David A. Dean SECRETARY OF STATE STATE OF TEXAS OFFICE OF THE SECRETARY OF STATE AUSTIN, TEXAS 78711 April 2, 1982 The Honorable Mark White Attorney General Supreme Court Building Austin, Texas 78711 Dear General White: There is apparently a distinct difference of opinion between my position as the State's Chief Election Officer and party defendant and your position as to what the state's position is in the congressional redistricting lawsuit, Seamon v. Upham. Therefore, I am requesting you to authorize me to hire Cullen Smith, Mike Morrison, and David Guinn, all of Waco, as outside counsel. If I have not heard from you by 6:00 p.m. today granting me this authority, I will ask the federal court to order the outside counsel requested. If you refuse to grant my request for outside counsel, I request that you fully advise the court that I adamantly oppose the implementation of the court drawn congressional districts for congressional districts 3, 5, 24, and 26 even on a temporary basis. Further, should you refuse my request for outside counsel, I request you file on my behalf any motions or pleadings that are delivered to you by 8:15 a.m. Monday, April 15, 1982, with the court no later than 9:00 a.m. of the same day in order for these matters to properly be presented to the court. Please advise me of your position by 6:00 p.m. today. Sincerely, David A. Dean Secretary of State DAD:dsw