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July 27, 2015

Deborah C. Hiser, Partner


111 Congress Avenue, Suite 1400
Austin, Texas 78701-4093
512.472.5456
512.703.5718 (direct)
512.480.5020 (direct fax)
Deborah.Hiser@huschblackwell.com

Via fax to: (512) 494-8017


Email to: publicrecords@texasattorneygeneral.gov and ken.paxton@texasattorneygeneral.gov
Urgent Response Requested
The Honorable Ken Paxton
Office of the Attorney General
PO Box 12548
Austin, TX 78711-2548
Re: Open Records Request under the Public Information Act Request
Dear General Paxton:
We have been notified by Senator Schwertners office that your office is in possession of a
videotape illegally recorded by BioMax Procurement Services, LLC, now known as the Center
for Medical Progress, at a Planned Parenthood facility in Houston.
Senator Schwertners office, in that communication, clearly states the Senate Health & Human
Services Committee Members and staff have viewed this specific videotape in preparation for a
public hearing that will be held on Wednesday. The communication from Senator Schwertners
office is included below. (See Exhibit A) Because the videotape has already been reviewed by
such Members and staff, it is no longer privileged.
Therefore, in fairness to Planned Parenthood as the subject of the investigation, and pursuant to
the Public Information Act, we are formally requesting of your office an opportunity to review
this video, in its entirety, prior to the scheduled hearing on Wednesday as referenced by Senator
Schwertner.
I also request a timely and quick response to this request. Please call me at (512) 703-5718.
Sincerely,

Deborah Hiser

AUS-6140267-1

Exhibit A
From: Thomas Holloway [mailto:Thomas.Holloway@senate.state.tx.us] 
Sent: Monday, July 27, 2015 2:39 PM
To: Hiser, Deborah
Cc: Robertson, Marilyn
Subject: RE: URGENT RESPONSE REQUESTED
Dear Ms. Hiser:
Our office is in receipt of your letter of July 26, 2015.
Neither the Senate Committee on Health and Human Services nor the Office of Senator Charles
Schwertner are in possession of the video referenced in your letter. However, the video in
question has been obtained by the Texas Attorney General's Office as part of an ongoing
investigation into the activities of Planned Parenthood in Texas. As a matter of legislative
privilege, the members of the Senate Committee on Health and Human Services and their
respective staffs have been granted limited access to review the video in advance of the hearing
on Wednesday, July 29 (see Gov't Code 552.008(b)).
With regard to your request to review the contents of this video, I would respectfully refer you to
the Office of the Attorney General.
Sincerely,
Tom Holloway
Chief of Staff
Senator Charles Schwertner
thomas.holloway@senate.state.tx.us
O: 512-463-0105
M: 512-923-5944

AUS-6140267-1

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