killeen isd attorney not comfortable releasing ron gray file - sensitivity

06/12/2008 18:12 7136232793 HUDGINS LAW FIRM PAGE 02/03 THE HUDGINS LAW FIRM EMAIL: ENORB8TROM®HUOSINS-mw,COM 24 Qreenway Plaza • Surte 2000 • Houston, Texas 77046 Tel 713-623*2550 • Fax 713-623-2793 June 12,2008 VIA FACSIMILE (512^ 819-9707 Joshua A. Schroeder Sneed, Vine & Perry, P.C. 2995 Dawn Drive, Suite D Georgetown, Texas 78628 Re: Cause No. 226628B Phyllis Nairn vx. Kiihen, I.S.D. In the 146* Court of Bell County, Texas Dear Josh: I am in receipt of your recent correspondence concerning production of documents in connection, with the above-referenced case. In this regard, please be advised that the bulk of the materials in my file consist of documents submitted by Mrs. Nairn in connection with her myriad grievances. Beyond that, I will not be producing any attorney-client communications. Mrs. Nairn's personnel file will be produced. As for Mr. Gray's personnel file, 1 am not comfortable producing it in its entirety absent an order of the Court As much as I hate to involve the Court in discovery disputes, given the sensitive nature of the information contained in a District employee's personnel file, and given that some of that information is protected from disclosure by the Texas Education Code, I feel it prudent not to release the file in its entirety unless and until ordered by a Court to do so. I would be willing to submit copies of portions of Mr. Gray's personnel file to the Court under sea] for consideration in camera. In addition, copies of correspondence wim and about Mrs. Nairn will be produced, as will copies of Tom Schatte's presentation to the Board of Trustees and resulting investigation report. Finally, a copy of the transcript of the Board meeting at which Mrs. Nairn's proposed nonrenewal was considered and ultimately accepted will be produced. You should have these documents within the next week. In the meantime, as you arc likely aware your client has suffered a number of defeats in her administrative proceeding since last we spoke. I believe the more pressing question EXHIBIT "Ja_"

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Page 1: Killeen ISD Attorney Not Comfortable Releasing Ron Gray File - Sensitivity

06/12/2008 18:12 7136232793 HUDGINS LAW FIRM PAGE 02/03

THE HUDGINS LAW FIRM

EMAIL: ENORB8TROM®HUOSINS-mw,COM

24 Qreenway Plaza • Surte 2000 • Houston, Texas 77046Tel 713-623*2550 • Fax 713-623-2793

June 12,2008

VIA FACSIMILE (512̂ 819-9707

Joshua A. SchroederSneed, Vine & Perry, P.C.2995 Dawn Drive, Suite DGeorgetown, Texas 78628

Re: Cause No. 226628BPhyllis Nairn vx. Kiihen, I.S.D.In the 146* Court of Bell County, Texas

Dear Josh:

I am in receipt of your recent correspondence concerning production of documents inconnection, with the above-referenced case.

In this regard, please be advised that the bulk of the materials in my file consist ofdocuments submitted by Mrs. Nairn in connection with her myriad grievances. Beyond that, Iwill not be producing any attorney-client communications.

Mrs. Nairn's personnel file will be produced. As for Mr. Gray's personnel file, 1 am notcomfortable producing it in its entirety absent an order of the Court As much as I hate toinvolve the Court in discovery disputes, given the sensitive nature of the information containedin a District employee's personnel file, and given that some of that information is protected fromdisclosure by the Texas Education Code, I feel it prudent not to release the file in its entiretyunless and until ordered by a Court to do so. I would be willing to submit copies of portions ofMr. Gray's personnel file to the Court under sea] for consideration in camera. In addition,copies of correspondence wim and about Mrs. Nairn will be produced, as will copies of TomSchatte's presentation to the Board of Trustees and resulting investigation report. Finally, a copyof the transcript of the Board meeting at which Mrs. Nairn's proposed nonrenewal wasconsidered and ultimately accepted will be produced. You should have these documents withinthe next week.

In the meantime, as you arc likely aware your client has suffered a number of defeats inher administrative proceeding since last we spoke. I believe the more pressing question

EXHIBIT "Ja_"

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