The opinion
ACCEPTED
03-15-00505-CV
15270981
THIRD COURT OF APPEALS
AUSTIN, TEXAS
2/13/2017 12:55:25 AM
JEFFREY D. KYLE
CLERK
No. 03-15-00505-CV
FILED IN
3rd COURT OF APPEALS
IN THE THIRD COURT OF APPEALS OF TEXASAUSTIN, TEXAS
2/13/2017 12:55:25 AM
JEFFREY D. KYLE
Clerk
DAVID A. ROGERS
Appellant
v.
GREGORIO “GREG” CASAR,
Appellee
Appeal from the 201st District Court
Travis County, Texas
FIRST AMENDED BRIEF OF APPELLANT
ON MOTION TO RECONSIDER THE COURT’S OPINION
And
ON MOTION TO RECONSIDER EN BANC THE COURT’S OPINION
David Rogers
Texas Bar No. 24014089
Law Office of David Rogers
595 Round Rock West Drive,
Suite 101
Round Rock, TX 78681
Telephone: (512) 923-1836
Fax: (512) 201-4082
ATTORNEY FOR APPELLANT
ORAL ARGUMENT REQUESTED
Rogers Appellant First Amended Brief on Motion to Reconsider and Reconsider En Banc p. i
No. 03-15-00505-CV
IN THE THIRD COURT OF APPEALS OF TEXAS
DAVID A. ROGERS,
Appellant
v.
GREGORIO “GREG” CASAR,
Appellee
Appeal from the 201st District Court
Travis County, Texas
FIRST AMENDED BRIEF OF APPELLANT
ON MOTION TO RECONSIDER THE COURT’S OPINION
And
ON MOTION TO RECONSIDER EN BANC THE COURT’S OPINION
David Rogers
Texas Bar No. 24014089
Law Office of David Rogers
595 Round Rock West Drive,
Suite 101
Round Rock, TX 78681
Telephone: (512) 923-1836
Fax: (512) 201-4082
ATTORNEY FOR APPELLANT
ORAL ARGUMENT REQUESTED
Rogers Appellant First Amended Brief on Motion to Reconsider and Reconsider En Banc p. ii
IDENTITY OF PARTIES AND COUNSEL
The following is a complete list of all parties, as well as the names and
addresses of all counsel:
PARTIES
Appellants/Plaintiffs:
Dr. Laura Pressley
Pro Se for Appellant Dr. Laura Pressley
David A. Rogers
Texas Bar No. 24014089
595 Round Rock West Drive, Suite 101
Round Rock, TX 78681
512-923-1836 — Telephone
512-201-4082 — Facsimile
Email: Firm@DARogersLaw.com
Pro Se
Appellees/Defendants:
Charles 'Chuck' Herring Jr. 09534100
cherring@herring-irwin.com
Jess Irwin - 10425700
jess@herring-irwin.com
Lauren Ross – 24092001
laurenbross@herring-irwin.com
Herring & Irwin, L.L.P.
1411 West Avenue, Ste 100
Austin, TX 78701
Phone: 512-320-0665
Fax: (512) 519-7580
Kurt Kuhn – 24002433
Kurt@KuhnHobbs.com
KUHN HOBBS PLLC
3307 Northland Drive, # 310
Rogers Appellant First Amended Brief on Motion to Reconsider and Reconsider En Banc p. iii
Austin, Texas 78731
(512) 476-6000
(512) 476-6002- Facsimile
ATTORNEYS FOR APPELLEE, GREGORIO "GREG" CASAR
Rogers Appellant First Amended Brief on Motion to Reconsider and Reconsider En Banc p. iv
TABLE OF CONTENTS
Identity of Parties and Counsel…………………………………………iii
Table of Contents……………………………………………………….v
Index of Authorities…………………………………………………….vi
Statement on Oral Argument……………………………………………1
Statement of the Case………………………………..………………….1
Statement of Facts………………………………………………………2
Statement of Issues Presented…………………………………..………4
Summary of Argument………………………………………………….5
Argument…………………………………………………………….….8
Prayer…………………………………………………………………..21
Certificate of Service…………………………………………..………22
Certificate of Compliance…………………………………………..…23
Appendix 1 (Casar sworn finance reports)
Appendix 2 (Rogers’ P&L for Pressley representation)
Rogers Appellant First Amended Brief on Motion to Reconsider and Reconsider En Banc p. v
INDEX OF AUTHORITIES
TEXAS SUPREME COURT
AIC Mgmt. v. Crews, 246 S.W.3d 640 (Tex. 2008)……….………….…………..17
Alex Sheshunoff Mgmt. Servs., L.P. v. Johnson, 209 S.W.3d 644 (Tex. 2006)…..17
Low v. Henry, 221 S.W.3d 609 (Tex. 2007) ………...……………………..…3, 8, 9
R.R. Comm 'n of Tex. v. Tex. Citizens for a Safe Future & Clean Water, 336 S.
W3d 619, (Tex. 2011) ………………………………………………..…………...16
Tex. Dep't of Parks & Wildlife v. Miranda, 133 S.W.3d 217 (Tex. 2004)……...….8
Tex. Dep't of Protective and Regulatory Services v. Mega Child Care, 145 S.W.3d
170, 177 (Tex. 2004). …………...………………………………………………..16
TEXAS COURTS OF APPEALS
Ebner v. First State Bank of Smithville, 27 S.W.3d 287 (Tex. App.—Austin
2000)………………………………………………………………………………14
In the Interest of T.K.W., 2010 Tex. App. LEXIS 1040, *11, 2010 WL 546584
(Tex. App. San Antonio Feb. 17, 2010)………………………………….…...……8
Randolph v. Jackson Walker, L.L.P., 29 S.W.3d 271 (Tex. App.-Houston [14th
Dist.] 2000, pet. denied)…………………………………………………..…..……8
TEX. CONSTITUTION
Tex. Const., Art. 1, Sec. 16……………………………………………………18-19
STATUTES
Texas Civil Practice and Remedies Code Chapter 10 …………………..………6, 9
TEX. CIV. PRAC. & REM. CODE 10.004………………………………..……3-6, 8-11
Texas Election Code, Chapter 52…………………………………….…………..20
Texas Election Code, Sec. 128.001(a)(2)……………………………………..15, 20
Texas Election Code, Sec. 213.016………………………………………...…15, 17
Texas Government Code 311.011 (b)……………………………………………….17
TEXAS RULES OF CIVIL PROCEDURE
Texas Rule of Civil Procedure 11………………………………2, 4, 7, 11-14
Rogers Appellant First Amended Brief on Motion to Reconsider and Reconsider En Banc p. vi
TEXAS RULES OF EVIDENCE
Tex. R. Evid.
201(c)(2)……………………………….……………………………19, 20
OTHER AUTHORITIES
Notes of Advisory Committee on Rules—1993 Amendment
https://www.law.cornell.edu/rules/frcp/rule_11 ………………..……………..11-12
Rogers Appellant First Amended Brief on Motion to Reconsider and Reconsider En Banc p. vii
TO THE HONORABLE THIRD DISTRICT COURT OF APPEALS:
1. Appellant, David A. Rogers (hereinafter “Rogers”), hereby moves that the
honorable Court of Appeals reconsider, as a panel or, in the alternative en banc,
and reverse the sanctions 1 order of the district court and render a decision
denying or modifying the sanctions against Rogers. In support of this motion
Rogers shows this honorable Court as follows:
Statement on Oral Argument
2. Oral argument is requested because this sanctions argument is legally
complex and the allegations regarding evidence may appear somewhat
perplexing.
Statement of the Case
3. Appellant Rogers represented Dr. Laura Pressley (“Pressley”) in a contested
2014 run-off election for the District 4 City Counsel seat of Austin, Travis County,
Texas. Pressley is a pro se Appellant of said contest in consolidated Appeal
Number 03-15-00368-CV.
4. Appellee Gregorio "Greg" Casar (“Casar”) is the contestee in Pressley’s
action. The trial court held that Casar won the run-off in said election.
1
Throughout this brief, Rogers will refer to “sanctionable conduct.” Rogers does not concede
that the conduct was properly found to be sanctionable, to the extent such concession might bar
further appeal. Rather, Rogers makes a conditional, arguendo concession. Even if the conduct
was sanctionable, the sanction was excessive.
Rogers Appellant First Amended Brief on Motion to Reconsider and Reconsider En Banc p. 1
5. Rogers asserts that the trial court, Honorable Dan Mills presiding, erred
in granting sanctions against Rogers. The motion for sanctions was based on
the factual allegations asserted in the 5th and 6th Amended Contests.2
6. The Trial Court and the panel failed to properly apply pertinent
provisions of TRCP Rule 11 regarding open court agreements, and the plain
language of Texas Civil Practice and Remedies Code Chapter 10 limiting
sanctions awards. In addition, newly created sworn public admissions by
Casar fatally undermine claims as to fees incurred.
Statement of Facts
7. Rogers adopts, incorporates, and includes by reference the Statement of
Facts in his Appeal Brief as if fully set forth herein. Rogers adds the following
facts, asking the Court to take judicial notice of public records under Tex. R. Evid.
201(c)(2), created by Casar and sworn by him under penalty of perjury.3 Relevant
2
In Casar’s Amended Motion for Sanctions, filed 5-22-2015, Casar complained of the 6th
Amended Contest, which omitted some of the materials complained of in the 5th Amended
Contest. (080715 CR 3-7) Similar complaints were made in the Second and Third Amended
Motion for Sanctions, filed 6-12-2015. (080715 CR 8-12) (072915 CR 1934-1939)
3
The URLs for these filings are: http://www.austintexas.gov/edims/document.cfm?id=234975
(July 15, 2015)
http://www.austintexas.gov/edims/document.cfm?id=246589 (Jan 15, 2016);
http://www.austintexas.gov/edims/document.cfm?id=258181 (July 15, 2016);
http://www.austintexas.gov/edims/document.cfm?id=264497 (Oct 11, 2016);
http://www.austintexas.gov/edims/document.cfm?id=265620 (Oct. 31, 2016);
http://www.austintexas.gov/edims/document.cfm?id=265717 (Nov. 2, 2016);
http://austintexas.gov/cityclerk/elections/2016campaignfinancereporting.htm ;
http://www.austintexas.gov/edims/document.cfm?id=269909 (Jan. 17, 2017)
These are official City of Austin Records, maintained on the City of Austin website, the accuracy
of which is sworn to by Mr. Casar on the second page of each report.
Rogers Appellant First Amended Brief on Motion to Reconsider and Reconsider En Banc p. 2
excerpts of these official City of Austin records and a summary chart are attached
as an Appendix. Casar’s sworn campaign finance records reveal payment of
$23,350 in legal fees to three law firms and $7,794.44 in legal costs. His sworn
statements show no incurred but unpaid costs and fees
8. No evidence was presented that Rogers possessed the ability to pay such a
large sanction; therefore, no controverting evidence was produced. If such
evidence had been put forward, it would have shown that Rogers’ law firm lost
$16,881.04 during the six months it represented Pressley, mainly due to Pressley’s
non-payment of large agreed expenses. See attached Appendix 2. The only
“evidence” pointed to by the trial court and the panel regarding Rogers’ ability to
pay sanctions4 was a post Motion for Summary Judgment settlement agreement,
prior to the conclusion of the sanctions hearing, in which Rogers’ reduced his fee
to Pressley by over $40,000. Rather than evidence of Rogers’ ability to sustain a
4
Ability to pay sanctions awards is a factor required to be considered in assessing sanctions
under the Low v. Henry, 221 S.W.3d 609 (Tex. 2007) decision, which explicates application of
TEX. CIV. PRAC. & REM. CODE 10.004. The trial court addressed this factor in paragraph 75 of
its decision, saying: “Rogers has assets and income sufficient to be able to pay a monetary
sanction. Specifically, Rogers is a practicing attorney who charges approximately $350/hour.
Additionally, Rogers testified he has the financial ability to be able to forgo legal fees of
approximately $51,500 from Pressley.” Rogers did not testify to that, nor is it true.
The court added in paragraph 148 of its decision, saying: “Rogers has the ability to earn income
sufficient to justify the award of sanctions.” In fact, the sanction combined with the non-
payment by Pressley led Rogers to dramatically downsize his practice, ending employment of
four contractors and reducing his physical space by more than 50%. Pressley’s non-payment on
this case alone was catastrophic for Rogers’ practice, and there is no evidence in the record that
he has the capability to pay the very large additional sanctions ordered by the trial court.
See also panel opinion at 49.
Rogers Appellant First Amended Brief on Motion to Reconsider and Reconsider En Banc p. 3
further $50,000 loss, it strongly suggests the truth – that Rogers did NOT have the
ability to pay such an enormous sanction.
Statement of Issues Presented
9. Issue 1. The trial court erred by awarding sanctions against Rogers without
applying the plain statutory language of Chapter 10 of the Civil Practices and
Remedies Code.
10. Sub issue 1-A: 10.004(b) requires least severe sanctions. “The sanction
must be limited to what is sufficient to deter repetition.”
11. Sub-issue 1-B: 10.004 (c)(3) limits “an order to pay to the other party” to
amounts actually “incurred” “because of the filing of the pleading or motion.”
Casar’s public filings show the actual “incurred” amount was only $31,144.33. The
sanctions ordered significantly exceeded this amount.
12. Sub-issue 1-C: 10.0004 (3) limits sanctions to amounts “actually incurred”
“because of the filing of the pleading or motion,” a “but/for” causation standard.
Sanctions must be no more than the amount that actually incurred “because of” the
“sanctionable” portions of the pleading.
13. Issue 2. The trial court and panel erred in holding that the right to seek
sanctions was not foreclosed and barred by the Rule 11 agreement that all issues
between the parties were resolved at the time the Rule 11 agreement was reached
in open court. The panel omitted from consideration the relevant portion of Rule
Rogers Appellant First Amended Brief on Motion to Reconsider and Reconsider En Banc p. 4
11 that allows such agreements to be made in open court without attorney
signatures.
14. Issue 3. The trial court and the panel erred in holding that a Cast Vote
Record (“CVR”) is necessarily a Ballot Image. A Ballot Image is a CVR. A tally
sheet is a CVR. A database record is a CVR. But all CVRs are NOT Ballot
Images. Travis County produces Database File Records, which are CVRs, but
which are not Ballot Images. The statutes requires Ballot Images.
Summary of Argument
15. Rogers requests this honorable Appeals Court reverse and render, denying
Casar’s Motion for Sanctions against Rogers.
16. Issue 1. The trial court and the panel erred by awarding sanctions without
applying the statutory plain language of the Civil Practices and Remedies Code,
Chapter 10.
17. Sub issue 1-A: 10.004(b) requires least severe sanctions. “The sanction
Rogers Appellant First Amended Brief on Motion to Reconsider and Reconsider En Banc p. 5
must be limited to what is sufficient to deter repetition.” Neither the trial court nor
the panel made a finding that the sanctions imposed were limited to what is
sufficient to deter repetition and no testimony or evidence as to what was necessary
to deter repetition was given in court.
18. Sub-issue 1-B: 10.004 (c)(3) limits “an order to pay to the other party” to
amounts actually “incurred” “because of the filing of the pleading or motion.”
Casar’s public filings show that only $31,144.44 was actually jncurred. The
sanctions ordered significantly exceed this amount. The maximum award,
assuming all attorney’s fees and all costs actually incurred were solely because of
the filing of “sanctionable” portions of the pleading, therefore, is $31,144.44.
19. Sub-issue 1-C: 10.0004 (3) limits sanction to amounts “actually incurred”
“because of the filing of the pleading or motion.” This is a but/for causation
standard. The sanctions must be limited to the amount that was incurred “because
of” the “sanctionable” portions of the pleading. The trial court and panel admit
that the CVR argument was not the basis of sanctions, so much of the cost
“actually incurred” was not due to the “sanctionable” conduct. The trial court
conceded this point yet it awarded 100% of “costs,” to Casar; therefore, it has
confessed that the award is in error.
20. The trial court and panel admit that the CVR argument was not the basis of
sanctions, so much of the cost “actually incurred” was not due to the sanctionable
Rogers Appellant First Amended Brief on Motion to Reconsider and Reconsider En Banc p. 6
conduct. The trial court conceded this point yet it awarded 100% of “costs,” to
Casar; therefore, it has confessed that the award is in error.
21. Issue 2. The trial court and panel erred in holding that the right to seek
sanctions was not foreclosed and barred by the Rule 11 agreement that all issues
between the parties were resolved for purposes of imposing sanctions. The panel
omitted from its consideration the relevant portion of Rule 11 that allows such
agreements to be made in open court without signature of the attorneys.
22. Issue 3. The trial court and the panel erred in holding that a Cast Vote
Record (“CVR”) is necessarily a ballot image. A ballot image is a CVR. A tally
sheet is a CVR. A database record is a CVR. But all CVRs are not ballot images.
(All elephants are grey mammals but not all grey mammals are elephants.)
23. Travis County produces Database File Records, which are CVRs, but
Rogers Appellant First Amended Brief on Motion to Reconsider and Reconsider En Banc p. 7
which are not Ballot Images, which are required by statute.
Argument and Authorities
24. Issue 1. In ordering and upholding the sanctions imposed, the trial court
and the panel ignored the plain language of Texas Civil Practice and Remedies
Code Chapter 10. The courts cited 10.001, 10.002 and 10.004, but did not engage
in analysis of the statute, opting instead to engage the Low5 decision and its
multifarious factors for a decision to sanction.
25. Questions of law are reviewed by the appellate court de novo.6
26. The trial court abused its discretion in awarding sanctions against Rogers by
ignoring the plain language of Texas Civil Practices and Remedies Code §10.004.
“A trial court's award of sanctions is reviewed under an abuse of discretion
standard. To determine if there is an abuse of discretion, we must look to see if the
court acted without reference to any guiding rules and principles." In the Interest of
T.K.W., 2010 Tex. App. LEXIS 1040, *11, 2010 WL 546584 (Tex. App. San
Antonio Feb. 17, 2010) (internal citations omitted.) “A trial court abuses its
discretion in imposing sanctions if it bases its order on an incorrect view of the law
or an erroneous assessment of the evidence.” Randolph v. Jackson Walker, L.L.P.,
29 S.W.3d 271, 276 (Tex. App.-Houston [14th Dist.] 2000, pet. denied). Such an
abuse of discretion requires reversal.
5
Low v. Henry, 221 S.W.3d 609, 614 (Tex. 2007).
6
Tex. Dep't of Parks & Wildlife v. Miranda, 133 S.W.3d 217, 226 (Tex. 2004)
Rogers Appellant First Amended Brief on Motion to Reconsider and Reconsider En Banc p. 8
27. Sub issue 1-A: 10.004(b) requires least severe sanctions. “The sanction
must be limited to what is sufficient to deter repetition.” Neither the lower court
nor the panel issued an order to perform or refrain from performing any act, the
most limited sanction authorized under §10.004(c). Neither the trial court nor the
panel made a finding that the sanctions were limited to what is sufficient to deter
repetition. There was no trial court testimony or other evidence about what was
necessary to deter repetition. The court asked multiple questions about sanctions
and the Low factors while Rogers and opposing counsel were under oath but not
regarding what was necessary to deter repetition.
28. The panel rejected the argument about the lack of evidence, stating that the
argument was waived for lack of citation to evidence in the record. But the point is
that there is no evidence in the record. No one testified about the minimum level
of sanction required, and no evidence on the question was presented by any party.
The trial court did not address the issue in its opinion, other than acknowledging
the existence of the standard in paragraph 150 and then not addressing it.
29. Sub-issue 1-B: 10.004 (c)(3) limits “an order to pay to the other party” to
amounts actually “incurred” “because of the filing of the pleading or motion.”
Casar’s public filings show amount actually “incurred” was only $31,144.44. The
sanctions order requires the payment of more than $31,144.44. The maximum
award, assuming all attorney’s fees and all costs “actually incurred” were solely
Rogers Appellant First Amended Brief on Motion to Reconsider and Reconsider En Banc p. 9
because of the filing of the “sanctionable” portions of the pleading, therefore, is
$31,144.44. Any amount over the amounts actually incurred is a penalty, which
must be paid to the court. TEX. CIV. PRAC. & REM. CODE 10.004(c)(2).
30. On page 48 of its opinion, the panel cites “TEX. CIV. PRAC. & REM. CODE
§10.004(c)(3) (authorizing as sanction order requiring sanctioned party to pay
reasonable expenses incurred as result of filing of pleading, including reasonable
attorney's fees).” The panel goes on to assert that Casar’s attorney presented
evidence of total attorney’s fees Casar had incurred. Subsequently, Casar has
created and filed with the City of Austin sworn campaign finance filings in which
he states that he has no incurred but not paid debt related to his campaign or office
holding, and that he has paid only $23,350.00 in legal fees, and only $7,794.44 in
legal costs.
31. This is unsurprising. In his August 12, 2015 order, Judge Mills specifically
found that “Casar has not paid any of the legal fees.” Supp. CR IV, Vol. 1, p. 5.
Casar’s sworn filings contradicting his attorney were not, of course, in evidence at
the time of trial, as they had not yet been created. But this is not a one-time error.
Casar swore seven times over a period of eighteen months that he had no
outstanding incurred but not paid debt. As Casar has, by his own sworn
statements, not “incurred” any debt, under CPRC 10.004(c)(3), the order to pay
him must be limited to, at most, the expenses actually “incurred.”
Rogers Appellant First Amended Brief on Motion to Reconsider and Reconsider En Banc p. 10
32. The trial judge when he was under the mistaken impression that over
$200,000 was actually incurred, when he awarded less than $100,000 in sanctions.
Under the facts sworn to seven times by Casar, no more than a maximum of
$15,000 should be awarded against the two defendants combined, and no more
than $8,000 of that against Rogers.
33. Sub-issue 1-C: 10.0004 (3) limits sanction to amounts “actually incurred”
“because of the filing of the pleading or motion.” This is a but/for causation
standard. The sanctions must be limited to the amount that was incurred “because
of” the “sanctionable” portions of the pleading.
34. The but/for causation standard was explicitly recognized by the Advisory
Committee that drafted the 1993 amendment to federal Rule 11, upon which the
Texas CPRC 10 amendments are based:
Since the purpose of Rule 11 sanctions is to deter rather than to
compensate, the rule provides that, if a monetary sanction is imposed,
it should ordinarily be paid into court as a penalty. However, under
unusual circumstances, particularly for [subdivision] (b)(1) violations,
deterrence may be ineffective unless the sanction not only requires the
person violating the rule to make a monetary payment, but also directs
that some or all of this payment be made to those injured by the
violation. Accordingly, the rule authorizes the court, if requested in a
motion and if so warranted, to award attorney's fees to another party.
Any such award to another party, however, should not exceed the
expenses and attorneys’ fees for the services directly and unavoidably
caused by the violation of the certification requirement. If, for
example, a wholly unsupportable count were included in a multi-count
complaint or counterclaim for the purpose of needlessly increasing the
cost of litigation to an impecunious adversary, any award of expenses
Rogers Appellant First Amended Brief on Motion to Reconsider and Reconsider En Banc p. 11
should be limited to those directly caused by inclusion of the
improper count, and not those resulting from the filing of the
complaint or answer itself. ...
Notes of Advisory Committee on Rules—1993 Amendment
https://www.law.cornell.edu/rules/frcp/rule_11 (Emphasis added.)
35. As both the trial and appellate courts admit that the CVR argument – the
bulk and heart of the litigation – was not the basis of sanctions, much of the “costs”
“actually incurred” was not due to the sanctionable conduct. Those costs, largely
the cost of depositions of Dr. Pressley and the County Clerk, would have been
incurred without the additional of the “sanctionable” portions of pleadings.
Despite that, the trial court awarded 100% of “costs” to Casar, after conceding that
less than 100% of “costs” were due to sanctionable conduct. Therefore, the trial
court has confessed that the “costs” award is in error. This error alone requires
reversal.
36. Issue 2. The trial court and panel erred in holding that the right to seek
sanctions was not foreclosed and barred by the Rule 11 agreement that all issues
between the parties were resolved at the time the agreement was made in open
court. The panel omitted from consideration the relevant portion of Rule 11 that
allows such agreements to be made in open court without attorney signatures.
Texas Rule of Civil Procedure 11. Agreement to be in writing.
Unless otherwise provided in these rules, no agreement between
attorneys or parties touching any suit pending will be enforced unless
it be in writing, signed and filed with the papers as part of the record,
Rogers Appellant First Amended Brief on Motion to Reconsider and Reconsider En Banc p. 12
or unless it be made in open court and entered of record.
37. The agreement Rogers seeks to enforce was made in open court and entered
of record. The panel asserts, on page 34 of its opinion, that “To be enforceable
under Rule 11, agreements between attorneys and parties must be signed.” That is
plainly not what the Rule requires.
38. The colloquy between the Court and the Attorneys at the May 26, 2015
hearing makes it abundantly clear that all parties are agreeing at that time to a
“Mother Hubbard” clause that closes all issues in the lawsuit effective on that day.
RR (May26,2015) Vol.4 p.120 line 18 – p.121 line 9.
18. MR. COHEN: Just a minute. Judge, on the order,
19. I think it should be very clear about this, you have --
20. you should put a mother hubbard clause in that says that
21. this order resolves all the issues between all the
22. parties in the case and is final and appealable. And if
23. you'll write that in there then we will be able to -- we
24. won't have the Court of Appeals sending it back for
25. some –
1. THE COURT: You want to do that, Mr. -
2. MR. HERRING: I have no objection to that.
3. THE COURT: You want me to just write it below
4. my signature?
5. MR. HERRING: Sure, that's fine.
6. THE COURT: What is it you want me to say --
7. MR. ROGERS: This order resolves all the issues
8. between all of the parties and it's final and appealable.
9. THE COURT: There you go.
Rogers Appellant First Amended Brief on Motion to Reconsider and Reconsider En Banc p. 13
42. This agreement meets the Rule 11 plain language requirements, and the
explication made by this Court in Ebner v. First State Bank of Smithville, 27
S.W.3d 287, 296, (Tex. App.—Austin 2000) (internal citations omitted.)
“To have a binding, open-court stipulation, the parties must dictate
into the record all material terms of the agreement and their assent
thereto.” The “made in open court” option in Rule 11 has been
construed to provide an alternative way to establish an agreement of
the parties when the preparation of a written agreement is not
practical. (Rule 11 satisfied if “oral waiver or agreement made in open
court is described in the judgment or an order of the court”).
43. Issue #3 The trial court and the panel erred in holding that a Cast Vote
Record (“CVR”) is necessarily a ballot image. A ballot image is a CVR. A tally
sheet is a CVR. A database record is a CVR. But all CVRs are not ballot images.
Rogers Appellant First Amended Brief on Motion to Reconsider and Reconsider En Banc p. 14
44. Travis County produces Database File Records, which are CVRs, but
which are not Ballot Images. See Testimony of Dana DeBeauvoir, Supp.
RR, Vol. 2, p. 211, line 9-24.
20. Q. I want to make sure I understand.
21. So you're saying Hart has one machine that
22 creates ballot images but not cast vote records, and another
23 machine that creates cast vote records but not ballot images?
24 A. I think that's fair enough to say.
45. The claims asserted by Rogers during the course of this election contest
preclude the imposition of sanctions pursuant to Texas Civil Practice and Remedies
Code Chapter 10. Most particularly, the trial court, while unpersuaded by the
argument that a CVR which does not contain a cast Ballot Image does not comply
with the statute, did not find the assertion sanctionable. This sound argument is the
heart of the case.
46. It is uncontested that the relevant Texas statutes were enacted in 19977 and
2003.8 Those statutes require “ballot image storage” and “images of ballots cast.”
47. Casar attempts to create ambiguity in the reading of the statutes by asserting
that various administrative agencies, years after enactment of the statutes, have
redefined the words of the statutes. However, the purported reinterpretations are
inconsistent with plain language and incongruent with the meaning of the statutes
as understood at the time of their enactment.
7
Texas Election Code, Sec. 128.001(a)(2)
8
Texas Election Code, Sec. 213.016
Rogers Appellant First Amended Brief on Motion to Reconsider and Reconsider En Banc p. 15
48. Administrative redefinition of statutes is not allowed. In R.R. Comm'n of Tex.
v. Tex. Citizens for a Safe Future & Clean Water, 336 S.W.3d 619, 625 (Tex. 2011), the
Texas Supreme Court reaffirmed its 20 year old rule that deference due to
administrative determinations is limited to those that are “‘reasonable and do[] not
contradict the plain language of the statute.’”.
49. The Safe Future Court added that “this deference is tempered by several
considerations:”
It is true that courts give some deference to an agency regulation
containing a reasonable interpretation of an ambiguous statute. But there
are several qualifiers in that statement. First, it applies to formal opinions
adopted after formal proceedings, not isolated comments during a
hearing or opinions [in a court brief]. Second, the language at issue must
be ambiguous; an agency's opinion cannot change plain language.
Third, the agency's construction must be reasonable; alternative
unreasonable constructions do not make a policy ambiguous.
Id. (internal citations omitted.) (emphasis added.)
50. Casar has put forward no evidence of any “formal opinions adopted after
formal proceedings,” and has explicitly attempted to rely on a 2008 “isolated
comments during a hearing or opinions [in a court brief].” These comments are due
no deference.
51. The plain language of the statutes require an “image” of a “ballot.” A “Cast
Vote Record,” as a mere database record is neither “image” nor “ballot.”
Rogers Appellant First Amended Brief on Motion to Reconsider and Reconsider En Banc p. 16
52. In Texas Dep’t of Protective and Regulatory Services v. Mega Child Care,
145 S.W.3d 170, 177 (Tex. 2004), the Texas Supreme Court, in overruling a 25-
year-long pattern of erroneous interpretation of administrative law by this court,
made it clear that Texas embraces an unusually strong version of the plain meaning
rule.
If the statutory text is unambiguous, a court must adopt the
interpretation supported by the statute's plain language unless that
interpretation would lead to absurd results.
See also AIC Mgmt. v. Crews, 246 S.W.3d 640 (Tex. 2008) (Willet, J., concurring)
(internal citations omitted) (citing to Alex Sheshunoff Mgmt. Servs., L.P. v.
Johnson, 209 S.W.3d 644, 652 n.4 (Tex. 2006) and 542 U.S. 241, 267, 124 S. Ct.
2466, 159 L. Ed. 2d 355 (2004) (Scalia, J., concurring in the judgment).
53. The language of Texas Election Code 128.001(a)(2) and 213.016 is
unambiguous, does not lead to absurd results, and does not work an absurdity or
manifest injustice. Therefore, the Court must enforce the plain language requiring
the storage and printing of images of ballots cast. Not database records. Not mere
electronic tally sheets.
54. Casar argues that the plain meaning rule does not apply, because subsequent
statements by administrative agencies contradict the plain meaning, citing Texas
Government Code 311.011 (b): “Words and phrases that have acquired a technical or
particular meaning, whether by legislative definition or otherwise, shall be construed
accordingly.”
Rogers Appellant First Amended Brief on Motion to Reconsider and Reconsider En Banc p. 17
55. First, there is no unanimous or consistent re-definition of a “ballot image” as a
“Cast Vote Record” at the federal level, within the Texas Secretary of State’s Office,
or within the manuals of Hart InterCivic governing this very voting system. The Hart
manuals concede that a CVR is not a ballot image. Hart's own Ballot Now
Operations Manual documentation9 provided to Travis County states that the eScan
subsystem scans each paper ballot to create an exact “digital image of the ballot”
cast. The eScan creates and stores a ballot image (a bitmap, .bmp file), then reads
the data to create a Cast Vote Record. (Ballot Now manual, CR (Vol. 1) 1422-
1729, page 1445 and 1680-1681). Thus, the Travis County’s Hart manual refers to
the CVR (a data structure used to transfer data for tabulation in Tally) and the
ballot image (bitmap, .bmp file) as two different creations.
56. Furthermore, each suggestion of such a re-definition put forth by Casar is dated
AFTER the statutes were enacted in 1997 and 2003,10 and so were not considered by
the legislature, and could not have been intended to have effect in defining statutes
written years earlier. TEX. CONST., ART. 1, SEC. 16. States: “No bill of attainder, ex
9
CR (Vol. 1) 1422-1729, Ballot Now Manual produced by Travis County. Overview, p. 1445:
The voted paper ballots that were printed for processing by an eScan unit at a polling place are
scanned by the scanner inside the eScan to create digital images of the voted ballots to extract the
cast vote records (CVRs) for delivery to the Tally application.
10
The Texas Secretary of State references cited are in 2012, 2014 and 2015. A single Election
Assistance Commission reference, which is mischaracterized as described supra, is dated 2007.
There is no evidence that the “Words and phrases [] ha[d] acquired a technical or particular
meaning” prior to statutory enactment.
Rogers Appellant First Amended Brief on Motion to Reconsider and Reconsider En Banc p. 18
post facto law, retroactive law, or any law impairing the obligation of contracts,
shall be made.” Administrative redefinitions are not exempt from this rule.
57. The Federal government also defines “Ballot image” without reference to
the notion of “Cast Vote Record.” In 1990, the Federal Election Commission’s
Performance and Testing Standard for Punchcard, Marksense, and Direct
Recording Electronic Voting Systems (DRE)11 reported:
To attain a measure of integrity over the process, DRE systems must
also maintain images of each ballot that is cast, such that records of
individual ballots are maintained by a subsystem independent and
distinct from the main vote detection, diagnostic, processing and
reporting path.
58. The FEC distinguishes what would later be known as “Cast Vote Records”
from ballot images, saying there should be two pathways for vote records in
DRE’s: a) images of ballots cast capability, and b) vote detection, processing and
reporting path for vote data. The CVR is a reporting path/subsystem for reporting
vote results to the Tally system and a ballot image is an image file that is
independent from a data reporting path.
11
The Court is requested to take judicial notice of this official federal government record, as
required under Texas Rule of Evidence 201.
http://votingmachines.procon.org/sourcefiles/fec1990.pdf
https://josephhall.org/fec_vss_1990_pdf/FEC_1990_Voting_System_Standards.pdf
The Federal Election Commission’s 1990 Performance and Testing Standard for Punchcard,
Marksense, and Direct Recording Electronic Voting Systems, p. 48.
Rogers Appellant First Amended Brief on Motion to Reconsider and Reconsider En Banc p. 19
59. The Federal Elections Commission’s 2002 Voting System’s Standards,
Volume 1, Performance Standards12 repeated the 1990 DRE requirement for
DRE’s two independent pathways for vote data and ballot images. (p. 31-Section
2.2.4.2, p. 60–Section 3.2.1b(2), and page 135—Section 9.5.1.2.a).13
60. The Texas Secretary of State’s Glossary defines “Ballot image” without
reference to notion of “Cast Vote Records,”14 and does not define “Cast Vote
Record.” Secretary of State’s Glossary of Election Terminology (CR (Volume 1)
1409, p. 2).
61. Casar suggests the SOS may casually redefine the words in statutes based on
TEX. ELEC. CODE §52.075, which allows the SOS to “prescribe the form and content
of a ballot for a… electronic voting system .. to conform to the formatting
requirements of the system.” This language does not allow the SoS to ignore the
requirement of Texas Election Code, Sec. 128.001(a)(2) for “a main computer to
coordinate ballot presentation, vote selection, ballot image storage, and result
tabulation.”
62. The Texas Election Code clearly requires “ballots,” “images of ballots
12
The Court is requested to take judicial notice of this official federal government record, as
required under Texas Rule of Evidence 201.
https://www.eac.gov/assets/1/Page/Voting%20System%20Standards%20Volume%20I.pdf
Elections Commission’s 2002 Voting System’s Standards, Volume 1, Performance Standards.
13
But see U.S. Election Assistance Commission Glossary, RR (Vol. 1) 1748.
Federal Election Assistance Commission Glossary 2007, RR (Vol. 1) 1745.
14
See Attached Exhibit RR (Volume 1) 1409, Texas Secretary of State’s Glossary of Election
Terminology, http://www.sos.state.tx.us/elections/laws/glossary.shtml.
Rogers Appellant First Amended Brief on Motion to Reconsider and Reconsider En Banc p. 20
cast,” and “ballot images” be counted and used to verify voters’ intent. An actual
digital, electronic image file in the form of various types such as a bitmap, pdf,
jpg, png, etc. is a different type of file from a CVR database file. The
legislature’s specific language of “ballot image” requires a secondary method for
verifying ballot counts. The Travis County method, simply printing out the same
CVR data to a predefined CVR template, and counting those CVR’s which is
what was already electronically counted, is not the independent verification path
mandated by the Legislature in order to preserve the integrity of the vote.
Prayer
63. Rogers prays that this Court reverse and render, denying Casar’s request
for sanctions in its entirety, or in the alternative, that the Court reverse and render
and substantially reduce the sanctions. Further in the alternative, Rogers prays
the court reverse and remand for further proceedings consistent with those errors
the Court determines.
RESPECTFULLY SUBMITTED,
/s/ David Rogers
DAVID ROGERS
Law Office of David Rogers
State Bar No. 24014089
1201 Spyglass Drive, Suite 100
Austin, TX 78746 (512) 923-1836
(512) 201-4082 (fax)
Firm@DARogersLaw.com
Rogers Appellant First Amended Brief on Motion to Reconsider and Reconsider En Banc p. 21
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing Motion was
served upon other parties and Counsel of record for Appellants via the Court’s
online filing system on this 13th day of February, 2017.
Kurt Kuhn
State Bar No. 24002433
KUHN HOBBS PLLC
3307 Northland Drive, # 310
Austin, Texas 78731
(512) 476-6000 Telephone
(512) 476-6002 Facsimile
Kurt@KuhnHobbs.com
Charles 'Chuck' Herring Jr.
State Bar No. 09534100
Herring & Irwin, L.L.P.
1411 West Avenue, Ste 100
Austin, TX 78701
(512) 320-0665 Telephone
(512) 519-7580 Facsimile
cherring@herring-irwin.com
ATTORNEYS FOR APPELLEE GREGORIO “GREG” CASAR
Dr. Laura Pressley
10203 Woodglen Cove
Austin, TX 78753
LauraPressley@startmail.com
Pro Se
/s/ David Rogers
DAVID ROGERS
Pro Se
Rogers Appellant First Amended Brief on Motion to Reconsider and Reconsider En Banc p. 22
CERTIFICATE OF COMPLIANCE
Pursuant to Texas Rule of Appellate Procedure 9.4(i), I hereby certify that
this document contains 4,496 words.
/s/David Rogers
David Rogers
SBN 24014089
Law Office of David Rogers
1201 Spyglass Suite 100
Austin, TX 78746
(512) 923-1836
(512) 201-4082 [Facsimile]
Rogers Appellant First Amended Brief on Motion to Reconsider and Reconsider En Banc p. 23
Appendix "1"
CASAR LEGAL EXPENSES & FEES
DATE NAME DESCRIPTION AMOUNT
06/30/15 Herring and Panzer legal expenses 7,794.44
08/26/15 Kuhn and Hobbs legal fees 15,000.00
12/28/16 McGinnis Lochridge legal fees 2,750.00
12/28/16 Herring and Panzer legal fees 2,750.00
12/28/16 Kuhn and Hobbs legal fees 2,750.00
Expense Subtotal; Legal Fees Subtotal: GRAND TOTAL :
$7,794.44 $23,350.00 $31,044.44
Casar Campaign Finance Report 7-15-2015
CANDIDATE I OFFICEHOLDER FORM CIOH
CAMPAIGN FINANCE REPORT COVER SHEET PG 1
1 Filer 1D 2 Total pages filed:
The CIOH Instruction Guide explains how to complete this form.
33 ~
>-::: ....
3 CA~ DIDATE / MS/MRS /MR FIRST Ml c:
OFFICE USE.ONL Y (ft
OFFICEHOLDER
Greg c::=
NAME Dilll> Re<>!IVed r ::0~
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fTI-
NICKNAME LAST SUFFIX --I
<~
Casar
~ !.:!:!~
4 CANDIDATE/ ADDRESS I PO BOX; APT I SUITE t:; CITY; ZIP CODE Date Har\d-dellvereel or OiUe' Postn'\al1(ed r
N
OFFICEHOLDER
MAIUNG
301 West 2nd Slreet ~
;;:>o;;
~~·
Receipt~
ADDRESS
U1
ocllan~ cl-ess Austin, TX 78701 Dale Processed
Dalo Image<!
5 CAMPAIGN MS/MRS/MR FIRST Ml
TREASURER
NAME Carlton l.
.................................................................................................................................. ........................................_..........._...................................
,_,, ,
NICKNAME LAST SUFFIX
Lee Cooke
6 CAMPAIGN STREET ADDRESS (NO PO BOX PLEASE); APT I SUITE #; CITY; STATE; ZIP CODE
TREASURER
ADDRESS
(Residence or ~ss)
8121 Bee Cave Road, Suite too Austin TX 78735
7 CAMPAIGN AREA CODE PHONE NUMBER EXlENSION
TREASURER
PHONE (512) 917-8008
8 REPORT
TYPE
D January 15
D 30th day before elettion
0 Runoff
D 151h day alter campaign treasu-er
appoimmeot (olficeholdef only)
0 July 15
D 8th day belore ele<:lion
D Exceelled 5500 lim«
D Final ~epoll (Ana<:h CIOH-FR)
9 PERIOD Month Day Year Month Day Year
COVERED 01/01/2015 THROUGH 06130/2015
10 ELECTION ELECTION DATE ELECTION TYPE
Month Day Year OPnmary ORunolf 001her
OGeneral ospeaal
11 OFFICE OFFICE HELD (if any) 12 OFFICE SOUGHT (if known}
Austin City Council District 4
GOTOPAGE2
Forms provided b1y Texas Ethics CommiSsiOn www.ethics.state.ocus Vers1on Vl.0.28282
CANDIDATE I OFFICEHOLDER REPORT: FORM CIOH
SUPPORT & TOTALS COVER SHEET PG 2
20133
13 CIOH NAME Casar, Greg 14 Filer ID
15 NOTICE This box is for notice of political contributions accepted or political expenditures made by po l~lcal committees to support the
FROM candidate I officeholder. These expenditures may have been made without the candidate's 01 officeholder's knowledge or
POLITICAL consent. Candidates and officeholders are required to report this information only if they receive notice of such expenditures.
COMMITIEE(S)
OIU!drtionaJPages COMMITIEE TYPE COMMmEE NAME
D GENERAL
COMMmEE ADDRESS
D SPECIFIC
COMMITIEE CAMPAIGN TREASURER NMIE
COMMITTEE CAMPAIGN TREASURER ADDRESS
16 CONTRIBUTION 1. TOTAL POLITICAL CONTRIBUTIONS OF $50 OR LESS (OTHER THAN PLEDGES,
TOTALS LOANS. OR GUARANTEES OF LOANS). UNLESS ITEMIZED $ 0.00
2. TOTAL POLITICAL CONTRIBlJTIONS
(OTHER THAN PLEDGES, lOANS, OR GUARANTEES OF LOANS) $ 35,785.55
----------
EXPENDITURE 3. TOTAL POLITICAl EXPENDITURES OF $100 OR lESS, UNLESS ITEMIZED
$ 0.00
TOTALS
4. TOTAL POLITICAL EXPENOrTUR£5
$ 0.00
----------
CONTRIBUTION 5. TOTAL POLITICAL CONTRIBUTIONS MAINTAINED AS OF THE LAST DAY OF THE
$ 34,706.62
BALANCE REPORTING PERIOD
----------
OUTSTANDING 6. TOTAL PRINCIPAL AMOUNT OF ALL OUTSTANDING LOANS AS OF THE LAST DAY
$ 0.00
LOAN TOTALS OF THE REPORTING PERIOD
17 AFFADAVIT
I swear, or affirm, under penalty of perjury, tha e accompanying report is
true and correct and includes an inlormatio quired to be reported by me
under Title 15, E ction Code.
,.•f.m~-.._ ROBERTO ACOSTA
fJ>,~'·l• Notary Public. State of Ie•os
t~!..~..:~J t.Av Commission Expnes
\~;,
-.,,,,......, ..~;;/
~
April 21. 2019
AFFIX NOTARY STAMP I SEAL ABOVE
Swom to and subscribed before me. by the said Carl:f.&{Og.JD (As~ • this the ___._17-"'---rft_l-}
_ _ _ _ day
of )vl.~ , 20 15 ,to certify which, witness my hand and seal of office.
www.el tcs.state.tx.us Vers10n Vl.0.2B282
SUBTOTALS - C/OH FORM C/OH
COVER SHEET PG 3
3 of 33
18 FILER NAME 19 Filer ID
Casar, G r eg
20 SCHEDULE SUBTOTALS
SUBTOTAL AMOUNT
NAME OF SCHEDULE
1.
0 SCHEDULE Al: MONETARY POLITICAL CONTRIBUTIONS $ 35,785.55
2.
0 SCHEDULE A2: NON-MONETARY (IN-KIND) POLITICAL CONTRIBUTIONS $
3.
0 SCHEDULE B: PLEDGED CONTRIBUTIONS $
4.
0 SCHEDULE E: LOANS $
5.
0 SCHEDULE Fl: POLITICAL EXPENDITURES FROM POLITICAL CONTRIBUTIONS $
6.
0 SCHEDULE F2: UNPAID INCURRED OBLIGATIONS $
7.
D SCHEDULE F3: PURCHASE OF INVESTMENTS FROM POLITICAL CONTRIBUTIONS $
B. D SCHEDULE G: POLITICAL EXPENDITURES FROM PERSONAL FUNDS $
9.
0 SCHEDULE H: PAYMENT FROM POLITICAL CONTRIBUTIONS TO A BUSINESS OF CIOH $
10.
0 SCHEDULE 1: NON-POLITICAL EXPENDITURES FROM POLITICAL CONTRIBUTIONS $ 8,873.37
SCHEDULE K: INTEREST, CREDITS, GAINS, REFUNDS, AND CONTR IBUTIONS RETURNED
11.
0 TO FILER $
Forms provided by Texas EthiCS CommiSSion www.eth1cs.srate.tx.us VersiOn Vl.0.282B<
NON~POLITICAL EXPENDITURES
SCHEDULE I
MADE FROM POLITICAL CONTRIBUTIONS
The Instruction Guide explains how to complete this form.
1 Total pages Schedule 1: 2 FILER NAME FileriD
Sell: 113 Rpt Casar, Greg 13
4 Date 5 Payee name
06/1112015 Central Market
6 Amount($) 7 Payee Address; City; State; Zip
4001 N Lamar Blvd.
168.84
Austin, TX 78756
8 PURPOSE (a) Category (See lns1111C1Jons tor ewnpleO or •=plablo cat"l!ories) (b) Description (See iTJStructions regarding type of lntormolion reqiiiiO(l .)
OF Event Expense food for fundraising event
EXPENDITURE
Date Payee name
06/03/2015 First Data
Amouot(S) Payee Address; City; State; Zip
119.60 5565 Glenridge Connector NE
Atlanta, GA 30342
PURPOSE (a) Category (see Jnstrutllons lor~· ot acr:tplallle categories) (b) Description (see instructions re~arding type or inlorrnalion AOqul~.)
OF Accounting/Banking merchant account fees
EXPENDITURE
Date Payee name
06/3012015 Herring & Panzer, L.L.P.
Amount($) Payee Address: City; State: Zip
1411 West Avenue, Suite 100
7.794.44
Austin, TX 78701
PURPOSE (a) Category (SH ilstnrdlonstor examples of acceplilble ~ies) (b) Description (See JnSUUCiions r<9Af0ing type Ill lntonnalfon requked.)
OF Legal Services legal expenses
EXPENDITURE
Date Payee name
06/1112015 Office Max
AmOUnt($) Payee Address; City; State; Zip
907 W 5th St.
5.49
Austin, TX 78703
PURPOSE (a) category {SoelflstrutllonS fOr txampln Dl &cttptablo colegories) (b) Description {Stt Instructions r~OJdlng type or Jnrorma1ion noqulftd.)
OF Event Expense nametags
EXPENDITURE
arms provt<lecJ o•y 1exas Etn1cs CommiSston www.ethlcs.state.tx.us vers1on Vl.0.28282
Casar Campaign Finance Report 1-15-2016
CANDIDATE I OFFICEHOLDER FORM CIOH
CAMPAIGN FINANCE REPORT COVER SHEET PG 1
1 Filer ID 2 Total pages filed:
The CIOH Instruction Guide explains how to complete this form.
8
3 CANDIDATE/ MS/MRSIMR FIRST Ml OFFICE USE ONLY
OFFICEHOLDER c.:>
Greg
NAME oare Recelwd )>
("_ c::
::.n (/)
NICKNAME LAST SUFFIX
z ::o:::!
~ , z
casar c..n C)
ITI-
0
4 CANDIDATE/ ADDRESS I PO BOX; APT I SUITE#; CITY; ZIP CODE
OFFICEHOLDER
301 West 2nd Street
MAILING
ADDRESS
D Chango at Ad<!.-- Austin, TX 78701 Oats- N '
Dale Imaged
5 CAMPAIGN MS/MRS/MR FIRST Ml
TREASURER
NAME Carlton L.
NICKNAME LAST SUFFIX
Lee Cooke
6 CAMPAIGN STREET ADDRESS (NO PO BOX PLEASE): APT I SUITE#; CITY; STATE; ZIP CODE
TREASURER
ADDRESS 8121 Bee Cave Rd., Ste. 100
(Residence ar BUsiness) Austin, TX 78735
7 CAMPAIGN AREA CODE PHONE NUMBER EXTENSION
TREASURER
PHONE (~12) 917-8008
8 REPORT
TYPE
0 January 15
D 30ih day before election
D Runoff 0 15th day after campaign treasure!
appolntmem (officeholder only)
0 July 15
0 8th day before elec.ian
D !:Xceede~ ~op 1.1f!1it . . 0 fii]~_R!!Jlorl (1\ttach 99.1:1-FR)
':··· -~·-··.~:~~:·i::_)·~.· ~- '; ·. >·;:;,·_~:;· ·-- .. 1
.··_~~:./~-~.''·~
9 PERIOD Month Day Year
COVERED 07/0112015 THROUGH
10 ELECTION· ELECTION DATE ELECTION TYPE
Month Day Yl!ar DPrirnuy ORunoff OO!her
OGeneral DSpecial
11 OFFICE OFFICE HELD [If any) i.2 OFFICE SOUGHT (If known)
Austin City Council
. .. : . .. . ..
...·,:' r. # ~ •••
· • · I ~
GOTOPAGE2
orms proVided bY Texas Ettucs ~,.:omm1ss1on www.ethics.state.tx.us Vers1on Vl.0.34046
CANDIDATE I OFFICEHOLDER REPORT: FORM ClOH
SUPPORT & TOTALS COVER SHEET PG 2
2of8
13 C/OHNAME Casar, Greg J41=iler ID
15 NOTICE This box is for notice of polilieaJ contributions acc;epted or political expenditures made by political committees to support the
FROM candidate I officehOlder. These expencfrtures may have been made wirhout the candidate's or officeholder's knowfedge or
POLITICAL consent. Candidates and officeholders are required to report this information only if they receive notice of such expenditures.
COMMITTEE($)
0 Addido~ Pages COMMITTEE TYPE COMMITTEE NAME
0 GENERAL
COMMITTEE ADDRESS
0 SPECIFIC
COMMITTEE CAMPAIGN TREASURER NAME
COMMITTEE CAMPAIGN TREASURER ADDRESS
16 CONTRIBUTION 1. TOTAL POLITICAL CONTRIBUTIONS OF $50 OR LESS (OTHER THAN PLEDGES,
TOTALS LOANS, OR GUARANTEES OF LOANS), UNLESS ITEMIZED $ 0.00
2. TOTAL POUTICAL CONTRIBUTIONS
(OTHER THAN PLEOGES, L.OANS, OR GUARANTEES OF LOANS) $ 1,180.00
EXPENDITURE 3. TOTAL POLITlCAL EXPENDITURES OF $100 OR LESS, UNLESS ITEMIZED
TOTALS $ 0.00
4. TOTAL POUTlCAL EXPENDmJRES
$ 0.00
CONTRIBU'UON 5. TOTAL POLITICAL CONTRIBUTIONS MAINTAINED AS OF THE LAST DAY OF THE
BALANCE REPORTING PERIOO $ 9,857.62
OUTSTANDING 6. TOTAL PRINCIPAL AMOUNT OF ALL OUTSTANDING LOANS AS OF THE LAST DAY
LOAN TOTALS OF THE REPORTING PERIOD $ 0.00
17 AFFADAVIT
I swear, or affirm, under pen~ry, that the accompanying report is
true and correct ancl includes all · aden required to be reported by me
·~-~
.tt~t:~z~,~ ROBERTO ACOSTA
~*'~i Notary Public·. State ot Texas
\r..··....~/ Comm. Exp11es 04-21·2019 ~-·
..,.o:..,.-" Notary ID 130198533
Si~f Candidate or Officeholder
AFFIX NOTARY STAMP I SEAL ABOVE
,~..,..
SWorn to and subscribed b~fore me, by the said C::"t.~.z.~ ~ this the day
of JANvML-f . 20 ' "
, to certify which, witness my hand and seal of office.
tZ . .A. ..~ LA- ~ A..,.,l;\ tJo-r"~ ~ VliS ~ '--"
Tille or omcer adm101stenng oam
S1gnature of otr1cer aa tunistering Printed name of officer aaminiStenng
orms provil:llil<:l by Texas Etntcs commiSston www.ethics.state.rx.us vers1on Vl.U.;:s.4U4t
SUBTOTALS • CIOH FORM C/OH
COVER SHEET PG 3
3of8
18 FILER NAME 19 Filer ID
Casar, Greg
20 SCHEDULE SUBTOTAlS
SUBTOTAL AMOUNT
NAME OF SCHEDULE
1. lEI SCHEDULE A1: MONETARY POLmCAL CONTRIBUTIONS $ 1,180.00
2. D SCHEDULE A2.: NON-MONETARY (IN-KIND) POLITICAL CONTRIBUTIONS $
3.
D SCHEDULE B: PLEDGED CONTRIBUTIONS $
4.
D SCHEDULE E: LOANS $
5. 0 SCHEDULE F1: POLITICAl EXPENDITURES FROM POLITICAL CONTRIBUTIONS $
6. D SCHEDULE F2: UNPAID INCURRED OBLIGATIONS $
7. D SCHEDULE F3: PURCHASE OF INVESTMENTS FROM POLITICAL CONTRIBUTIONS $
8. D SCHEDULE F4: EXPENDITURES MADE BY CREDIT CARD $
9.
D SCHEDULE G: POLITICAL EXPENDITURES FROM PERSONAL FUNDS $
10.
D SCHEDULE H: PAYMENT FROM POLITICAL CONTRIBUTIONS TO A BUSINESS OF CIOH $
11. 00 SCHEDULE 1: NON-POLITICAl EXPENDITURES FROM POLITICAL CONTRIBUTIONS $ 16,634.56
SCHEDULE K: INTEREST, CREDITS, GAINS. REFUNDS, ANO CONTRIBLmONS RETURNED
12.
D TO FILER $
orms provtaea oy 1exas t:.tntcs CommtsSJOn www.etntcs.state.tx.us VersiOn Vl .O.~
NON-POLITICAL EXPENDITURES SCHEDULE I
MADE FROM POLITICAL CONTRIBUTIONS
The Instruction Guide explains how to complete this form.
1 Total pages Schedule 1: 2 FILERNAME
Casar, Greg ·
13 FileriD
Sch: 212 Rpt: 7/8
4 Date 5 Payee name
08126/2015 Kuhn Hobbs PL!,.C
6 Amoum($) 7 Payee Address; City; State; Zip
15,000.00 3307 Northland Dr.
Ste. 310
Austin, TX 78731
8 PURPOSE (a) Category (Seo lnsvucllons tor examples oiiii:CIIpblble ca~egortes) (b) Description (SOe lnslrucdons regonling type of lnfonna11cn requi.-.1.)
OF Legal Services Legal fees
EXPENDITURE
Date Payee name
07/0112015 Lopez Saltarelli, Amelia
Amount($) Payee Address; City; State: Zip
P. 0. Box 1687
75.00
Rockport, TX 78381
PURPOSE (a) category (See lnS!ruL11cns fllr examples at acceplabfo ClllegOrln) (b) Description (Set! lnstruc:llons regarding type ollnformadon requln!d.)
OF Solicitation/Fundraising Expense Return of contribution
EXPENDITURE I
Date Payee name
OB/0112015 Mclean & Howard LLP
Amount($) Payee Address; City; State; Zip
1,000.00 901 5 Mopac Expy
Bldg 2, Ste..225
Austin, TX 78746
PURPOSE (a) Category (See lnSirueiiMS for eamp~es o1 ataiptable C818g011e$) (b) Description (See inmlctions regarding type at lnfn.-n raquln!d.)
OF Solicitation/Fundraising Expense return Contribution
EXPENDITURE
'
t-orms proVided by Texas Ettltcs commtsston WNW.emtcs;state.tx.us versron Vl.0.3404~
Casar Campaign Finance Report 7-15-2016
CANDIDATE I OFFICEHOLDER FORM CIOH
CAMPAIGN FINANCE REPORT COVER SHEET PG 1
Filer ID 2 Total pages filed:
The C/OH Instruction Guide explains how to complete this form.
3 CANDIDATE/ MS/MRS/MR FIRST
r Ml
OFFICE USE ONLY
5
OFFICEHOLDER
NAME
Greg ~
Dale Re<:eived r..=>
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NICKNAME LAST SUFFIX c.:.::
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Casar
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4 CANDIDATE/ ADDRESS I PO BOX; APT I SUITE#; CITY; ZIP CODE Dille Hand-dotivM!d or Oale P~~ed rn :::_
OFFICEHOLDER
MAILING
301 West 2nd Street
--
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r~u~ .;~
Rec<!iPl#
ADDRESS
D Change ol Address Austin, TX 78701 n
Dale Processed
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r-
Dale Imaged
5 CAMPAIGN MS/MRS/MR FIRST Ml
TREASURER
NAME Carlton L.
................................................................................................................................................................................................................................
NICKNAME LAST SUFFIX
Lee Cooke
6 CAMPAIGN STREET ADDRESS (NO PO BOX PLEASE); APT I SUITE #; CITY; STATE; ZIP CODE
TREASURER
ADDRESS
(R•sl<lence or tiUSNl t SS)
8121 Bee Cave Rd., Ste. 100
Austin, TX 78735
7 CAMPAIGN AREA CODE PHONE NUMBER EXTENSION
TREASURER
PHONE (512) 917-8008
8 REPORT
TYPE
D January 15
D 30th day before election
D Runoff
0 15th day after campaign treasurer
appointment (officehOlder only)
0 July 15
0 8th day before election
D El<ceeded $50Cllimlt
D Final Report (Attach CIOH-FR)
9 PERIOD Month Day Year Month Day Year
COVERED
01101/2016 THROUGH 06/30/2016
10 ELECTION ELECTION DATE ELECTION TYPE
Month Day Year DPrimary O Runoff oother
11108/2016
@General Ospecial
U OFFICE OFFICE HELD (if any} 12 OFFICE SOUGHT (if known)
Austin Crty Council District 4 Austin City Council District 4
GOTOPAGE2
arms prov1aeo 01y 1exas t.tn1cs Comm rssron www.ethics.stale.tx.us Versron Vl.O . ZO~
CANDIDATE I OFFICEHOLDER REPORT: FORM C/OH
SUPPORT & TOTALS COVE~ SHEET PG 2
2015
13 C I OHNAME Casar. Greg 14 Filer ID
15 NOTICE This box is for notice of political contributions accepted or political expenditures made by political comminees to support the
FROM candidate I officeholder. These expenditures may have been made without the candidate's or offiCeholder's knowledge or
POLITICAL consent. Candidates and officeholders are required to report this information only if they receive notice of such expenditures.
COMMITTEE(S)
COMMITTEE TYPE COMMITTEE NAME
0 GENERAL
COMMITTEE ADDRESS
0 SPECIF=IC
COMMITTEE CAMPAIGN TRi;ASURER NAME
COMMITTEE CAMPAIGN TREASURER ADDRESS
16 CONTRIBUTION 1. TOTAL POLITICAL CONTRIBUTIONS OF= $50 OR LESS (OTHER THAN PLEDGES.
TOTALS LOANS, OR GUARANTEES OF LOANS). UNLESS ITEMIZED $ 0.00
2. TOTAL POLITICAL CONTRIBUTIONS
(OTHER THAN PLEDGES. LOANS, OR GUARANTEES OF LOANS) $ 0.00
----------
EXPENDITURE 3. TOTAL POLITICAL EXPENDITURES OF $100 OR LESS, UNLESS ITEMIZED
0.00
TOTALS $
4. TOTAL POLITICAL EXPENDITURES
$ 0.00
---- ------
CONTRIBUTION 5. . TOTAL POLITICAL CONTRIBUTIONS MAINTAINED AS OF THE LAST DAY OF THE
$ 7,210.62
BALANCE REPORTING PERIOD
--OUTSTANDING
- ------- 6. TOTAL PRINCIPAL AMOUNT OF ALL OUTSTANDING LOANS AS OF THE LAST DAY
lOAN TOTALS OF THE REPORTING PERIOD $ 0.00
17 AFFADAVIT
I swear. or affirm, under penalty of perjury, that lhe accompanying report is
true and c ect and includes all information required to be reported by me
under Tit! 1 . Election Code
AFFIX NOTARY STAMP I SEAL ABOVE
www.et 1cs.state.t.x.us
SUBTOTALS • C/OH FORM CJOH
COVER SHEET PG 3
3of5
18 FILER NAME 19 Filer ID
Casar. Greg
20 SCHEDULE SUBTOTALS
SUBTOTAl AMOUNT
NAME OF SCHEDULE
1. 0 SCHEDULE Al: MONETARY POLITICAL CONTRIBUTIONS $
2.
D SCHEDULE A2: NON-MONETARY (IN-KIND) POLITICAL CONTRIBUTIONS $
3. D SCHEDULE B: PLEDGED CONTRIBUTIONS $
4.
D SCHEDULE E: LOANS $
5. D SCHEDULE Fl: POLITICAL EXPENDITURES FROM POLITICAL CONTRIBUTIONS $
6.
D SCHEDULE F2: UNPAID INCURRED OBLIGATIONS $
7. 0 SCHEDULE F3: PURCHASE OF INVESTMENTS FROM POLITICAL CONTRIBUTIONS $
B.
0 SCHEDULE F4: EXPENDITURES MADE BY CREDIT CARD $
9. 0 SCHEDULE G : POLITICAL EXPENDITURES FROM PERSONAl FUNDS $
10.
0 SCHEDUlE H PAYMENT FROM POLITICAL CONTRIBUTIONS TO A BUSINESS OF C/OH $
11.
0 SCHEDULE 1: JIION·POLITICAL EXPENDITURES FROM POLITICAL CONTRIBUTIONS $ 1,647.00
SCHEDULE K: INTEREST, CREDITS, GAINS, REFUNDS, AND CONTRIBUTIONS RETURNED
12.
0 TO FILER $
orms provtaea oy texas l::tntcs commtss•on www.etntcs.state.bcus ver:110n Vl.O.LU;
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Casar Campaign Finance Report 10-11-2016
CANDIDATE I OFFICEHOLDER FORM C/OH
CAMPAIGN FINANCE REPORT COVER SHEET PG 1
1 Filer ID 2 Total pages filed:
The C/OH Instruction Guide explains how to complete this form.
74
3 CANDIDATE/ MS/MRS/MR FIRST Ml OFFICE USE ONLY
OFFICEHOLDER
Greg
NAME Date Rocei~~ed 25
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. . . .. . . . . . . .. . . . . . . . .. . .. . ...... . . . . . . . .. . . .. . . . . .. . . . .. . . . . . . . . . . . . . . . . . . . . .. . . . . . . . ... . . . . . . . . . . . . .. . . . . . . u . . . . . . . . . . . . . .. . . .. . . . . . .. . . . . . . . . . . . . . .. . . . .
NICKNAME LAST SUFFIX =
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Casar rnZ
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4 CANDIDATE/
OFFICEHOLDER
ADDRESS I PO BOX: APT I SUITE # ; CITY; ZIP CODE Dale Ha/\d·deiiVered Gr Dale Postm~ - _....,.
MAILING
P.O. Box 2391 -u ~-<
ADDRESS
D Change ot Address Austin, TX 78768
Rec"'t•
Date Processed
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Dale Imaged
5 CAMPAIGN MS/MRS/MR FIRST Ml
TREASURER
NAME Gustavo
''"''" ' ''"'''"''"noooooo•onooooOOOOOOOo O oooo o oonooou oo ooooOoooooooooooo~ooooo ooO ooooo ooo ooooooooooo.,ooooooo o oo o o oooooooooonoooo oooo oo oooooo o ooouooo•.,••••,.•n•••••oooooooooo""'"'"''''''"'''"'""''""''''
NICKNAME LAST SUFFIX
Garcia
6 CAMPAIGN STREET ADDRESS (NO PO BOX PLEASE); APT I SUITE#; CITY; STATE; ZIP CODE
TREASURER
ADDRESS 7401 Ophelia Dr.
Austin , TX 78752
(Residence or Business)
7 CAMPAIGN AREA CODE PHONE NUMBER EXTENSION
TREASURER
PHONE (512) 452-3857
8 REPORT
TYPE
D January 15
0
30th day llefore election . 0 Runoff
D 15th day after campaign treasurer
appointment (oflk:eholder only) ·
D July 15
D 8th day beirne election
D Exceeded $500 limit
D Final Report (Anach C/OH-FR)
9 PERIOD Month Day Year Month Day Year
COVERED
07/01/2016 THROUGH 09129/2016
10 ELECTION ELECTION DATE tLECTION TYPE
Month Day Year DPrimary ORunoff o other
11108/2016
0General ospecial
11 OFFICE OFFICE HELD (if any) 12 OFFICE SOUGHT (if kf10Wn)
Austin City Council District 4 Austin City Council Place 4
GOTOPAGE2
Forms p rov1aea 0'y 1 exas ttn1cs comm1ss•on www.ettucs.state.tx.vs Vers 1on Vl.0 .10'3t
CANDIDATE I OFFICEHOLDER REPORT: FORM C/OH
SUPPORT & TOTALS COVER SHEET PG 2
2of 74
13 C/OH NAME Casar. Greg 14 Filer ID
15 NOTICE This box is for notice of political conttibutions accepted or political expenditures made by political commirrees to support the
FROM candidate I officeholder. These expenditures may have been made without che candidate's or officeholder's knowledge or
POLITICAL consent. Candidates and officeholders are required to report this information only if they receive notice ot such expenditures.
COMMITTEE($)
D Additional Pages COMMITTEE TYPE COMMITTEE NAME
D GENERAL
COMMITTEE ADDRESS
D SPECIFIC
COMMITTEE CAMPAIGN TREASURER NAME
COMMITTEE CAMPAIGN TREASURER ADDRESS
16 CONTRIBUTION 1. TOTAL POLITICAL CONTRIBUTIONS OF $50 OR LESS (OTHER THAN PLEDGES,
LOANS, OR GUARANTEES OF LOANS), UNLESS ITEMIZED $ 0.00
TOTALS
2. TOTAL POLITICAL CONTRIBUTIONS
(OTHER THAN PLEDGES, LOANS, OR GUARANTEES OF LOANS) $ 34,450.50
----------
EXPENDITURE
TOTALS
3. TOTAL POLITICAL EXPENDITURES OF $100 OR LESS, UNLESS ITEMIZED
$ 114.27
4. TOTAL POLITICAL EXPENDITURES
$ 62,469.63
----------
CONTRIBUTION
BALANCE
5. TOTAL POLITICAL CONTRIBUTIONS MAINTAINED AS OF THE LAST DAY OF THE
REPORTING PERIOD $ 25,038.49
----------
OUTSTANDING
LOAN TOTALS
6. TOTAL PRINCIPAL AMOUNT OF ALL OUTSTANDING LOANS AS OF THE LAST DAY
OF THE REPORTING PERIOD $ 20.00
17 AFFADAVIT
I swear, or affirm. under penalty of perjury. that the accompanying report is
true and correct and includes all information required to be reported by me
• ff"''""'" SUSAN HI>.RR~t lexas
'!:li~~"\ Notorv PuOlic. s.tote .
;~~ My Cornmissron Expues """"~
~ ~~·l
~:;,;r.,,~,\~~
July 23. 201<1
•
L. C:i~
. \date or Officeholder
·~
AFFIX NOTARY STAMP I SEAL ABOVE
Sworn to and subscribed before me, by the said ~v'.t&:t ('A SD4t"' , this the 1(~
.20 \ v . day
of oc=tv'b-«1 to certify which, witne~y hand and seal ot office.
;;;;Jltl.
Sign~f dfficer adm nrstemu
s'-15t~vt ttu.('('"
Printed name at officer admrmstering
I
~oh.,-L... /
Title ot on1cer administering oCJ
orms provided by Texas EthiCS Commtss1on www.ethiCS.state _tJcus Vers1on Vl.0.109E
SUBTOTALS· C/OH FORM C/OH
COVER SHEET PG 3
3ol74
18 FILER NAME 19 Filer ID
Casar, Greg
20 SCHEDULE SUBTOTALS
SUBTOTAL AMOUNT
NAME OF SCHEDULE
1. [8] SCHEDULE Al: MONETARY POLITICAL CONTRIBUTIONS $ 33,831.00
2. [8] SCHEDULE A2: NON-MONETARY (IN-KIND) POLITICAL CONTRIBUTIONS $ 619.50
3. D SCHEDULE B: PLEDGED CONTRIBUTIONS $
4.
0 SCHEDULE E: LOANS $
5. [8] SCHEDULE Fl: POLITICAL EXPENDITURES FROM POUTICAL CONTRIBUTIONS $ 62,469.63
6. 0 SCHEDULE F2: UNPAID INCURRED OBLIGATIONS $
7.
D SCHEDULE F3: PURCHASE OF INVESTMENTS FROM POLITICAL CONTRIBUTIONS $
8. D SCHEDULE F4: EXPENDITURES MADE BY CREDIT CARD $
9. D SCHEDULE G: POLITICAL EXPENDITURES FROM PERSONAL FUNDS $
10. D SCHEDULE H: PAYMENT FROM POLITICAL CONTRIBUTIONS TO A BUSINESS OF C/OH $
11. D SCHEDULE 1: NON-POLITICAL EXPENDITURES FROM POLITICAL CONTRIBUTIONS $
SCHEDULE K: INTEREST. CREDITS. GAINS, REFUNDS. AND CONTRIBUTIONS RETURNED
12. D TO FILER $
orms provl!:led b\y Texas EthiCS Comm1ss1on www.ethics.state.tx.us Vers1on Vl.O.l09€
Casar Campaign Finance Report 10-14-2016
I
I
CORRECTION/AMENDMENT AFFIDAVIT
FOR CANDIDATE/OFFICEHOLDER FORM COR-C/OH
1 F1ler ID (Ethics Commission Filers) Total pages f1led:
OFFICE USE ONLY
37
.....,
3 CANDIDATE/
OFFICEHOLDER
NAME
MS I MRSIMR
NICKNAME
FIRST
Gregorio
lAST
Ml
SUFRX
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-
4 ORIGINAL REPORT
TYPE ~
D
January t5
0
Runoff Other (specify!
~
3
.,<-<
Julyl5 Exceeoed SSOO limil
0~
D 301h d2}' before elect on
0 15th day anor treasurer
appointMent (o~""'oo'der only)
Date Hand·dohvered o r O!£~ostm atk efT1
:::0
D 8 th day ::>etore election
0 Fin_,l rcpott Recotpl II I '·"'
~unt S
~
5 ORIGINAL PERIOD Date Ptocusea
Oay Year tAcnU1 Day Yeor
COVCRED
12 / 07 / 2014 THROUGH 12 / 31 / 2014 Oal e Imaged
6 EXPLANATION OF CORRECTION •
The original report inadvertently did not include Form 2-2-42.
7 AFFIDAVIT
I swear. or affirm. under penalty of perjury. that this corrected
report is true and correct.
Check ONLY if applicable:
Semiannual reports: I swear, o r affirm, that the original report was
made in good faith and without an intent to m islead or to misrepre-
ir~~~~~~~~~~~~~~~ sent the information contained in the report .
.:-~~~~~~t~,..~ SUSAN HARRY
{'[~/'~ Notorv Public. ~tote 01 rerc;;- Other reports: I swear. or affirm, that I am filing this corrected
;.-:.·.~ .. ~~ My commtss1on Expires!-- report not later than the 14th busin ess day after the date I learned
"•::f.;¥,.;:~~-'" July 23. 2019 that the report as originally f ile'\is inaccurate-ef'lncomplete. I swear.
\:;;;;;;;;;;;;:;:;;;;;;i;;;;;;;;;;;;;;;;;;;;;;;;;::;;;~ or affirm. that any error or omiss ion)n'the report as origina lly filed
was made in good faith\ ~/ - /
//\\...---
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:~_.. ····. / '\ /
L£_· . \' , --::..__
Si ~e \f~~ad1r11~ oath Prmted neme of officer administt!ri~g oath ) Tille or officer adm~ng oath
Remember To Attach Any Part Of The Campaign Finance Report Form
Needed To Report And Explain Corrections
Forms vrovided by Texas Ethics Commission www.ethics.state .tx.us Revised 0412712015
Casar Campaign Finance Report 10-31-2016
CANDIDATE I OFFICEHOLDER FORM C/OH
CAMPAIGN FINANCE REPORT COVER SHEET PG 1
Filer iD 2 Total pages filed:
The C/OH Instruction Guide explains how to complete this for m. 11 37
3 CANDIDATE / MS /MRS / MR FIRST Ml OFFICE USE ONLY
OFFICEHOLDER
G reg
NAME Dare Reoehled ,..~
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......................................................................................................................................................... (:_~ )
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NICKNAME LAST SUFFIX
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4 CANDIDATE / ADDR ESS I PO BOX; APT I SUITE #; CITY; ZIP CODE Date Hand-deiverea or Date PosTmarked ,: ~
1 1
OFFICEHOLDER
MAILING
P .O. Box 2391 ......., < :::2
: I I
r~~
RecetpC # 0
ADDRESS 0
D Change ol Address Austin, T X 78 768
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Date ?rocessed ::.?
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Calc Imaged
5 CAMPAIG N MS / MRSI MR FIRST Ml
TREASURER
NAME
6uS\t:tvo
n ooooo o oooooo ooooo ou o ooo o oooo o ooo o oo o o o ooooooooo• o oooo o o o o o oo•o•••·•••· •• •· • • • ••• •••·•~ · •• • ••• •• •• •••,.• • •••• • -- •••••••• • ••·•• •• ••• • • • • • •• •• • • ••••• • • •• • ••• • •••••••••••• • ••• • ••••• • • • •• · ·•• • ·••• • ••• • •·• • • • ••• • •••••••• • ••• 00
• •• • •
NICKNAM E LAST SUFFIX
b.o-< cJ..~
6 CAMPAIGN STREET ADDRESS (NO PO BOX PLEASE); APT I SUITE #; C ITY; STATE; ZIP CODE
TREASURER
ADDRESS
(Res:denc e or aur.inc~!:)
'1 ,01 Ofr"'.t\ \D. Or.
ftMS'q'y\._ . '1'} l <f> l5'Q
7 CAMPAIGN AREA CODE PHONE NUMBER EXTENSION
TREASURER
PHONE E"'\;;l Lfsd-~ ~5}
8 REPORT
TYPE
D January 15
D 30th day befO<e election
D Runoff
D 15th day after campaign treasurer
appointment (offiCeholder only)
D July 15
0 81h day before etecuon
D Exceeded S500 limit
D Final Repor1 (Attach CIOH-FR)
9 PERIOD Month Day Year Month Day Year
COVERED THROUGH
09/3 0/2016 10129/2016
10 ELECTION ELECTION DATE ELECTION TYPE
Month Day Year DPnmary O Runofl O O!her
1 1108/2016
0 Genetal o special
11 OFFICE OFFICE HELD (if any) 12 OFFICE SOUGHT (if known)
A ust in C i ty Council District 4 Austin C ity Council D istrict 4
GOTOPAGE2
orms prov1aea cy 1exas l::lh1cs com m iSSIOn www.ethiCS.state.tx.us VersiOn Vl.0. 1480
CANDIDATE I OFFICEHOLDER REPORT: FORM CIOH
SUPPORT & TOTALS COVER SHEET PG 2
2ofJq
13 C/OH NAME Casar, Greg 14 Filer tO
15 NOTICE This box is for notice of political contributions accepted or political expenditures made by political committees to support the
FROM candidate I officeholder. These expenditures may have been made withouc the candidate's or officeholder's knowledge or
POLITICAL consent. Candidates and officeholders are required to report this information only if they receive notice of such expenditures.
COMMITIEE(S)
O Additional Pages COMMITIEE TYPE COMMITIEE NAME
0 .GENERAL Travis County Democratic Party
COMMmEE ADDRESS
D SPECII'IC P .0. Box 684263
Austin, TX 78768
COMMITIEE CAMPAIGN TREASURER NAME
Harding , Vincent
COMMITIEE CAMPAIGN TREASURER ADDRESS
7204 Hartnell Drive
Austin, TX 78723
16 CONTRIBUTION 1. TOTAL POLITICAL CONTRIBUTIONS OF $50 OR LESS (OTHER THAN PLEDGES,
TOTALS LOANS, OR GUARANTEES OF LOANS), UNLESS ITEMIZED $ 0.00
2. TOTAL POLJnCAL CONTRIBUTIONS
(OTHER THAN PLEDGES, LOANS, OR GUARANTEES OF LOANS} $ 16.857.35
----------
EXPENDITURE
TOTALS
3. TOTAL POLITICAL EXPENDITURES OF $100 OR LESS, UNLESS ITEMIZED
$ 0.00
4. TOTAL POLITICA L EXPENDITURES
$ 30,464.04
----------
CONTRIBUTION 5. TOTAL POLITICAL CONTRIBUTIONS MAINTAINED AS OF THE lAST DAY OF THE
$ 27,274.87
BALANCE REPORTING PERIOD
-- --------
OUTSTANDING 6. TOTAL PRINCIPAL AMOUNT OF ALL OUTSTANDING LOANS AS OF THE LAST DAY
$ 20.00
LOAN TOTALS OF THE REPORTING PER IOD
17 AFFADAVIT
I swear. or affirm, under penalty of perjury, that the accompanying report is
uue and correct d includes all informallon reqUired to be reported by me
under - ;de 15. lion Code.
·"'"~~''::••,,, SUSAN HARRY
~-~··
gR_·' ·Y••,
··~r, Notary Public . Stole of .Texos
~..:. :~1 My Commissron Expues
\~,·,;;·\<~:.-'"
,,,..._.,,, July 23, 2019
AFFIX NOTARY STAMP I SEAL ABOVE
Sworn to a d subscribed beforelrrlJ' by the said _ ___:b;=:.. (. :..:....o:-h--"""""'....,.-.""""'.__
.'J_ _ ____, this the --~--='-\.._.s+
_____ day
of , 20~. to certify which , witne
www.e tcs.state.tx.us VerSIOn 1. .1480
r •
SUBTOTALS - C/OH FORM C/OH
COVER SHEET PG 3
3 of37
18 FILER NAME 19 Filer ID
Casar, Greg
20 SCHEDULE SUBTOTALS
SUBTOTAL AMOUNT
NAME OF SCHEDULE
1. 0
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