1

IN THE UNITED STATES DISTRICT COURT 

FOR THE WESTERN DISTRICT OF TEXAS 

SAN ANTONIO DIVISION 

TEXAS DEMOCRATIC PARTY, GILBERTO §

HINOJOSA, Chair of the Texas Democratic § 

Party, JOSEPH DANIEL CASCINO, § 

SHANDA MARIE SANSING, and § 

BRENDA LI GARCIA § 

Plaintiffs, § 

§ 

v. § Case No. 5:20-cv-00438

§ 

GREG ABBOTT, Governor of Texas; RUTH § 

HUGHS, Texas Secretary of State, DANA § 

DEBEAUVOIR, Travis County Clerk, and § 

JACQUELYN F. CALLANEN, Bexar County § 

Elections Administrator § 

§ 

Defendants. § 

UNOPPOSED MOTION OF THE REPUBLICAN PARTY OF TEXAS FOR LEAVE

TO FILE AMICUS BRIEF IN OPPOSITION TO

PLAINTIFFS’ MOTION FOR PRELIMINARY INJUNCTION

The Republican Party of Texas (“RPT”) respectfully asks this Court for leave to file an 

amicus brief in opposition to Plaintiffs’ Motion for Preliminary Injunction.

1 All parties have 

consented to the filing of this motion.2

1 No party’s counsel authored the attached brief in whole or in part, and no one other than amicus and its counsel 

contributed money to fund the brief’s preparation or submission.

2 Counsel for all parties have consented to the filing of this Amicus Brief as of May 13, 2020.

Case 5:20-cv-00438-FB Document 41 Filed 05/13/20 Page 1 of 4
2

INTEREST OF PROPOSED AMICUS CURIAE

The Republican Party of Texas is a political party recognized by the Texas Election Code. 

We believe that elections are fair when the process by which elections are conducted is consistent 

and predictable. We support elections free from the flames of fear and uncertainty fanned by the 

Texas Democratic Party and liberal activists, whose true goal is to create a voting environment 

where checks and balances are few, and voter fraud can thrive. Our focus is to ensure that elections 

are conducted safely and consistently with the letter and spirit of the laws of Texas. Challenges to 

duly enacted election procedures, such as those brought by Plaintiffs in the present case, can only 

damage the integrity and legitimacy of the election results. After all, “there must be a substantial 

regulation of elections if they are to be fair and honest and if some sort of order, rather than chaos, 

is to accompany the democratic processes.” Storer v. Brown, 415 U.S. 724, 730 (1974). The 

Republican Party of Texas thus has a significant interest in this important case.

ARGUMENT

RPT’s brief will be useful to the Court’s resolution of the important issues in this case. The 

brief highlights the Republican Party’s unique perspective regarding the Supreme Court’s Purcell

doctrine and its application to the present case. Specifically, there is strong public interest in the 

orderly administration of elections and the remedy Plaintiffs seek would wreak havoc on Texas’s

election process. This disorder stems from the extreme proximity to the upcoming primary 

elections.

CONCLUSION

For the foregoing reasons, the Republican Party of Texas respectfully requests this Court 

grant this motion for leave to file its Amicus Brief.

This the 13th day of May, 2020. Respectfully submitted, 

Case 5:20-cv-00438-FB Document 41 Filed 05/13/20 Page 2 of 4
3

REPUBLICAN PARTY OF TEXAS

Wade Emmert*

General Counsel

Republican Party of Texas

Texas State Bar No. 00793688

Emmert Law Firm, PC

100 Crescent Court, Suite 700

Dallas, TX 76013

Telephone: (469) 607-4502

Facsimile: (469) 436-6378

wade@emmertlaw.com

*Counsel admitted but currently on inactive 

status. Readmission fee submitted.

ATTORNEYS FOR AMICUS CURIAE

By: /s/ Dallin B. Holt 

Dallin B. Holt

Texas State Bar No. 24099466

Holtzman Vogel Josefiak Torchinsky PLLC

34 N. Hill Dr., Suite 100

Warrenton, VA 20186

Telephone: (540) 341-8808

Facsimile: (540) 341-8809

dholt@hvjt.law

Case 5:20-cv-00438-FB Document 41 Filed 05/13/20 Page 3 of 4
4

CERTIFICATE OF SERVICE

I do hereby certify that, on this 13th day of May 2020, the foregoing was electronically 

filed with the Clerk of Court using the CM/ECF system, which gives notice of filing to all 

counsel of record. 

/s/ Dallin B. Holt

Dallin B. Holt

Counsel for Amicus Republican Party of Texas

Case 5:20-cv-00438-FB Document 41 Filed 05/13/20 Page 4 of 4