EXCEPTIONAL REPORTING SERVICES, INC 

UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF TEXAS 

CORPUS CHRISTI DIVISION 

MARC VEASEY, ET AL., ) CASE NO: 2:13-CV-00193 

 ) 

 Plaintiffs, ) CIVIL 

 ) 

vs. ) Corpus Christi, Texas 

 )

RICK PERRY, ET AL., ) Wednesday, September 3, 2014 

 ) (7:59 a.m. to 12:11 p.m.) 

 Defendants. ) (1:10 p.m. to 5:49 p.m.) 

BENCH TRIAL - DAY 2 

BEFORE THE HONORABLE NELVA GONZALES RAMOS, 

UNITED STATES DISTRICT JUDGE 

Appearances: See Next Page 

Court Recorder: Genay Rogan 

Clerk: Brandy Cortez 

Court Security Officer: Adrian Perez 

Transcriber: Exceptional Reporting Services, Inc. 

 P.O. Box 18668 

 Corpus Christi, TX 78480-8668 

 361 949-2988 

Proceedings recorded by electronic sound recording;

transcript produced by transcription service. 

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APPEARANCES FOR:

Plaintiffs: CHAD W. DUNN, ESQ. 

 KEMBEL SCOTT BRAZIL, ESQ. 

 Brazil and Dunn 

4201 Cypress Creek Parkway, Suite 530 

Houston, TX 77068 

ARMAND DERFNER, ESQ. 

P.O. Box 600 

Charleston, SC 29402 

 J. GERALD HEBERT, ESQ. 

 Attorney at Law 

 191 Somervelle Street #405 

 Alexandria, VA 22304 

NEIL G. BARON, ESQ. 

914 FM 517 Rd. W, Suite 242 

Dickinson, TX 77539 

LUIS ROBERTO VERA, JR., ESQ. 

111 Soledad, Suite 1325 

San Antonio, TX 78205 

EMMA P. SIMSON, ESQ. 

Campaign Legal Center 

215 E. Street NE 

Washington, DC 20002 

Mexican American EZRA D. ROSENBERG, ESQ. 

Legislative Caucus, Dechert, LLP 

et al.: 902 Carnegie Center, Suite 500 

 Princeton, NJ 08540-6531 

MARK A. POSNER, ESQ. 

AMY L. RUDD, ESQ. 

LINDSEY COHAN, ESQ. 

JENNIFER CLARK, ESQ. 

Lawyers’ Committee for Civil Rights 

1401 New York Ave. NW, Suite 400 

Washington, DC 20005 

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APPEARANCES FOR: (CONTINUED) 

United States RICHARD DELLHEIM, ESQ. 

of America: ELIZABETH S. WESTFALL, ESQ. 

ANNA BALDWIN, ESQ. 

PAMELA CARLIN, ESQ. 

AVNER SHAPIRO, ESQ. 

U.S. Department of Justice 

950 Pennsylvania Ave. NW 

Washington, DC 20530 

BRUCE I. GEAR, ESQ. 

Department of Justice 

1800 G Street NW 

Washington, DC 20006 

Ortiz Plaintiffs, JOSE GARZA, ESQ. 

et al.: 7414 Robin Rest Dr. 

 San Antonio, TX 78209 

ROBERT W. DOGGETT, ESQ. 

Texas Rio Grande Legal Aid, Inc. 

4920 North IH 35 

Austin, TX 78751 

MARINDA VAN DALEN, ESQ. 

Texas RioGrande Legal Aid, Inc. 

531 E. St. Francis 

Brownsville, TX 78520 

Texas League of Young RYAN HAYGOOD, ESQ. 

Voters Education Fund: NATASHA KORGAONKAR, ESQ. 

NAACP Legal Def. and Educational Fund 

 40 Rector St., 5th Floor 

 New York, NY 10006 

Also present: Imani Clark 

 DANIELLE CONLEY, ESQ. 

 KELLY DUNBAR, ESQ. 

Wilmer Cutler Pickering, et al. 

 1875 Pennsylvania Avenue, NW 

 Washington, DC 20006 

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APPEARANCES FOR: (CONTINUED) 

Texas Association of ROLANDO L. RIOS, ESQ. 

Hispanic County Judges 115 E. Travis 

and County Suite 1654 

Commissioners: San Antonio, TX 78205 

Also present: ROGER GALVAN, County Commission 

 Calhoun County 

State of Texas: JOHN BARRET SCOTT, ESQ. 

 Deputy Attorney General 

 for Civil Litigation 

 Office of the Attorney General 

 P.O. Box 12548 

 Austin, TX 78711 

 JOHN REED CLAY, JR., ESQ. 

 LINDSEY E. WOLF, ESQ. 

 JENNIFER ROSCETTI, ESQ. 

 G. DAVID WHITLEY, ESQ. 

 STEPHEN L. TATUM, JR., ESQ. 

 STEPHEN R. KEISTER, ESQ. 

 Office of the Attorney General 

 P.O. Box 12548 

 MC001 

 Austin, TX 78711 

 ARTHUR D’ANDREA, ESQ. 

 Office of the Attorney General 

 209 W. 14th Street, 7th Floor 

 Austin, TX 78701 

 BEN A. DONNELL, ESQ. 

 Donnell Abernethy Kieschnick 

 555 N. Carancahua, Suite 400 

 Corpus Christi, TX 78401 

WHITNEY DEASON, ESQ. 

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INDEX

PLAINTIFFS' WITNESSES DIRECT CROSS REDIRECT RECROSS

MICHAEL HERRON 

 BY MR. DERFNER 8 96 

 BY MR. SCOTT 78/95 

 BY MS. BALDWIN 93 

EULALIO MENDEZ, JR. 

 BY MS. VAN DALEN 97 

 BY MS. WOLF 110 

RAMONA BINGHAM 112 

(EXCERPTS OF VIDEO DEPO) 

KRISTINA MARIE MORA 

 BY MR. SHAPIRO 113 

 BY MR. SCOTT 134 

YAIR GHITZA 

 BY MS. BALDWIN 146 189 

 BY MR. SCOTT 167 190 

RANDALL BUCK WOOD 

 BY MR. DUNN 192 240 

 BY MR. CLAY 213 

BLAKE GREEN 

 BY MS. KORGAONKAR 247 

 BY MR. TATUM 260 

DAWN WHITE 

 BY MS. RUDD 268 

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INDEX (CONTINUED)

PLAINTIFFS' WITNESSES DIRECT CROSS REDIRECT RECROSS

GORDON BENJAMIN 

 BY MR. BARON 288 

 BY MS. ROSCETTI 296 

PHYLLIS WASHINGTON 

(EXCERPTS OF VIDEO DEPO) 299 

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1 RANDALL BUCK WOOD, PLAINTIFFS’ WITNESS, SWORN 

2 MR. CLAY: Thank you, sir. 

3 DIRECT EXAMINATION 

4 BY MR. DUNN: 

5 Q Please tell us your name. 

6 A Randall Buck Wood. 

7 Q Do you go by Buck? 

8 A I -- it’s my second name. Yes and that’s what everybody 

9 knows me by. 

10 Q All right, Mr. Wood. As you know, my name is Chad Dunn. 

11 I represent one of the Plaintiffs in this lawsuit. I retained 

12 you as an expert; is that true? 

13 A That’s correct. 

14 Q All right. You have in front of you the report that you 

15 issued in this case; is that correct? 

16 A Yes. 

17 MR. DUNN: And for the Court’s benefit, that’s 

18 Plaintiffs’ Exhibit 776. 

19 Q Included in the exhibit is your CV; is that true? 

20 A It was. Let’s see if it’s -- yes. 

21 Q Okay. And I assume your representations in your CV about 

22 your education, training and experience are accurate? 

23 A Yes. I -- I’m not sure. It seems to me that during the 

24 deposition, they -- it was brought to my attention that I was 

25 listed as the Executive Director of the Texas Chapter of Common 

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1 Cause at one time and I’m not seeing that right now but I don’t 

2 think there was a designation of the Executive Director. I was 

3 the chief cook and bottle washer but -- so -- 

4 Q Okay. 

5 A Other than that, yes, it’s -- yeah, correct. 

6 Q All right. So let’s just back up. Tell us where you were 

7 born and where you grew up and went to school and that sort of 

8 thing.

9 A I was born in Athens, Texas July 7th, 1944. I grew up in 

10 a little town called Edom, Texas which is about 20 miles from 

11 Athens. I attended a common school district, Edom Common 

12 School District through the eighth grade and then I went to Van 

13 High School. All that’s in Van Zandt County.

14 I then went to Tyler Junior College for two years. I 

15 transferred to the University of Texas and got an undergraduate 

16 degree in history and then went to law school -- well, actually 

17 I did some of it at the same time. I went to law school and 

18 graduated in ’68. 

19 Q And which law school was that? 

20 A University of Texas. 

21 Q After attending law school, were you admitted to the Bar? 

22 A Yes. 

23 Q And when was that? 

24 A September of ’68. 

25 Q Have you practiced law in Texas since then? 

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1 A Yes. 

2 Q Okay. Give us a sense of what kind of law you practiced 

3 over your 40-plus years. 

4 A Oh, first of all, I spent some time as a lawyer in -- for 

5 the State of Texas. I was the Director of Elections for the 

6 Secretary of State for some 3-something years. I then lobbied 

7 for Common Cause for two years and that involved a lot of 

8 election stuff like campaign finance and things of that nature.

9 I then became the General Counsel of the Comptroller of Public 

10 Accounts in ’75 when Bob Bullock took office and I was then 

11 promoted to the Chief Deputy Comptroller which was the Number 

12 Two person in the Comptroller’s office and I left in April or 

13 May of ’77 and went into private practice with a firm we 

14 created and exists today. 

15 Q So you’ve practiced law as a private attorney since about 

16 1977?

17 A Yes. 

18 Q Is one of the areas of law that you focused on is election 

19 law?

20 A Yes. 

21 Q Give us a sense of the type of matters you handle in the 

22 area of election law. 

23 A I don’t know what type of matter I haven’t handled. Since 

24 I had been Director of Elections and been involved in elections 

25 all of life -- my family was a very political family -- we 

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1 immediately started -- our little firm started getting clients 

2 that had election problems, election contests, recounts, 

3 investigations, qualifications to run for office and everything 

4 and even though it didn’t provide a steady stream of income, we 

5 did a lot of it and I still do. 

6 Q Is it fair to say that most of the reported state 

7 appellate decisions on election law in the last 30 years have 

8 your name or another lawyer at your firm’s name on it? 

9 A You know, I don’t know the percentage but it’d be pretty 

10 high.

11 Q All right. You’ve handled a number of matters at the 

12 Texas Supreme Court? 

13 A I’m usually in the Texas Supreme Court every other year or 

14 every year. 

15 Q On election-related matters? 

16 A Yes. 

17 Q Okay. So let’s just talk a little bit about election 

18 contests. What exactly is an “election contest” under state 

19 law?

20 A An “election contest” is a legislatively delegated lawsuit 

21 that’s delegated to the judiciary. We had to pass a 

22 Constitutional amendment to have election contest. It’s tried 

23 almost identically to any other civil lawsuit. There are some 

24 restrictions in the election code which override certain Rules 

25 of Civil Procedure and things but other than that, it’s tried 

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1 just like an ordinary lawsuit except it can’t be tried to a 

2 jury.

3 Q And in an election contest, is occasionally one of the 

4 issues whether there’s somebody or some group of persons have 

5 lawfully voted? 

6 A Whether they were qualified to vote or voted unlawfully, 

7 yes, that is true in almost every election contest. 

8 Q And, in fact, what is the ultimate legal issue the judge 

9 is asked to decide in an election contest? 

10 A They’ve got basically three options. They can uphold the 

11 result of the election as stated -- as it’s canvassed. They 

12 can declare the other person -- the challenger who didn’t win 

13 in the primary, they can declare that person the victor or they 

14 call a new election if they can’t determine the outcome. 

15 Q And what effect does discovery of illegal voting have on 

16 the outcome in an election contest? 

17 A Well, I wouldn’t say this is true in every case but almost 

18 every case, somebody won and somebody lost by a very small 

19 margin, you know. Now, that sometimes can be a pretty good 

20 size but, you know, a statewide race, let’s say. Or it can be 

21 a few votes. So whether people that voted in that election 

22 were legally entitled to vote in that election and how they 

23 voted is an issue in 99 percent of election contests. 

24 Q Is it fair to say that you’ve handled scores of election 

25 contests?

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1 A At one time, I had tried election contests in 50 counties. 

2 The reason I know that I was hanging pictures on my wall of the 

3 courthouses until my (indiscernible) managers told me that 

4 wasn’t going to work anymore. But I’m sure I’ve tried election 

5 matters. Some of them would be qualifications for office and 

6 things like that in a hundred counties. 

7 Q Are there many lawyers in Texas that handle election8 related work on a regular basis? 

9 A Not on a regular basis. That’s pretty unusual. Some 

10 people will have had maybe one or two matters. If you’re 

11 talking about election contests, now there’s -- like I said, 

12 there’s other variations on the theme, recounts and all things 

13 like that. There used to be a number of lawyers and many of 

14 them in Austin -- a number of them in Austin but they’ve 

15 retired or are deceased. There are a few other lawyers that I 

16 know that have done election contests, a few. There’s some in 

17 south Texas that do some and the reason I know is they’re 

18 usually on the other side of the election contest from me but 

19 not many. 

20 Q Is it fair to say that as far as you know, there’s no 

21 other attorney in the state that’s handled as many of these 

22 matters as you have? 

23 A I’m not sure that’s the case. 

24 Q Okay. Now, occasionally in election-related disputes, 

25 does somebody raise the allegation that there was fraudulent 

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1 voting or illegal voting? 

2 A Well, we’ve got to be -- I don’t like to use the word 

3 “illegal” voting. Most people who vote who are not eligible to 

4 vote are not doing it intentionally. They don’t know that 

5 they’re not eligible to vote. They may have moved outside of a 

6 state representative’s district or something and still thought 

7 they could vote for that candidate and they go ahead and vote.

8 I’d say intentional voter fraud in person is very rare. And I 

9 just don’t like to use that term “illegal voter” because most 

10 of them that we find that are not eligible to vote really 

11 didn’t commit any crime. 

12 Q Now, when you talk about intentional voter fraud in person 

13 being rare, are you referring to voter impersonation? 

14 A Well, what I was really referring there is in some 

15 instances -- and I have been involved in a number of election 

16 contests, the election officials themselves were involved in 

17 it. So it was at the polling place -- that the election 

18 officials at the polling place were actually involved in that 

19 fraud.

20 If you’re talking about impersonation of a voter -- 

21 in other words, a voter trying to vote impersonating another 

22 voter, I’ve never seen one. 

23 Q Has it been raised though in cases you’ve handled? 

24 A No. 

25 Q Has somebody alleged at least colloquially or in a press 

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1 release that there’s illegal impersonation and then you get 

2 involved in the election contest and it turns out there were 

3 none?

4 A Um, I know of one where that happens but I was not 

5 personally involved in it. Impersonation just -- it just 

6 doesn’t happen. I mean, I know it could -- can happen and, 

7 therefore, it probably has happened. I’ve been told by lawyers 

8 that they’ve heard of it. It just -- it doesn’t happen and it 

9 doesn’t happen for a very simple reason. It almost can’t 

10 happen, not without being detected. 

11 Q And why is it your opinion it can’t happen without being 

12 detected?

13 A Well, I can see that if someone went to some trouble -- 

14 I’m talking about an individual here -- and they found out that 

15 -- they just decided they’d go vote under somebody else’s name.

16 Let’s just say they just decided to do that. Well, they’re 

17 almost certainly going to get caught. First, you’d have to 

18 pick your voter out that you’re going to impersonate and then 

19 you would have to hope that that person hadn’t already voted 

20 either by mail or in person in early voting and then you would 

21 have to hope that that person didn’t come in and try to vote 

22 later because you’re going to get caught.

23 And as I said, I have been told that it’s happened on 

24 a very small number of people from the state because they got 

25 caught. It’s just almost impossible to do. On anything other 

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1 than a -- kind of a nutty situation where somebody just thinks 

2 they’ll go down and vote for their neighbor or something, it 

3 doesn’t happen. 

4 Q When a would-be voter impersonator goes into the polls, do 

5 they have to be concerned if the election worker might 

6 recognize them or might know the person they’re trying to 

7 impersonate?

8 A Sure. I will say this -- and this is because of my years 

9 of experience. The people that are the election officials at 

10 the polling place, they generally have been doing that for 

11 quite a while and they know people in that area. It’s not -- 

12 it’s not as -- like it used to be because now we have early 

13 voting in person and sometimes you can go to any polling place.

14 You can go to polling places all over but yes, you would have 

15 to be concerned they wouldn’t know who you were or who the 

16 voter was and these are all felonies and they’re multiple 

17 felonies.

18 Q And a would-be voter impersonator, do they also have to -- 

19 prior to SB14, wouldn’t they also have to have some 

20 identification or some documentation that links them to the 

21 person they wanted to vote for? 

22 A Yes. We -- I was on the -- Lieutenant Governor Hobby 

23 appointed me to the Advisory Commission to revise the election 

24 code back in ’83 through ’85 and we looked at the entire code 

25 obviously but since I was mainly put on there because of 

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1 election issues and conduct of elections, I looked at all the 

2 laws. We changed some of the laws, quite a few, in fact. I 

3 don’t think I’ve totally answered your question. 

4 Q Well, the question was, prior to SB14, if somebody wanted 

5 to -- 

6 A Oh, yes, I got it. 

7 Q -- commit voter impersonation, wouldn’t they need some 

8 article from -- 

9 A They would. We built into the law prior to the voter ID 

10 laws, everybody calls it -- we built in an identification 

11 provision and it could be satisfied a number of different ways 

12 but you would had to have something indicating that you were 

13 that person. 

14 Q And that could be a voter registration card under the old 

15 law; is that right? 

16 A Yes. 

17 Q That could be a utility bill under the old law? 

18 A Yes. 

19 Q Driver -- 

20 A Well, obviously that utility bill would have to show the 

21 address that’s -- that the election officials would have had on 

22 the voter rolls. 

23 Q And you -- of course, you could use your driver’s license 

24 under the old law? 

25 A Sure. 

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1 Q Okay. On the other articles that were listed, are they 

2 typically things you’d have to get out of -- let’s call it a 

3 victim’s mail in order to impersonate them?

4 A I’m not sure what you mean. 

5 Q Well, like a utility bill or a telephone bill. 

6 A Oh, well, you either have to get it out of their mail or 

7 -- I don’t know how you would do it but I guess you could rob 

8 mailboxes.

9 Q Okay. Which -- would that also be a crime? 

10 A Yes, of course. 

11 Q All right. Now, is there voter fraud occurring by mail? 

12 A Yes, very definitely. 

13 Q I mean, would you characterize it as a problem, the amount 

14 of voter fraud by mail? 

15 A It is a serious problem. 

16 Q Explain the problem to us, please. 

17 A Well, it didn’t used to be such of a problem because prior 

18 to our passing legislation that let anybody over the age of 65 

19 vote by mail, you had to have some doctor’s excuse or something 

20 in effect saying that you are unable to attend the polls. Now, 

21 that was pretty easy to get if you were elderly and you 

22 normally had a doctor and they would sign one for you but what 

23 really happened was when they went to, in effect, no excuses 

24 over 65 mail-in voting, the -- there’s nobody supervising you 

25 when you have that ballot if you’re the voter. You may -- the 

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1 voter may never even see the ballot.

2 We have actually had evidence in election contests

3 where the people that were living the fraud knew what day the 

4 ballot was being mailed out and actually went and got it out of 

5 the mailbox before the person -- the voter ever even saw it.

6 And the usual system is they go to nursing homes. They go to

7 -- and I say “they.” I’m talking people that commit this kind 

8 of fraud and they’re organized. 

9 They go to people’s houses that -- sometimes they 

10 cultivate these people year-round. I’ve had cases where they 

11 had like a hundred or a hundred and fifty people that they knew 

12 that were old that were infirm and they’d go by and see them in 

13 the off-season. They were friends and then, of course, they 

14 would get them a ballot and they would generally vote the 

15 ballot for them. 

16 Q You -- 

17 A That’s common. 

18 Q You mentioned that there’s organized efforts on mail-in 

19 voter fraud. Is it easier in mail-in voter fraud to harvest or 

20 turn in a number of fraudulent votes? 

21 A It’s very easy. 

22 Q Is it more difficult to in person commit voter fraud to 

23 the degree enough to change an election outcome? 

24 A I’ve never seen one and the reason being, unless the 

25 election official at the polling place is in on the fraud, it’s 

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1 just -- almost doesn’t happen. 

2 Q And you were asked in your deposition by Mr. Clay a number 

3 of questions in this case. You recall that? 

4 A Yes. 

5 Q One of the answers that you gave -- you thought you had 

6 seen recently -- well, strike that. One of the answers you 

7 gave is that there are often allegations that noncitizens have 

8 successfully voted. Do you remember that conversation? 

9 A Yes. 

10 Q Is it your experience that noncitizens are voting in 

11 Texas?

12 A I don’t know why it is but a -- in south Texas and east 

13 Texas, there are a lot of election contests, a lot of election 

14 disputes and contests. The -- it always comes up that somebody 

15 says somebody’s dead that voted. I’ve heard that from my 

16 clients and I’ve heard it from the other side and everything 

17 and in my 42 years of doing this -- or 44 years, I’ve never 

18 found one, not one. 

19 Q Is that the same for noncitizens? 

20 A I found a noncitizen a few years back for the first time 

21 and that is -- that is always something that people -- oh, I 

22 know so-and-so and they’re not a citizen or I know so-and-so 

23 and he’s dead or that person’s dead. When you get through with 

24 it, I had never found it until just by accident and it was a 

25 vote by mail. 

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CERTIFICATION

I certify that the foregoing is a correct transcript from the 

electronic sound recording of the proceedings in the aboveentitled matter. 

 September 4, 2014 _ 

TONI HUDSON, TRANSCRIBER 

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