t -' 

TEXAS 

GILBERTO 

Democratic 

CASCINO, 

and BREND 

V. GREG ARE 

HUGHS, 1 

PAXTON, 

DEBEAUV 

JACQUEL' 

Elections A 

iN THE UNITED STATES DISTRICT COURT 

FOR THE WESTERN DIVISION OF TEXAS 

SAN ANTONIO DIVISION 

DEMOCRATIC PARTY, 

I1NOJOSA, Chair of the Texas 

Party, JOSEPH DANIEL 

HANDA MARIE SANSING, 

. LI GARCIA, 

Plaintiffs, 

)TT, Governor of Texas, RUTH 

xas Secretary of State, KEN 

exas Attorney General, DANA 

'IR, Travis County Clerk, 

F. CALLANEN, Bexar County 

Defendants. 

FILED 

MAY 112020 

CLERK, U.S. IiCT COURT WESTERN DI1T OF TEXAS BY 

DE TYCLERf( 

Case No.: -cy-004_F B 

Ml TION OF LEAGUE OF UNITED LATIN AMERICAN CITIZENS AND 

TEXAS LE GUE OF UNITED LATIN AMERICAN CITIZENS TO INTERVENE AS 

PLAIN 'IFFS PURSUANT TO FEDERAL RULE OF CIVIL PROCEDURE 24 

TO THE HOI' ORABLE JUDGE FRED BIERY: 

Proposd Plaintiff-Intervenors League of United Latin American Citizens ("LULAC") and 

Texas Leagu of United Latin American Citizens ("Texas LULAC") (together, "LULAC 

Plaintiffs") sek to intervene in this proceeding because it affects the organizations' core mission 

and their members' fundamental right to vote. 

LULA is the largest and oldest Latino civil rights organization in the United States with 

over 132,000 iiembers nationwide and over 1,000 local councils. Texas LULAC is the statewide 

chapter of LUAC and seeks to protect the voting rights of its over 20,000 members and the 

broader Latin community. This year, in the midst of an ongoing public health crisis, that mission 

includes ensuring that Latino voters are able to safely cast their ballots by mail, rather than having 

to choose bet'een risking their health by voting in person or not voting at all. Unfortunately, 

Defendants ha'e sought to deny access to absentee ballots to the majority of Texans, including 

1 

Case 5:20-cv-00438-FB Document 30 Filed 05/11/20 Page 1 of 13
Y 1 LULAC 

existing 

members, by prohibiting voters from applying for mail ballots pursuant to the 

exception under state law. By enforcing unreasonably restrictive eligibility 

criteria, and b' threatening to prosecute organizations like LULAC Plaintiffs that seek to advise 

voters about title disability option, Defendants have imposed unconstitutional burdens on LULAC 

Plaintiffs' riglts to speech and association and their members' rights to vote, thereby violating the 

First, Fourteeth, and Twenty-Sixth Amendments to the United States Constitution, as well as 

Section 2 of tle Voting Rights Act (the "VRA"). 

In ordr to protect these constitutional and federal statutory rights, LULAC Plaintiffs 

hereby move Ito intervene as plaintiffs in this action. LULAC Plaintiffs are entitled to intervention 

as of right unc 

LULAC Plain 

timely, and ti 

questions of h 

This 

outbreak of C 

of the panden 

permitted, in 

highly-contag 

because the St 

in the nation, 

court judge re 

vote by mail, 

Federal Rule of Civil Procedure 24(a). In the alternative, the Court should permit 

to intervene under Federal Rule of Civil Procedure 24(b) because its motion is 

claims proposed in their Complaint, see Ex. 1 ("LULAC Compi."), present 

and fact that overlap with the pending litigation. 

FACTUAL BACKGROUND 

and Fall, the ongoing public health crisis triggered by the widespread 

VID-19 will severely affect voting in Texas. LULAC Compl. ¶J 36-43. As a result 

many voters, including members of Texas LULAC, will seek to vote by mail, if 

to avoid crowded in-person polling locations where they risk contracting the 

disease. See id. ¶ 38. But many Texans may not be able to cast absentee ballots 

of Texas maintains among the most restrictive absentee voting eligibility criteria 

exclude the majority of Texas voters. See id. ¶J 38-39. While a Texas state 

y ruled that the State must permit voters to rely on C OVID- 19 as an excuse to 

Defendants have ignored this ruling. See id. ¶J 45-49. They continue to seek 

2 

Case 5:20-cv-00438-FB Document 30 Filed 05/11/20 Page 2 of 13
'I enforcement cf their extremely restrictive policy on vote by mailincluding by appealing the state 

court's decisin, relying on an asserted automatic stay, and insisting on the decision's limited 

application to a single countyand have gone so far as to demand that county officials follow 

their restrictie policy and threaten to prosecute any voter who claims the right to vote by mail 

based on an iiability to vote in person due to COVID-19, and any third parties who educate or 

assist such voers. See id. Absent relief from this Court, LULAC Plaintiffs and their members have 

no choice but 40 either follow Defendants' restrictive vote by mail policiessacrificing either their 

health or their voteor risk criminal prosecution. 

On April 7, 2020, the Texas Democratic Party and several individual Plaintiffs filed this 

litigation alleging that, in light of the COVID- 19 pandemic, Defendants' restrictive eligibility 

criteria for vo4ing by mail violate their own and their members' rights under the First, Fourteenth, 

and Twenty-Sixth Amendments to the Constitution, as well as Section 2 of the VRA, among other 

claims. See Dlt. No. 1. Three weeks later, and before Defendants had entered an appearance in the 

matter, on April 29, 2020, Party Plaintiffs amended their Complaint and filed a Motion for 

Preliminary IIjunction on their First, Fourteenth, and Twenty-Sixth Amendment claims, among 

others. See Dl$. Nos. 9 ("Party Pls.' Am. Compi."), 10. Four days later, on May 3, 2020only six 

working days efore LULAC Plaintiffs filed this MotionDefendants' counsel first entered their 

appearance in he litigation. See, e.g., Dkt. Nos. 17-19. Defendants have not yet responded to the 

Party Plaintiff' motion for a preliminary injunction. A hearing on the motion has been set for May 

15, 2020, and io substantive proceedings have otherwise occurred in the litigation. 

Plaintiffs now seek to intervene in the pending litigation. Texas LULAC was 

founded in 1 29 as the Texas chapter of the League of United Latin American Citizens, the 

nation's oldet and largest Latino civil rights organization. These nonprofit membership 

Case 5:20-cv-00438-FB Document 30 Filed 05/11/20 Page 3 of 13
organizations are dedicated to protecting the civil rights of Latinos in Texas, and as part of that 

mission, have invested significant time and resources promoting voting, voting rights, and civic 

participation tmong their members and within their communities. Unlike the Party Plaintiffs, 

LULAC P1aiitiffs are nonpartisan organizations, with over 20,000 members across Texas, 

including De$ocrats, Republicans, and Independents. 

LULA Plaintiffs seek to challenge Defendants' restrictions on absentee voting in this 

year's upcoming elections. Like Party Plaintiffs, LULAC Plaintiffs allege that in light of the 

COVID- 19 paidemic, Defendants' unreasonably restrictive eligibility criteria for absentee voting 

violate their riembers' rights to speech and to vote as protected by the First, Fourteenth, and 

Twenty-Sixth kmendments to the Constitution, and further violate Section 2 of the VRA based on 

the particular harms Defendants' policies will impose on Latino voters like LULAC Plaintiffs' 

members. Coi$pare Party Pls.' Am. Compl. ¶J 79-81, 86-94, 99-101, with LULAC Compl. 

¶J 53-73. LU1AC Plaintiffs also allege that Defendants' unreasonably restrictive vote by mail 

iciesalonside Attorney General Paxton's draconian threat to prosecute third party 

organizations that advise voters that they can vote by mail pursuant to the state's disability 

exception if they fear contracting coronavirusunconstitutionally burden Plaintiffs' First 

Amendment rihts of free speech and association. See LULAC Compi. ¶J 64-69. 

ARGUMENT 

I. LULAC P'aintiffs' Are Entitled to Intervene as of Right Pursuant to Rule 24(a). 

to Federal Rule of Civil Procedure 24(a), a court must permit a third party to 

intervene as ofright in a litigation if four conditions are met: 

(1) he motion to intervene is timely; (2) the potential intervener asserts an 

interest that is related to the property or transaction that forms the basis of 

the controversy in the case into which she seeks to intervene; (3) the 

disosition of that case may impair or impede the 

ru 

Case 5:20-cv-00438-FB Document 30 Filed 05/11/20 Page 4 of 13
ntial intervener's ability to protect her interest; and (4) the existing 

ies do not adequately represent the potential intervener's interest. 

John Doe No. 1 v. Glickman, 256 F.3d 371, 375 (5th Cir. 2001), "Although the movant bears the 

burden of estblishing its right to intervene, Rule 24 is to be liberally construed," and "[fjederal 

courts should allow intervention when no one would be hurt and the greater justice could be 

attained." WalHMart Stores, Inc. v. Tex. Alcoholic Beverage Comm 'n, 834 F.3d 562, 565 (5th Cir. 

2016) (quoting Texas v. United States, 805 F.3d 653, 656 (5th Cir. 2015); Sierra Club v. Espy, 18 

F.3d 1202, 125 (5th Cir. 1994)) (internal quotation marks omitted). 

A. LULAC Plaintiffs' Motion to Intervene Is Timely. 

LULA Plaintiffs' Motion to Intervene (the "Motion") is timely. The purpose of the 

timeliness anaysis is to "guard against prejudicing the original parties by the failure to apply 

sooner." John oe No. 1, 256 F.3d at 375. The analysis is contextual, with courts often relying on 

four factors asia framework: 

1) how long the potential intervener knew or reasonably should 

ave known of her stake in the case into which she seeks 

) intervene; (2) the prejudice, if any, the existing parties may suffer 

ecause the potential intervener failed to intervene when she knew 

r reasonably should have known of her stake in that case; (3) the 

rejudice, if any, the potential intervener may suffer if the court 

oes not let her intervene; and (4) any unusual circumstances that 

/eigh in favor of or against a finding of timeliness. 

Id. at 376. Eah of the four factors weighs in favor of LULAC Plaintiffs. 

First, tle Motion was filed only one month after the litigation began, and less than two 

weeks after the Party Plaintiffs filed an amended complaint and motion for preliminary injunction. 

See Dkt. Nos. 1, 9, 10. Defendants' counsel entered their appearances in the action just six working 

days ago, see, .g., Dkt. No 17; Defendants have not answered; and there have been no substantive 

proceedings in the matter, let alone trial or final judgment. Such circumstances favor a finding of 

Case 5:20-cv-00438-FB Document 30 Filed 05/11/20 Page 5 of 13
timeliness. S WalMart, 834 F.3d at 565 (finding a proposed intervenor's motion timely where 

it sought inteijvention before discovery progressed and did not seek to delay or reconsider phases 

of the litigati4n that had already concluded); John Doe No. 1, 256 F.3d at 377 (finding that an 

one month delay in filing motion to intervene, prior to trial or entry of judgment, is 

"not unreasonble"); Edwards v. City of Houston, 78 F.3d 983, 1001 (5th Cir. 1996) (finding that 

the filing of a notion to intervene prior to the entry of judgment "favors timeliness") 

these same circumstances confirm that LULAC Plaintiffs' intervention does not 

prejudice the existing parties. See Sierra Club v. Espy, 18 F.3d 1202, 1206 (5th Cir. 1994) 

("Prejudice mist be measured by the delay in seeking intervention, not the inconvenience to the 

existing partie of allowing the intervener to participate in the litigation."). LULAC Plaintiffs have 

not delayed inseeking to intervene, and the Party Plaintiffs do not oppose the Motion. Moreover, 

while Defenth4nts oppose the Motion for unstated reasons, it would be nonsensical for them to 

claim any prejidice when their own counsel appeared in the action just six working days before 

LULAC P1ainiffs filed this Motion. 

Third, LULAC Plaintiffs will be prejudiced by a denial of this Motion. The existing 

litigation addrsses questions around whether and how Texansincluding Texas LULAC's over 

20,000 membrsmay exercise their fundamental right to vote during a pandemic that has 

impacted the Latino community. See, e.g., LULAC Compl. ¶J 4, 35, 41-42. 

The question cf whether Defendants' actions improperly abridge or deny the rights of minority 

voters is centra' to the pending litigation, and directly implicates the rights and interests of LULAC 

Plaintiffs' menbers and communities. Moreover, the outcome of the litigation will directly impact 

LULAC Plaintffs' ability to engage in effective voter engagement activity central to their mission. 

An adverse outome would severely burden LULAC Plaintiffs' First Amendment rights and their 

Case 5:20-cv-00438-FB Document 30 Filed 05/11/20 Page 6 of 13
members' ex 

protecting th 

1002-03 (finc 

of their fundamental right to vote. LULAC Plaintiffs have a strong interest in 

e rights both through trial and, if necessary, on appeal. See Edwards, 78 F.3d at 

that potential intervenors would be prejudiced if denied the opportunity to appeal 

the ruling in a action in which they sought to intervene). 

Final1, Party Plaintiffs' pending Motion for a Preliminary Injunction is an unusual 

circumstance that counsels in favor of permitting intervention. Denial of intervention will preclude 

LULAC Plaiitiffs from participating in the upcoming preliminary injunction hearing and 

representing t4ieir members' interests in the crafting of any potential remedy.' 

B. LULAC Plaintiffs' Interests Directly Relate to the Matter that Forms the Basis of the Contrversy in the Pending Litigation. 

The "iiterest test" seeks to determine whether the potential intervenor has a "direct, 

substantial, [ailid] legally protectable' interest in the property or transaction that forms the basis of 

the controversly in the case into which she seeks to intervene." John Doe No. 1, 256 F.3d at 379 

(quoting Espy 18 F.3d at 1207); see also WalMart, 834 F.3d at 566 ("The touchstone of the 

inquiry is wheher the interest alleged is legally protectable."). The requirement "may be judged 

by a more 1enint standard if the case involves a public interest question or is brought by a public 

interest group.' Brumfield v. Dodd, 749 F.3d 339, 344 (5th Cir. 2014). 

LULA Plaintiffs challenge the exact same absentee voting restrictions as Party Plaintiffs. 

The oruani 

Constitution 

and their members plainly have a legally-protectable interest in whether the 

VRA permit these restrictions to deny or severely burden their right to free speech 

and associatioii and their members' exercise of the fundamental right to vote in the upcoming 

'To the extent ntervention is granted, LULAC Plaintiffs will seek to participate in the preliminary injunction procedings. LULAC Plaintiffs will file their own preliminary injunction motion within 

two days of thir Motion to Intervene being granted, and do not seek to delay these proceedings 

nor any other edsting deadlines in the case. 

'A 

Case 5:20-cv-00438-FB Document 30 Filed 05/11/20 Page 7 of 13
elections League of UnitedLatin American Citizens, Dist. 19 v. City of Boerne, 659 F.3d 421 

(5th Cir. 21 1) (finding a legally-protectable interest where the intervenor sought 

to protect his ight to vote); see also WalMart, 834 F.3d at 568-69 (finding a legally protectable 

interest wher the intervenor is subject to the regulations at issue in an action). But the impact on 

LULAC Plaiijitiffs' interests is even more palpable here, where, as just one example, Party 

Plaintiffs claiin that Defendants' absentee ballot eligibility requirements deny "minority voters" 

like most of liexas LULAC's over 20,000 members"an equal opportunity to participate in the 

political procss" in violation of the VRA. See Party Pis.' Am. Compi. 80. Minority voters like 

LULAC's members have a direct, protectable, and particularly substantial interest in whether 

Defendants' eiforcement of its election laws violates their right to vote under the VRA. 

C. Dispoition of the Existing Litigation May Impair or Impede LULAC Plaintiffs 

Abiliti to Protect Their and Their Members' Interests. 

To satisfy the third prong of the intervention analysis, a proposed intervenor must show 

only that "disposition of the action may impair or impede their ability to protect their interests." 

See Brumfield 749 F.3d at 344. An intervenor's interest "is impaired by the stare decisis effect of 

the district coi.rt's judgment." Espy, 18 F.3d at 1207. 

of the pending litigation may impair not only the interests of LULAC Plaintiffs 

and their members, but also LULAC Plaintiffs' ability to protect those interests. An outcome in 

Defendants' favor would have a persuasive effect on any separate litigation by LULAC Plaintiffs 

asserting consttutional and statutory claims related to Texas' vote by mail restrictions. Moreover, 

a less than adeuate outcome in the Party Plaintiffs' favor might only partially vindicate LULAC 

Plaintiffs' righ$s and interests, and if achieved through settlement or consent decree, may prevent 

LULAC Plaintiffs from providing input or appealing issues of particular importance to their 

Case 5:20-cv-00438-FB Document 30 Filed 05/11/20 Page 8 of 13
members 

formal mt 

D.P 

Fi 

plaintiffs' 

Plaintiffs 

community. See Espy, 18 F.3d at 1207 (describing the "legal rights associated with 

namely the briefing of issues, presentation of evidence, and ability to appeal") 

Plaintiffs May Not Adequately Represent LULAC Plaintiffs' Interests. 

a potential intervenor must carry a "minimal" burden of showing that the existing 

of its interests "may be inadequate." Espy, 18 F.3d at 1207. LULAC 

that burden here. As nonpartisan organizations, LULAC Plaintiffs seek to protect 

and vindicate the rights of over 20,000 members and their communities, including Democrats, 

Republicans, and Independents, regardless of political affiliation. While their interests in this 

litigation ma overlap to some extent with those of the Party Plaintiffs, the Party Plaintiffs 

partisan organizations and officials whose loyalties are to their own membersmay not 

adequately represent the interests of all of LULAC Plaintiffs' members. Moreover, as Latino 

membership 4rganizations, LULAC Plaintiffs mission is to defend the civil rights of the Latino 

community, which has been disproportionately impacted by COVID- 19, and will be 

impacted by the unavailability of absentee voting. See LULAC Compi. ¶IJ 4, 

35, 41-42 (decribing the high rates of COVID- 19 among Texas Latinos, and the risks of voting 

in person for Iatino voters). While LULAC Plaintiffs' interest may overlap the interest of the Party 

Plaintiffs' intrest, it not identical. Finally, while LULAC Plaintiffs' legal claims overlap in large 

part with the party Plaintiffs, they are distinguishable, and LULAC Plaintiffs have an interest in 

pursuing their own legal theories and claims to protect their rights and the rights of their members. 

LULAC Plaintiffs meet each of the four preconditions to intervention as of right. As such, 

under Federal Rule of Civil Procedure 24(a), LULAC Plaintiffs are entitled to intervene. 

II. Even If IULAC Plaintiffs Are Not Permitted to Intervene as of Right, Permissive 

Intervention Is Appropriate. 

Case 5:20-cv-00438-FB Document 30 Filed 05/11/20 Page 9 of 13
Even 

intervene wi 

intervener "1 

intervention is not required as of right, a court may still permit a third party to 

three conditions are met: (1) the motion to intervene is timely; (2) the potential 

a claim or defense that shares with the main action a common question of law or 

fact"; and (3) intervention will not unduly delay or prejudice the adjudication of the original 

parties' right. Fed. R. Civ. P. 24(b). Permissive intervention under Rule 24(b) "is wholly 

discretionary vith the [district] court." New Orleans Pub. Serv., Inc. v. United Gas Pipe Line Co., 

732 F.2d 452 470-71 (5th Cir. 1984) (en banc). 

As dicussed above, LULAC Plaintiffs' motion is timely. See supra at 5-7. Moreover, 

many of LUL4C Plaintiffs' claims share common questions of fact and law with those of the Party 

Plaintiffs, incuding their claims under the First, Fourteenth, and Twenty-Sixth Amendments, and 

the VRA. Intrvention will not delay the ongoing proceedings or otherwise prejudice the existing 

parties in any respect. The litigation is still at its inception, and even with respect to Party Plaintiffs' 

pending motin for preliminary injunction, if permitted to intervene, LULAC Plaintiffs will not 

seek to stay o delay resolution of Party Plaintiffs' motion, but will merely seek to represent their 

interests and tie interests of their members in the upcoming proceeding. See supra at 7 n. 1. 

Each 4liscretionary factor favors permitting LULAC Plaintiffs to intervene. In addition, 

judicial 

LULAC 

their membei 

Voting Right 

Intervene in I 

favors intervention, particularly considering that any separate litigation by 

would be brought in the same courthouse as the pending litigation. 

CONCLUSION 

this litigation directly affects the fundamental rights of LULAC Plaintiffs and 

under the First, Fourteenth, and Twenty-Sixth Amendments, and Section 2 of the 

LULAC Plaintiffs respectfully request that the Court grant their Motion to 

litigation. 

10 

Case 5:20-cv-00438-FB Document 30 Filed 05/11/20 Page 10 of 13
DATED: Mty 11, 2020 Respectfully submitted, 

Danielle M. 

Rob Weinei 

Ravi S. Dos 

Molly E. Th 

Jonathan Di 

Campaign I 

1101 14th S 

Washington 

Telephone: 

Facsimile: ( 

jdi 

* motions for 

forthcoming 

* 

gal Center 

NW Ste, 400 

DC 20005 

W2) 736-2200 

02) 736-2222 

aignlegal.org 

ipaignlegal.org 

,aignlega1.org 

tmpaignlegal.org 

rignlegal.org 

admission pro hac vice 

Is! Luis Roberto Vera, Jr. 

Luis Roberto Vera, Jr. 

LULAC National General Counsel 

Law Offices of Luis Roberto Vera, Jr. & 

Associates 

407 W. Ware Blvd. 

San Antonio, TX 78221 

Telephone: (210) 225-3300 

lrvlaw@sbcglobal.net 

Counsel for LULAC Plaintiffs 

11 

Case 5:20-cv-00438-FB Document 30 Filed 05/11/20 Page 11 of 13
CERTIFICATE OF SERVICE 

I hereby certify that on this 11th day of May, 2020, the following documents were traditionally 

filed with th&Clerk of the Court: 

Motio to Intervene of League of United Latin American Citizens and Texas League of 

Unite Latin American Citizens 

Comp aint of League of United Latin American Citizens and Texas League of United Latin 

Amer can Citizens (attached as Exhibit 1 to Motion to Intervene) 

Pr000 ed Order 

The following counsel were thereafter served via the Court's CMIECF system: 

Counsel for Ipefendants Abbott, Hughs. and Counsel for Defendant DeBeauvoir: 

Paxton: 

Leslie W. Dippel 

Anne Marie T [ackin Sherine Elizabeth Thomas 

Office of the ttorney General Cynthia W. Veidt 

300 West 1 5t Street Andrew M. Williams 

General Litig tion-lith Floor Travis County Attorney's Office 

Austin, TX 7 701 P0 Box 1748 

Phone: (512) 36-0161 Austin, TX 78767 

Email: anna.r ackin@oag.texas.gov Phone: (512) 854-2911 

Email: leslie.dippeltraviscountytx.gov 

Michael Abr ns Email: sherine.thomastraviscountytx.gov 

Cory A. Scan on Email: cynthia.veidt@traviscountytx.gov 

Office of the kttorney General Email: drew.williams@traviscountytx.gov 

P.O. BOx 12 48 

Capitol Statioi Counsel for Plaintiffs: 

Austin, TX 7 711-2548 

Phone: (512) 63-2120 K. Scott Brazil 

Email: micha 1.abrams@oag.texas.gov Brazil & Dunn 

Email: cory.s an1onoag.texas.gov 13231 Champion Forest Dr. 

Suite 406 

Counsel for [ efendant Callanen: Houston, TX 77069 

Phone: (281) 580-6310 

Robert D. Gn en Email: scott@brazilanddunn.com 

Bexar Count) District Attorney 

Civil Divisioi Chad W. Dunn 

101 W. Nuev Brazil & Dunn 

7th Floor 4407 Bee Caves Road 

San Antonio, EX 78205 Building 1, Suite 111 

Phone: (210) 35-2146 Austin, TX 78746 

Email: robert. reen@bexar.org Phone: (512) 717-9822 

Email: chad@brazilanddunn.com 

12 

Case 5:20-cv-00438-FB Document 30 Filed 05/11/20 Page 12 of 13
Martin Antho y Golando 

The Law Offi e of Martin Golando, PLLC 

405 N. St. M4ry's Street, Suite 700 

San Antonio, TX 78205 

Phone (210) 92-8543 

Email: martinkgolando@gmail.com 

Richard Alan Grigg 

Law Offices cfDicky Grigg, PC 

4407 Bee Cavfes Road 

Building 1, Si$te 111 

Austin, TX 7746 

Phone: (512) 74-6061 

Email: dicky(2ri-1aw.com 

Robert Leslie vIeyerhoff 

Texas Democatic Party 

314 E. Highla$id Mall Blvd. #508 

Austin, TX 7752 

Phone: (512) 478-9800 

Email: rmeyerhofftxdemocrats.org 

13 

s/Luis Roberto Vera, Jr. Luis Roberto Vera, Jr. 

Case 5:20-cv-00438-FB Document 30 Filed 05/11/20 Page 13 of 13