4/14/2016 11:41:35 AM Velva L. Price District Clerk GN-16-000200 Travis County D-1-GN-16-000200 Ruben Tamoz INTHE DISTRICT COURT OF KENT SCHAFFER, COLLIN COUNTY DISTRICT ATTORNEY PROTEM, BRIAN WICE, COLLIN COUNTY DISTRICT ATTORNEY PRO TEM, and NICOLE DEBORDE, COLLIN COUNTY DISTRICT ATTORNEY PRO TEM Plaintiffs, ‘TRAVIS COUNTY, TEXAS: v. KEN PAXTON, ATTORNEY GENERAL OF TEXAS, 53RD (ton cc tt en 2D CU Dan en ee Mar her Defendant. PLAINTIFFS’ ORIGINAL PETITION FOR DECLARATORY RELIEF COME NOW Plaintiffs Collin County District Attorneys Pro ‘Tem, Kent Schaffer, JUDICIAL DISTRICT Brian Wice, and Nicole DeBorde (collectively, “Special Prosecutors” or “Plaintiffs”), and file this, their Original Petition for Declaratory Relief, As their cause of action, Plaintiffs would respectfully show the Court the following: SUMMARY This suit is brought pursuant to TEX. Gov'r Cope § 552.324, challenging an open records letter ruling of the Attorney General (OR2016-00027) and seeking a declaratory judgment that the information at issue is exempt from disclosure under the Texas Public Information Act, TEX. Gov't CODE 552.001 et seq, (the “Act”), asdisclosure would violate a court order, hinder an ongoing criminal prosecution, and negatively affect the privacy and property rights of a third party.t DISCOVERY CONTROLPLAN L Discovery in this case is intended to be conducted under Level 3 of Rule 190.4 of the Texas Rules of Civil Procedure. IL PARTIES 2 Plaintiff Collin County District Attorney Pro Tem Kent Schaffer is an attorney appointed to represent the Collin County District Attorney's Office in matters pending in the 416" Judicial District Court of Collin County, styled The State of Texas v. Warren Kenneth Paxton, Jr. and numbered 416-81913-2015, 416-82148-2015, and 416- 82149-2015, Mt. Schaffer is a resident of Harris County, Texas. 3. Plaintiff Collin County District Attorney Pro Tem Brian Wice is an attorney appointed to represent the Collin County District Attorney's Office in matters pending in the 416" Judicial District Court of Collin County, styled The State of ‘Texas v. Warren Kenneth Paxton, Jr. and numbered 416-81913-2015, 416-82148-2015, and 416-82149-2015. ‘Mr. Wice is a resident of Harris County, Texas. Plaintiff Collin County District Attorney Pro Tem Nicole DeBorde is an attorney appointed to represent the Collin County District Attorney's Office in matters pending in the 416" Judicial District Court of Collin County, styled The State of Texas v. Warren Kenneth Paxton, Jr. and numbered 416-81913-2015, 416-82148-2015, and 416- 82149-2015. Ms. DeBordeis a resident of Harris County, Texas. 5 Defendant Ken Paxton is the Attorney General of the State of Texas. He may be served with process at 300 W. 15th Street, Austin, Texas 78701. He is sued only is his official capacity as Attorney General of the State of Texas, 2I. JURISDICTION AND VENUE 6 This is a suit that secks declaratory relief pursuant to the requirements of the Act. As such, jurisdiction is proper pursuant to Texas Government Code § 552.224. 7. Pursuant to ‘Texas Governinent Code § 552.324, venue is proper in ‘Travis County, Vv. FACTS 8 On October 14, 2015, Special Prosecutor Schaffer received, via email, a request under the Texas Public Information Act from Gromer Jeffers, Jr. of The Dallas Morning News requesting “copies of all records turned over thus far to the defense as part of discovery in the Ken Paxton case.” Exhibit A. 8. On the same day, Schaffer responded to Joffors’ request via email and stated that they would be unable to provide the information requested as it is excepted from disclosure under Tex, Gov'r Copr § 552.108 and requests of this type have already been addressed in Attorney General Opinion OR2015-13456, Exhibit . 10. On October 21, 2015, Special Prosecutor Wice submitted a written request to the Attorney General for an opinion regarding Jeffers’s request for information, asserting the requested information was excepted from disclosure under TEx. Gov'r CopR § 552.108, in addition to being prohibited under the Michael Morton Act. Exhibit B.A copy of this request was provided to the requestor. ct On October 27, 2015, Wice submitted a copy of the request and evidence of when the open records request was received. Exhibit C.1. ‘The Office of the Attorney General issued OR2016-00027 on January 4, 2016, ordering the requested information be released, due to its finding that the district attorney's office, acting by and through the Special Prosecutors failed to comply with the requirements of the Act in seeking an opinion from the Attorney General. Exhibit D. VL ‘CAUSE OF ACTION - DECLARATORY RELIEF 12. Pursuant to Sections 552.324, 552.325, and 552.358(b) and (c) of the Texas Government Code, Plaintiffs petition this Court to render a declaratory judgment that public disclosure of the discovery turned over to Paxton’s defense counsel is not required under the Act. 14. ‘Such disclosure would, hinder ongoing prosecution of the underlying cases, be in direct violation of a court order, and violate the privacy and property rights of Ken Paxton, 15. ‘The information requested is excepted from disclosure under the Act. Section ‘522.108 of the Act provides that “[iJnformation held by a.prosecutor that deals with the detection, investigation, or prosecution of crime is excepted from the requirements of Section 552.021 iff (1) release of the information would interfere with the detection, investigation, or prosecution of crime.” Tex, Gov't Cope §552.108(a)(1). Generally, the release of information pertaining to an open case is presumed to interfere with the criminal investigation. See Houston Chronicle Publ'g Co. v. City of Houston, $31 $.W.2d 177, 184-185 (Tex. Civ. Ap. — Houston [14th Dist] 1975), writ ref'd n.re. per curiam, 536 S.W.2d 559 (Tex. 1976). The information requested by Jefifrs on behalf of The Dallas Morning News concerns the pending prosecution of Paxton and should be excepted from disclosure.16. Even if't is determined that the Special Prosecutors failed to properly request an opinion of the Attorney General on the information requested, the information should be withheld to protect the privacy and property interests of Paxton. Requested information may be withhold when it involves a person's privacy or property interests. TEx. GOv'l CODE § 562.305. When a third party's privacy or property interests are involved, the governmental agency that received the request need not raise this issue in its request for a decision from the Attorney General, but may do so in its petition for declaratory relief. Boeing Co. v. Paxton, 466 S.W 3d 831, 838 (Tex. 2015). Even if the third party's right to privacy is not set out in argument to the Attorney General in requesting an opinion, the confidential information need not automatically be disclosed. Id; Tsx. Gov'r Cove § 552.326(b). ‘The information requested by Jeffers on behalf of The Dallas Morning News necessarily implicates the privacy and property interests of Paxton, including, but not limited to, his right to an impartial trial under the Sixth Amendment to the United States Constitution, Indeed, public disclosure of the discovery in the cases pending against Paxton is prohibited by the existing order of the 416" Judicial District Court of Collin County. ‘The judge presiding over these matters issued a directive to all counsel, under threat of sanction, that no evidence was to be released to the press that has not been presented in open court. Judge Gallagher memorialized this order in writing on January 8, 2016. Exhibit B. Judge Gallagher's order is further bolstered by the Supreme Court's insistence that legal trials are not to be won through the use of the media. Sheppard v. Maxwell, 384 US, 233, 350 (1966) (citing Bridges v. California, 314 US, 252, 271 (1941). a1. Plaintiffs would show that the Attorney General's decision is incorrect and that Plaintiffs should be entitled to withhold all of the information identified as exompt or excepted from disclosure. 18, Plaintiffs have exhausted their remedies set forth under the Act and, thus, Plaintiffs have no recourse under the statute except to seek a declaratory ruling from this Court. vil. NOTICE TOREQUESTOR 1. Pursuant to Section 552.325(b) of the Texas Government Code, the District Attorney Pro Tem has informed, by certified mail, Gromer Jeffers, Jr. of the existence of this suit, his right to intervene or to choose not to participate in the suit, the fact thet this suit is against the Attorney General, and the address and phone number of the Attorney General. See Exhibit F, vIn. RELIEF SOUGHT WHEREFORE, PREMISES CONSIDERED, Plaintiffs pray: (‘That the Defendant be cited to appear and answer herein; (2) That upon trial of the merits of this action, this Court enter declaratory judgment that the information which was the subject of Plaintiffs’ request for an Attorney General opinion, as pled herein, and OR2016-00027, is exempt from disclosure under the ‘Lexas Public Information Act and may be withheld; (3) That Plaintiffs be awarded reasonable attorneys’ fees incurred in bringing this action; (4) ‘That Plaintiffs recover all costs of court; and,() That Plaintiffs have such other and further relief both at law and in equity to which they may show themselves justly entitled. Respectfully submitted, FELDMAN & FELDMAN, P.C. 4sLDavid M. Feldman DAVID M. FELDMAN State Bar No: 06886700 david feldman@feldmanlawpe.com 3355 West Alabama St, Ste. 1220 Houston, Texas 77098 ‘Telephone (713) 986-9471 Facsimile (713) 986-9472 ATTORNEY FOR PLAINTIFFSEXHIBIT AMr. Jeffers, In response to your request: we are unable to provide you with any of the information that you are seeking from us. As you know, the information that you are requesting concems an ongoing criminal investigation and prosecution of Mr. Paxton. The Government Code, @Section 55.108 in particular, provides that Information held by a prosecutor that deals with the investigation or prosecution of crime is excepted from the requirements of disclosure if the release would interfere with said investigation or prosecution. The information you seek may not be turned over since it would, in fact, interfere with our ability to continue to investigate and prosecute this case. We are not seeking an opinion from the Attorney General for the State of Texas since he has already issued an opinion on this very issue. A copy of that opinion is attached. Best regards, On Wed, Oct 14, 2015 at 3:00 PM, Jeffers Jr., Gromer wrote: Dear Mr. Kent Schaffer: Please accept this request under the Texas Public Information Act for copies of all records tured over thus far to the defense as part of discovery in the Ken Paxton case. Please supply these records in electronic format to the extent they exist that way. Ifyou determine that some or all of the informalionis excepted from required disclosure, please request an opinion from the attorney genera'’s office and provide me with a copy of that request for an opinion. | make this request as a reporter for The Dallas Morning News and on its behalf, Please confirm that you have received this email. Thanks, Gromer JeffersRECEIVED JUL ~8 2085 CWVH.BIVSION CRIMINAL DISTRICT ATTORHy Suly 6, 2015 Ms, Ashley D. Foust Assistant Distt Attorney ‘Tarrant County 401 West Belknap, Ninth Floor Fort Worth, Texas 76196-0201 OR201-13456 Re: Request for the autopsy report for a named individual; ME Case no, 1416606 Dear Ms, Four: ‘The Office of the Attorney General has reveived your request for a ruling and assigned your request ID# 577523, Aficr reviewing your argoments end the submitted information, we have determined yout request does not present a novel or complex issue. Thus, we are addressing your claims in ‘memorandum opinion, You claim the submitted information may be withheld fiom public disclosure pursuant to section 552.108(aX!) of the Goverment Code on behalf a law enforcement agency witha law enforcement interest, Further, you infocm this office the law enforcement agency abjects (© the disclosure of the information because it relates to an ongoing criminal case and release would interfere with the case. Thus, we conclude you may withhold the submitted information pursuant to section 552.108(@)(). For more information on the cited exception, please refer to the open government information on our website at Iutps/hvyes. uae. stale bsasfopenmemorulinys.shunk. You ‘may also contact our Open Government Hotline at 1-877-OPENTEX. Enc: Submitted documents Requestor (w/o enclosures) 0ttice Woy LIS, Supin, Texan OEEAE SIRS HasEXHIBIT BBrian W. WicE LAWER ‘THE LYRIG CENTRE 440 LOUISIANA + SUITE 900 HOUSTON, TEXAS 77002-1695 (719) 624-9922 Fax (713) 286-7768 wiedan@aene October 21, 2015 Brantley Starr Office of the Attorney General Deputy Attorney General for Legal Counsel P.O. Box 12548 Austin, Texas 78711-2548 RE: REQUEST FOR ATTORNEY GENERAL'S OPINION IN RESPONSE TO PUBLIC INFORMATION ACT REQUEST FROM DALLAS MORNING NEWS Dear Mr. Starr: The undersigned, along with Kent Schaffer and Nicole DeBorde, are the Collin County District Attorneys Pro Tem [“Special Prosecutors”] in the matter of the State of Texas v. Warren Kenneth Paxton, Jr. On October 14, 2015, Mr. Schaffer received an e-mail, pursuant to the Texas Public Information Act [“TPIA”], from DALLAS MORNING NEWS reporter Gromer Jeffers, seeking “copies of all records turned over this far to the defense as part of discovery in the Ken Paxton case.” That same day, Mr. Schaffer informed Mr. Jeffers via e-mail that the Special Prosecutors were declining his request based on an opinion from your office, No. 577523,' concluding that this material could be withheld from public disclosure pursuant to TEX.GOVT. CODE §552.108(a)(1) because it relates to an ongoing criminal case and release would interfere with the case. Because Mr. Jeffers did not concur with Mr. Schaffer’s conclusion * This opinion, dated July 6. 2015, was in response to the request of Tarrant County Assistant District Attorney Ashley Fourt, who sought your office's opinion on whether her office was obligated to release an autopsy report in a pending criminal matter.Letter to Brantley Starr October 21, 2015 Page 2 that your office’s opinion was dispositive of his TPIA request, he requested that we seek an opinion from your office, in spite of our belief that Mr. Jeffers’ request is devoid of merit.* Accordingly, pursuant to the relevant provisions of the TPIA, the Special Prosecutors hereby ask your office to provide us with an opinion that is responsive to Mr. Jeffers’ TPIA request. You may contact us at the following e-mail addresses: . Kent Schaffer: kentschaffer@gmail.com . Brian Wice: wicelaw@att.net . Nicole DeBorde: nicole@bsdlawfirm.com Thank you for your attention to this matter. ‘ely yours, BWWdje cc: Kent Schaffer Nicole DeBorde Gromer Jeffers * First, the Special Prosecutors believe that Mr. Jeffers’ request, as recounted above, is foreclosed by your office's July 6” opinion. Second, all discovery in criminal eases in Texas is governed by TEX.CODE CRIMPROC. Art. 39.14, which does not contemplate that discovery be disseminated to a third party. Third, the Michael Morton Act, the most recent codification to Art. 39.14,which the State has agreed applies to this case, expressly provides in Section E that, “This subsection prohibits disclosure of provided discovery to any third party.” 2EXHIBIT CBrian W. WicE LAWYER THE LYRIC GENTRE 440 LOUISIANA + SUITE 900 HOUSTON, TEXAS 77002-1698 (71a) 5ea-o922 Fax (719) 286-7768 wcelav@utnee October 27, 2015 Office of the Attorney General Open Records Division P.O. Box 12548 Austin, Texas 78711-2548 RE: REQUEST FOR ATTORNEY GENERAL'S OPINION IN RESPONSE TO PUBLIC INFORMATION ACT REQUEST FROM DALLAS MORNING NEWS AG OPEN Recorbs Act ID No. 592938 Dear Sir or Madam: In response to your facsimile dated October 26, 2015, I am enclosing a copy of an e-mail from Gromer Jeffers of the Dallas Morning News to Collin County District Attorney Pro Tem Kent Schaffer that represents “a signed statement or sufficient evidence of [the] date [Mr. Schaffer] received the open records act request” from Mr. Jeffers and Mr. Schaffer's response thereto. ‘Thank you for your attention to this matter. Sincerely yours, /s/ Brian W. Wice BRIAN W. WICE BWW:dje cc: Kent Schaffer Nicole DeBorde Gromer JeffersEXHIBIT DJanuary 4, 2016 Mr. Brian W. Wice Attorney Pro Tem for the Collin County District Attorney's Office 440 Louisiana, Suite 900 Houston, Texas 77002-1635 0R2016-00027 Dear Mr. Wice: You ask whether certain information is subject to required public disclosure. under the Public Information Act (the “Act”), chapter 552 of the Government Code. Your request was assigned ID# 592938. ‘The Collin County District Attomey’s Office (the “district attorney's office”), which you represent as Attorney Pro Tem, received a request for “all records tumed over thus far to the defense as part of discovery in [a specified] case.” You claim the requested information is excepted from disclosure under section 552.108 of the Government Code.' We have considered the exception you claim, ‘We must address the district attomey’s office’s obligations under section 552.301 of the Government Code when requesting a decision from this office under the Act. Pursuant to section 552.301(e), a governmental body is required to submit to this office within fifteen business days of receiving an open records request: (1) written comments stating the reasons why the claimed exceptions apply that would allow the information to be withheld, (2) a copy of the written request for information, (3) a signed statement or ‘Although you alo raise article 39.14 of the Code of Criminal Procedure, we note article 39.14 _governs the discovery of information andthe testimony of witnesses in criminal proceedings. See Crim. Pro. Code at 39.14. Article 39-14 does not expressly make information confidential fr purposes of the Act. See ‘Open Records Decision Nos. 658 at 4 (1998) (statutory confidentiality under section 552.101 mustbe expres, and confidentiality requirement will not be implied from stamtory structure), 478 at 2 (1987) (statutory ‘confidentiality requires express language making certain information confidential or stating that information stall not be released to public; see also Open Records Decision No. 575 at 2 (1990) (explicitly stating, discovery privileges ate not covered by statulory predecessor o section 352.101). Auer TEXAS 7871-2548 TeL(512) 463-2100 we: WwW, TEXASATTORNEY GENERAL COY ‘Pal nly Opp EgloMr. Brian W. Wice - Page 2 sufficient evidence showing the date the governmental body received the written request, and (4) a copy of the specific information requested or representative samples, labeled to indicate which exceptions apply to which parts of the documents. Gov’ t Code § 552.301(e). You state, and provide documentation showing, the district attorney's office received the request for information on October 14, 2015. You requested a ruling from this office on October 21, 2015. On October 26, 2015, this office sent you an acknowledgment of your request for a ruling, specifying in that acknowledgment the requirements of section 552,301(€), On October 27,2015, in response to that acknowledgment, the district attorney's office submitted only a copy of the written request for information. As of the date of this letter, you have not submitted for our review written comments stating the reasons why the ‘claimed exception applies or a copy or representative sample of the specific information requested. Accordingly, we find the district attorney's office failed to comply with the requirements of section 552.301 of the Government Code, Pursuant to section 552.302 of the Government Code, a governmental body’s failure to comply with section 552.301 results in the legal presumption the requested information is public and must be released unless a compelling reason exists to withhold the information ‘from disclosure. See id. § 552.302; Simmons v. Kuzmich, 166 S.W 34342, 350 (Tex. App— Fort Worth 2005, no pet.); Hancock v. State Bd. of Ins., 797 S.W.2d 379, 381-82 (Tex. App.—Austin 1990, no writ) (governmental body must make compelling demonstration to ‘overcome presumption of openness pursuant to statutory predecessor to section 552,302); see also Open Records Decision No. 630 (1994). Generally, a compelling reason to withhold information exists where some other source of law makes the information confidential or where third party interests are at stake. Open Records Decision No. 150 at 2 (1977). Although you assert the requested information is excepted under section 552.108 of the Government Code, this section is discretionary in nature, It serves only to protect a governmental body's interests and may be waived, and, as such, it does not constitute a ‘compelling reason to withhold information for purposes of section 552.302. See Simmons, 166 S.W.3d at 350 (section 552.108 is not compelling reason to withhold information under section 552.302); Open Recortis Decision Nos. 665 at 2n.5 (2000) (discretionary exceptions generally), 663 at 5 (1999) (waiver of discretionary exceptions), 177 at 3 (1977) (statutory predecessor to section 552.108 subject to waiver). Thus, the requested information may not bbe withheld under section 552. 108 of the Government Code. Furthermore, because you have not submitted a copy or representative sample of the requested information to this office for our review, we have no basis for finding the requested information is otherwise confidential by law. Consequently, we have no choice but to order the requested information released pursuant to section 552.302. If you believe the information is confidential and may not awfully be released, you must challenge this ruling in court pursuant to section 552.324 of the Government Code. ‘This letter ruling is limited to the particular information at issue in this request and limited to the facts as presented to us; therefore, this ruling must not be relied upon as a previous determination regarding any other information or any other circumstances.Mr. Brian W. Wice - Page 3 This ruling triggers important deadlines regarding the rights and responsibilities of the governmental body and of the requestor. For more information concerning those rights and responsibilities, please visit our website at htip:/www texasattornevgeneral.gov/open/ ‘orl_tuling_info.shtml, or call the Office of the Attomey General's Open Government Hotline, toll free, at (877) 673-6839. Questions concerning the allowable charges for providing public information under the Act may be directed to the Office of the Attomey General, toll free, at (888) 672-6787. Sincerely, Kenny Moreland Assistant Attorney General ‘Open Records Division KIM/sdk Ref: ID# 592938 RequestorEXHIBIT ENO. 416-81913-2015 NO. 416-82148-2015 NO. 416-82149-2015 THE STATE OF TEXAS (INTHE DISTRICT COURT x vs. X= COLLIN COUNTY, TEXAS x WARREN KENNETH PAXTON, JR. 416™ JUDICIAL DISTRICT RDE! |ARDING DISCOVERY AND MEDIA DISSEMINATION ‘The Court previously instructed counsel for the State and the Defense that (1) the Michael Morton Act shall apply to these proceedings for all matters involving discovery pursuant to Art. 39.14 of the Code of Criminal Procedure and (2) the parties are to make no extrajudicial statements or otherwise engage in conduct calculated to, in effect, try these proceedings in the media in violation of Rule 3.07 of the Texas Disciplinary Rules of Professional Conduct. The Court believes it best to memorialize the same in writing, The parties have agreed to the entry of this order. Accordingly, itis therefore: ORDERED that the Michael Morton Act shall apply to these proceedings, and ORDERED that counsel for either party in these causes shall not make any extrajudicial statements that they expect to be disseminated by means of public communication if the lawyer knows or reasonably should know that it will have a substantial likelihood of materially prejudicing these proceedings, except as, provided by Rule 3.07(c) of Texas Disciplinary Rules of Professional Conduct, IT IS FURTHER ORDERED that lawyers shall not counsel or assist another person to make such statements. This order also applies equally to the dissemination ofany discovery exchanged by the parties which has not been formally admitted into evidence in these proceedings. SIGNED this 8" day of January, 2016, JUDGE WRESIDINGEXHIBIT FCcnusten.Fe.owan Cris Feldmancfeldmeniawpecon Davo Puoaean® David-eldman@feldmaniswpzom “ard aed Lab nt ope La Trend eagle orcoue, Scuuiasan Lore HOPrER& ADEISTHON ‘Mr. Gromer Jeffers The Dallas Morning News 508 Young St. Dallas Texas 75202 | | FELDMAN & FELDMAN 9955 WESTALABAMASS,, SUITE1220 HOUSTON, TEXAS77098 ‘TELEPHONE: 713-986-0471 FACSIMILE: 713-986-9472 ‘www feldmanlawpe.com January 14,2016 Ccurasm sonar ‘Chwasin Gennvretdinaniawpe.com DinonaNonnsssersavie DindeaSulvanitelamantawpecoe, SiuansonSnrr no SoatnonSntkanaalup om Re: Collin County District Attorneys Pro Tem challenge to Attorney General Letter Opinion 0R2016-00027 Dear Mr, Jeffers: Please be advised the undersigned has been appointed Attorney Pro Tem by Judge Gallagher. Today, on behalf of Collin County District Attorneys Pro’Tem, Kent Schaffer, Brian Wice, and Nicole DeBorde, a declaratory judgment suit was filed against the Attorney General, challenging the Attorney General's ruling related to your requests for “all records turned over thus far to the defense as part of discovery in the Ken Paxton case.” A copy of the suit is attached. A cause number has not yet been assigned to the suit. ‘When the cause number is assigned, Iwill send that information to you Pursuant to Section 552.325(b) of the Government Code, you are also advised of the following: © Pursuantto Section 552.326(@), you have theright to intervene in thissuit. You may also choose not to participate in the suit. © Thissuit is against the Texas Attorney General in Travis County district court.‘Mr, Gromer Jeffers January 14, 2016 Page 2 of 2 * The Texas Attorney General's physical address is: Office of the Attorney General 300 W. 15th Street Austin, TX78701 * The Texas Attorney General’s mailing address is: Office of the Attorney General PO Box 12548 Austin, TX 78711-2548 + The Texas Attorney General's phone number is 512-463-2100, Sincerely, Abntest Lon David Feldman ae oe. Ban Col, ttre for Ken Paxton emai Kent Sbatr a ned Nicole DeBorde (vis email) Brian Wice (via email)Cause Noman (row cusea use aver SIviHD KENTSCHAEE EM, AND NICOLE DE BORDR, DIS ‘Acivil ase ifort soe must be compel ad sbi when rp pti o apa i ed tn ment plion fer mifienon oman for enorme yaw cn. The norton shuld othe best ee CIVIL CASE INFORMATION SHEET R,COLLAN COUT Te eS Al Asean nae on ar i rs be ater oe a fs nao) 2 new iil fay I, probate, o Besson 1. Gone! arti fr periea coplting eve inforwation sheet | Mane parts in eae Petsn realy compictng sit acy Pu Paine ime em Pinson Pro PnPatener iki said femanGtdoeninnscom it WD Ase Keuftafit.ColinCamy Danks | Floste ase Tetpne ‘Alu {BSE Walsham Sus Suite 1220 Wie, Colin Coun Diss sabes Mawes ms Adlon aces in Cold Supper Case: cipisiawzp re ‘Necle Delos. Colin Comiy Dat, : Hono T TR ase ‘tomer Eo Tsar coda Pere Sie: Stee No Defensa) Respite aor aa s700 Frat Far adit ce peo an sot Paporant Rr ln ne Ce et mts) Git Fey aw = z Pest daiwa Acton Cont Injaiy or Dang eal Papert MareigeKeationthip (uote V2) Deon Tavasi Baton Tine Doms nat afrconest fcooamesA feonmction Condesa Pca Marge void | [lMatinton Cody pebiCeat Eetrtion Eprsniin Dione IModifenion—Oiter FrowtMisepesenation | stlpetce louie Tite ‘Elwin crises “Tile Toe Detonnet Jacsming Hrepessto Try Tite Edvcaiien Fnfieceren Moca oy ne Pepe esemiy Medi! ae Beeps corsa) Jovi Proteins Eibuppon Orr bil for Void sido een Ca ; ae Mater One anitytaw | | Parca Cua Reto Eire Fp Pte ris Tiksipeonadisis sis eet icn jdt Nii “gent rmination ea Rovevosie Bian Corus [Ct Proceton is Product ssn Fortre ine Charge ical Surpor Elvriortabesscome— | Epiinive Orr Siodyer Vian — penne eb reine Removal of isis | foes! Preting oni ny or Demag: er ot in pea Acces fe Hotes PaerioPareses Triage ine Ce mation 9 ares Tibia DhawyeDicpine Rigs Dlother Parent jess procedure or red Wapulabie nap ylecy more han JReatnion pole Tesiany Herwinaion ‘Conneion JecriierStck = JWorter® Componsaion de Viens Toros terface Josie Employ orig hemes: Goer Desemoey a EBinretecnt py demon Te Probate & Menta Heal fax Appia PrataTana ao (Gurion a rt Dulingueney TEdepenient Admission Journey Miooe her independent Admission Mental eal nhs ivan te vache lew Elem ston ppl fm Musial o Juste Court Fists Frgudgmanc Tens Pcie Oder Reoshae Bsceusvaion era Renna Orde nein Hanover[totais som emo ele ea fil Taw eae ing donages of any ind, pales, cows, expen, pejdgnent lex, and aor Tet the $100,000 ed noasronsay ct [poe dann as cn no low $200,000 hut ot mote ina $1,00,00 Glove $1.099008 Reve6% SUPPLEMENTARY PROBATE CASE INFORMATION SHEET ) ‘Travis Coonry Pronate CouRTNO. 1 Cause No. C-1-PB-. - This sheet is a supplement to the Civil Case Information Sheet required by Texas Rule of Civil Procedure 78a, Both the Civil Case Information Sheet and this supplementary sheet should be completed whenever an original petition or application is filed in this Court. Except for the case style, there's no duplication between the two sheets. If you are e-ling the original petition or application, an information sheet cannot be the lead document. “The information should be the best avalable at the time of fling, understanding thatthe information may change before triel, This Information does nol constitute a discovery request, response, oF supplementation, and is not admissibe at tial 1. Ca Proposed Ward's name" or “Paintis) v. ‘style. Please indicat the corec case ste. For example, “Estate of Decadent's name,” “Guardlanshp ofthe Parson and Esta of list all partes; allach additonal page as nocessary (an estate or guardianship canna be a party; i's the executor, administaor, or guardian who has the capacity to sue or be sued), Defendant(s)” it “Paint v. Defendant 2. Related case(s). Has this case been previously filed, or is it related toa case previously filed in this court orin another court? Oo a BaNo Yes, inthis court. Cause No. C-1-PB. (Cynon case is quasiansip ater 1102, wil be same couse number) (Crom case is quatiansp ater chal 48 now causo number & new se) Yes, in another cour: Court: Cause No, ‘tach page(s) as needed. Kyou are afaching page(s) vith information about addon related cases, check here: [J 3, Indicate case type (check only one case type, but see addtional box if ling a guardianship application) independent Administration ‘All Other Estate Procoodings. ‘Ancillary Cases (new cause #) CT Probate Ltrs Testamentary (ledependent) ga. + ca Cy Later w/ copy of wi rt 2120 Ci indop. Admin, Wil Annexed Al~ 3000) Cindep. Admin. wth Heship ea 0) C Foreign wal Later nop) put + 302) Dependent Administration C1 Probate Muntment of Tite f+ sn C1 Murimont Tite more than 4 years after date of death i +318 Mune copy of wil 22 Ca Hetship No Administration +a C1 smal Estate aa rou +300) [1 Dependent Adminstration (all dependent atiinstatons: executor, wi arene, wi heship, or wih hetshpffolon) 0-00) 1 Temporary Administration (PAT » 2019) {Ci Foreign Wit Letters (dependent) Fat = 508) ‘Guardianship / 1301 Trust ~ Adult, C1 Foreign Wit Recording only (Pa +384) 111.252 Wil Deposit or Application to Produce: Wit ew +304) (D7 1955 Custodial Account (es7 +3014) 1 1361 Sate of Property of Minor PsP +338) ‘Guardianship! 1301 Trust= Minor Miscellaneous Estate Applications Tins econ laid oan rdopendent Admistaben (aces eaur-ardered severance) (mai) (Analy action lated to Dependent ‘Admnsraten (nebes curtordored fevarance) POA si) (Clancy action relates to Guadanshi of an Adult rues cout eee soverace) (Pm 311) Ant action related to Guarani of Mor (nchices courtrdered Severance) (pa +36) Clnetary acon atin iis cout becase ase isa party (eludes coutardete severance) (031 {his is a guardianship appicaton, answer Ul ‘ype in the boxes below {is the applicant's attorney certified? [] Yes ‘An atlomey representing a guardianship applicant must be certified by the State Bar of ‘Texas for having successful completed a four-hour course of stu in quardians iplaw. he following question and check the case Ono (11151 Application to Open Safety Deposit Box (poe +2109) 117 152 Emergency Intervention funeral, bute, ental) (P+ 201) [1153 Application for Access to intestale's Account information @F +202) 1 Guarsip Ad Person ony re +303) Di ouaresship Adu state onty 2 «325 Ci euara stip adut Per & Estate pes +302 Ci ovare stip ad Temporary r+ 027 C1 1301 or rT Trust Acute +2010) 1282 Appointment of Non-Resident Guarlan~ Adult a+ 308) 011383 incapactates Spouse; Community Property (015 Supplementary Probate Cour Cover_Sht_ 0 1D Guard ship Minor Person ony a « 2047) 1D Guard ship Minor Estate only rue 30) C1 Guard'ship Minor Per & Estate Pus + 2028) T Guard'ship Minor Temporary (Pur +3105) TD 1201 Trust Minor (eam + 2106) C1252 Appointment of Non-Resident Guardian Minor Gra «3107, er2015 4102 iiwvestigations & Chapter 48 ‘Ey Court initiated 1102 gor +s028) chapter 48 Protection ye. 3120) All Other Cases” Ty Trust action not related ta estate or ‘guardianship (P3T +3018) ff reated to estate or guardianship, see “ancy cases" above) 11 1354 Recetvership of Minor or Incapacitated (Rn + 3120) 17 1356 Contracts of Minors (PoM + 121)