WILLIAM P. CLEMENTS, JR. GOVERNOR OFFICE OF THE GOVERNOR STATE CAPITOL AUSTIN, TEXAS 78711 November 6, 1981 The Honorable Mark White Attorney General of Texas Supreme Court Building Austin, Texas RE: Seamon vs. Upham, et. al. Dear General White: I believe it would establish a terrible precedent, irreparably harming the Office of Governor, to subject the Governor of Texas to oral deposition in a case such as this where the Governor has acted in his official capacity and such actions have no direct relevance to the issues in the case. Accordingly, I respectfully request that you provide the Governor's Office your ablest and most comprehensive counsel in identifying all lawful means of prohibiting oral deposition of the Governor, evaluating and advising me of such means, and fully pursuing to completion the means I choose. If, due to shortage of time or staff and the volume of other business, you cannot provide these services in the manner that this significant issue to the State of Texas requires, please certify to me that I may retain other counsel to handle this matter. Sincerely, William P. Clements, Jr. Governor WPCJr:srh