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43aAppendix D2. Gingles II: Political Cohesion of Hispanic Votersa. Methodologies: Homogeneous, EcologicalRegression, and Ecological InferenceDr. Engstrom applied three accepted methods ofstatistical analysis <strong>to</strong> Irving’s election data 13 -homogeneousprecinct analysis (“HPA”), ecological regression (“ER”),and ecological inference (“EI”)-<strong>to</strong> determine whe<strong>the</strong>rHispanic voters vote cohesively. (Pl.’s Ex. 25, at 4.) HPAand ER were both approved in Gingles and have beenutilized by numerous courts in Voting Rights Act cases.Gingles, 478 U.S. at 53 n. 20, 106 S.Ct. 2752. Recently,EI has been used <strong>to</strong> supplement evidence derived fromHPA and ER. See e.g., United States v. Village of PortChester, No. 06 Civ. 15173(SCR), 2008 WL 190502, at *11(S.D.N.Y. Jan. 17, 2008); United States v. City of Euclid,580 F.Supp.2d 584, 596 (N.D.Ohio 2008).HPA simply reports <strong>the</strong> percentage of <strong>the</strong> votesreceived by a candidate withing <strong>the</strong> precincts in whicha particular group constitutes over 90% of <strong>the</strong> peoplereceiving ballots. (Id. at 5.) There are no homogenousHispanic precincts in any of <strong>the</strong>se elections in Irving, so13. Both Dr. Engstrom and Dr. Alford utilized SSRV data,prepared by Mr. Ely based on precinct level election returns andlists of people who received ballots provided by <strong>the</strong> Dallas CountyDepartment of <strong>Election</strong>s, <strong>to</strong> analyze <strong>the</strong> candidate preferences ofHispanic and non-Hispanic voters. (Trial Tr. vol. 1, 200, Feb. 17.)Spanish surname matching is <strong>the</strong> norm for this type of analysis,and in Dr. Engstrom’s opinion it is <strong>the</strong> best measure of <strong>the</strong> Hispanicvoters in each voting precinct. (Id. at 201-02; PL’s Ex. 25, at 4.)

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