Brief in Support of Motion to Dismiss: Sets forth several arguments for why the case should be dismissed. The principle argument is that the Texas money laundering statute does not apply to the election code. The brief argues that the Texas Election Code by and large stands apart from the penal code, where conspiracy and money laundering are found.

The reason that Earle is perverting the law in this way — using the penal code to prosecute alleged election code violations — is because he does not have the power to charge DeLay with election code violations. Only the DA in DeLay’s home county can do that, and he is not pursuing any charges. Therefore, Earle is attempting to use inapplicable statutes — conspiracy and money laundering — to prosecute DeLay. If the court follows the precedents cited in the brief, Earle is unlikely to succeed.

Motion for Change of Venue: Takes the trial out of predominantly liberal Travis County, if granted.

Motion to Recuse: Lists no fewer than 34 separate contributions Judge Bob Perkins has made to Democrats and Democratic groups — his contributions to MoveOn.org have gotten a lot of attention, and rightly so, but far more important to this case are his donations to Texas Partnership PAC, run by former speaker of the Texas House and aviation enthusiast Pete Laney, in 2002. During 2002, Texas Partnership PAC worked in direct opposition to DeLay’s Texans for a Republican Majority PAC. The conflict of interest couldn’t be more clear.