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Nos. 416-81913-2015 416-82148-2015 416-82149-2015

THE STATE OF TEXAS § IN THE DISTRICT COURT § V. § 416th JUDICIAL DISTRICT § WARREN KENNETH PAXTON, JR. § COLLIN COUNTY, TEXAS

______________________________________________________________

MOTION TO RECONSIDER ORDER ON STATE’S MOTION FOR CHANGE OF VENUE

______________________________________________________________

TO THE HONORABLE JUDGE GEORGE GALLAGHER:

Warren Kenneth Paxton, Jr. (“Paxton”), files this Motion to Reconsider

Order on State’s Motion for Change of Venue as follows:

Respectfully, we ask that the Court reconsider its order changing venue as it

is completely unsupported by the evidence and is contrary to the law. The Court

should enter an order denying the Motion for Change of Venue and hold trial in

Collin County on May 1, 2017.

The standard the Special Prosecutors were required to meet can be found in

Tex. R. Crim. Pro. Art. 31.02 and requires that the State prove that the trial “cannot

be safely and speedily had” in Collin County. The State has provided no evidence

to that effect. In response to expert testimony, scientifically collected data, and a

crystal clear statute, the Special Prosecutors presented nothing but hyperbole in an

effort to venue shop.

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The ethical concerns of this Court are mistaken. They are based upon a

misdirection ploy by the Special Prosecutors, totally unrelated to whether a jury

can be picked in Collin County. The Special Prosecutors, after ample opportunity,

have presented zero evidence that a trial cannot be safely and speedily had in

Collin County.

“…a fair and impartial trial between the accused and the State cannot be safely and speedily had…”

Tex. R. Crim. Pro. Art. 31.02. The State has utterly failed to meet its burden under

clear standard that the law requires.

We request that the Court view State’s Exhibit 14 for what it is: an invitation

to an ordinary fundraiser, held over three years ago and long before the Special

Prosecutors were appointed. The invitation provides no support for transferring

venue or continuing this case. The only evidence before this Court relevant to the

change of venue motion that is not hyperbole or gossip is the polling data

presented by Glen Bolger at the March 29, 2017, hearing. That evidence showed,

overwhelmingly, that the citizens of Collin County have not formed an opinion one

way or another about Mr. Paxton or the Special Prosecutors. And those that have,

hold opinions that favor the State, not Mr. Paxton. Both the motion to change

venue and to continue this case should be denied.

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ARGUMENT

A. The Richardson Fundraiser Presents No Ethical Issue

The Court has expressed concern over “ethical problems” manifested by a

December 2013 political fundraiser sponsored by Keresa and J.R. Richardson for

Paxton, to which multiple Collin County elected officials and County

Commissioners were invited to attend. During the sealed portion of the hearing,

Special Prosecutors introduced into evidence an invitation to the fundraiser. While

the Defense was not furnished a copy of the invitation, what it believes to be the

invitation is attached as Exhibit A.

The fundraiser was conducted nearly three and a half years ago, on

December 4, 2013. That was a year and a half before the grand jury investigation.

It was months before the investigation by the State Securities Board concluded.

And of course, it was long before the Special Prosecutors were appointed. The

current concerns and disputes swirling around payments to the Special Prosecutors

were not issues at that time, nor was the guilt or innocence of Paxton.

The event in question was typical of political fundraisers thrown on Paxton’s

behalf during his campaign for Attorney General. This event was also typical of

fundraisers thrown around the State for candidates of offices large and small, be

they state representatives, state senators, judges, city council members, or any

other office. To that end, attached as Exhibit B, is a compilation of recent political

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fundraiser invitations. Note that it is the routine habit and practice of elected

officials to attend fundraisers and social events for other members of their party,

regardless of whether a personal relationship exists.

The Court seemed to express specific concern about the Collin County

Commissioners who were listed as hosts for the December 2013 Richardson

fundraiser. While Paxton does not recall whether particular Commissioners

actually attended the fundraiser, suffice it to say that then-Commissioner, Matt

Shaheen, has since been elected a state representative and is no longer a county

commissioner. Also, donation records show that only one Commissioner—Cheryl

Williams—made any donation to Paxton in relation to the event, in the modest

amount of $250. And while County Judge Keith Self later donated $5,000 to

Paxton’s campaign approximately three months after the event, none of the other

Honorary Hosts listed on Exhibit A ever donated to Paxton, and the referenced

donations combined were relatively small. This is not surprising, as most elected

officials who are honorary hosts do not contribute to the fundraiser event.

Notably, Collin County Commissioners Duncan Webb and Cheryl Williams,

in addition to County Judge Self, voted in support of payments to the Special

Prosecutors notwithstanding the lawsuit filed by Jeffory Blackard and the

subsequent lawsuit filed last week in which the Richardson Family Living Trust is

a named plaintiff.

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As mentioned earlier, the Court warned of a potential “ethical problem”

manifested by the Richardson political fundraiser. The defense does not believe

the fundraiser presents any ethical issue. This was a commonplace political

fundraiser, it was held over three years ago, and all but one of the current county

commissioners that were present has voted to fund—and continue funding—

Paxton’s prosecution. Thus, it is difficult to directly address any ethical issue that

the Court might have been concerned with. And while it is unclear whether the

Special Prosecutors introduced the invitation in support of their motion for

continuance or their motion to transfer venue, they certainly did not advocate that

any sort of ethical concern existed. Even if the Special Prosecutors did introduce

the fundraiser invitation to raise some sort of ethical concern, it should be noted

that the lawyers involved in this case, including one of the defense lawyers and one

of the Special Prosecutors, have hosted political fundraisers for judges that they

have appeared before. An invitation to just such an event is attached as Exhibit C.

B. Evidence of The Richardson Fundraiser Does Not Support Transferring Venue

The defense understood the Court’s concern over the fundraiser as

something that may bear on the issue of whether to transfer venue in this case. The

Defense would posit that the fact of the Richardson Family Living Trust filing suit

to block payments to the special prosecutors is no different than the fact that the

Blackard Family Limited Partnership, LP, filed suit to block such payments.

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Whether it be Mr. Blackard or the Richardsons, these are concerned citizens

exercising their constitutional right to petition courts over an issue that is of great

concern to them: the spending of County resources. And those lawsuits have no

connection to a fundraiser held by politically active citizens of this county well

over a year and a half before this case was presented to a grand jury. As everyone

involved in this case knows, fundraisers such as this—be they dinner parties,

barbeques, or golf tournaments—are extremely common in politics.

Respectfully, the defense believes that nothing new has been presented that

should dissuade the Court from its original position that it intended to carry the

Motion to Transfer Venue through jury selection and was inclined to pick a jury in

Collin County. Further, the Court should note that the Blackard/Richardson

lawsuit actually names not only the special prosecutors as defendants, but also

some of the same elected officials and individuals who co-hosted the Richardson

fundraiser—namely, Commissioners Webb, Hill, and Williams, in addition to

County Judge Self.

More importantly, it is hard to fathom that change of venue is still the

subject of consideration—let alone merited—given the evidence presented by the

Defense when pollster Glen Bolger testified during the March 29th hearing that:

1. Among those jury-eligible Collin County residents who were aware of the Paxton indictment, three-fourths of them did not have an opinion as to Paxton’s guilt or innocence.

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2. A large majority of those who were aware of the indictment have not changed their opinions over time – in other words, the so-called “Team Paxton” has had no impact on their opinions.

3. Indeed, more people now believe that Paxton is guilty than when he was first charged – a statistic that is driven totally by Democratic-leaning individuals.

4. An overwhelming majority had no opinion of the Special Prosecutors, and over 90% of those individuals have not changed their opinions about the Special Prosecutors in the last year.

CONCLUSION

Based on the facts presented to the Court, there is no significant bias or

preconceived notions about this case among potential jurors in Collin County.

State’s Exhibit 14 does nothing to change that fact, nor does the event it describes

have any ethical implications on the parties in this case or in any other matter.

Indeed, it was nothing more than a routine fundraising event that occurred over

three years ago—before any indictment in this case and unrelated to any issues

subsequently raised therein. Again, there is simply no basis to transfer venue, and

the case should therefore stay in Collin County.

Paxton requests this Court to reconsider its order and hold a trial on May 1,

2017, on the current schedule. There is no evidence to support this change of

venue and changing venue on the evidence presented to this Court is contrary to

law. Alternatively, Paxton requests the Court to reconsider its prior ruling on this

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issue, and carry the motion until trial—attempt to pick a fair and impartial jury in

Collin County for trial on May 1, 2017.

Respectfully submitted,

Dan Cogdell HILDER & ASSOCIATES, P.C. Co-Lead Counsel Cogdell Law Firm, L.L.C. 402 Main Street /s/ Philip H. Hilder Fourth Floor Philip H. Hilder Houston, Texas 77002 State Bar No. 09620050 Telephone: (713) 426-2244 Co-Lead Counsel Facsimile: (713) 426-2255 Q. Tate Williams dan@cogdell-law.com State Bar No. 24013760 Paul L. Creech Terri Moore State Bar No. 24075578 300 Burnett St., Ste. 160 819 Lovett Blvd., Houston, TX 77006 Fort Worth, TX 76102-2755 Telephone: (713) 655-9111 Telephone: (817) 877-4700 Facsimile: (713) 655-9112 moore@terrimoorelaw.com philip@hilderlaw.com tate@hilderlaw.com paul@hilderlaw.com Heather J. Barbieri Bill Mateja Barbieri Law Firm, P.C. Polsinelli 1400 Gables Court 2950 N. Harwood, Suite 2100 Plano, Texas 75075 Dallas, Texas 75201 Telephone: (972) 424-1902 Telephone: (214) 397-0030 Facsimile: (972) 208-2100 mateja@polsinelli.com hbarbieri@barbierilawfirm.com J. Mitchell Little Scheef & Stone, LLP State Bar No. 24043788 2600 Network Blvd., Ste. 400 Frisco, TX 75034

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Telephone: (214) 472-2100 Facsimile: (214) 472-2150 mitch.little@solidcounsel.com OF COUNSEL

ATTORNEYS FOR DEFENDANT, WARREN KENNETH PAXTON, JR.

CERTIFICATE OF SERVICE

I hereby certify that on March 30, 2017, a true and correct copy of the above and foregoing was served on all counsel of record via electronic case filing and/or hand delivery. /s/ Philip H. Hilder Philip H. Hilder

EXHIBIT A

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The Honorary Host Committee State Representative Jodie Laubenberg

State Representative Jeff Leach

State Representative Scott Sanford

State Representative Van Taylor

State Representative Scott Turner

County Judge Keith Self

District Attorney Greg Willis

County Commissioner Chris Hill

County Commissioner Matt Shaheen

County Commissioner Duncan Webb

County Commissioner Cheryl Williams

Invite you to join them for a fundraising reception benefitting

Wednesday, December 4, 2013

with special guest

Senator Rick Santorum

6:00 PM – Host Committee Reception (Minimum $250 per person/$500 per couple)

at the home of

Keresa and JR Richardson 200 Falling Water * McKinney, Texas 75070

Please RSVP using the following page

Senator Paxton has been endorsed by:

Texas Right to Life PAC - Texans for Fiscal Responsibility - Texas Home School Coalition - Young Conservatives of Texas Penny Nance, President and CEO, Concerned Women for America*

Kaye T. Goolsby, Statewide Leadership Team Chairman; Grassroots Leadership Chairman, Ted Cruz Campaign Kelly Shackelford, Chairman, Ted Cruz for Senate Statewide Leadership Team; President, Liberty Institute*

Cathie Adams, President, Texas Eagle Forum*; Former Chairman, Republican Party of Texas Ernest Angelo, Jr., Former Republican National Committeeman

Tim Lambert, President, Texas Home School Coalition*; Former Republican National Committeeman Ann Hettinger, Former State Director of Concerned Women for America of Texas*

Jonathan Saenz, President, Texas Values* Rick Green, Former Texas State Representative; Host, WallBuilders* Live

Carol Everett, Founder and CEO of the Heidi Group* Michelle Smith, State Director of Concerned Women for America of Texas*

Peggy Venable Hon. Matt Orwig, Former U.S. Attorney - Hon. John Ratcliffe, Former U.S. Attorney

Hon. Cliff Stricklin, Former Asst. U.S. Attorney - Jay Johnson, Former Asst. U.S. Attorney Kevin Collins, Former Asst. U.S. Attorney

24 Texas State Representatives

*organization listed for identification purposes only

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RSVP

Wednesday, December 4, 2013 Home of Keresa & JR Richardson

200 Falling Water * McKinney, Texas 75070

6:00 PM – Host Committee Reception (Minimum $250 per person/$500 per couple)

□ Yes, you can count on me/us to serve on the Host Committee at the following level: □ Chairmen □ Co-Chairs □ Benefactors $25,000 $10,000 $5,000

□ Patrons □ Hosts □ Supporters □ Friends $2,500 $1,000 $500 $250

□ No, I/we will be unable to attend. Enclosed please find my contribution of $ ________

Name(s) for nametag purposes

Address City State Zip Code

Office Phone Home Phone Cell Phone

Email Fax

Employer / Occupation Spouse Employer / Occupation (if joint contribution)

State law requires us to obtain and report the full name and address of all donors. Additionally, we are required to obtain and report the principal occupation or job title and full name of the employer of individuals whose contributions equal or exceed $500 in a reporting period.

□ Enclosed is my check made payable to: Ken Paxton Campaign

Or, please charge my:

□ Visa □ Mastercard □ American Express □ Discover

Card #__________________________ Exp. Date_____________ Security Code_________

Name on card___________________________ Signature_________________________________ Under Texas law, individuals and political action committees may contribute to political campaigns. Texas law does not limit the amount donors can contribute to a candidate. Corporate contributions are prohibited.

Contributions can also be made online at www.kenpaxton.com.

For more information or to RSVP, contact Sara Coburn at sara@kenpaxton.com or 214/458-5245 or

Lisa Freeman at lisa.freeman@verizon.net or 972/742-7712

Pol. Adv. Paid for by Ken Paxton Campaign · P.O. Box 3476, McKinney, TX 75070

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EXHIBIT B

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You are cordially invited to a reception honoring State Representative Jeff Leach

Fcaturi.ng Special Gueet

Honorable Glenn Hegar Tena Comptroller

Tuesday, November 3, 2015 6:00 PM Prift1c Hoot Committee Rcapbon {Mm1- IJJ())

6:.30 PM General Rcapcio.>

event1013 1013 E. 15da S-, PUo, TX 7S<114

M.mofCa .;.. JwlpJalm Pa)IW

CMa c-JyJllSliatf d# l'-a C.-Host of-0. ~ wirll JP~ Dr. 11',. 620 JIM

Vwe will auend the reception by donating:

0 $10,000/oouple Major Underwriter

.......................... 'lffliOll, .... _ ......... ,... .....

......... ._.,.....,."'............ .... ....... 'XO . . ....... ...... ~ ...................... .,. ...... "... .. ..... ....._ ... ..... ---a $5,000/couple Patriol Council 0 $2500/couple Lone Suir Council a $1,000/cou pie Benefactor

C.•~.e

Cd!-

0 S500/couple Sponsor 0 $250/couple Advocate 0 $100 Supponer 0 $50 Individual TtckeL Please list my/our name on the sponsor board as·

a ~can\ ancnd but please •a:tpl my ~ntr!butlon ors __ _ Pl-. fllMe dleckl payable 10: "Jdf n-h c-.-1sn·

Ind mall with this form,10: P.O. Box 166186. PllM, TX 75086 ,,,,,..,..

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Pol. Adv paid for by the Jeff Leach Campaign, P.O Box 866186, Plano, TX 75086

Please make checks payable to: “Jeff Leach Campaign”and mail with this form to: P.O. Box 866186, Plano, TX 75086

To RSVP or for more information please contactMary McClure at mary@jeffleach.com or 972.795.5278.

State law requires us to use our best efforts to collect and report the full name and address, principal occupationor job title, and full name of employer of individuals whose contributions equals or exceeds $500 in a reportingperiod. Corporate contributions are prohibited by state law and contributions are not tax deductible for federalincome tax purposes.

I/we will join the Host Committee by donating: q $10,000/couple (Major Underwriter) q $5,000/couple q $2,500/couple q $1,000/couple q $500/couple q $250/couple q Individual Ticket $45 # of Tickets ______ Please list my/our name on the sponsor board as: ___________________________________________________________q I/We can’t attend but please accept my contribution of $_________.

Name

Address

City/State/Zip

Cell Phone

Work Phone

Home Phone

Fax

Email

Employer

Occupation

Tuesday, October 21, 20145:30 PM Private Host Committee Reception

6:00 PM General Reception

at the home of The Honorable James and Dr. Betty Muns

5508 Saint Andrews CourtPlano, Texas 75093

Honorary Hosts

Host Committee

Senator Glenn Hegar, GOP Nominee for Texas ComptrollerSenator Dan Patrick, GOP Nominee for Texas Lt. Governor

Senator Ken Paxton, GOP Nominee for Texas Attorney GeneralGeorge P. Bush, GOP Nominee for Texas Land Commissioner

State Representative Jodie LaubenbergState Representative Scott SanfordState Representative Van Taylor

State Representative Scott TurnerState Representative-Elect Matt Shaheen

County Judge Keith SelfDistrict Attorney Greg Willis

Commissioner Chris HillCommissioner Mark Reid

Commissioner Duncan WebbCommissioner Cheryl Williams

Commissioner-Elect Susan FletcherMayor Laura Maczka

Mayor Steve and Sally Terrell

Atmos Energy PACSharron Albertson

Craig and Julie Atkinson Dan and Sarah Avitua

Randy and Kathy Brodhead Mike Brodie

Centerpoint Energy PACMickey ChristakosCharles Christian

Brad and Lisa ClarkDixie Clem

Steve and Dixie Cook Mike and Paulette Eberhart

Lisa Gallagher Ellrich

Energy Future Holdings PACCharles Eisemann

Jeff and Mary Carl FinkelsteinJohn and Nita Ford

Friends of UT Dallas Jerry and Judy GallagherJosh & Kaytie GrahamCary and Amber GrayTim and Peggy HornerRay and Ann Huffines

Buddy JonesTom KaderNeal Katz

Rusty Kelley

Kevin and Richi KyserRon and Darlene Leach Ryan and Melissa LeachMr. and Mrs. P. Lembke

Cathy and Harold MacDowellShirley Mangrum

Bill MartinDavid McCall

Justin and Joanna McCordDarrell and Paula McCutcheon

Drayton McLaneCandy Noble

Erle NyeChuck and Julie O’Reilly

John and Michelle ProfanchikBobby and Phyllis Ray

Raytheon PAC Jack and Elizabeth Reaves

Bryan ReederBlair & Lauren Robinson

Bill ShaddockMark Speese

Claudia Tatum Texans for Lawsuit Reform

Karl VoigtsbergerJames Webb

John and Leahray Wroten(Partial listing at time of printing)

You are cordially invited to join the Host Committee for a fundraiser in support of

State Representative Jeff LeachFeaturing Special Guest

Christi CraddickChairman of the Texas Railroad CommissionChair of the Texas GOP 2014 Victory Campaign

and Master of Ceremonies Mark Davis, The Mark Davis Show

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Commissioner of the Texas Railroad Commission

Ryan SittonRyan Sitton is one of the world’s leading energy experts. Elected to the Railroad Commission on Nov. 4, 2014 to a six-yearterm, Ryan Sitton is the first engineer to serve on the Commission in 50 years. A native North Texan, Sitton graduated fromTexas A&M University where he earned a degree in Mechanical Engineering, and met his wife, Jennifer. In 2006, Ryan andJennifer founded PinnacleART, an engineering and technology company focused on reliability and integrity programs for theoil, gas, and petrochemical, mining, pharmaceutical, and wastewater industries. As Railroad Commissioner, Ryan is workingto make the Commission more efficient and effective so Texas can lead America to energy independence.

Pol. Adv paid for by the Jeff Leach Campaign, P.O Box 866186, Plano, TX 75086

Please make checks payable to: “Jeff Leach Campaign”and mail with this form to: P.O. Box 866186, Plano, TX 75086

To RSVP or for more information please contactMary McClure at mary@jeffleach.com or 972.795.5278.

State law requires us to use our best efforts to collect and report the full name and address, principal occupationor job title, and full name of employer of individuals whose contributions equals or exceeds $500 in a reportingperiod. Corporate contributions are prohibited by state law and contributions are not tax deductible for federalincome tax purposes.

I/we will attend the reception by donating: ❑ $10,000/couple (Major Underwriter) ❑ $5,000/couple (Patriot Council) ❑ $2,500/couple (Lone Star Council) ❑ $1,000/couple (Benefactor) ❑ $500/couple (Sponsor) ❑ $250/couple (Advocate) ❑ $100/couple (Supporter) ❑ $50 (Individual Ticket) Please list my/our name on the sponsor board as: ___________________________________________________________

❑ I/We can’t attend but please accept my contribution of $_________.

Name

Address

City/State/Zip

Cell Phone

Work Phone

Home Phone

Fax

Email

Employer

Occupation

You are cordially invited to a Reception HonoringState Representative Jeff Leach

Featuring Special Guest SpeakerThe Honorable Ryan Sitton

Special Guest Appearance By

Rafael CruzThursday, October 20, 2016

6:00 PM Host Committee Reception ($250/couple and up)6:30 PM General Reception

event1013 1013 E. 15th Street, Plano, Texas 75074

State Senator Van TaylorState Rep. Jodie Laubenberg

State Rep. Scott SanfordState Rep. Matt ShaheenState Rep. Scott Turner

Justin Holland, GOP Nominee for HD 33The Hon. Terry Box

The Hon. Greg WillisThe Hon. Keith SelfThe Hon. Chris Hill

The Hon. Susan FletcherThe Hon. Duncan Webb

The Hon. Cheryl WilliamsTrevor Ahlberg

Sharron AlbertsonCraig & Julie Atkinson

Dan & Sarah AvituaJakob & Jennifer Bearden

Suzanne Blackstone

David Bristol Mike Brodie

Mike & Joanie Buster Lee Chapman

Chevron Employees PACMickey Christakos

Dallas Eagle Forum PACDoug Deason

Tim DunnCharles Eisemann

Lisa Gallagher EllrichEnergy Future Holdings PAC

Tony & Connie EwingGeorge Flint

Jeff & Mary Carl FinkelsteinFriends of UT Dallas PAC

Jerry & Judy GallagherDr. Jack & Deb GrahamJosh & Kaytie Graham

Cary & Amber GrayMark & Elizabeth GreerJim & Pamela Hillhouse

Ray & Ann HuffinesOlin Jaye

Dr. Tom & Nancy JohnsonTom Kader

Rusty KelleyChip Loper

Harold MacDowellThe Honorable Jerry Madden

Shirley MangrumCarroll MaxwellDavid McCall

James McCarleyDarrell & Paula McCutcheon

Jim McGeeDrayton McLane

Mike Olcott

Oncor – Paul BlantonChuck and Julie O’Reilly

Bobby RayRaytheon PAC

Jack & Elizabeth ReavesTy and Sharon RichardsonBlair & Lauren Robinson

Stan & Carol SewellBill ShaddockNathan SheetsMark Speese

Texans for Lawsuit Reform PACTexas Construction Association PACTexas Restaurant Association PAC

Trinity Industries PACKathy WardJames Webb

(Partial listing at time of printing)

Honorary Host Committee

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CHAIRMEN Nita Ann Hebb

Wade Hebb

HOSTS Keith and Annette Bell

Wynne and Liddy Breeden Rick and Lisa Carmona

David and Beth Dearing Dwight Haddock

Robert and Sherry H ulsey Drs. Stuart and Shari Spitzer

Hon. Jimmy and Marilyn Weaver

Co-Hos rs cc.. Hon. Jakie Alle.f!-­~-l.l 1n. Bo and Kay Hall Hon. Kenneth and Judy Sc oen~ Greg an Suzanne Shumpert

(Ion. Erleigh and Aaron Wiley Wa e anc:LEYelyn..Williams

Hon. Bruce and Susie Woo .

P ATRIOTS Tom and Nancy Aldinger Chad and Lisa Berberich Tim and Beth Spillman

Von Carl and Sylvia Thomas

SPONSORS Hon. Bill and Kathy Baker

Loyd and Eve Baldwin J. W. and Ann Barrow

Bruce Bryant Elise Chitty

Hon. John and Lori Cook Dr. Paul and Rudi English Eugene and Betty Glaeser

Hon. David and Kay Hinds ]. Kenneth Lee

Jim and Bonnie McGinty Hon. Dick and Nancy Murphy

Dr.Alan Nix David R. Parker

Elliott H. Snyder, M.D. and Marilyn Snyder

John •

You are invited to our annual Kaufman County

Reception honoring

U.S. CONGRESSMAN

}EB HENSARLING TEXAS, 5TH DISTRICT

Thursday, August 27, 2015 5:30 pm

at Kabars Ranch the home of Nita Ann Hebb

7722 FM 1388 Kaufman,Texas75142

Business Casual Attire

Chairmen: $2,700 •Hosts: $1,000 Co-Hosts: $500 • Patriots: $250 • Sponsors: $100

Single Sponsors: $50 • Single Ticket: $25

Please RSVP to Bunni Pounds, 972.271.7788, bunnit~· Ma

or retum the the

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ongrc \man Michael Burg ~ ongre,,man Jcb lien~arling

( ongrcs~man Kenny 1arch, nt ongrcs m, n John Ratcliffe

( ongre . man P le e~sion!i

Doug and Jodi B. rt k Dr. P pper ~napple PAC

Enc Fox

BUILD PA RI hard H. Collins

Ray and Ann Huffine

Atmo. Energy PAC Roger and ue Dalton

D nbury Resources Inc. PAC

Randy and Kathy Brodhead Dr. Kenneth H. Cooper

Taffy and Melinda Goldsmith Dr. Ammanullah Khan

Jack E. Anderson, Jr. Dr. Allan and Virginia de Villeneuve

Frank and Diana Finn

Honorary Co-Hosts t te Senator Van 1aylor

tate R pr s ntativi: Jodie L ubenbcrg t.11 R pres ntative Jeff I each

~tat Representative cott antord State Repres ntative Matt hahe n

Major Underwriters Al G. Hill, Jr.

Pat and haron Lobb National Apartment As ociation PAC

Congressional Council Ve ter T. Hughes, Jr.

Mr. and Mrs. John V. Lattimore, Jr. Dr. C.E. and Beverly McCoy

Chuck and Julie O'Reilly

Patriot Council National Air Traffic Controllers Association PAC

Erle and Alice Nye

Lone Star Council Dr. and Mrs. Charles Ku John and Ellie Landon

Hon. Pam Little and Larry Little Tom and Sharon Meurer

UPS PAC

Benefactors Jame Hallam Bill Kramer

County Judg K 1th elf ommi ioner Chris Hill

omm1 ion r u an Hetch r Commi ioner Duncan \ 'ebb

Commis ioner Cheryl William

Realtor PAC Beck} R dman

Toyot Lexu PAC

Trinity Indu tne Emploree PAC John and Leahrar Wroten

Eric and Katina Zepp

Bob and Lola anford Carolyn and Mark pee e

Wayne and Buena teven on

Charlie O'Reilly H. Ro Perot, r.

Sam and Judy Roach Felix and Sandra Thetford

Jim 1cGee Hon. Geraldine "Tincy" MiUer

Dr. Carey A. Patrick

You are cordially invited to attend a fundraising dinner honoring

CONGRESSMAN SAM JOHNSON Republican, Third District of Texas

With Special Guest,

DR. FRANK LUNTZ

Pollster, Author, and CEO of Luntz Global

And Master of Ceremonie

MARK DAVIS

660AM The Answer

Monday, October 17th, 2016 6:00 PM - Private VIP Reception (Minimum $500 per couple)

6:45 PM - Dinner

Business Attire

Plano Marriott at Legacy Town Center 7121 Bishop Road I Plano, Texas 75024

Reply Form enclosed

for more information, please contact Gabriella Pate at 972-424-9573 or Gabriella@ amfolmsonforCongr .. 0111 18

YOU ARE CORDIALLY INVITED TO THE

ANNUAL THANKSGIVING RECEPTION honoring

Thursday, November 17, 2016 6:00 pm - 7:30 pm

ATTHEHOMEOF

Ruth and Bryan Kaminski 5609 Champions Drive

Plano, Texas 75093

HONORARY HOSTS

Rep.] odie Laubenberg, Rep.] eff Leach, Rep. Scott Sanford, Rep. Matt Shaheen, Rep. Scott Turner,

& Republican Nominee (HD/ 33) Justin Holland

During this season of Thanksgiving, join us as we celebrate our freedoms, our liberties and our great state of Texas.

Pol. Adv. Paid for by Van Taylor Campaign

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H n mryHo t mmittee Join us£ the 0 2

~ 1. tors: • • ·11. l'f. 1. t Ken F:v:f, lJI

• l.·n.1h'r l1tY1.11 ' 1.' Sh1pit\1 Rtp. f, 'nJ Af.lddt•n Rep . .ft Ji · /,.ml ·nfJc.. r;.: Rc:p. Eh t Jcti I ·.1ch Rep. Eh <.:t • • NI Turn ·r Rt p. Flee/ .'X l ,It • ':1111t1n.f

Com.mi si ner : Jm{'l!,c Keith Self Wi Comm . .1\f.11t .\/1,i/1 'en Comm. Du 11 .111 H 'c: bl Cc.m1111. Chc:ry/ W1/hum c 1mm . .f"- ~ }JYllL' •

Comm. JJ 't Chns Hill

City Council: lf<..111. I'hil Dy r Ht 1i. Li • .i Smith Hon. B 11 Harri. H 11. Andre D<wid. 111

llc...,n. F.lf ;\finer

Hc...,n. Jim Duggan Hclf1. Lee Dunlap Hl,n. Fat Galfagh r

of

TAYLO *** STATE REPRESE TATIVE I PL O,T

nesday, December 6, 5:30 .m. VIP ec .ption

eneral eception 6:00 .m.

At hehomeof

Ruth & Bryan Kaminski 5609 Champio

Plano, Te as 7 5 93

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***************************** C I/we will attend and participate at the following level:

$5,000 Texas Patriot 2,500 Texa Bootstraps 1,000 Texas Lass 500 Texa.

0 $250 Ticket O I can't att nd, but I'm , nding a contribution of-----0 rl asc charge to: OVisa 0 Ma ter ard

Cardholdcr Name (printed) ________ _

Card. 'umber _____________ _

Exp. Ilatc ______ ccv Number ____ _

You may fax form t W72) 490-7070

State law requires u to u be t ffort t Ile t Jnd report the full name and addre , prin ipJ\ oc upati n r job tit! , and full n m 1. i employer of individual whose contribution quals r x ds 3l in a reporting period.

All Contributors Please Read and Complete: Full Name. _________________ _

Add re

City ________ State ____ Zil -----

H m_'·-------------------Phonc __________________ _

Fax ----------------------~ Empl y r ________________ _

0 cupati n. ________________ _

•ror m~.m.! intormalknt, please c ntact D'rinJa Randall, Campai~n Manager, 214-673-3404 r drinda.r.m 1.lll a ,'l.m.ul. m. Complete and rd urn this form to Van Taylor ampaign, addr"ss bd w.

Paid pol. adv. Van Taylor Campai~n * P.O. B x 261676 Plan , Texas 75026 * www.V.111T.wl r.~: m

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HONORARY HOST COMMITTEESen. Van Taylor

Rep. Jodie LaubenbergRep. Je� Leach

Rep. Matt ShaheenRep. Scott TurnerJudge Keith Self Sheri� Terry Box

Mayor Reed GreerMayor Brian Loughmiller

Mayor Ray SmithMayor Sean Terry

Mayor Pro-Tem Travis UsseryCouncilman Chuck BranchCouncilman Randy Pogue

Commissioner Susan Fletcher Commissioner Chris Hill

District Attorney Greg Willis

Please make personal and PAC checks payable to:Scott Sanford for State Representative

5100 Eldorado Pkwy #102-805 - McKinney, TX 75070

RSVP: Email - events@scottsanford.us or call - (972) 672-8352

Pol. Ad. Paid for by Scott Sanford for State Representative21

POL. ADV. PAID FOR BY FRIENDS OF KEITH SELF

q Yes, I/we will serve on the Host Committee at thefollowing level (levels are per couple):

q Benefactor - $2,500 per coupleq Patron - $1,000 per coupleq Chairman - $500 per coupleq Host - $250 per coupleq Friend - $125 per couple

Host Committee members: please list how you prefer yourname listed on printed materials:

_______________________________________________

_______________________________________________

q I will attend the 6:15 PM General Reception by purchasing _______ tickets at $40/person.

q I will not be able to attend, but please accept my contribution of $________.

Name____________________________________________________________

Address __________________________________________________________

City ____________________________________State_____ Zip ____________

Cell Phone_________________________________________________________

Home Phone_______________________Work Phone______________________

Email____________________________________________________________

Employer_________________________________________________________

Occupation_______________________________________________________

Please make checks payable to: “Friends of Keith Self”and mail to 1911 Lorraine Avenue, Allen, TX 75002

For more information please contact: Keith Self (214) 454-5075 ~ keith.self@tx.rr.com

or Kim Watts (214) 236-1053 ~ kimberlywatts@verizon.net You may RSVP by faxing this form to (972)219-0515

State law requires us to use best efforts to collect and report the full name and address, principal occupationor job title, and full name of employer of individuals whose contribution equals or exceeds $500 in a report-ing period. Corporate contributions cannot be accepted by state law. Contributions are not tax deductible forfederal income tax purposes.

Honorary HostsSenator Ken Paxton Rep. Jodie Laubenberg Rep. Jeff Leach Rep. Scott Sanford Rep. Van Taylor Rep. Scott Turner

Invite you to join them for a Campaign Kick-Off Reception

benefitting

Collin County Judge Keith SelfThursday, June 20, 2013

5:30 - 6:15 PM Host Committee Reception (minimum $125/couple)6:15 - 7:15 PM General Reception ($40/person)

Home of JR & Keresa Richardson200 Falling Water, McKinney, TX 75070

Please RSVP if attending

Scott TurnerVan TaylorScott SanfordJeff LeachJodie LaubenbergKen Paxton

Keith Self June 20 McKinney Event Invite_Layout 1 5/13/13 10:47 AM Page 1

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WITH OUR SPECIAL GUEST THE HONORABLE

Majority Leader. U.S. House of Representatives. 1995-2002

Sponsorship Levels: S250 to S2.500 r coup o

To RSVP or for mn information please contact Khn Watts at: £2141236-1053 kbnberlywattS@verizon.net

Kevil BrafDIOll at: l2141544-8812 kevill@brannonco.com

HONORARY HOST COMMITIEE

Stole Senator Aarence Shapiro S4ale Saler Je IWseii

Stole Representative Jome~ Slate ...... M'ry IWili1

Stute Re1nsentative Brian MMI Stute Repr-iutift Burt s.l.ims

The Honorable Kei1h Seff, Collin (.DClllly Jadge

The Honorable Phyllis Cole, Cal-. County Cll!lllllllianlr Predllt l

The Honorable Jerry Hoagland, Caln Coanly Conaisiioner Precild 2

The Honorable Joe Jaynes, Collin County CDll1llissiaMf Prllild 3

The Honorable, Jack llakhell, Caln County ~ Prllild 4

Mayor Steve Terrel, Allen Mayor Carilen Hawsd, Celiaa Mayor Mate SiR1JS0n, Frism Mayor Bil Whitheld, Mdi11Aey

Mayor Charles Niswanger, Pr111p1r

HOST COMMITIEE* (5/l«:lfir lne/s frx die Host Crrnmlflee d be ttcDgGZed at -ii

c.llie & Ill. Hamer Adams Bil & Danna lealon llilli & Branck AsNey l111 Ktley

A11111s Energy PAC John lnajlp Is & Sllphanie Baks Ill. Jim & Claillia Laiemey 8-is & Dama Bak• V'1 l.animare Sim & 1'1111 Baxllr Ill. licil llbo¥ic Jell&Daallmd Ridi&Shxyl.ewis 1M & Wy "- The Han. Brilll & Danna laufinils

l.Dlis A. Beed.I, k Mate & Cheryl Maswy Banrie Ruth~ Cali Mate & Kelly Mclruyer

lob & Flora Brands Phi ~ Mel&....,_.,_ nM&Moa.Met. Rebe<ca Brewer hill & Christie Mowery The Hon. David & Mendy Bristol Bab P•ry The Hon. Jean & Glenn Calison Jim & Joarie Pl! flank ClllWjlbeR Brandon & Jemil• Pogue Wade Chessman Micllael & Swin Puhl Ill. Stan Cln1W lee & Swin Riffe Di. Rudy & l'olli Cluner 5cn &Anita loadi Mark & Samantha Calib Oavt & Ji. Bob & Claude Am Colim llis Saw David & Tina Craig Raliwt S... Chris & Shely Cronin le111$ l'odialric Weal~ HI & Kiissy Darling Scan & Rollin Turner Don Day UM.d s.gK9 ~PAC Tom Duffy Jerry VtWt1 Ridt Ftanklii (111 & M.cy w.lwcMI Friends of UTD Phi & .laMI Whell Dr Tonwny Gough llMI & Pally Whilllll\1

Clff Henderson Ms\ W1Q11i1s DI. Uaydele llopkins °*YI & Jahn ......

The Hon. Pete Huff Jim & ... --Independent IRsur9K9 Don & Sue Wtls

Agm ol T11as Ill. Brad & r.ida Wv!11111 M.it&a.thltlilon &ic&._z...,

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Honor. ry Co-Hosts Con re1.rman}oe Barton

mgrr.tsman A'lichad Burgt'Ss, M.D. Congressman Rolph H,11/

Congrt•ssman ]eh Hensarling Congressman Kenny Jl,.forchant

Congressman Pete• Sessions State Senator Flormre Shapiro Sta/,• Rep.Jodie Lnubenberg

State Rep.Jerry Madden State Rep. Ken Paxton State Rep. Van Taylor

County judge Keith Self County Commissioner J oe Jay nes

County Commissioner M att Shaheen Cozm~v Commissio11er D uncan Wcbb

County Commissio11er Cheryl Williams

l\lt~jor Underwriters Doug and Jodi Barttk

Da-..•id and Tina Craig

Al Hill, Jr. Bunker and Caroline Hunt

Rick and Tanya Franklin Pat and Sharon Lobb

Ross and Margot Perot

Congressional Council Richard H. Collins

DOCS PAC

Milla Perry Jones Vic Lattimore

a/tonal Apartment Association

/ohn and Michelle Profanchik

B.M. Rankin Mark and Carolyn Speese

Roger Staubach John and Leahray Wroten

Eric Zepp

Lone Star Council

Ebby Halliday /Jeers

Bill Darling

Abron Kah

Dr. Jimmy Laferney

R.hy1 Best

1 (;ni Brinker

Vrv1·K1ik Churk unJJulie O'Reilly

I.any a/Jll Pdt JJyrtl Hrtatt /· /1•/1 ha

J~d 11nd Jl11rht1ru l•or1•mun /11/yn A'r11tt11 t

anA 11111/ f'uthlrr11 l.tlUlfl)!,t'r

Benefactor

Sponsor~

Charlie O'Reilly Realtors PAC

Dan and Lois Thomas

Larry Steinberg

Felix and Sa11dm The{/ord D1: Brad a11d Patriria f!f!yso11g

j ohn ). flt•mo11 .f . Po1cy

j ohn N.11//1111

!Jar rd/ 11 111/ Ga 1/t• 'fl111•

You are cordially invited to attend

a reception honoring

CONGRESSMA s JO Republican, Third District ofTexa

with special guest

so

CONGRESS11AN ERIC CANTOR

U.S. House Majority Leader

~lond.1y1 November 7, 2011

5: 0 P~1 Private o-Ho t Reception

6:00 P~1 General Reception

TPC Craig Ran h

000 ollin McKinney Parkway

!vlcK.inncy, Texas 75070

IJ • • Reph,· en ·lo ·ed :>Usmc,s attire

For 1110rc i11j(m11atio11 plcme collfact Mt~ry M. McClun· at 9721..J._ ..J.-9573 or Mary0 Sa111Jolimo11jor 011gn·ss .com

F RAND AUTHORIZED BY FRiEf\Ios OF SAM JOHNSON (f>t1rtiul /111i11.' ut 111111• o/p1 i11 1 i11xJ~--------------L------1-LCl!.1.i~~!..O!l..!.!::~~..!..!.:~:!!::!:.:::....::...::.....:...~=-..:._----------

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EXHIBIT C

26

Join the Host Committee

for a fundralser supporting Catherine Baen

David Bires Dan Cogdell

Skip Cornelius Erle Davis

Nlcole DeBorde Dick Degeurln Ronald Green

Matt Hennessey Robert Jones

J~e,

James Kennedy Richard Kunlanslcy

Jim Lindeman Edward Mallett Alvin Nunnery Anthony Osso Kent Schaffer

Randy Schaffer Brian Wice

Connie Wiiiiams Cornell Wiiiiams

fv1 ~iA T. J ____

Name:

33q~ Cr~ D~LU CMc..rt Arman dos

2630 Westhelmer Tuesday, July 26, 2011

5:30 to 7:00 p.m.

Please RSVP to Brittany at (713) 978-7701 or by email at brittany@lonestarstrategies.com

- -----------------------Address:

--------~-----~-~-~-----CI ty: ---------- - State: _____ Zip: ___ _

Occupatlon: __ ~---------------~-~-­Phona: -----------Email:------ ---- -

_ I will attend Judge Jackson's fundraiser and contribute by check:

- $5,000 - $2,500 - $ l ,000 - $500 $ __

_ I cannot attend, but will help Judge Jackson with$ __

Please mall personal or PAC checks payable to: Marfa Jackson Campaign, 3401 Louisiana St., Ste. 250, Houston, TX 77002

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