits to the Press Statement. The document was created to assist the Governor and his staff in formulating a public statement regarding legislative accomplishments from the 82nd legislature. Ultimately, the document was used to advise the Governor's Press Office in formulating a final press statement. The document was created prior to creation and issuance of a final press release issued by the Governor's Office regarding the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the



179


Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00089301

TX_00089302

Steffany Duke; Lucy Nashed; Catherine Frazier; Jeff Boyd; Jonathan Hurst; OOG Press Office; Ken Armbrister; Mike Morrissey; Kathy Walt

Matthew Thompson


Attachment to above confidential attorney-client communication (TX_00089290) between OOG Speeachwriter Matthew Thompson and OOG Chief of Staff and Attorney Jeff Boyd sent for the purposes of seeking legal advice regarding legislative summaries and effective dates.~~This document consists of a draft Press Release prepared by OOG Speechwriter Matthew Thompson summarizing legislation passed during 82nd legislature that was deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding suggested edits to the Press Release and the legislation summarized therein. The document was created to assist the Governor and his staff in formulating a Press Release summarizing important legislation passed during the 82nd legislature. Ultimately, the document was used to advise the Governor's Press Office in formulating a final press release summarizing important legislation passed during the 82nd legislature and the effective dates of each. The document was created prior to creation



180


and issuance of a final press release issued by the Governor's Office. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00089303

TX_00089303

OOG Press Office; Jeff Boyd; Matthew Thompson; Jonathan Hurst; Ken Armbrister; Mike Morrissey Allison Castle


Confidential e-mail communication between OOG Director of Communciations Allison Castle and OOG Chief of Staff and Attorney Jeff Boyd sent for the purposes of seeking legal advice regarding legislative summaries and effective dates.~~This document consists of e-mail communications between OOG Director of Comunications Allison Castle and OOG Executives and Press Office staff regarding the drafting of a Press Release summarizing legislation passed during the 82nd legislature that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding suggested edits to the Press Release. The document was created to assist the Governor and his staff in formulating a public statement regarding legislative accomplishments from the 82nd legislature. Ultimately, the



181


document was used to advise the Governor's Press Office in formulating a final press statement. The document was created prior to creation and issuance of a final press release issued by the Governor's Office regarding the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00089304

TX_00089305

OOG Press Office; Jeff Boyd; Matthew Thompson; Jonathan Hurst; Ken Armbrister; Mike Morrissey Allison Castle


Attachment to above confidential attorney-client communication (TX_00089274) from by OOG Chief of Staff and Attorney Jeff Boyd to OOG Executives and Pres Office staff sent for the purposes of providing legal advice regarding legislative summaries and effective dates.~~This document consists of a draft Press Release prepared by OOG Chief of Staff Jeff Boyd summarizing legislation passed during 82nd legislature that was deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding suggested edits to the Press Release and the legislation summarized therein. The document was



182


created to assist the Governor and his staff in formulating a Press Release summarizing important legislation passed during the 82nd legislature. Ultimately, the document was used to advise the Governor's Press Office in formulating a final press release summarizing important legislation passed during the 82nd legislature and the effective dates of each. The document was created prior to creation and issuance of a final press release issued by the Governor's Office. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00089306

TX_00089307

Becky Dean;~Lucy Nashed;~Allison Castle;~Jeff Boyd;~Governor's Press Office;~Mary Anne Steffany Duke


This document consists of e-mail communications between OOG Press Office staff and Deputy Press Secretaries regarding the preparation of a press release summarizing legislation passed during the 82nd legislature that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his



183


Wiley staff in formulating a public statement regarding legislative accomplishments from the 82nd legislature. Ultimately, the document was used to advise the Governor's Press Secretaries in formulating a final press statement. The document was created prior to creation and issuance of a final press release issued by the Governor's Office regarding the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00089308

TX_00089309

Becky Dean;~Lucy Nashed;~Allison Castle;~Jeff Boyd;~Governor's Press Office;~Mary Anne Wiley Steffany Duke


Attachment to above confidential e-mail communication (TX_00089306) between OOG Press Staff and OOG Chief of Staff and Attorney Jeff Boyd sent for the purposes of seeking legal advice regarding legsilative summaries and effective dates.~~This document consists of a draft press release prepared by OOG Press Assistant Steffany Duke regarding legislation passed during 82nd legislature that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The



184


document was created to assist the Governor and his staff in formulating a public statement regarding legislative accomplishments from the 82nd legislature. Ultimately, the document was used to advise the Governor's Press Secretaries in formulating a final press statement. The document was created prior to creation and issuance of a final press release issued by the Governor's Office regarding the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00089310

TX_00089310

Allison Castle; Lucy Nashed; Josh Havens

Matthew Thompson


This document consists of e-mail communications between OOG Deputy Press Secretaries and OOG Press staff regarding media requests for a comment by the Governor on letters submitted to DOJ opposing the preclearance of SB 14 that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain media responses by the Governor. The document was created to assist the Governor and his staff in



185


deciding whether to issue a press statement in response to the media inquery. Ultimately, the document was used to advise the Governor on his decision to issue a press statement responding to SB 14 preclearance opposition. The document was created prior to a final decision by the Governor whether to issue a press statement responding to the request for commentary at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00089311

TX_00089312

Matthew Thompson;~Allison Castle; Josh Havens Lucy Nashed


This document consists of e-mail communications between OOG Deputy Press Secretaries and OOG Press staff regarding media requests for comments from the Governor on letters submitted to DOJ opposing the preclearance of SB 14 that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain media responses by the Governor. The document was created to assist the Governor and his staff in deciding whether to issue a press



186


statement in response to the media inquery. Ultimately, the document was used to advise the Governor on his decision to issue a press statement responding to SB 14 preclearance opposition. The document was created prior to a final decision by the Governor whether to issue a press statement responding to the request for commentary at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00089313

TX_00089314

Lucy Nashed; Jeff Boyd; Mary Anne Wiley; Kathy Walt; Josh Havens; Matthew Thompson; Ken Armbrister; Allison Castle


Confidential, internal e-mail communication from OOG Deputy Press Secreatry to The Governor's Chief of Staff and Attorney Jeff Boyd and Deputy General Counsel sent for the purposes of requesting legal advice regarding challenges to SB 14 preclearance. ~~This document consists of e-mail communications from the OOG Deputy Press Secretary to the Governor's Chief of Staff, Deputy General Counsel, and the OOG Press Office and Communication staff regarding a potential response to media attacks on Voter ID that were deemed important by



187


Jonathan Hurst; Steffany Duke

the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding SB 14. The document was created to assist the Governor and his staff in deciding whether to issue a press statement responding to the media attacks. Ultimately, the document was used to advise the Governor on his decision to issue a press statement. The document was created prior to a final decision by the Governor whether to issue a press statement regarding the media attacks at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00089315

TX_00089316

Allison Castle

Jonathan Hurst


This document consists of e-mail communications from the OOG Director or Budget, Planning and Policy Honathen Hurst to OOG Deputy Press Secretary Allison Castle regarding a potential response to statements submitted to the DOJ opposing preclearance of SB 14. The document contains the advice, opinion, and recommendations of the author regarding an appropriate media response. The



188


document was created to assist the Governor and his staff in deciding whether to issue a press statement responding to statements in opposition of SB 14 preclearance. Ultimately, the document was used to advise the Governor on his decision to issue a press statement. The document was created prior to a final decision by the Governor whether to issue a press statement regarding the statements in opposition to SB 14 at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00089317

TX_00089317

Allison Castle Lucy Nashed


This document consists of an e-mail communication between the Governor's Deputy Press Secretary and the Governor's Director of Communications regarding potentnail responses to media commentary attacking SB 14 that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain media responses. The document was created to assist the Governor and his staff in deciding whether to issue a



189


press statement in response to the media attacks on SB 14. Ultimately, the document was used to advise the Governor on his decision to issue a press statement responding to media commentary. The document was created prior to a final decision by the Governor whether to issue a press statement responding to the attacks on SB 14 at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00089318

TX_00089319

Allison Castle; Lucy Nached; Mary Anne Wiley; Kathy Walt; Josh Havens; Matthew Thompson; Ken Armbrist Jeff Boyd


Confidential, internal e-mail communication from OOG Chief of Staff and Attorney Jeff Boyd to OOG staff and policy advisors sent for the purposes of providing legal advice regarding the application of SB 14. ~~This document consists of e-mail communications between the Governor's Chief of Staff, Deputy General Counsel, Deputy Press Secretary, and OOG Press Division staff regarding media responses to media commentary about Voter ID that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and



190


er; Jonathan Hurst; Steffany Duke

recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to issue a press statement in response to the media commentary. Ultimately, the document was used to advise the Governor on his decision to issue a press statement responding to attacks on SB 14. The document was created prior to a final decision by the Governor whether to issue a press statement regarding the media commentary at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00089320

TX_00089320

OOG Press Office Josh Havens


This document consists of e-mail communications between the Governor's Deputy Press Secretary and the OOG Press Division regarding media responses to media inqueries about the Governor's expectations regarding the DOJ's potential preclearance determination for SB 14 that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and



191


recommendations of the author regarding certain media responses. The document was created to assist the Governor and his staff in deciding whether to issue a press statement in response to the media inquery. Ultimately, the document was used to advise the Governor on his decision to issue a press statement refusing to comment until a preclearance determination has been made. The document was created prior to a final decision by the Governor whether to issue a press statement responding to the media inquery at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00089321

TX_00089321

OOG Press Office;~Brandy Marty;~Jeff Boyd

Catherine Frazier


This document consists of e-mail communications between the Governor's Chief of Staff and Deputy Chief of Staff, Press Secretary, and the OOG Press Division regarding media responses to DOJ's denial of preclearance for SB 14 that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The



192


document was created to assist the Governor and his staff in deciding whether to issue a press statement in response to the denial of preclearance. Ultimately, the document was used to advise the Governor on his decision to issue a press statement condemning the DOJ's actions. The document was created prior to a final decision by the Governor whether to issue a press statement regarding the DOJ's preclearance determination at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00089322

TX_00089322

Catherine Frazier;~OOG Press Office;~Brendy Marty;~Jeff Boyd

Catherine Frazier


This document consists of e-mail communications between the Governor's Chief of Staff and Deputy Chief of Staff, Press Secretary, and the OOG Press Division regarding media responses to DOJ's denial of preclearance for SB 14 that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the



193


Governor and his staff in deciding whether to issue a press statement in response to the denial of preclearance. Ultimately, the document was used to advise the Governor on his decision to issue a press statement condemning the DOJ's actions. The document was created prior to a final decision by the Governor whether to issue a press statement regarding the DOJ's preclearance determination at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00089323

TX_00089324

Governor's Office Press Division; Governor's Office Budget, Panning and Policy Division staff; and Governor' Dan Wilmot


This document consists of e-mail communications between OOG policy advisors and staff regarding media responses to the debate over federal health care funding in Texas that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain media articles. The document was created to assist the Governor and his staff in deciding whether to issue a response to the media article at issue in



194


s Office Federal Relations Division staff

the document. Ultimately, the document was used to advise the Governor on his decision whether to release a press statement on the issue. The document was created prior to a final decision by the Governor whether to issue a statement to the press clarifying the facts regarding federal health care funding at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.

TX_00089325

TX_00089327

Governor's Office Press Division Lucy Nashed


This document consists of e-mail communications between OOG staff regarding media responses to ongoing political debates concerning federal health care funding and state Voter ID and redistricting lawsuits that were deemed important by the Governor's policy advisers. The document contains the advice, opinion, and recommendations of the author regarding certain legislation. The document was created to assist the Governor and his staff in deciding whether to support or oppose the legislation at issue in the document. Ultimately, the document was used to advise the Governor on his



195


decision whether to veto or sign a bill. The document was created prior to a final decision by the Governor whether to veto or sign the legislation at issue in the document. As such, the document does not memorialize or evidence the Office of the Governor's final policy. The document was placed in a shared internal network accessible to executive and other Office of the Governor staff. The document was reviewed and relied upon by Office of the Governor staff as part of the Office of the Governor's decision-making process. The document was not shared with the public, and the document cannot be produced in a redacted form without disclosing privileged information.


196


1

State of Texas v. Eric Holder, Jr., Attorney General of the United States

Case No. 1:12-cv-00128

United States District Court for the District of Columbia

TEXAS LEGISLATIVE COUNCIL

SECOND REVISED PRIVILEGE LOG

May 23, 2012

Beginning Beginning Beginning Beginning Doc. NumberDoc. NumberDoc. NumberDoc. Number

End Doc. End Doc. End Doc. End Doc. NumberNumberNumberNumber

Basis for Basis for Basis for Basis for WithholdingWithholdingWithholdingWithholding DescriptionDescriptionDescriptionDescription DateDateDateDate SourcesSourcesSourcesSources

Sender / Sender / Sender / Sender / AuthorAuthorAuthorAuthor RecipientRecipientRecipientRecipient

TX_00041842 TX_00041845

Attorney-Client Privilege; Legislative Privilege

Document responsive to a public information law request that was provided to the council in order to obtain legal advice regarding the request. Reflects legislator thoughts, opinions, or mental impressions on Voter ID. 11/29/2011

TLC (LEGAL DIVISION)

Colby Beuck (Atty.) (Rep. Harless)

Ross Giesinger (Atty.)

TX_00041846 TX_00041846






Case 1:12-cv-00128-RMC-DST-RLW Document 139-2 Filed 05/23/12 Page 1 of 181Case 1:12-cv-00128-RMC-DST-RLW Document 152-4 Filed 05/25/12 Page 1 of 181

2

TX_00041847 TX_00041847






TX_00041848 TX_00041848






TX_00041849 TX_00041850







3

TX_00041851 TX_00041853






TX_00041854 TX_00041855






TX_00041856 TX_00041859







4

TX_00041860 TX_00041862






TX_00041863 TX_00041865






TX_00041866 TX_00041868







5

TX_00041869 TX_00041871






TX_00041872 TX_00041874






TX_00041875 TX_00041875







6

TX_00041876 TX_00041880






TX_00041881 TX_00041884






TX_00041885 TX_00041887







7

TX_00041888 TX_00041889


Document responsive to a public information law request that was provided to the council in order to obtain legal advice regarding the request. Reflects legislator thoughts, opinions, or mental impressions on Voter ID. Reflects legislator thoughts, opinions, or mental impressions on Voter ID. 11/29/2011




TX_00041890 TX_00041894






TX_00041895 TX_00041896







8

TX_00041897 TX_00041947






TX_00041948 TX_00042058






TX_00042059 TX_00042059







9

TX_00042060 TX_00042111






TX_00042138 TX_00042138


Confidential legal analysis of compliance with legislative rules and the Texas Constitution prepared by an attorney that was requested by and provided to legislative clients separately and independently.

(82nd Legislature)


Jennifer Jackson (Atty.)

Karina Davis (Senate Parliamentarian) & Chris Griesel (House Parliamentarian/Atty.)

TX_00042139 TX_00042141


Notes re: telephone discussions seeking legal advice on legislative drafting. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.

(82nd Legislature)



Sen. Lucio; Rep. Y. Davis; Rep. Harless (Rep. Y. Davis has waived privileges.)

TX_00042142 TX_00042142


Notes re: telephone discussions seeking legal advice on legislative drafting. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.

12/15/2010 (82nd

Legislature) TLC (LEGAL DIVISION)


Rep. Todd Smith


10

TX_00042143 TX_00042143


Confidential legal analysis of compliance with legislative rules and the Texas Constitution prepared by an attorney that was requested by and provided to legislative clients separately and independently. (Part.)

5/5/2011 (82nd




TX_00042144 TX_00042144



5/5/2011 (82nd




TX_00042145 TX_00042145


Confidential communication among TLC attorneys containing legal research on Voter ID laws in other states.

3/11/2011 (82nd



Anne Peters (Atty.)

TX_00042146 TX_00042146



5/5/2011 (82nd





11

TX_00042147 TX_00042147



5/5/2011 (82nd




TX_00042151 TX_00042154 Legislative Privilege

Drafting file for house committee-hearing stage analysis of SB 14 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill as required by house rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.

2/25/2011 (82nd

Legislature)

TLC (RESEARCH DIVISION) Liz Morris Rep. Bonnen


Drafting file for house committee-hearing stage analysis of SB 14 documenting information relating to the production of confidential proposed detailed analysis of the

2/25/2011 (82nd

Legislature)



12

subject matter and other content of a bill as required by house rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.



2/23/2011 (82nd

Legislature)



Drafting file for house committee-hearing stage analysis of SB 14 documenting information relating to the production of

2/25/2011 (82nd

Legislature)



13

confidential proposed detailed analysis of the subject matter and other content of a bill as required by house rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.



2/23/2011 (82nd

Legislature)



14



2/25/2011 (82nd

Legislature)



Drafting file for house committee-hearing stage analysis of SB 14 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill as required by house rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental

2/25/2011 (82nd

Legislature)



15

impressions on Voter ID.



2/23/2011 (82nd

Legislature)



Drafting file for house committee-hearing stage analysis of SB 14 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill as required by house rules and that was requested by and

2/25/2011 (82nd

Legislature)



16

provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.



2/23/2011 (82nd

Legislature)



Drafting file for house second-reading stage analysis of SB 14 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill as required by house

3/15/2011 (82nd

Legislature)



17

rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.


Drafting file for house second-reading stage analysis of SB 14 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill as required by house rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.

3/10/2011 (82nd

Legislature)



Drafting file for house second-reading stage analysis of SB 14 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and

3/10/2011 (82nd

Legislature)



18

other content of a bill as required by house rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.



3/21/2011 (82nd

Legislature)



Drafting file for house second-reading stage analysis of SB 14 documenting information relating to the production of confidential proposed

3/15/2011 (82nd

Legislature)



19

detailed analysis of the subject matter and other content of a bill as required by house rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.



3/15/2011 (82nd

Legislature)



Drafting file for house second-reading stage analysis of SB 14 documenting information relating to

3/10/2011 (82nd

Legislature)



20

the production of confidential proposed detailed analysis of the subject matter and other content of a bill as required by house rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.



3/15/2011 (82nd

Legislature)



21



3/21/2011 (82nd

Legislature)



Drafting file for house second-reading stage analysis of SB 14 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill as required by house rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental

3/21/2011 (82nd

Legislature)



22




3/21/2011 (82nd

Legislature)



Drafting file for house second-reading stage analysis of SB 14 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill as required by house rules and that was requested by and provided to the

3/10/2011 (82nd

Legislature)



23

legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.



(82nd Legislature)



Drafting file for house second-reading stage analysis of SB 14 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill as required by house rules and that was

3/21/2011 (82nd

Legislature)



24

requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.



2/25/2011 (82nd

Legislature)


TX_00042289 TX_00042308


Drafting file for house committee-stage analysis of SB 14 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill

2/25/2011 (82nd

Legislature)

TLC (RESEARCH DIVISION) Liz Morris Sen. Fraser


25

as required by house rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.


Conference committee report side-by-side drafting file reflecting legislator communications. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.

4/18/2011 (82nd

Legislature)




4/27/2011 (82nd

Legislature)



Conference committee report side-by-side drafting file reflecting legislator communications. (Part.) Reflects legislator thoughts, opinions, or mental

4/29/2011 (82nd

Legislature)



26




4/29/2011 (82nd

Legislature)




4/27/2011 (82nd

Legislature)




4/27/2011 (82nd

Legislature)



Conference committee report side-by-side drafting file reflecting legislator

4/27/2011 (82nd

Legislature)



27

communications. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.



4/27/2011 (82nd

Legislature)






Drafting file for house second-reading stage analysis of SB 14 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill as required by house rules and that was

3/15/2011 (82nd

Legislature)



28




3/21/2011 (82nd

Legislature)



Drafting file for house second-reading stage analysis of SB 14 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill

3/25/2011 (82nd

Legislature)



29




3/15/2011 (82nd

Legislature)



Drafting file for house second-reading stage analysis of SB 14 documenting information relating to the production of confidential proposed detailed analysis of the

3/15/2011 (82nd

Legislature)



30




3/15/2011 (82nd

Legislature)

TLC (RESEARCH DIVISION)

Liz Morris; Jennifer Jackson (Atty.) Rep. Bonnen


Drafting file for house second-reading stage analysis of SB 14 documenting information relating to the production of

3/15/2011 (82nd

Legislature)



31




3/15/2011 (82nd

Legislature)



Drafting file for house committee stage analysis of SB 14 documenting

2/25/2011 (82nd

Legislature)



32

information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill as required by house rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.



2/25/2011 (82nd

Legislature)



33



2/25/2011 (82nd

Legislature)



Drafting file for house second-reading stage analysis of SB 14 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill as required by house rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental

2/25/2011 (82nd

Legislature)



34




2/25/2011 (82nd

Legislature)



Drafting file for house second-reading stage analysis of SB 14 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill as required by house rules and that was requested by and provided to the

3/21/2011 (82nd

Legislature)



35

legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.



3/15/2011 (82nd

Legislature)


TX_00042440 TX_00042440


Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the

2/25/2011 (82nd


Jennifer Jackson (Atty.) Rep. Harless


36

legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.

TX_00042441 TX_00042473


Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.

1/13/2011 (82nd


Jennifer Jackson (Atty.) Rep. Hopson

TX_00042474 TX_00042501


Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on

10/25/2010 (82nd




37

Voter ID.

TX_00042502 TX_00042516



1/3/2011 (82nd



TX_00042517 TX_00042522



2/17/2011 (82nd


Jennifer Jackson (Atty.) Rep. Isaac


38

Voter ID.

TX_00042523 TX_00042578



7/20/2010 (82nd


Jennifer Jackson (Atty.) Rep. Riddle

TX_00042579 TX_00042592



11/12/2010 (82nd



Rep. Hilderbran


39

Voter ID.

TX_00042593 TX_00042659



7/21/2010 (82nd



Rep. Betty Brown

TX_00042660 TX_00042730



11/12/2010 (82nd



Rep. Hilderbran


40

Voter ID.

TX_00042731 TX_00042778



11/18/2010 (82nd



Rep. Todd Smith

TX_00042779 TX_00042804



12/17/2010 (82nd


Jennifer Jackson (Atty.) Rep. Bonnen


41

Voter ID.

TX_00042805 TX_00042831



11/5/2010 (82nd



Rep. “Doc” Anderson

TX_00042832 TX_00042835



3/23/2011 (82nd


Anne Peters (Atty.) Rep. Castro


42

Voter ID.

TX_00042850 TX_00042852



1/24/2011 (82nd


Jennifer Jackson (Atty.) Sen. Williams

TX_00042900 TX_00042904



1/21/2011 (82nd


Jennifer Jackson (Atty.) Sen. Birdwell


43

Voter ID.

TX_00042995 TX_00043013


Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID. (Lieutenant governor acts in a legislative capacity when serving as president of the senate.)

1/26/2011 (82nd



Lt. Gov. Dewhurst

TX_00043014 TX_00043016


Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as

1/26/2011 (82nd


Anne Peters (Atty.)

Sen. Dan Patrick


44

requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.

TX_00043028 TX_00043078



2/2/2011 (82nd


Jennifer Jackson (Atty.) Rep. Bohac

TX_00043079 TX_00043090


Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or

2/2/2011 (82nd



Rep. Van Taylor


45

mental impressions on Voter ID.

TX_00043091 TX_00043127



2/17/2011 (82nd



TX_00043128 TX_00043171



2/25/2011 (82nd




46

Voter ID.

TX_00043172 TX_00043177



3/15/2011 (82nd


Anne Peters (Atty.) Rep. Bonnen

TX_00043178 TX_00043183



3/15/2011 (82nd




47

Voter ID.

TX_00043184 TX_00043190



3/15/2011 (82nd



TX_00043191 TX_00043212



3/15/2011 (82nd




48

Voter ID.

TX_00043213 TX_00043218



3/15/2011 (82nd



TX_00043237 TX_00043244



3/17/2011 (82nd


David Hanna (Atty.) Rep. Alonzo


49

Voter ID.

TX_00043245 TX_00043252



3/17/2011 (82nd


David Hanna (Atty.) Rep. Alonzo

TX_00043253 TX_00043265



3/17/2011 (82nd


Jennifer Jackson (Atty.) Rep. Alonzo


50

Voter ID.

TX_00043266 TX_00043290



3/17/2011 (82nd


Allison Zaby (Atty.) Rep. Alonzo

TX_00043291 TX_00043298



3/17/2011 (82nd




51

Voter ID.

TX_00043299 TX_00043307



3/17/2011 (82nd



TX_00043308 TX_00043312



3/21/2011 (82nd


Anne Peters (Atty.) Rep. Zedler


52

Voter ID.

TX_00043313 TX_00043322



3/21/2011 (82nd


Jennifer Jackson (Atty.) Rep. Zedler

TX_00043323 TX_00043330



3/21/2011 (82nd


Jennifer Jackson (Atty.) Rep. Branch


53

Voter ID.

TX_00043339 TX_00043343



3/21/2011 (82nd


Mark Wimmer (Atty.) Rep. Alonzo

TX_00043344 TX_00043347



3/22/2011 (82nd


Anne Peters (Atty.) Rep. Alonzo


54

Voter ID.

TX_00043348 TX_00043353



3/22/2011 (82nd



TX_00043354 TX_00043359



3/23/2011 (82nd


Anne Peters (Atty.)

Rep. Castro; Rep. Martinez-Fisher (Martinez-Fisher has waived privileges.)


55

Voter ID.

TX_00043372 TX_00043375



3/23/2011 (82nd



TX_00043376 TX_00043379


Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client.

3/23/2011 (82nd




56

Reflects legislator thoughts, opinions, or mental impressions on Voter ID.

TX_00043390 TX_00043395



3/27/2011 (82nd


Jennifer Jackson (Atty.) Rep. Lozano

TX_00043405 TX_00043413



4/1/2011 (82nd


Jennifer Jackson (Atty.) Sen. Watson


57

Voter ID.

TX_00043414 TX_00043493



4/18/2011 (82nd


Jennifer Jackson (Atty.) Sen. Fraser

TX_00043494 TX_00043513



4/20/2011 (82nd




58

Voter ID.

TX_00043514 TX_00043527



4/20/2011 (82nd



TX_00043528 TX_00043545



4/26/2011 (82nd




59

Voter ID.

TX_00043546 TX_00043562



12/21/2010 (82nd



TX_00043563 TX_00043578



12/21/2010 (82nd




60

Voter ID.

TX_00043579 TX_00043610



10/11/2010 (82nd



Sen. Birdwell & Sen. Fraser

TX_00043611 TX_00043644



12/13/2010 (82nd



Rep. Hilderbran


61

Voter ID.

TX_00043645 TX_00043657



12/13/2010 (82nd


Jennifer Jackson (Atty.) Rep. Elkins

TX_00043658 TX_00043716



10/11/2010 (82nd



Rep. Todd Smith


62

Voter ID.

TX_00043717 TX_00043737



11/29/2010 (82nd



TX_00043738 TX_00043747



2/16/2011 (82nd


Anne Peters (Atty.) Rep. Sheets


63

Voter ID.


Research relating to Arizona Voter ID law and reflecting legislator communications. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.

4/14/2009 (81st

Legislature)

TLC (RESEARCH DIVISION) Jason Bane

Rep. Todd Smith


Research relating to Arizona Voter ID law and reflecting legislator communications. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.

4/14/2009 (81st

Legislature)


Rep. Todd Smith


Research relating to Voter/ballot fraud in the State of Texas and reflecting legislator communications. 2/24/2006


Amy Young (Deceased.) Rep. Denny


Research relating to Florida voter ID law and acceptance of provisional ballots and reflecting legislator communications. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter

3/26/2009 (81st

Legislature)


Rep. Todd Smith


64

ID.


Research relating to Florida voter ID law and acceptance of provisional ballots and reflecting legislator communications. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.

3/26/2009 (81st

Legislature)


Rep. Todd Smith


Update of research relating to Voter/ballot fraud in the State of Texas and reflecting legislator communications. Reflects legislator thoughts, opinions, or mental impressions on Voter ID. 1/2/2008


Chandler Lewis Rep. Berman


Drafting file for house committee stage bill analysis for HB 125 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill as required by house rules and that was

3/31/2009 (81st

Legislature)

TLC (RESEARCH DIVISION) Liz Morris

Rep. Todd Smith


65



Drafting file for house committee stage bill analysis for HB 125 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill as required by house rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.

3/31/2009 (81st

Legislature)


Rep. Todd Smith


Drafting file for house committee stage bill analysis for HB 125 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill

3/31/2009 (81st

Legislature)


Rep. Todd Smith


66




3/31/2009 (81st

Legislature)


Rep. Todd Smith


Drafting file for house committee stage bill analysis for HB 125 documenting information relating to the production of confidential proposed detailed analysis of the

3/31/2009 (81st

Legislature)


Rep. Todd Smith


67




3/31/2009 (81st

Legislature)


Rep. Todd Smith


Drafting file for house committee stage bill analysis for HB 3556 documenting information relating to the production of

3/31/2009 (81st

Legislature)


Rep. Todd Smith


68




3/31/2009 (81st

Legislature)


Rep. Todd Smith


69



3/31/2009 (81st

Legislature)


Rep. Todd Smith


Drafting file for house committee stage bill analysis for HB 3556 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill as required by house rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental

3/31/2009 (81st

Legislature)


Rep. Todd Smith


70



Drafting file for house committee stage bill analysis for SB 362 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill as required by house rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.

3/31/2009 (81st

Legislature)


Rep. Todd Smith


Drafting file for house committee stage bill analysis for SB 362 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill as required by house rules and that was requested by and

3/31/2009 (81st

Legislature)


Rep. Todd Smith


71

provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.



3/31/2009 (81st

Legislature)


Rep. Todd Smith


Drafting file for house committee stage bill analysis for SB 362 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill as required by house

3/31/2009 (81st

Legislature)


Rep. Todd Smith


72

rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.



3/31/2009 (81st

Legislature)


Rep. Todd Smith


Drafting file for house committee stage bill analysis for SB 362 documenting information relating to the production of confidential proposed detailed analysis of the subject matter and

3/31/2009 (81st

Legislature)


Rep. Todd Smith


73

other content of a bill as required by house rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.



3/31/2009 (81st

Legislature)


Rep. Todd Smith


Drafting file for house committee stage bill analysis for SB 362 documenting information relating to the production of confidential proposed

3/31/2009 (81st

Legislature)


Rep. Todd Smith


74

detailed analysis of the subject matter and other content of a bill as required by house rules and that was requested by and provided to the legislative client. (Part.) Reflects legislator thoughts, opinions, or mental impressions on Voter ID.



3/31/2009 (81st

Legislature)


Rep. Todd Smith


Confidential email between TLC and committee staff discussing the timing of the consideration of

3/07/2011 (82nd Legislature)


Carey Eskridge

Tammy Edgerly; Liz Morris; Kindal Wetuski


75

legislation and reflecting legislator communications. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.


Email attachment--analysis of proposed legislation documenting information relating to the production of confidential proposed detailed analysis of the subject matter and other content of a bill as required by house rules and that was requested by and provided to the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.

(82nd Legislature)



Email attachment--proposed legislation. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.

(82nd Legislature)



76

TX_00206169 TX_00206170


Confidential email from third-party attorney to legislative staff sent for the purpose of providing legal advice regarding voter ID legislation.

3/26/2009 (81st


Glen Shuffler (Atty. assisting Rep. Bonnen's office.)

Steven Schar (Rep. Todd Smith); Jennifer Jackson (Atty.); Travis Richmond (Rep. Todd Smith)


Confidential email between TLC and committee staff relating to the background and purpose section of an analysis of legislation and reflecting legislator communications. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.

2/23/2011 (82nd

Legislature)


Carey Eskridge

Steven Schar (Rep. Bonnen)


Confidential email between TLC and committee staff relating to the timing of an analysis of legislation and reflecting legislator communications. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.

3/2/2011 (82nd

Legislature)


Carey Eskridge



77


Confidential email between TLC and committee staff relating to the timing of an analysis of legislation and reflecting legislator communications. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.

3/2/2011 (82nd

Legislature)



Carey Eskridge


Confidential email between TLC and committee staff relating to the retraction of a request for the analysis of legislation and reflecting legislator communications. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.

3/3/2011 (82nd

Legislature)


Carey Eskridge



Confidential email between TLC and committee staff relating to the timing of the consideration of voter ID legislation and to the substance of the legislation and reflecting legislator communications. Reflects legislator thoughts, opinions, or mental impressions on

3/7/2011 (82nd

Legislature)



Carey Eskridge; Jason Thurlkill


78

Voter ID.


Email attachment--proposed language for analysis of legislation reflecting legislator communications. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.

(82nd Legislature)



Email attachment--proposed legislation. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.

(82nd Legislature)



Confidential email between TLC and committee staff relating to the substance of an analysis of legislation and reflecting legislator communications. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.

3/15/2011 (82nd

Legislature)



Carey Eskridge


Confidential email between TLC and committee staff relating to the delivery of an analysis of

3/15/2011 (82nd

Legislature)



Carey Eskridge


79

legislation and reflecting legislator communications. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.


Confidential email between TLC and committee staff relating to the delivery of a comparison between two analyses of legislation and reflecting legislator communications. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.

3/22/2011 (82nd

Legislature)


Carey Eskridge

Steven Schar (Rep. Bonnen); Tammy Edgerly


Email attachment—proposed analysis of proposed legislation. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.

(82nd Legislature)



Nonresponsive confidential email between TLC and committee staff requesting analysis of legislation not related to voter ID reflecting legislator communications. Reflects legislator thoughts, opinions, or

5/7/2011 (82nd

Legislature)


Bonnie L. Bruce (Rep. Solomons)

Tammy Edgerly; Liz Morris; B. Fitzgibbons (Rep. Deshotel)


80

mental impressions on Voter ID.


Nonresponsive email attachment—proposed language for analysis of legislation not related to voter ID reflecting legislator communications. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.

(82nd Legislature)


TX_00206556 TX_00206569



3/21/2005 (79th


Jennifer Jackson (Atty.) Rep. Denny


81

TX_00206570 TX_00206579



3/29/2005 (79th


David Hanna (Atty.) Rep. Denny

TX_00206612 TX_00206617



4/19/2005 (79th


Jennifer Jackson (Atty.) Rep. Escobar


82

TX_00206618 TX_00206626



4/19/2005 (79th



TX_00206631 TX_00206643



4/19/2005 (79th


Jennifer Jackson (Atty.) Rep. Coleman


83

TX_00206644 TX_00206655



4/19/2005 (79th


Jennifer Jackson (Atty.) Rep. Chavez

TX_00206656 TX_00206659



4/18/2005 (79th




84

TX_00206751 TX_00206755



5/2/2005 (79th


Jennifer Jackson (Atty.) Rep. Leibowitz

TX_00206756 TX_00206767



5/2/2005 (79th




85

TX_00206768 TX_00206771



5/2/2005 (79th



TX_00206772 TX_00206775



5/2/2005 (79th




86

TX_00206776 TX_00206779



5/2/2005 (79th



TX_00206780 TX_00206783



5/2/2005 (79th




87

TX_00206784 TX_00206787



5/2/2005 (79th



TX_00206788 TX_00206791



5/2/2005 (79th



Rep. Al Edwards


88

TX_00206792 TX_00206795



5/2/2005 (79th


Cynthia Stein (Atty.) Rep. Chavez

TX_00206796 TX_00206799



5/2/2005 (79th




89

TX_00206800 TX_00206803



5/2/2005 (79th



TX_00206804 TX_00206825



5/20/2005 (79th




90

TX_00206826 TX_00206836



2/25/2005 (79th



TX_00206837 TX_00206852



3/4/2005 (79th




91

TX_00206853 TX_00206873



5/17/2005 (79th



TX_00206874 TX_00206904



5/18/2005 (79th




92

TX_00206905 TX_00206916



5/21/2005 (79th



TX_00206917 TX_00206920



5/24/2005 (79th


Peg Peterson (Atty.) Rep. Solis


93

TX_00206921 TX_00206924



5/24/2005 (79th


Peg Peterson (Atty.) Rep. Chavez

TX_00206925 TX_00206928



5/24/2005 (79th




94

TX_00206929 TX_00206932



5/24/2005 (79th


Peg Peterson (Atty.) Rep. Alonzo

TX_00206933 TX_00206937



5/24/2005 (79th




95

TX_00206938 TX_00206941



5/25/2005 (79th



TX_00206942 TX_00206949



5/25/2005 (79th




96

TX_00206950 TX_00206956



5/25/2005 (79th



TX_00206957 TX_00206986



12/20/2004 (79th


Jennifer Jackson (Atty.) Rep. Nixon


97

TX_00206987 TX_00206990



2/23/2005 (79th



TX_00206991 TX_00207020



3/7/2007 (80th



Rep. Betty Brown


98

TX_00207283 TX_00207286



4/10/2007 (80th



TX_00207287 TX_00207298



4/10/2007 (80th




99

TX_00207299 TX_00207309



4/10/2007 (80th



TX_00207313 TX_00207322



4/13/2007 (80th



Rep. Betty Brown


100

TX_00207323 TX_00207333



4/13/2007 (80th



Rep. Betty Brown

TX_00207334 TX_00207343



4/13/2007 (80th


Jon Heining (Atty.) Rep. Leibowitz


101

TX_00207344 TX_00207364



4/13/2007 (80th


Anne Peters (Atty.) Rep. Leibowitz

TX_00207378 TX_00207389



4/16/2007 (80th



Rep. Betty Brown


102

TX_00207401 TX_00207404



4/16/2007 (80th



Rep. Betty Brown

TX_00207405 TX_00207415



4/16/2007 (80th


Anne Peters (Atty.)

Rep. Betty Brown


103

TX_00207504 TX_00207513



4/19/2007 (80th


David Hanna (Atty.)

Rep. Betty Brown

TX_00207514 TX_00207517



4/19/2007 (80th


David Hanna (Atty.)

Rep. Betty Brown


104

TX_00207605 TX_00207614



4/20/2007 (80th


Anne Peters (Atty.)

Rep. Betty Brown

TX_00207615 TX_00207620



4/21/2007 (80th


David Hanna (Atty.) Rep. Strama


105

TX_00207621 TX_00207625



4/21/2007 (80th


David Hanna (Atty.) Rep. Strama

TX_00207626 TX_00207637



4/23/2007 (80th


Jennifer Jackson (Atty.) Sen. Jackson


106

TX_00207642 TX_00207648



4/23/2007 (80th


Anne Peters (Atty.) Rep. Raymond

TX_00207649 TX_00207652



4/23/2007 (80th




107

TX_00207653 TX_00207656



4/23/2007 (80th


Jennifer Jackson (Atty.) Rep. Heflin

TX_00207657 TX_00207660



4/23/2007 (80th


Jennifer Jackson (Atty.) Rep. Chavez


108

TX_00207690 TX_00207706



10/30/2006 (80th



Rep. Betty Brown

TX_00207707 TX_00207734



11/10/2006 (80th



Rep. Harper-Brown


109

TX_00207735 TX_00207764



12/5/2006 (80th



Rep. Kolkhorst

TX_00207765 TX_00207809



7/10/2006 (80th




110

TX_00207863 TX_00207912



3/4/2009 (81st



Rep. Betty Brown

TX_00207913 TX_00207927



3/23/2009 (81st



Rep. Betty Brown


111

TX_00207928 TX_00207958



4/28/2009 (81st



Rep. Betty Brown

TX_00207959 TX_00207976



4/29/2009 (81st



Rep. Betty Brown


112

TX_00207977 TX_00207991



5/12/2009 (81st



TX_00207992 TX_00208018



4/28/2008 (81st


Jennifer Jackson (Atty.) Rep. Phil King


113

TX_00208019 TX_00208067



9/26/2008 (81st



Rep. Betty Brown

TX_00208068 TX_00208095



10/9/2008 (81st




114

TX_00208096 TX_00208125



10/28/2008 (81st



Rep. Betty Brown

TX_00208126 TX_00208139



12/4/2008 (81st




115

TX_00208140 TX_00208162



1/22/2009 (81st



TX_00208163 TX_00208184



2/17/2009 (81st




116

TX_00208185 TX_00208206



2/18/2009 (81st



TX_00208207 TX_00208221



2/19/2009 (81st



Rep. Todd Smith


117

TX_00208222 TX_00208230



2/20/2009 (81st


Jennifer Jackson (Atty.) Rep. Chisum

TX_00208231 TX_00208249



3/30/2009 (81st


Eric Hougland (Atty.) Rep. Chisum


118

TX_00208250 TX_00208259



3/30/2009 (81st


Eric Hougland (Atty.) Rep. Chisum

TX_00208260 TX_00208273



3/30/2009 (81st




119

TX_00208274 TX_00208287



3/30/2009 (81st



TX_00208288 TX_00208306



4/30/2009 (81st




120

TX_00208307 TX_00208309



5/15/2009 (81st



Rep. Betty Brown

TX_00208310 TX_00208312



5/15/2009 (81st


Anne Peters (Atty.)

Rep. Betty Brown


121

TX_00208313 TX_00208315



5/15/2009 (81st



Rep. Betty Brown

TX_00208316 TX_00208328



2/18/2009 (81st



Sen. Shapleigh


122

TX_00208329 TX_00208355



1/20/2009 (81st



Lt. Gov. Dewhurst

TX_00208356 TX_00208369



2/18/2009 (81st



Sen. Shapleigh


123

Voter ID.

TX_00208370 TX_00208388



2/18/2009 (81st



Sen. Shapleigh

TX_00208389 TX_00208406



2/18/2009 (81st



Sen. Shapleigh


124

Voter ID.

TX_00208407 TX_00208422



3/2/2009 (81st



Lt. Gov. Dewhurst

TX_00208423 TX_00208437


Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as

3/8/2009 (81st


Jennifer Jackson (Atty.) Sen. Watson


125

requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.

TX_00208438 TX_00208456



3/9/2009 (81st



Lt. Gov. Dewhurst

TX_00208457 TX_00208487


Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential

3/12/2009 (81st




126

proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.

TX_00208488 TX_00208498



3/16/2009 (81st



TX_00208499 TX_00208505


Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator

3/17/2009 (81st


Anne Peters (Atty.)

Rep. V. Gonzales


127

thoughts, opinions, or mental impressions on Voter ID.

TX_00208506 TX_00208513



3/17/2009 (81st



Rep. V. Gonzales

TX_00208514 TX_00208574



3/25/2009 (81st



Rep. Todd Smith


128

Voter ID.

TX_00208575 TX_00208581



3/30/2009 (81st



TX_00208582 TX_00208604



3/30/2009 (81st


Anne Peters (Atty) Rep. Alonzo


129

Voter ID.

TX_00208605 TX_00208611



4/6/2009 (81st


Jennifer Jackson (Atty.) Rep. Dutton

TX_00208612 TX_00208642



4/9/2009 (81st



Rep. Todd Smith


130

Voter ID.

TX_00208643 TX_00208681



4/9/2009 (81st



Rep. Todd Smith

TX_00208682 TX_00208703



4/16/2009 (81st



Rep. Todd Smith


131

Voter ID.

TX_00208704 TX_00208715



4/20/2009 (81st


Jennifer Jackson (Atty.) Rep. Miklos

TX_00208716 TX_00208770



4/26/2009 (81st



Rep. Todd Smith


132

Voter ID.

TX_00208771 TX_00208810



4/27/2009 (81st



House Parliamentarian Denise Davis (Atty.)

TX_00208811 TX_00208837



4/28/2009 (81st



Rep. Todd Smith


133

TX_00208838 TX_00208882



4/28/2009 (81st



House Parliamentarian Denise Davis (Atty.)

TX_00208883 TX_00208912



4/29/2009 (81st



Rep. Todd Smith

TX_00208913 TX_00208935


Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the

4/30/2009 (81st



Rep. Todd Smith


134

production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.

TX_00208936 TX_00208994



4/30/2009 (81st



Rep. Betty Brown

TX_00208995 TX_00209039


Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the

5/1/2009 (81st



Rep. Todd Smith


135

legislative client. Reflects legislator thoughts, opinions, or mental impressions on Voter ID.

TX_00209040 TX_00209063



5/4/2009 (81st



Rep. Todd Smith

TX_00209064 TX_00209130



5/5/2009 (81st


Anne Peters (Atty.) & Jennifer Jackson (Atty.)

Rep. Todd Smith


136

Voter ID.

TX_00209131 TX_00209155



5/5/2009 (81st



Rep. Todd Smith

TX_00209156 TX_00209168



5/11/2009 (81st



Rep. Todd Smith


137

Voter ID.

TX_00209169 TX_00209175



5/11/2009 (81st



Rep. Todd Smith

TX_00209176 TX_00209183



5/11/2009 (81st



Rep. Todd Smith


138

Voter ID.

TX_00209184 TX_00209197



5/11/2009 (81st



Rep. Todd Smith

TX_00209198 TX_00209248



5/12/2009 (81st



Rep. Betty Brown


139

Voter ID.

TX_00209249 TX_00209296



5/12/2009 (81st



TX_00209297 TX_00209312



5/12/2009 (81st


Gabe Brake (Atty.) Rep. Hopson


140

Voter ID.

TX_00209313 TX_00209336



5/12/2009 (81st



TX_00209337 TX_00209342



5/12/2009 (81st




141

Voter ID.

TX_00209422 TX_00209435



5/13/2009 (81st



Rep. Hopson; Rep. Leibowitz; Rep. Veasey (Veasey has waived privileges.)

TX_00209436 TX_00209443



5/13/2009 (81st



Rep. Hopson; Rep. Anchia (Anchia has waived privileges.)


142

Voter ID.

TX_00209444 TX_00209448



5/13/2009 (81st



TX_00209449 TX_00209488



5/14/2009 (81st



Rep. Todd Smith


143

Voter ID.

TX_00209489 TX_00209492



5/14/2009 (81st



Rep. Todd Smith

TX_00209493 TX_00209498



5/14/2009 (81st



Rep. Todd Smith


144

Voter ID.

TX_00209499 TX_00209518



5/14/2009 (81st

Legislature) TLC ((LEGAL DIVISION))


Rep. Todd Smith

TX_00209519 TX_00209525



5/14/2009 (81st



Rep. Todd Smith


145

Voter ID.

TX_00209526 TX_00209534



5/14/2009 (81st



Rep. Todd Smith

TX_00209535 TX_00209542



5/14/2009 (81st



Rep. Todd Smith


146

Voter ID.

TX_00209543 TX_00209550



5/14/2009 (81st



Rep. Todd Smith

TX_00209551 TX_00209561



5/15/2009 (81st



Rep. Betty Brown


147

Voter ID.

TX_00209562 TX_00209569



5/15/2009 (81st



Rep. Betty Brown

TX_00209570 TX_00209575



5/15/2009 (81st



Rep. Betty Brown


148

Voter ID.

TX_00209576 TX_00209582



5/15/2009 (81st



Rep. Betty Brown

TX_00209583 TX_00209587



5/15/2009 (81st


Anne Peters (Atty.)

Rep. Betty Brown


149

Voter ID.

TX_00209588 TX_00209594



5/15/2009 (81st


Anne Peters (Atty.)

Rep. Betty Brown

TX_00209595 TX_00209602



5/15/2009 (81st



Rep. Betty Brown


150

Voter ID.

TX_00209603 TX_00209613



5/15/2009 (81st



Rep. Betty Brown

TX_00209614 TX_00209630



5/15/2009 (81st


Anne Peters (Atty.)

Rep. Betty Brown


151

Voter ID.

TX_00209631 TX_00209648



5/17/2009 (81st


Anne Peters (Atty.)

Rep. Hernandez

TX_00209649 TX_00209673



5/18/2009 (81st



Rep. Leibowitz; Rep. Herrero; Rep. A. Martinez; (Martinez has waived privileges.)


152

Voter ID.

TX_00209674 TX_00209679



5/18/2009 (81st



TX_00209680 TX_00209685



5/18/2009 (81st




153

Reflects legislator thoughts, opinions, or mental impressions on Voter ID.

TX_00209686 TX_00209707



5/18/2009 (81st



Rep. Todd Smith

TX_00209708 TX_00209720



5/18/2009 (81st



Rep. Todd Smith


154

Voter ID.

TX_00209721 TX_00209729



5/18/2009 (81st



Rep. Todd Smith

TX_00209730 TX_00209738



5/18/2009 (81st



Rep. Todd Smith


155

Voter ID.

TX_00209785 TX_00209839



5/18/2009 (81st



Rep. Todd Smith

TX_00209840 TX_00209847



5/19/2009 (81st




156

Voter ID.

TX_00209848 TX_00209856



5/19/2009 (81st



Rep. Todd Smith

TX_00209857 TX_00209876



5/19/2009 (81st



Rep. Todd Smith


157

Voter ID.

TX_00209877 TX_00209944



5/19/2009 (81st


Anne Peters (Atty.)

Rep. C. Turner

TX_00209945 TX_00209950



5/19/2009 (81st


Anne Peters (Atty.)

Rep. C. Turner


158

Voter ID.

TX_00209951 TX_00209957



5/19/2009 (81st


Sarah Munson (Atty.) Rep. Alonzo

TX_00209958 TX_00209963



5/19/2009 (81st


Anne Peters (Atty.)

Rep. C. Turner


159

Voter ID.

TX_00209964 TX_00209967



5/19/2009 (81st



Rep. Todd Smith

TX_00209968 TX_00209982



5/20/2009 (81st




160

Voter ID.

TX_00209983 TX_00210001



5/20/2009 (81st



Rep. Todd Smith

TX_00210002 TX_00210020



5/20/2009 (81st



Rep. Todd Smith


161

Voter ID.

TX_00210021 TX_00210029



5/20/2009 (81st



Rep. Todd Smith

TX_00210030 TX_00210038



5/20/2009 (81st



Rep. Todd Smith


162

Voter ID.

TX_00210039 TX_00210056



5/20/2009 (81st



TX_00210084 TX_00210088



5/21/2009 (81st


Jennifer Jackson (Atty.) Rep. Dutton


163

Voter ID.

TX_00210089 TX_00210104



5/21/2009 (81st


Emily Howell (Atty.) Rep. Herrero

TX_00210105 TX_00210112



5/21/2009 (81st


Anne Peters (Atty.) Rep. Herrero


164

Voter ID.

TX_00210113 TX_00210139



5/22/2009 (81st


Anne Peters (Atty.)

Rep. C. Turner

TX_00210140 TX_00210150



5/22/2009 (81st


Anne Peters (Atty.)

Rep. C. Turner


165

Voter ID.

TX_00210151 TX_00210161



5/22/2009 (81st


Anne Peters (Atty.)

Rep. C. Turner

TX_00210162 TX_00210174



5/22/2009 (81st


Anne Peters (Atty.)

Rep. C. Turner


166

Voter ID.

TX_00210175 TX_00210183



5/22/2009 (81st


Anne Peters (Atty.)

Rep. C. Turner

TX_00210184 TX_00210191



5/22/2009 (81st


Anne Peters (Atty.)

Rep. C. Turner


167

Voter ID.

TX_00210192 TX_00210198



5/22/2009 (81st


Anne Peters (Atty.)

Rep. C. Turner

TX_00210199 TX_00210224



5/22/2009 (81st


Anne Peters (Atty.)

Rep. C. Turner


168

Voter ID.

TX_00210225 TX_00210234



5/22/2009 (81st


Anne Peters (Atty.)

Rep. C. Turner

TX_00210235 TX_00210243



5/22/2009 (81st


Anne Peters (Atty.)

Rep. C. Turner


169

Voter ID.

TX_00210244 TX_00210251



5/22/2009 (81st


Anne Peters (Atty.)

Rep. C. Turner

TX_00210252 TX_00210274



5/22/2009 (81st


Anne Peters (Atty.)

Rep. C. Turner


170

Voter ID.

TX_00210275 TX_00210284



5/22/2009 (81st


Anne Peters (Atty.)

Rep. C. Turner

TX_00210285 TX_00210296



5/22/2009 (81st


Anne Peters (Atty.)

Rep. C. Turner


171

Voter ID.

TX_00210297 TX_00210319



5/22/2009 (81st


Anne Peters (Atty.)

Rep. C. Turner

TX_00210335 TX_00210401



5/22/2009 (81st



Rep. Todd Smith


172

Voter ID.

TX_00210628 TX_00210640



5/22/2009 (81st


Eric Hougland (Atty.)

Rep. Betty Brown; Rep. Button

TX_00210641 TX_00210660



5/22/2009 (81st



Rep. Todd Smith


173

Voter ID.

TX_00210661 TX_00210689



5/22/2009 (81st



Rep. Todd Smith

TX_00210690 TX_00210694



5/22/2009 (81st



Rep. Todd Smith


174

Voter ID.

TX_00210695 TX_00210701



5/22/2009 (81st



Rep. Todd Smith

TX_00210702 TX_00210710



5/22/2009 (81st



Rep. Todd Smith


175

Voter ID.

TX_00210711 TX_00210729



5/23/2009 (81st


Jennifer Jackson (Atty.) Sen. Patrick

TX_00210750 TX_00210769



5/24/2009 (81st



Rep. Betty Brown


176

Voter ID.

TX_00210770 TX_00210775



5/24/2009 (81st



Rep. Todd Smith

TX_00210776 TX_00210783



5/24/2009 (81st




177

Voter ID.

TX_00210828 TX_00210833



5/24/2009 (81st


Jennifer Jackson (Atty.) Rep. Miklos

TX_00210834 TX_00210846



5/25/2009 (81st




178

Voter ID.

TX_00210847 TX_00210853



5/25/2009 (81st


Anne Peters (Atty.) Rep. Dunnam

TX_00210854 TX_00210862



5/25/2009 (81st


Jennifer Jackson (Atty.) Rep. Dunnam


179

Voter ID.

TX_00210863 TX_00210868



5/25/2009 (81st



TX_00210869 TX_00210875



5/25/2009 (81st




180

Voter ID.

TX_00210876 TX_00210882



5/25/2009 (81st



TX_00210883 TX_00210890


Legislative drafting file documenting confidential communications between attorney and legislative client and other information relating to the production by the attorney of confidential proposed legislation as requested by the legislative client. Reflects legislator thoughts, opinions, or mental impressions on 39958




181

Voter ID.


1

Office of the Governor Contested Document Privilege Claim Index Legislative Privilege

Materials in the Possession of an Executive Agency over which the State of Texas Has Asserted a Legislative Privilege TX_00034902-TX_00034902, TX_00037744-TX_00037744, TX_00038291-TX_00038291 Attorney-Client Privilege Materials for which the State of Texas Failed to Provide Sufficient Information Regarding Attorney-Client Privilege TX_00057324-TX_00057324, TX_00057547-TX_00057562, TX_00089306-TX_00089307 Materials over which the State of Texas Has Asserted the Attorney-Client Privilege Where the Parties to the Communication Have Not Entered an Attorney-Client Relationship TX_00057456-TX_00057475, TX_00057699-TX_00057746, TX_00089130-TX_00089187, TX_00089226-TX_00089227 Materials over which the State of Texas Has Asserted the Attorney-Client Privilege Where the Advice Appears to Concern Political, Strategic, or Policy Issues TX_00057294-TX_00057308, TX_00057321-TX_00057323, TX_00057357-TX_00057366, TX_00057367-TX_00057368, TX_00057369-TX_00057414, TX_00057415-TX_00057417, TX_00057418-TX_00057455, TX_00057538-TX_00057539, TX_00057565-TX_00057609, TX_00057608-TX_00057678, TX_00057756-TX_00057759, TX_00057807-TX_00057999, TX_00058039-TX_00058068, TX_00058070-TX_00058304, TX_00058334-TX_00058336, TX_00058353-TX_00058783, TX_00058792-TX_00058829, TX_00058830-TX_00058449, TX_00059450-TX_00060257, TX_00060258-TX_00060258, TX_00060259-TX_00060260, TX_00060641-TX_00073627, TX_00073800-TX_00074003; TX_00089076-TX_00089078, TX_00089251-TX_00089305, TX_00089308-TX_00089309 Deliberative Process Privilege Materials over which the State of Texas Has Asserted the Deliberative Process Privilege that Address SB 14 and Predate Enactment TX_00057287-TX_00057288, TX_00057294-TX_00057308, TX_00057369-TX_00057414, TX_00057418-TX_00057455, TX_00057538-TX_00057539, TX_00057608-TX_00057678, TX_00058001-TX_00058038, TX_00058039-TX_00058068, TX_00058299-TX_00058310, TX_00058343-TX_00058352, TX_00058784-TX_00058791, TX_00058830-TX_00058449,


2

TX_00073709-TX_00073722, TX_00073764-TX_00073773, TX_00074010-TX_00074011, TX_00074226-TX_00074234, TX_00074236-TX_00074236; TX_00089064-TX_00089075


1

Texas Legislative Council Contested Document Privilege Claim Index

Attorney-Client Privilege Materials over which the State of Texas Has Asserted the Attorney-Client Privilege that Reflect Communications with the Texas Legislative Council:

TX_00041842-TX_00042111, TX_00042138-TX_00042138, TX_00042142-TX_00042147, TX_00042440-TX_00042852, TX_00042995-TX_00043016, TX_00043028-TX_00043090, TX_00043091-TX_00043218, TX_00043237-TX_00043244, TX_00043245-TX_00043330, TX_00043339-TX_00043359, TX_00043376-TX_00043379, TX_00043390-TX_00043395, TX_00043405-TX_00043657, TX_00043717-TX_00043747, TX_00206556-TX_00206579, TX_00206612-TX_00206626, TX_00206631-TX_00206659, TX_00206751-TX_00207020, TX_00207283-TX_00207309, TX_00207313-TX_00207364, TX_00207378-TX_00207389, TX_00207401-TX_00207415, TX_00207504-TX_00207517, TX_00207605-TX_00207637, TX_00207642-TX_00207660, TX_00207690-TX_00207809, TX_00207863-TX_00209342, TX_00209422-TX_00209738, TX_00209785-TX_00210056, TX_00210084-TX_00210319, TX_00210335-TX_00210401, TX_00210628-TX_00210729, TX_00210750-TX_00210783, TX_00210770-TX_00210783, TX_00210828-TX_00210890 Materials over which the State of Texas Has Asserted the Attorney-Client Privilege that Reflect Internal Research within the Texas Legislative Council:

TX_00042145-TX_00042145 Legislative Privilege

Public Documents over which the State of Texas Has Asserted a State Legislative Privilege:

TX_00043748-TX_00044191 Materials over which the State of Texas Has Asserted a State Legislative Privilege Despite the Relevant Legislators Not Having Invoked a Privilege:

TX_00043237-TX_00043244, TX_00043245-TX_00043307, TX_00043339-TX_00043347, TX_00043354-TX_00043359, TX_00043372-TX_00043379, TX_00206631-TX_00206643, TX_00206656-TX_00206659, TX_00206929-TX_00206932, TX_00206938-TX_00206956, TX_00208260-TX_00208287, TX_00208499-TX_00208513, TX_00208575-TX_00208604, TX_00209631-TX_00209673, TX_00209951-TX_00209957 Materials Concerning Sponsors of SB 14 over which the State of Texas Has Asserted a State Legislative Privilege:

TX_00041842-TX_00042111, TX_00042138-TX_00042138, TX_00042139-TX_00042141, TX_00042309-TX_00042396, TX_00042440-TX_00042440, TX_00042474-TX_00042501,


2

TX_00042502-TX_00042516, TX_00043128-TX_00043171, TX_00043414-TX_00043545, TX_00043579-TX_00043610, TX_00208126-TX_00208139, TX_00208457-TX_00208498 Materials Concerning Committee Chairs, Committee Staff, or Legislative Leadership over which the State of Texas Has Asserted a State Legislative Privilege:

TX_00042151-TX_00042308, TX_00042397-TX_00042438, TX_00042779-TX_00042804, TX_00042995-TX_00043013, TX_00043091-TX_00043127, TX_00043172-TX_00043218, TX_00043348-TX_00043353, TX_00206173-TX_00206212, TX_00208163-TX_00208184, TX_00208329-TX_00208355, TX_00208407-TX_00208422, TX_00208438-TX_00208456, TX_00209249-TX_00209296, TX_00210039-TX_00210056 Materials Concerning Legislators Who Spoke in Favor of SB 14 over which the State of Texas Has Asserted a State Legislative Privilege:

TX_00042142-TX_00042142, TX_00042523-TX_00042578, TX_00042731-TX_00042778, TX_00042850-TX_00042852, TX_00043546-TX_00043578, TX_00043658-TX_00043716, TX_00043748-TX_00043774, TX_00044165-TX_00044171, TX_00075930-TX_00075941, TX_00075949-TX_00075962, TX_00075969-TX_00076003, TX_00206169-TX_00206170, TX_00206804-TX_00206825, TX_00207765-TX_00207809, TX_00208068-TX_00208095, TX_00208207-TX_00208221, TX_00208514-TX_00208574, TX_00208612-TX_00208703, TX_00208716-TX_00208770, TX_00208811-TX_00208837, TX_00208883-TX_00208935, TX_00208995-TX_00209197, TX_00209449-TX_00209550, TX_00209686-TX_00209738, TX_00209785-TX_00209876, TX_00209964-TX_00209967, TX_00209983-TX_00210038, TX_00210335-TX_00210401, TX_00210641-TX_00210729, TX_00210770-TX_00210783, TX_00210834-TX_00210846 Other Materials Concerning SB14 over which the State of Texas Has Asserted a State Legislative Privilege:

TX_00042139-TX_00042141, TX_00042146-TX_00042147, TX_00042441-TX_00042473, TX_00042517-TX_00042522, TX_00042579-TX_00042730, TX_00042805-TX_00042835, TX_00042900-TX_00042904, TX_00043014-TX_00043016, TX_00043028-TX_00043090, TX_00043308-TX_00043330, TX_00043354-TX_00043359, TX_00043390-TX_00043395, TX_00043405-TX_00043413, TX_00043579-TX_00043644, TX_00043645-TX_00043657, TX_00043658-TX_00043716, TX_00043717-TX_00043747, TX_00043775-TX_00044164, TX_00044172-TX_00044191, TX_00205341-TX_00205360, TX_00206556-TX_00206579, TX_00206612-TX_00206626, TX_00206644-TX_00206655, TX_00206751-TX_00206803, TX_00206826-TX_00206928, TX_00206933-TX_00206937, TX_00206957-TX_00207020, TX_00207283-TX_00207309, TX_00207313-TX_00207364, TX_00207378-TX_00207389, TX_00207401-TX_00207415, TX_00207504-TX_00207517, TX_00207605-TX_00207637, TX_00207642-TX_00207660, TX_00207690-TX_00207764, TX_00207863-TX_00208067, TX_00208096-TX_00208125, TX_00208140-TX_00208162, TX_00208185-TX_00208206, TX_00208222-TX_00208259, TX_00208288-TX_00208328, TX_00208356-TX_00208406, TX_00208423-TX_00208437, TX_00208605-TX_00208611, TX_00208704-TX_00208715, TX_00208771-TX_00208810, TX_00208838-TX_00208882, TX_00208936-TX_00208994,


3

TX_00209198-TX_00209248, TX_00209297-TX_00209342, TX_00209422-TX_00209448, TX_00209551-TX_00209630, TX_00209649-TX_00209685, TX_00209877-TX_00209950, TX_00209958-TX_00209963, TX_00209968-TX_00209982, TX_00210084-TX_00210319, TX_00210628-TX_00210640, TX_00210750-TX_00210769, TX_00210828-TX_00210833, TX_00210847-TX_00210890 Materials Concerning Prior Voter ID Proposals over which the State of Texas Has Asserted a State Legislative Privilege:

TX_00075969-TX_00076003 Materials Concerning Other Legislative Proposals over which the State of Texas Has Asserted a State Legislative Privilege:

TX_00075930-TX_00075941, TX_00075932-TX_00075941, TX_00075949-TX_00075962


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