3/20/2025 11:17 AM Marilyn Burgess - District Clerk Harris County Envelope No. 98683562 By: Michael Robbins Filed: 3/20/2025 11:17 AM
CAUSE NO.: 1767513 1767514 1881218 1881219 § § § § §
v. STEVEN F. HOTZE
IN THE DISTRICT COURT OF HARRIS COUNTY, TEXAS
s D ist ric t C ler k
THE STATE OF TEXAS
177th JUDICIAL DISTRICT
DEFENDANT STEVEN F. HOTZE’S MOTION TO DISMISS FOR DISCOVERY ABUSE TO THE HONORABLE EMILY MUNOZ DETOTO:
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For years, the Harris County District Attorney’s Office has trampled on Dr. Hotze’s
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rights. Because Dr. Hotze opposed her in elections and publicly stood for conservative values,
In this Motion to Dismiss, Dr. Hotze requests relief from Ogg’s abuse
ar
motivated prosecutions.
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former Harris County District Attorney Kim Ogg targeted Dr. Hotze by engaging in politically
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of the discovery process and her failure to produce documents in violation of this Court’s orders
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and Texas Code of Criminal Procedure Article 39.14. I. Background
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In 2020, in his capacity as president of Liberty Center for God & Country (“Liberty”),
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Dr. Hotze was investigating vote fraud through a group of independent contractors hired by
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Liberty. One of the independent contractors, Mark Aguirre, (“Aguirre”), was involved in an
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automobile accident with David Lopez (“Lopez”). No one was injured in the accident and Dr. Hotze was not present. The vote fraud investigation uncovered information related to vote fraud in, among other things, the ballot by mail process, i.e., deceased individuals voting by mail. The information related to vote fraud was presented to the Harris County District Attorney’s Office (“DA’s Office”). The DA’s Office chose not to investigate. Page 1 of 12