Case: League of United Latin American Citizens v. Nelson

COMPLAINT for Injunctive and Declaratory Relief ( Filing fee $ 405 receipt number ATXWDC-21645149), filed by League of United Latin American Citizens Council 102, Texas League of United Latin American Citizens, Common Cause, League of United Latin American Citizens. (Attachments: # 1 Civil Cover Sheet Civil Coversheet, # 2 Exhibit Ex. A, # 3 Exhibit Ex. B, # 4 Exhibit Ex. C, # 5 Exhibit Ex. D, # 6 Exhibit Ex. E, # 7 Exhibit Ex. F, # 8 Exhibit Ex. G, # 9 Exhibit Ex. H, # 10 Exhibit Ex. I, # 11 Exhibit Ex. J, # 12 Exhibit Ex. K, # 13 Exhibit Ex. L, # 14 Exhibit Ex. M, # 15 Exhibit Ex. N, # 16 Exhibit Ex. O, # 17 Exhibit Ex. P, # 18 Exhibit Ex. Q, # 19 Exhibit Ex. R, # 20 Exhibit Ex. S, # 21 Exhibit Ex. T, # 22 Exhibit Ex. U)(Grigg, Richard) (Entered: 03/26/2026)

1 Civil Cover Sheet Civil Coversheet

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2 Exhibit Ex. A

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3 Exhibit Ex. B

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4 Exhibit Ex. C

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5 Exhibit Ex. D

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6 Exhibit Ex. E

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7 Exhibit Ex. F

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8 Exhibit Ex. G

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9 Exhibit Ex. H

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10 Exhibit Ex. I

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11 Exhibit Ex. J

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12 Exhibit Ex. K

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13 Exhibit Ex. L

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14 Exhibit Ex. M

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15 Exhibit Ex. N

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16 Exhibit Ex. O

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17 Exhibit Ex. P

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18 Exhibit Ex. Q

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19 Exhibit Ex. R

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20 Exhibit Ex. S

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21 Exhibit Ex. T

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22 Exhibit Ex. U

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REQUEST FOR ISSUANCE OF SUMMONS by Common Cause, League of United Latin American Citizens, League of United Latin American Citizens Council 102, Texas League of United Latin American Citizens. (Grigg, Richard) (Entered: 03/26/2026)

STANDING ORDER (dated 12/16/2025) REFERRING CASE to Magistrate Judge Susan Hightower. Signed by Judge Alan D Albright. (cr5) (Entered: 03/30/2026)

Case assigned to Judge Alan D Albright. CM WILL NOW REFLECT THE JUDGE INITIALS AS PART OF THE CASE NUMBER. PLEASE APPEND THESE JUDGE INITIALS TO THE CASE NUMBER ON EACH DOCUMENT THAT YOU FILE IN THIS CASE. (cr5)

If ordered by the court, all referrals and consents in this case will be assigned to Magistrate Judge Hightower. (cr5)

CASE REFERRED to Magistrate Judge Susan Hightower. (when order closing case was entered in error, the referral was removed) (cc3)

Summons Issued as to Paul Adams, Kaleb Breaux, Joyce Hudman, Jane Nelson, Frank Phillips. (cr5) (Entered: 03/30/2026)

MOTION to Appear Pro Hac Vice by Richard Alan Grigg of Danielle Lange ( Filing fee $ 100 receipt number ATXWDC-21666970) by on behalf of Common Cause, League of United Latin American Citizens, League of United Latin American Citizens Council 102, Texas League of United Latin American Citizens. (Attachments: # 1 Proposed Order Proposed Order). Motions referred to Judge Susan Hightower. (Grigg, Richard) (Entered: 03/30/2026)

1 Proposed Order Proposed Order

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MOTION to Appear Pro Hac Vice by Richard Alan Grigg of Daniel Brophy ( Filing fee $ 100 receipt number ATXWDC-21666981) by on behalf of Common Cause, League of United Latin American Citizens, League of United Latin American Citizens Council 102, Texas League of United Latin American Citizens. (Attachments: # 1 Proposed Order Proposed Order). Motions referred to Judge Susan Hightower. (Grigg, Richard) (Entered: 03/30/2026)

To be Referred to AU Mag Judge

Case Assigned/Reassigned

ORDER GRANTING 5 Motion to Appear Pro Hac Vice as to DANIELLE LANG. Pursuant to our Administrative Policies and Procedures for Electronic Filing, the attorney hereby granted to practice pro hac vice in this case must register for electronic filing with our court within 10 days of this order. Registration is managed by the PACER Service Center Signed by Judge Alan D Albright. (cc3) (Entered: 03/31/2026)

ORDER GRANTING 6 Motion to Appear Pro Hac Vice as to DANIEL BROPHY. Pursuant to our Administrative Policies and Procedures for Electronic Filing, the attorney hereby granted to practice pro hac vice in this case must register for electronic filing with our court within 10 days of this order. Registration is managed by the PACER Service Center Signed by Judge Alan D Albright. (cc3) (Entered: 04/01/2026)

MOTION to Appear Pro Hac Vice by Richard Alan Grigg of Alexis Grady ( Filing fee $ 100 receipt number ATXWDC-21686948) by on behalf of Common Cause, League of United Latin American Citizens, League of United Latin American Citizens Council 102, Texas League of United Latin American Citizens. (Attachments: # 1 Proposed Order). Motions referred to Judge Susan Hightower. (Grigg, Richard) (Entered: 04/01/2026)

MOTION to Appear Pro Hac Vice by Richard Alan Grigg of Renata O'Donnell ( Filing fee $ 100 receipt number ATXWDC-21686955) by on behalf of Common Cause, League of United Latin American Citizens, League of United Latin American Citizens Council 102, Texas League of United Latin American Citizens. (Attachments: # 1 Proposed Order). Motions referred to Judge Susan Hightower. (Grigg, Richard) (Entered: 04/01/2026)

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MOTION to Appear Pro Hac Vice by Richard Alan Grigg of Sejal Jhaveri ( Filing fee $ 100 receipt number ATXWDC-21686958) by on behalf of Common Cause, League of United Latin American Citizens, League of United Latin American Citizens Council 102, Texas League of United Latin American Citizens. (Attachments: # 1 Proposed Order). Motions referred to Judge Susan Hightower. (Grigg, Richard) (Entered: 04/01/2026)

ORDER GRANTING 9 Motion to Appear Pro Hac Vice as to ALEXIS GRADY. Pursuant to our Administrative Policies and Procedures for Electronic Filing, the attorney hereby granted to practice pro hac vice in this case must register for electronic filing with our court within 10 days of this order. Registration is managed by the PACER Service Center Signed by Judge Alan D Albright. (cc3) (Entered: 04/02/2026)

ORDER GRANTING 10 Motion to Appear Pro Hac Vice as to RENATA O'DONNELL. Pursuant to our Administrative Policies and Procedures for Electronic Filing, the attorney hereby granted to practice pro hac vice in this case must register for electronic filing with our court within 10 days of this order. Registration is managed by the PACER Service Center Signed by Judge Alan D Albright. (cc3) (Entered: 04/02/2026)

ORDER GRANTING 11 Motion to Appear Pro Hac Vice as to SEJAL JHAVERI. Pursuant to our Administrative Policies and Procedures for Electronic Filing, the attorney hereby granted to practice pro hac vice in this case must register for electronic filing with our court within 10 days of this order. Registration is managed by the PACER Service Center Signed by Judge Alan D Albright. (cc3) (Entered: 04/02/2026)

MOTION for Extension of Time to File Answer by Kaleb Breaux, Frank Phillips. (Attachments: # 1 Proposed Order). Motions referred to Judge Susan Hightower. (Davis, Robert) (Entered: 04/27/2026)

Order on Motion for Extension of Time to Answer

Set/Reset Answer Deadline

Text Order GRANTING 15 Defendants Frank Phillips and Kaleb Breaux's Unopposed Motion to Extend Answer Date entered by Judge Susan Hightower. The Court ORDERS that Defendants Frank Phillips and Kaleb Breaux have until June 11, 2026 to answer or otherwise respond to the Complaint. The Court directs the parties to Judge Alan D Albright's Standing Order Regarding Joint or Unopposed Requests to Change Deadlines issued September 18, 2025 ordering them to file any such request as a stipulation or notice to the Court instead of a motion. (This is a text-only entry generated by the court. There is no document associated with this entry.) (SH)

Reset Deadlines: Kaleb Breaux answer due 6/11/2026; Frank Phillips answer due 6/11/2026. (pg)

NOTICE of Unopposed Request to Extend Responsive Pleading Date by Joyce Hudman (Blakley, Jesse) (Entered: 05/01/2026)

Unopposed MOTION for Extension of Time to File Answer re 1 Complaint,,, by Jane Nelson. (Attachments: # 1 Proposed Order). Motions referred to Judge Susan Hightower. (Rhines, Zachary) (Entered: 05/08/2026)

NOTICE of Attorney Appearance by Zachary Louis Rhines on behalf of Jane Nelson. Attorney Zachary Louis Rhines added to party Jane Nelson(pty:dft) (Rhines, Zachary) (Entered: 05/08/2026)

Order on Motion for Extension of Time to Answer

Text Order GRANTING 17 State Defendant's Unopposed Motion for Extension of Time to Respond to Complaint entered by Judge Susan Hightower. The Court ORDERS that Defendant Jane Nelson, in her official capacity as the Texas Secretary of State, has until June 10, 2026 to file a pleading responsive to Plaintiffs' Complaint. The Court directs the parties to Judge Alan D Albright's Standing Order Regarding Joint or Unopposed Requests to Change Deadlines issued September 18, 2025 ordering them to file any such request as a notice or stipulation to the Court instead of a motion. (This is a text-only entry generated by the court. There is no document associated with this entry.) (SH)

NOTICE of Attorney Appearance by Munera Al-Fuhaid on behalf of Jane Nelson. Attorney Munera Al-Fuhaid added to party Jane Nelson(pty:dft) (Al-Fuhaid, Munera) (Entered: 05/19/2026)

NOTICE of Voluntary Dismissal by Common Cause, League of United Latin American Citizens, League of United Latin American Citizens Council 102, Texas League of United Latin American Citizens (Lang, Danielle) (Entered: 05/28/2026)

Order Dismissing Case

AMENDED ORDER. Joyce Hudman (in her official capacity as Brazoria County Clerk) terminated as a defendant.. Signed by Judge Alan D Albright. (cc3) (Entered: 06/01/2026)

Case No Longer Referred to Magistrate Judge

CASE NO LONGER REFERRED to Magistrate Judge Susan Hightower. (cc3)

Unopposed MOTION to Withdraw as Attorney Zachary Rhines by Jane Nelson. (Attachments: # 1 Proposed Order)(Rhines, Zachary) (Entered: 06/08/2026)

Order on Motion to Withdraw as Attorney

Text Order GRANTING 23 Motion to Withdraw as Attorney entered by Judge Alan D Albright. On this date, the Court considered State Defendant Jane Nelson's Unopposed Motion to Withdraw Zachary L. Rhines as Counsel. After considering the motion, the Court is of the opinion that the motion should be GRANTED. Accordingly, it is ORDERED, ADJUDGED and DECREED that Zachary L. Rhines is hereby withdrawn as counsel of record for Defendant, Jane Nelson, in her official capacity as Secretary of State of Texas in this matter. (This is a text-only entry generated by the court. There is no document associated with this entry.) (BBlc)

MOTION to Transfer Case to Eastern District of Texas, Sherman Division by Kaleb Breaux, Frank Phillips. (Attachments: # 1 Proposed Order)(Davis, Robert) (Entered: 06/10/2026)

MOTION to Dismiss by Kaleb Breaux, Frank Phillips. (Attachments: # 1 Proposed Order)(Davis, Robert) (Entered: 06/10/2026)

1 Proposed Order

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MOTION to Stay Discovery and Scheduling pending resolution of Motions To Dismiss by Kaleb Breaux, Frank Phillips. (Attachments: # 1 Proposed Order)(Davis, Robert) (Entered: 06/10/2026)

MOTION to Dismiss for Lack of Jurisdiction by Jane Nelson. (Al-Fuhaid, Munera) (Entered: 06/10/2026)

MOTION to Dismiss for Lack of Jurisdiction, Motion to Dismiss for Failure to State a Claim by Paul Adams. (Nicholas, Barbara) (Entered: 06/12/2026)

Case Referred to Magistrate Judge

NOTICE of Unopposed Extension of Responsive Pleading Deadlines by Common Cause, League of United Latin American Citizens, League of United Latin American Citizens Council 102, Texas League of United Latin American Citizens (Lang, Danielle) (Entered: 06/22/2026)

MOTION to Appear Pro Hac Vice by Sejal Jhaveri as to Anna Baldwin ( Filing fee $ 100 receipt number ATXWDC-22184180) by on behalf of Common Cause, League of United Latin American Citizens, League of United Latin American Citizens Council 102, Texas League of United Latin American Citizens. (Attachments: # 1 Proposed Order). Motions referred to Judge Susan Hightower. (Jhaveri, Sejal) (Entered: 06/24/2026)

ORDER GRANTING 30 Motion to Appear Pro Hac Vice as to ANNA BALDWIN. Pursuant to our Administrative Policies and Procedures for Electronic Filing, the attorney hereby granted to practice pro hac vice in this case must register for electronic filing with our court within 10 days of this order. Registration is managed by the PACER Service Center Signed by Judge Alan D Albright. (cc3) (Entered: 06/25/2026)

Response in Opposition to Motion, filed by Common Cause, League of United Latin American Citizens, League of United Latin American Citizens Council 102, Texas League of United Latin American Citizens, re 24 MOTION to Transfer Case to Eastern District of Texas, Sherman Division filed by Defendant Kaleb Breaux, Defendant Frank Phillips (Grady, Alexis) (Entered: 07/09/2026)

Response in Opposition to Motion, filed by Common Cause, League of United Latin American Citizens, League of United Latin American Citizens Council 102, Texas League of United Latin American Citizens, re 25 MOTION to Dismiss filed by Defendant Kaleb Breaux, Defendant Frank Phillips, 28 MOTION to Dismiss for Lack of Jurisdiction Motion to Dismiss for Failure to State a Claim filed by Defendant Paul Adams (Attachments: # 1 Exhibit A - Emailed NVRA Notice Letter to County Officials, # 2 Exhibit B - LULAC NVRA County Notice Letter, # 3 Exhibit C - Common Cause NVRA County Notice Letter, # 4 Exhibit D - Certified Mail Slips and USPS Tracking)(Grady, Alexis) (Entered: 07/09/2026)

1 Exhibit A - Emailed NVRA Notice Letter to County Officials

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2 Exhibit B - LULAC NVRA County Notice Letter

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3 Exhibit C - Common Cause NVRA County Notice Letter

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4 Exhibit D - Certified Mail Slips and USPS Tracking

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Response in Opposition to Motion, filed by Common Cause, League of United Latin American Citizens, League of United Latin American Citizens Council 102, Texas League of United Latin American Citizens, re 27 MOTION to Dismiss for Lack of Jurisdiction filed by Defendant Jane Nelson (Attachments: # 1 Exhibit A - LULAC NVRA Notice Letter, July 6, 2026)(Brophy, Daniel) (Entered: 07/09/2026)

1 Exhibit A - LULAC NVRA Notice Letter, July 6, 2026

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Response in Opposition to Motion, filed by Common Cause, League of United Latin American Citizens, League of United Latin American Citizens Council 102, Texas League of United Latin American Citizens, re 26 MOTION to Stay Discovery and Scheduling pending resolution of Motions To Dismiss filed by Defendant Kaleb Breaux, Defendant Frank Phillips (Brophy, Daniel) (Entered: 07/09/2026)

REPLY to Response to Motion, filed by Kaleb Breaux, Frank Phillips, re 25 MOTION to Dismiss filed by Defendant Kaleb Breaux, Defendant Frank Phillips (Davis, Robert) (Entered: 07/15/2026)

REPLY to Response to Motion, filed by Kaleb Breaux, Frank Phillips, re 26 MOTION to Stay Discovery and Scheduling pending resolution of Motions To Dismiss filed by Defendant Kaleb Breaux, Defendant Frank Phillips (Davis, Robert) (Entered: 07/15/2026)

NOTICE of Attorney Appearance by Grey Walton Johnston on behalf of Jane Nelson. Attorney Grey Walton Johnston added to party Jane Nelson(pty:dft) (Johnston, Grey) (Entered: 07/16/2026)

RESPONSE in Support, filed by Jane Nelson, re 27 MOTION to Dismiss for Lack of Jurisdiction filed by Defendant Jane Nelson (Johnston, Grey) (Entered: 07/16/2026)

Unopposed MOTION to Withdraw as Attorney by Jane Nelson. (Attachments: # 1 Proposed Order). Motions referred to Judge Susan Hightower. (Johnston, Grey) (Entered: 07/22/2026)

1 Proposed Order

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Unopposed MOTION for Extension of Time to File Response/Reply as to 28 MOTION to Dismiss for Lack of Jurisdiction Motion to Dismiss for Failure to State a Claim by Paul Adams. (Attachments: # 1 Proposed Order). Motions referred to Judge Susan Hightower. (Nicholas, Barbara) (Entered: 07/22/2026)

1 Proposed Order

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Text Order GRANTING 40 Defendant Jane Nelson's unopposed motion to withdraw as counsel entered by Judge Susan Hightower. The Court ORDERS that Grey W. Johnston shall be terminated from the docket of this case. (This is a text-only entry generated by the court. There is no document associated with this entry.) (SH)

Order on Motion to Withdraw as Attorney

Order on Motion for Extension of Time to File Response/Reply

Text Order GRANTING 41 Defendant Paul Adams' Unopposed Motion to Extend Deadline to File His Reply in Support of His Motion to Dismiss, and Brief entered by Judge Susan Hightower. The Court ORDERS that Adams has until July 24, 2026 to file his Reply. The Court further ORDERS the parties to comply with Judge Alan D Albright's Standing Order Regarding Joint or Unopposed Requests to Change Deadlines issued September 18, 2025 ordering them to file any such request as a notice or stipulation to the Court instead of a motion. (This is a text-only entry generated by the court. There is no document associated with this entry.) (SH)

REPLY to Response to Motion, filed by Paul Adams, re 28 MOTION to Dismiss for Lack of Jurisdiction Motion to Dismiss for Failure to State a Claim filed by Defendant Paul Adams (Nicholas, Barbara) (Entered: 07/24/2026)

MOTION to Amend Complaint by Common Cause, League of United Latin American Citizens, League of United Latin American Citizens Council 102, Texas League of United Latin American Citizens. (Attachments: # 1 Exhibit A - Amended Complaint, # 2 Exhibit B - Redline Version of Amended Complaint, # 3 Exhibit A-1, # 4 Exhibit A-2, # 5 Exhibit A-3, # 6 Exhibit A-4, # 7 Exhibit A-5, # 8 Exhibit A-6, # 9 Exhibit A-7, # 10 Exhibit A-8, # 11 Exhibit A-9, # 12 Exhibit A-10, # 13 Exhibit A-11, # 14 Exhibit A-12, # 15 Exhibit A-13, # 16 Exhibit A-14, # 17 Exhibit A-15, # 18 Exhibit A-16, # 19 Exhibit A-17, # 20 Exhibit A-18, # 21 Exhibit A-19, # 22 Proposed Order). Motions referred to Judge Susan Hightower. (Grady, Alexis) (Entered: 07/29/2026)

1 Exhibit A - Amended Complaint

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2 Exhibit B - Redline Version of Amended Complaint

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3 Exhibit A-1

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4 Exhibit A-2

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5 Exhibit A-3

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6 Exhibit A-4

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7 Exhibit A-5

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8 Exhibit A-6

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9 Exhibit A-7

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10 Exhibit A-8

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11 Exhibit A-9

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12 Exhibit A-10

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13 Exhibit A-11

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14 Exhibit A-12

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15 Exhibit A-13

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16 Exhibit A-14

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17 Exhibit A-15

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18 Exhibit A-16

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19 Exhibit A-17

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20 Exhibit A-18

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21 Exhibit A-19

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22 Proposed Order

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Proposed Scheduling Order by Common Cause, League of United Latin American Citizens, League of United Latin American Citizens Council 102, Texas League of United Latin American Citizens. (Jhaveri, Sejal) (Entered: 08/06/2026)

RESPONSE and Objection to 44 Scheduling Recommendations/Proposed Scheduling Order by Kaleb Breaux, Frank Phillips. (Davis, Robert) (Entered: 08/11/2026)

Response in Opposition to Motion, filed by Kaleb Breaux, Frank Phillips, re 43 MOTION to Amend Complaint filed by Plaintiff Texas League of United Latin American Citizens, Plaintiff League of United Latin American Citizens Council 102, Plaintiff League of United Latin American Citizens, Plaintiff Common Cause (Davis, Robert) (Entered: 08/11/2026)

Response in Opposition to Motion, filed by Jane Nelson, re 43 MOTION to Amend Complaint filed by Plaintiff Texas League of United Latin American Citizens, Plaintiff League of United Latin American Citizens Council 102, Plaintiff League of United Latin American Citizens, Plaintiff Common Cause (Al-Fuhaid, Munera) (Entered: 08/12/2026)

NOTICE of Unopposed Extension of Plaintiffs' Reply Deadline by Common Cause, League of United Latin American Citizens, League of United Latin American Citizens Council 102, Texas League of United Latin American Citizens (Lang, Danielle) (Entered: 08/14/2026)

REPLY to Response to Motion, filed by Common Cause, League of United Latin American Citizens, League of United Latin American Citizens Council 102, Texas League of United Latin American Citizens, re 43 MOTION to Amend Complaint filed by Plaintiff Texas League of United Latin American Citizens, Plaintiff League of United Latin American Citizens Council 102, Plaintiff League of United Latin American Citizens, Plaintiff Common Cause (Attachments: # 1 Exhibit A - July 6, 2026 NVRA Notice Letter)(Brophy, Daniel) (Entered: 08/19/2026)

Notice

Order