Vol. 4 Federal Redistricting Trial Transcript

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Sept. 9. 2011

The witness answering all questions below is Ryan Downton, the general counsel to the Texas House Committee on Redistricting.

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18 Q [Mattax with Texas AG] Now, did — was this the original configuration in C-144

19 of C-35?

20 A. No. You can see that there are changes in the southern

21 region between C-125 and C-144, as reflected by the red lines.

22 Q. Did you make those changes or were they requested?

23 A. I made those changes at the request of, in this case,

24 Representative Villarreal and Representative Castro. They

25 liked the idea of 35 and having the new — a new district, a

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1 new Hispanic district in central Texas .

2 Their concern was that they wanted it to be a Bexar

3 County-based district, and they wanted to make sure that the

4 district was sufficiently weighted towards Bexar County, as

5 opposed to Travis County , and so we made both initial changes

6 and additional changes later on in the process to try to

7 weight it towards Bexar County .

8 JUDGE SMITH: Are they Republicans or Democrats

9 or —

10 THE WITNESS: I’m sorry. They are both Democrats.

11 BY MR. MATTAX:

12 Q. And are they both Hispanic?

13 A. Yes.

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18  JUDGE SMITH: When you mention the name of a

19 representative, it would be helpful, at least to me, if you

20 would say what party.

21 THE WITNESS: I will try to do that. Representative

22 Menendez is a Democrat.

23 And then we also had — Representative Castro and

24 Representative Villarreal had identified parts of central San

25 Antonio that they really wanted in the new District 35. So we

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1 had those tensions as to how to address some of Representative

2 Menendez’s concerns, while also addressing Representative

3 Villarreal and Representative Castro’s concerns.

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21 Q [Renea Hicks]. Okay. And you testified that State Representative

22 Villarreal and State Representative Castro came to you and

23 asked to move more of District 35 into the south San Antonio

24 area, correct?

25 A. Into Bexar County, and then into specific areas of San

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1 Antonio, to the extent possible. I would say central San

2 Antonio.

3 Q. Okay. In downtown?

4 A. Yes.

5 Q. This courthouse?

6 A. That is probably correct. I’m sorry. I am not that

7 familiar with San Antonio  geography.

8 Q. And you acceded to their requests?

9 A. Yes.