Supreme Court Filing Henry vs Cox

No 15-0993_______________________________________

IN THE SUPREME COURT OF TEXAS_______________________________________

THE HONORABLE MARK HENRY COUNTY JUDGE

OF GALVESTON COUNTY

Petitioner

THE HONORABLE LONNIE COX

Respondent____________________________________________________

On Petition for Review from the First Court of Appealsat Houston Texas

_______________________________________________________________

PETITIONERrsquoS EMERGENCY MOTION FOR EXPEDITEDCONSIDERATION (BY 9 AM TOMORROW WEDNESDAY

JANUARY 6) OF EMERGENCY MOTION TO STAY COURT OFAPPEALSrsquo MANDATE

_______________________________________________________________

TO THE HONORABLE SUPREME COURT OF TEXAS

Petitioner the Honorable Mark Henry County Judge of Galveston County

files this Emergency Motion for Expedited Consideration (By 9 AM Wednesday

January 6) of Emergency Motion to Stay Court of Appealsrsquo Mandate and would

show the Court as follows

Background

1 On December 22 2015 the First Court of Appeals affirmed the trial

courtrsquos temporary injunction in the underlying case and the denial of Petitionerrsquos

FILED15-0993152016 35023 PMtex-8465518SUPREME COURT OF TEXASBLAKE A HAWTHORNE CLERK

plea to the jurisdiction Henry v Cox --- SW3d ---- No 01-15-00583-CV (Dec

22 2015)1 Justice Harvey Brown concurred in part and dissented in part2 Justice

Brownrsquos dissent implicates issues concerning the trial courtrsquos subject matter

jurisdiction

2 On December 22 2015 the First Court of Appeals also issued its

mandate with the opinion and judgment3 The issuance of the mandate caused the

court of appealsrsquo judgment to take effect immediately for a trial on a permanent

injunction TEX R APP P 186 511(b) The court of appeals issued its mandate

instantaneously even though the dissenting opinion on its face triggers this Courtrsquos

appellate jurisdiction TEX GOVrsquoT CODE sect 22225(c)

3 Petitioner desires to file a petition for review with this Court to seek

review of the court of appealsrsquo judgment and opinion Because the court of

appeals already issued its mandate a permanent injunction is certain to issue

before the partiesrsquo briefing in this Court can be completed and before any decision

by this Court can be rendered invoking potential mootness issues

1 The court of appeals issued a corrected opinion the next day on December 23 2015 Thecorrected majority opinion dated December 23 2015 is attached to Petitionerrsquos EmergencyMotion at Stay the Court of Appealsrsquo Mandate at Tab A2 Justice Brownrsquos concurring and dissenting opinion is attached to Petitionerrsquos EmergencyMotion at Stay the Court of Appealsrsquo Mandate at Tab B3 The mandate is attached to Petitionerrsquos Emergency Motion at Stay the Court of AppealsrsquoMandate at Tab C

4 As a result on December 23 2015 Petitioner filed an Emergency

Motion to Stay the Court of Appealsrsquo Mandate with this Court Petitioner asked

the Court for relief on an emergency basis by January 11 2016 because that is

when the trial on the permanent injunction was set

Updated Information

5 On January 4 the trial court issued a notice setting a hearing for

tomorrow Wednesday January 6 2016 at 1030 am and required all motions to

be considered be filed today by 1000 am (Tab A)

6 Today January 5 RespondentPlaintiff Judge Lonnie Cox filed a

Motion for Contempt against Petitioner and his trial counsel for not complying

with the temporary injunction that was stayed by the underlying appeal and

potentially resulting in jail without bail (Tab B) see TEX R APP P 291(b) TEX

CIV PRAC amp REM CODE sect 6001(b)(4) 51014(a)(8) (b) TEX R CIV P 692

Requested Relief

7 As a result Petitioner respectfully requests the Court to grant his

Emergency Motion for Stay the Court of Appealsrsquo Mandate on an emergency

expedited basis by 900 am tomorrow Wednesday January 6 2016 and to stay

all proceedings in the trial court so that Petitioner may seek review in this Court of

the court of appealsrsquo judgment and opinion by filing a petition for review See TEX

R APP P 181(a) Without this requested emergency relief Petitioner will be

effectively denied the right to seek further review in this Court

Prayer for Relief

WHEREFORE PREMISES CONSIDERED Judge Henry respectfully

requests the Court to grant this Emergency Motion for Expedited Consideration

and to further grant his Emergency Motion for Stay of the Court of Appealsrsquo

Mandate on an emergency expedited basis by 900 am tomorrow Wednesday

January 6 2016 staying all proceedings in the trial court so that Petitioner may

seek review of the court of appealsrsquo judgment and opinion in this Court by filing a

petition for review Judge Henry further prays for all other relief to which he may

be justly entitled

Respectfully submitted

BEIRNE MAYNARD amp PARSONS LLP

s N Terry Adams Jr

Edward L FriedmanState Bar No 07462950efriedmanbakerlawcomBAKER amp HOSTETLER LLP811 Main 401 Suite 6111Houston Texas 77002Telephone (713) 751-1600Fax (713) 751-1717

N Terry Adams JrState Bar No 00874010tadamsbmpllpcomJoseph M NixonState Bar No 15244800jnixonbmpllpcomJames E ldquoTreyrdquo Trainor IIIState Bar No 24042052ttrainorbmpllpcom

Nicholas D SteppState Bar No 24077701nsteppbmpllpcomBEIRNE MAYNARD amp PARSONS LLP1300 Post Oak Blvd 25th FloorHouston Texas 77056Telephone (713) 623-0887Fax (713) 960-1527

Counsel for PetitionerThe Honorable Mark Henry

County Judge of Galveston County

CERTIFICATE OF CONFERENCE

I hereby certify that I have conferred with Mark Stevens counsel for theHonorable Lonnie Cox on January 5 2016 regarding this Motion and he indicatedthat Respondent is opposed to it being granted

s Nicholas D Stepp

Nicholas D Stepp

CERTIFICATE OF SERVICE

I hereby certify that I have complied with the Texas Rules of AppellateProcedure and the Local Rules of this Court and that the foregoing EmergencyMotion for Expedited Consideration of the Emergency Motion for Stay of theCourt of Appealsrsquo mandate has been electronically filed and served on all counselof record below in accordance with these Rules on this the 5th day of January2016

Mark W StevensPO Box 8118Galveston Texas 77553markwandstevsbcglobalnet

Counsel for Respondent

s N Terry Adams Jr

N Terry Adams Jr

No15CV0583

THE HON LONNIE COX IN THE 56th JUDICIAL V THE HON MARK HENRY COUNTY JUDGE OF GALVESTON COUNTY THE HON KENNEHT ldquoKENrdquo CLARK THE HON RYAN DENNARD DISTRICT COURT OF THE HON STEPHEN HOLMES THE HON JOSEPH GIUSTI ALL IN THEIR OFFICIAL CAPACITIES ONLY AND GALVESTON COUNTY TEXAS GALVESTON CO TEXAS

MOTION FOR CONTEMPT UNDER TRCP 692

TO THE HONORABLE JUDGE OF SAID COURT NOW COMES The Hon Lonnie Cox Plaintiff and movant herein and

under Tex R CivP 692 requests that the honorable judge presiding issue either

show cause orders or attachments commanding that The Hon Mark A Henry

and Joseph Nixon Esq appear before this Court and show cause why they should

not be held in contempt In support movant Cox would show the following

1 On July 6 2015 this court entered a temporary injunction (attached) after

having read the text of the same in open court and in the presence of

Defendant Mark A Henry his counsel Edward Friedman and other persons

named below At that time the injunction became binding under TRCP 683

on Respondent Henry his ldquoofficers agents servants and employees and

attorneys and those persons in active concert or participation with tdhem

who receive actual notice of the order by personal service or otherwiserdquo

2 The order of injunction was appealed on July 6 2015 in Case Number 01-

15mdash00583-CV

Filed 152016 72038 AMJOHN D KINARD - District Clerk

Galveston County TexasEnvelope No 8450016

By Shailja Dixit152016 90925 AM

3 On July 7 2015 Respondent Henry acting through attorney Edward

Friedman petitioned the Court of Appeals in 01-15-00583-CV for a stay of

the injunction That request was denied per order of the Court of Appeals on

July 8 2015 On December 22 2015 the Court of Appeals issued an

opinion and judgment affirming the temporary injunction and issued

mandate

4 In the interval between July 6 and July 14 2015 it appeared that Respondent

Henry and the County were preparing to obey the order For instance Ms

Bonnie Quiroga was invited by HR director Peri Bluemer to fill out

paperwork to receive payments

5 However on July 14 2015 Counsel Joseph Nixon entered this case by

means of a letter attached hereto which constituted direct and inexcusable

defiance of this Courtrsquos Temporary injunction In that letter Mr Nixon

declared in substance that the interlocutory appeal ldquosuspendedrdquo the

temporary injunction That assertion was incorrect as a matter of law and

upon information and belief was known by counsel Nixon to be a

misstatement of the law The governing provisions are Texas Rules of

Appellate Procedure 292 293 and 294 which do NOT suspend or nullify

an injunction but which merely place enforcement power with the appellate

6 In his letter of July 14 2015 Mr Nixon went on to state in substance that

Ms Quiroga was not a county employee would not receive any pay or

facilities (eg phone county email office)

7 Following Mr Nixonrsquos letter of July 14 2015 Respondent and those acting

in concert with him abruptly changed course As per Mr Nixonrsquos letter of

July 14 Ms Quiroga was denied pay and has not been paid a salary or any

other compensation since that date [Ms Quiroga has been able to draw

retirement an entitlement which is beyond any pretended authority of denial

by Respondent Henry] On or about July 16 Mr Nixon or those acting in

concert directly instructed the County Auditor Mr Kevin Walsh that

Bonnie Quiroga was not to be paid

8 On one or more occasions after July 6 and July 14 2015 the door to the

Administratorrsquos Office on the 4th

9 On one or more occasions after July 6 2015 and subsequent upon

information and belief Mark A Henry informed County facilities and

Information technology (ldquoITrdquo) personnel to absent themselves from the

County Justice Center so that requests of either Bonnie Quiroga or any of the

trial judges to provide Ms Quiroga with phone email or other facilities

would not be acted on

Floor of the Galveston County Justice

Center has been locked ie the locks have been changed It should be

noted that the space was unlocked only recently ie after the issuance of the

Court of Appealsrsquo opinion on December 22 2015

10 On one or more occasions after July 6 2015 Respondent Henry or those

acting in concert did not circulate a copy of the temporary injunction as

ordered therein but instead advised county employees by various means

that Ms Quiroga was not a county employee of any kind and that her

directives and requests were to be disregarded See eg the memorandum

of Mark Henry Galveston County Judge to Kevin Walsh Galveston County

Treasurer dated July 16 2015 In that memo Judge Henry referred

contemptuously to the temporary injunction as ldquoancillary orders from

District Court and claimed wrongly that those orders were ldquosuspendedrdquo

11 The temporary injunction of July 6 2015 further ordered that Justice

Administration employees not be fired or otherwise reassigned In

disobedience of that Order and in an attempt to destroy the subject matter of

this litigation and thus evade the jurisdiction of the Court of Appeals and this

Court on or about August 23 2015 Justice Administration employees

Monica Gracia Roger Morrison Clint Purcell and LaTressa DuPuis and

possibly others were ldquoinvitedrdquo to a conference with HR Director Peri

Bluemer The substance of the conference was to inform those workers that

the Justice Administration Department was being administratively

reconfigured and that as of the beginning of the fiscal year (October 1) there

would be one less position than presently authorized Those employees in

some cases were ldquoofferedrdquo the option of transferring to other county

positions (eg in the roads or traffic division) and were told in substance by

Ms Bluemer that two commissionersmdashnot namedmdashwere ldquoconfidentrdquo that

the lesser pay of the new positions could be adjusted to meet their current

salaries with Justice Administration

12 MsBluemer reports directly to County Judge Mark A Henry

13 The obvious import of the August 2015 meetings with Ms Bluemer was that

if the employees did not promptly resign from Justice Administration and

accept employment in other capacities they might be without a job as of

October 1 2015

14 The above scheme would have had two immediate effects First in direct

violation of the Temporary Injunction of July 6 2015 it would reassign

most or all of Justice Administration employees and effectively abolish

Department of Justice Administration

15 The second effectmdashlater appreciated by one justice on the Court of

Appealsmdashwas that all of the subject Justice Administration Employees

would become ldquoat willrdquo employees at the pleasure of Mark A Henry a

status which could be used to secured their cooperation as witnesses in this

or other proceedingsmdashon pain of losing their jobs if they incurred the

displeasure of County Judge Mark A Henry

16 The substance of the meetings with Peri Bluemer are described in the

attached affidavits of Clint Purcell Monica Gracia and The Hon Susan

Criss former judge of the 212th

17 The interviews with Peri Bluemer described above were the subject of an

emergency Petition for Mandamus or Prohibition in Case No 01-15-00797-

CV In Re Lonnie Cox When Respondent Henry asked for more time in

which to file a response Justice Jennings of the Court of Appeals

emphatically refused that extension explaining

District Court who attended with and on

behalf of Ms LaTressa Dupuis

ldquoThe allegations presented in the petition and supporting affidavits are serious See eg TEX Loc GOVrsquoT CODE ANN Sec 151004 (Vernon 2008)(ldquoThe commissioners court or a member of the court may not attempt to influence the appointment of any person to an employee position authorized by the court under this subchapterrdquo) TEX PENAL CODE ANN Sec 3605 (felony offense of ldquoTampering with Witnessrdquo) 36006 (felony offense of ldquoObstruction or Retaliationrdquo) 3902 (offense of ldquoAbuse of Official Capaictyrdquo))Vernon 2011) 3903 (offense of ldquoOfficial Oppressionrdquo)(Vernon Supp 2014)rdquo

Respondent Henry and Others relented from their plan immediately following that

action but retain the pretended ability in the future

18 As of this date an ldquoexecutiverdquo session was scheduled for Monday January

4 between the Commissioners and their ostensible counsel prsesumably

Joseph Nixon A public hearing is scheduled for 130 pm on Tuesday

January 5 at which ldquosettlementrdquo of this case and funding are supposedly to

be discussed

19 Such belated pretense at ldquocompliancerdquo does not purge the contempt or solve

the underlying problem On at least two occasionsmdashthe interval of July 6

and July 14 and the current interval of December 22 to he presentmdash

Resondent Henry and those acting in concert with him have feigned

compliance only to reverse course when the immediate threat of sanctions

had been avoided Movant Cox maintains that they will do so in the future

ie this is a situation capable of repetition and almost certain to be repeated

in the absence of firm and decisive action by this Couet

Movant Cox prays that a show cause order or order of attachment be issued

whereby The Hon Mark A Henry and Mr Joseh Nixon Esq are to appear before

the Court and show cause why they should not be held in contempt for

disobedience of the Temporary Injunction issued by this Court on July 6 2015

Prayer

Respectfully submitted s Mark W Stevens Mark W Stevens

TBN 19184300 P Box 8118

Galveston Texas 77553 4097656306

Fax 4097656459 Email markwandstevsbcglobalnet

Counsel for The Hon Lonnie Cox of the 56th

Judicial District Court

Verification--Unsworn Declaration Per TCPampRC 132001

State of Texas Of Mark W Stevens

County of Galveston

1 My name is Mark W Stevens I am counsel of record for The Hon Lonnie Cox in Case No 15CV0583 appeal case No 01-15-00583-CV and No 01-15-00797-CV I am above the age of 21 years (born May 7 1949) and am competent in all respects to make this oath

2 My office address is PO Box 8118 Galveston Texas My bar card number is 19184300 I have prepared and read the foregoing pleading All statements of fact therein are based upon my personal knowledge and are true and correct I am counsel for Judge Cox familiar with the events in this case since and including June 9 2015 and in the related appellate cases

3 This statement is submitted under the provisions of TCPampRC 132001 subject to penalty of perjury

4 Executed in Galveston County State of Texas on the 4th

____Mark W Stevens_______________________

Day of January 2016

Mark W Stevens TBN 19184300

Note A signed original of this instrument is in the file of Mark W Stevens

The foregoing was efiled and e-mailed PDF to Mr Edward Friedman on January 5 2016 to Mr Edward Friedman at

Certificate of Service

efriedmanbakerlawcom and also to James P Allison (jallisonallison-basscom) Terry Adams Jr at the firm of Beirne Maynard Parsons LLP (tadamsbmpllpcom) and Joseph E Trey Trainor at ttrainorbmpllpcom An additional copy of this instrument has been served via email to Mr Joseph M Nixon at the firm of Bierne Maynard amp Parsons (jnixonbpmllpcom) The Justice Administration Department has been requested to forward a copy of this Petition to the Hon Sharolyn Wood

s Mark W Stevens

List of Attachments and Attachments Follow

Temporary Injunction

Attachments

Letter of July 14 2015

Memorandum of Kevin Walsh

Affidavit of Monica Gracia

Affidavit of Clint Purcell

Affidavit of Susan Criss

J Jennings Order of 92115 in No 01-15-00797-CV

JOHN 0 KINARD CLERKDISIC1 COUftT

trlLmh(i~1W JUL 0 6 ~01

Cause No 15CV0583 ~~~~~ijIu~~ BY_

The Hon Lonnie Cox sect In the District Courts of Local Administrative Judge Galveston Co sect

VS sect Galveston County Texas

The Hon Mark Henry sect

County Judge Galveston Co sect 56th Judicial District

ORDER GRANTING TEMPORARY INJUNCTION

On the 19th day of June 2015 came on to be heard the motion for contempt and the request for

a temporary injunction filed by The Hon Lonnie Cox Judge of the 56th Judicial District Court of

Galveston Texas and Local Administrative Judge for Galveston County againstThe Hon Mark Henry

County Judge Galveston County Texas in the 405th District Court This hearing was set in the

Temporary Restraining Order signed on June 9 2015

All parties appeared and announced ready With the Supreme Court denial of Respondent

Henrys motion to stay the case proceeded

Preliminary motions filed by Respondent Henry were heard Respondent Henrys Plea to the

Jurisdiction was denied Respondent Henrys Plea in Abatement was denied Respondent Henrys ~

Motion to Dismiss was considered well taken and after consulting with the attorneys for both parties

this case was transferred to the 56th Judicial District Court of Galveston County Texas by agreement

The attorneys agreed to proceed on the application for temporary injunction and postpone for

later hearing the motion for contempt Exhibits were admitted The Rule was invoked as limited by the

agreement of the parties and ruling of the Court The case was recessed at request of the pa rties until

Monday June 222015

Testimony was presented on june 22 and june23 The Temporary Restraining Order Signed in

this case was extended for an additional fourteen days per the decree signed in this cause Closing

arguments were presented on June 25th bull At the close of arguments the Court announcedthat the

temporary injunction was granted A hearing to consider the injunction order to be signed was set

Petitioner Cox is entitled to a writ of temporary injunction under the principals of equity and the

statutes of Texas relating to injunctions Respondent Henry intentionally interfered with the

r15-Cv-0583 DCORDER Order

1 i~iilllllllllllill I~

i bull

independence of the Galveston County judiciary and the ability of the Galveston County judiciary to

perform its judicial functions The Court rules

bull that Petitioner Cox has the probable right to recover relief in his suit that Respondent

Henry may not eliminate and attempt to control the replacement of the administrator

for the courts in Galveston County and then manipulate employment terms and

applicants to replace the administrator position to eliminate suitable applicants

bull that Petitioner Cox and the courts of Galveston County are irreparably injured by the

acts committed by Respondent Henry and will be irreparably injured by further acts to

interfere with the administrative ability of the courts to perform their judicial functions

bull that the last peaceable status quo should be restored pending final trial in the case and

bull that if not enjoined Respondent Henry will continue to deny administrative support for

the Galveston County courts further interfering with the independence of the

Galveston County judiciary and the ability of the Galveston County judiciary to perform

its judicial functions

From the evident presented the Court finds

Galveston County created an administrative department to serve the administrative needs of its

courts and to assist county government in court related projects Fourteen years ago the judges

selected Bonnie Quiroga as the second director of Judicial Administration and such selection was

approved by Commissioners Court The testimony was that Ms Quiroga had been employed by

Galveston County for thirty years at the time she was terminated by Respondent Henry on July 24 2014

so was well known by the other employees and elected officials

The director of this hybrid judicial-governmental administrative department called Justice

Administration reported to the County Judge for the county government related duties and to the Local

Administrative Judge for the judicial administrative duties The principal duties of Justice Administration

are judicial administration This department had a Director and other employees supervised by the

Director Offices for Judicial Administration are located in proximity to the Galveston County courts in

the Galveston Justice Center The other employees duties are judicial in nature The Director reported

daily to the Local Administrative Judge The Director also reported to the County Judge for the

government related projects

On July 24 2014 County Judge Mark Henry terminated the employment of the Director of

Judicial Administration from both her governmental related responsibilities as weB as her duties to the

Galveston County judiciary Respondent Henry did not consult with the judiciary nor did he advise the

judiciary that he intended to terminate the Director of Judicial Administrations duties performed for the

Galveston County Courts Petitioner Cox disputes that grounds existed to terminative Ms Quiroga

By an Order on September 242014 the Hon Lonnie Cox local Administration Judge signed an

order clearly stating the position of the Local Administrative Judge and ordering that the termination of

the Galveston County Justice Administrator was void and ordered the attempt to hire a new justice

administrator to cease No motion to set aside this order has been filed The September 24 2014

order has not been set aside The order is attached as Exhibit A

The Court finds that Petitioner Cox has shown his probable right to recover by Respondent

Henry intentionally disregarding Judge Coxs September 24th order and by Respondent Henrys actions

to force his hand-picked candidates as the judiciarys chief administrative officer Respondent Henry

placed his HR employee Peri Bluemer in charge of choosing the replacement Director of Justice

Administration In her testimony Ms Bluemer demonstrated a lack of knowledge about courts

administrative duties of the courts and the nature of trust and confidence necessary in any person

holding this sensitive court position

The Court finds that Petitioner Cox will show his probable right to recover as Respondent

Henrys HR employee used standards she designed to limit the consideration to only three applicants

eliminating applicants familiar with the Galveston County courts and attorneys in good standing with the

State Bar while including a wholly unacceptable applicant who could not meet the standards of integrity

necessary in such a sensitive position due to addiction to drugs and whose law license had been

suspended by the State Bar

On short notice the HR employee unilaterally set 3D-minute interviews of each of the three

allowed applicants during court hours while courts were in jury trials emailing the judges with

instructions as to when the judges could appear for the already scheduled interviews

TheHR employee acknowledged that the three finalists were her choice and their interviews

were set without checking with the court coordinators to ensure that the judges trial schedules would

allow their attendance at the interviews During the testimony of the HR employee she did not state

that the judges would have been able to select the new director from the three chosen applicants only

I r bull1

that they would be allowed to interview the three finalists for 30 minutes each if the judges had

appeared at the interviews she set

The Court finds this qualification and interview process was designed to orchestrate the

selection of the replacement administrator for the courts without an open application and interview

process and without the advice or consent of the judiciary This justice administration answerable only

to the county judge would improperly undermine the independence of the judiciary

The Court finds that Petitioner Cox will show his probable right to recover as the Galveston

judiciary sought support of its position on the selection of a judicial administrator With no chief judicial

administrative officer for the Galveston courts for 60 days and without meaningful inclusion in the

process to select a successor Petitioner Cox sought assistance of the Office of Court Administration to

obtain an opinion from the Attorney Generals Office as guidance for the issues involved in terminating

and hiring court administrative employees

In response Respondent Henry hired a litigation attorney to bring a mandamus action in the

appellate courts attacking Judge Coxs September 24th order informing the Attorney Generals Office of

this litigation to terminate the request for an opinion on the growing dispute as to the rights of the judiciary -=-=--shy

When the mandamus request was denied in April 2015 the Galveston County courts had been

without the administrative director since July 24 20~

The Court finds that Petitioner Cox has shown his probable right to recover when additional

requests to restore the necessary judicial administrative official resulted in Commissioner Court

workshops about a new position not the hiring of an employee to perform the judicial duties which

position continued to be vacant

the Court finds that Petitioner Cox has shown his probable right to recover as Respondent

Henry continued to disregard Judge Coxs September 24th order yet proposed a new position

Petitioner Coxs testimony was that the salary of the proposed new position would eliminate

candidates with the qualifications for the supervisory judicial administrator position Petitioner Coxs

position is that by June 2015 Respondent Henry abandoned his plan to force a hand-picked candidate

as the judiciarys chief administrative officer yet used the ability to set the salary for the new position

at a sufficiently low salary to continue to control the hiring process

Respondent Henrys staff member Tyler Drummond was assigned to determine the salary for

the new judicial administrator Mr Drummond graduated from a Vermont law school two years ago

and did not demonstrate knowledge about courts administrative duties of the courts and court

administrators He had prior experience working for the Vermont legislature

The Court finds that Petitioner Cox has shown his probable right to recover by Mr Drummond

setting a low salary level for the judicial administration supervisor without any expertise in court

administrator salaries without using a unbiased approach in his attempt to substantiate the salary level

for the new judicial administrator supervisor position He performed his salary search without

including the salaries from other area counties and without input from the Galveston judiciary or the

judiciary in any of his comparative counties

The Court finds that Petitioner Cox has shown his probable right to recover as Mr Drummonds

lack of knowledge of Texas and counties in Texas demonstrates his lack of qualifications to

independently establish a salary by which a candidate with sufficient qualifications for the position could

be hired

The Court finds that Petitioner Cox has shown his probable right to recover as Respondent

Henrys staff employee used standards he designmiddoted without sufficient expertise to establish an

appropriate salary range for such a position

The Court finds that Petitioner Cox has shown his probable right to recover as the Drummond

salary survey process was arbitrary and designed to orchestrate the salary of the replacement

administrator for the courts at the lowest possible level improperly undermining the independence of

the judiciary

After ten months without a judicial administrator for the Galveston courts Judge Cox as Local

Administrative Judge issued an order on June 82015 titled Order to Effectuate Enforcement of Order

of September 242014 returning Bonnie Quiroga the former Director of Judicial Administration to her

former judicial duties The June 8 order is Exhibit B A time line submitted by Petitioner is attached as

Exhibit C

On June 5 2015 Respondent Henry had been advised of this action by the judges and advised

Ms Quiroga would be returned to work

The Court further finds that Petitioner Cox has shown his probable right to recover as

Respondent Henrys attempts to force his will as to employment of the judicial administrator included

the attempt to intimidate the Galveston judges by including filing complaints with the Judicial Conduct

Commission as part of the Agenda for June 9 and June 13 Commissioners Court meetings

The Court finds that Petitioner Cox has demonstrated the irreparable injury if a temporary

injunction is not issued as shown by the conduct of Respondent Henry who after keeping the position

vacant for over eleven months has attempted to stymie the effort of the judges to restore a judicial

administrator by further actions of

bull setting emergency Commissioners Court meetings for Tuesday June 92015 and then

Saturday June 13 2015 to terminate the Justice Administration department and to

implement a new judicial administrator system with the director to be paid the disputed

Drummond salary

bull by including filing complaints with the Judicial Conduct Commission as part of the Agenda

for June 9 and June 13 Commissioners Court meetings

bull changing the lock on the door of the office of the Director of Justice Administration on or

about Friday June 5 2015 and again after the Galveston County Sheriff opened the changed

bull attempting to exclude Bonnie Quiroga from the office of Director of Judicial Administration

by seeking to have the Galveston County Sheriff arrest Ms Quiroga for trespass and by

seeking to have the Galveston County District Attorney bring criminal trespass charges

against Ms Quiroga

bull denying telephone office space computer service and email access to Bonnie Quiroga

bull denying payment to Ms Quiroga by refusing to process payment requests

bull sending emails to Galveston County departments heads to disregard her requests or

directives she might issue as judicial administrator for the Galveston County courts and

bull on June 23 2015 during the testimony of this temporary injunction hearing having Deputy

Clint Purcell of Justice Administration contacted to tell him his position was eliminated

After these actions by Respondent Henry Petitioner Cox filed this suit and obtained a

Temporary Restraining Order on June 92015 and a temporary injunction hearing setting for June 19

2015 Respondent Henry was advised of these actions and was advised Ms Quiroga would be returned

to work for the judges

injunction is not issued as shown by the conduct of Respondent Henry who attempted to stymie the

effort of the judges to restore a judicial administrator by holding an emergency Commissioners Court

meeting on June 13 2015 to create a new judicial administrator position at the salary level Respondent

Henry knew was at a salary level the judiciary considered arbitrarily low to attract a suitable candidate

Petitioner Coxs position is that the judiciary in Galveston County can only obtain the services of

a judicial administrator by returning to the last peaceable status quo before the actions of Respondent

Henry to control the selection of the person to hold this position which improperly undermines the

independence of the judiciary

It is therefore ORDERED ADJUDGED and DECREED that Respondent Mark Henry County Judge

of Galveston County his agents servants and representatives and all those acting in concert with him

shall restore the employment of the Justice Administration Dir~ctor Bonnie Quiroga as an employee of

Galveston County under the same terms judicial administrative organization and salary scale of

employment as employed on July 232014 to perform all administrative duties serving the courts of

Galveston County as performed onJuly 23 2014 which employment shall be supervised by the

Galveston County local Administrative Judge This injunction does not include Justice Administration or

its Director performing any duties relating to the law library pretrial release or recovering costs

It is further ORDERED ADJUDGED and DECREED that Respondent Mark Henry County Judge of

Galveston County his agents servants and representatives and all those acting in concert with him

shall instanter perform all necessary actions to carry out the reinstatement of Bonnie Quiroga to her

positon as Galveston County Justice Administrator including but not limited to

a issuing to Ms Quiroga a key to her office in the Justice Center

b directing IT to provide a computer and access to Galveston County Employee e-mail and other

systems necessary for the performance of her job duties

c providing Ms Quiroga with a phone for her office

d directing Human Resources to allow Ms Quiroga to complete all paperwork necessary for her

to be reinstated effective June 82015 as a full time employee and

e- directing the Treasurer to reinstate effective June 8 2015 and pay by the issuance of the ~

appropriate check or direct deposit to Ms Quiroga her same salary as was paid prior to July 24 20141t is (

further ORDERED ADJUDGED and DECREED that Respondent Mark Henry County Judge of Galveston

County his agents servants and representatives and all those acting in concert with him shall restore

the employment ofthe Justice Administration employee Officer Clint Purcell as an employee of Justice

Administration under the same terms administrative organization and salary scale of employment as

employed on June 19 2015 to perform all administrative duties serving the courts of Galveston County

as performed on June 19 2015 which employment shall be supervised by the Galveston County

Administrative Judge and as directed by the Director of Justice Administration

Galveston County his agents servants and representatives and all those acting in concert with him are

hereby enjoined from

1 Taking any action on the matters

(a) relating to application by county and district court judges for authority to appoint

administrative employees for the courts other than in compliance with this temporary

injunction

(b) relating to justice administrator other than in compliance with this temporary

injunction

(c) relating to Galveston County staff and agents regarding Bonnie Quiroga other than in

compliance with this temporary injunction

(d) relating to Galveston County facilities used by Galveston County courts court staff and

administrative staff other than in compliance with this temporary injunction and

(e) relating to applications to appoint court administrative employees other than in

These are the matters contained in agenda items No 31 (e) (h) Il (p) and (r) originally posted for

special meetings of June 9 and June 13 2015which was the subject of the June 9th TRO

Pvt laquo(tV 2 ~g enpoundrance to the Galveston County Justice Center by Justice Administration personnel

including Bonnie Quiroga

3 Preventing or impeding in any way the provision of and the use of computer telephone

and utility services to Justice Administration personnel including Bonnie Quiroga

4 Preventing or impeding in any way the provision of and the use of county equipment and

furnishings necessary to Justice Administration personnel including Bonnie Quiroga to perform their

administrative duties

4 Instructing any Galveston County employees to disregard directives instructions or requests

of Justice Administration including Bonnie Quiroga to perform the duties of Justice Administration

5 Appointing or employing any person other than Bonnie Quiroga to perform the duties of

Director of Justice Administration as directed by the Hon Lonnie Cox Administrative Judge of Galveston

County

6 Reassigning or relocating any employee who was an employee of Justice Administration on

July 23 2014 including but not limited to Bonnie Quiroga Monica Gracia and Deputy Clint Purcell

7 Taking any action to prevent or impede access by Justice Administration personnel including

Bonnie QUiroga Monica Graciaand Deputy Clint Purcell to the offices occupied by Justice

Administration on July 23 2014

shall restore Justice Administration under the same terms judicial administrative organization and

salary scale of employment as existed on July 232014 so that Justice Administration may perform all

administrative duties serving the courts of Galveston County as performed on July 23 2014 which

duties shall be supervised by the Galveston County Administrative Judge

It is further ORDERED that Respondent Mark Henry immediately provide written notice by copy

of this Order to each County Commissioner and all County Department Heads and employees under the

supervision of Galveston County Commissioners Court This injunction does not include Justice

Administration performing any duties relating to the law library pretrial or recovering costs

This case is set for trial on January 11 2016 the date agreed to by the attorneys for both

parties A docket control order will be issued

Bond for this temporary injunction is set at $100 Finding that Petitioner Cox has previously

posted bond in the amount of $100 such amount shall be posted as bond for this injunction

Disobedience of this Order is subject to the penalties provided by Rule 692 Texas Rules of Civil

Procedure

On the approval of the bond all writs are to issue

Signed ~ if I zo t5 -cr 1- 1 m

EX PARTE sect IN~-~ HONORABLE MARK HENRY sect GALVESTON COUN1Y TEXAS

AND GALVESTON COUNTY sect 56TH IUDICIAL DISTRICT

COMMISSIONERS COURT sect

On this the 2tdaYOf Sept~ber 2014 the Administrative Judge of the Galveston

County District CollItS considered the actions of the Honorable Mark Henry and the Galveston

County Commissioners Court in tenninating the employment of the Galveston County Justice

Administrator on or about July 24 2014 in proceeding to post the position for employment of a

new justice administrator and in proceeding to interview candidates to fill the position The

authority to appoint end tenninate court personnel lies with the courts no~ the county judge nor the

commissioners court and the county judges termination of the justice administrator and proposed

selection of a replacement violates the separation of powers doctrine and inmnges on the courts

inherent powers These actions also violate Local Government Code Sec 151004 which prohibits

the county judge and commissioners court from attempting to influence the appointment ofa person

to a position authorized by the commissioners court for the department of another district county Of

precinct officer in the county

It is therefore ORDERED AND DECREED that the actions of the county judge and

commissioners court of terminating the employment ofthe Galveston County Justice Administrator

was a void act without legal authority and is hereby NULLIFIED and set aside Further that the

county judge and commissioners court are ordered to cease and desist the process of attempting to

hire a new justice administrator

EXPARTE~HENRY sect AND GALVESTON COUNTY COJvfMISSIONERS COURT

sect 56th JUDICIAL DISTRICT

ORDER TO EFFECTUATE ENFORCEMENT OF ORDER OF SEPTEMBER 24 2014

iEfeitremembered that on the 24th day of September 2014 an Order was issued

by the Administrative Judge of the Galveston County District Courts nulljfYing and

setting aside the illegal and void act by the County Judge andor the Commissioners

Court oftenninating the employment of the Galveston County Justice Administrator

Bonnie Quiroga To carry out the reinstatement of Ms Quiroga to her position effective

June 8 2015 the Court issues the following Order to effectuate the enforcement of said

Order of September 24 2014

The County Judge andor the Commissioners Court and those individuals agents

or departments acting under their direction will immediately perfonn all necessary

actions to carry out the reinstatement of Bonnie Quiroga to her position as Galveston

County Justice Administrator including but not limited to

bull Issuing to Ms Quiroga a key to her office in the Justice Center

IIgt Directing IT to provide a computer and access to Galveston County employee e-

mail and other systems necessary for the perfonnance ofher job duties

I Providing Ms Quiroga with a phone for her office

Directing Human Resources to allow her to complete all paperwork necessary for

her to be reinstated as a full time employee and

bull Directing the Treasurer to reinstate and pay by the issuance of the appropriate

check or directdeposit to Ms Quiroga her same salary as was paid prior to her

unlawful tennination

SIGNED on this the 8th day ofJune 2015

-b---cot

LONNIE COX 56th JUDICIAL DISTRICT

ADMINISTRATIVE DISTRICT JUDGE

July 242014 Sept 52014 Sept 22 2014 Sept 242014 Sept 24 2014 Oct 62014 Oct 7 f014 Feb4ZOI5 Feb 202015 April 14 2015

May 122015 June 5 2015 June 8 2015 June 92015 June 9 2015 June 132015 June 192015

BQ fired Email toMB Request for AG Opinion LC Issues Order Finalist Interview Invitation to Meet with Commissioners Court

Mandamus and Stay Filed Mandamus Denied Rehearing for Mandamus Filed Mandamus Denied 1st Compromise Meeting 2nd Compromise Meeting Judges Send Notice LC Issue Order Effectuating Enforcement File TRO and Contempt ofCourt Commissioners Court Meeting 2nd Commissioners Court Meeting Hearing Temporary Injunction

BEIRN MAYNARD amp PARSONS LLP

1300 POST OAK BOULEVARD

SUITE 2500

HOUSTON TEXAS 77056-3000

-JOSEPH M NIXON (713) 623-0887 DRECT DAL (713) 871-6809

BOARD CERTIFIED FAX (713) 960-1527

EMAIL JNIXON8MPLLPCOM

CiVIL TRIAL LAW TEXAS BOARD OF LEGAL SPECIALIZATION

July 14 2015

Mark W Stevens VIA FIRST CLASS MAIL Attorney at Law CERTIFIED MAIL PO Box 8118 FACSIMILE (409) 765-6459 AND Galveston Texas 77553 EMAIL markwandstevsbcglobalnet

Re Cause No 15CV0583 The Honorable Lonnie Cox Local Administrative Judge Galveston Co v The Honorable Mark Henry County Judge Galveston County in the 56th Judicial District Court of Galveston County Texas

Dear Mr Stevens

I now represent the Honorable Mark Henry in the above-referenced case and have attached for your review a file-stamped copy of the Notice of Appeal which was filed on July 13 2015 Because the appeal is based upon the courts denial of the plea to the jurisdiction and the trial courts incorrect assumption of subject matter jurisdiction the entire proceeding including the application ofthe temporary injunction is stayed pursuant to Tex Civ Prac amp Rem Code sect S I014(a)(8) and (b) You should further note that the filing of the notice of appeal suspended the temporary injunction pursuant to Tex R App P 291 (b) and Tex Civ Prac amp Rem Code sect 6001 (b)(4)

Accordingly Ms Bomlie Quiroga will no longer be allowed access to Galveston County facilities office or infrastructure other than that which is accessible to the pUblic She is of course not considered an employee of the County has no job function or duties and will not receive a salary or benefits from the County

I realize it is not necessary for you to remind your client that this matter is no longer in either his jurisdiction or the jurisdiction of the trial court if it ever was Accordingly any attempt to unilaterally enforce the temporary injunction by way of a new ex parte verbal or written order will be met with the most rigorous of opposition utilizing all lawful means necessary to protect the civil rights of those who are County employees

If you have any questions please do not hesitate to contact me

Very truly yours

~l4rz7h~ Joseph M Nixon

2198919v19999991114011 EXHIBIT A P 14

Filed 7113201581335 PM JOHN D KINARD - District Clerk

Galveston County Texas Envelope No 6048080

By Shailja Dixit 714201593554 AM

CAUSE NO lS-CV-0583

THE HON LONNIE COX sect IN THE DISTRICT COURT OF sect

PLAINTIFF sect sect

v sect 56TH JUDICIAL DISTRICT sect

THE HON MARK HENRY COUNTY sect JUDGE OF GALVESTON COUNTY sect

sect DEFENDANT sect GALVESTON COUNTY TEXAS

NOTICE OF APPEAL

Defendant The Honorable Mark Henry County Judge of Galveston County files

this Notice of Appeal pursuant to section Sl014(a)(8) of the Texas Civil Practice and

Remedies Code and Rules 2S1 and 261(b) of the Texas Rules of Appellate Procedure

and would respectfully show the Court as follows

1 Defendant The Honorable Mark Henry County Judge of Galveston County

desires to appeal this Courts Order signed June 23 201S that denies his Plea to the

Jurisdiction in the above-captioned matter

2 Defendant appeals to the First or Fourteenth Court of Appeals in Houston

Texas Defendant believes this interlocutory appeal should go to the First Court of

Appeals because Defendant has previously filed a related (a) original proceeding and (b)

interlocutory appeal in the First Court of Appeals- both arising from this same case

a No 01-14-00820-CV In re Galveston County Judge Mark Henry et al and

b No 01-15-00S83-CV The Honorable Mark henry Judge of Galveston County v The Honorable Lonnie Cox

EXHIBIT vAP P 24

3 A copy of this Notice of Appeal has been served on all parties to the

proceeding from which this interlocutory appeal is taken See TEX R App P 2Sl(e)

281(b)

4 This interlocutory appeal is an accelerated appeal under Rule 281 of the

Texas Rules of Appellate Procedure and is not a parental termination or child protection

case TEX R App P 281 25 1 (d)(6)

5 This interlocutory appeal results in an automatic stay of all proceeding in the

trial COUlt during the pendency this appeal TEX Cry PRAC amp REM CODE sect51014(b)

BAKER amp HOSTETLER LLP

By Iisl Edward L Friedman Edward L Friedman Texas Bar No 07462950 efriedmanbakerlawcom 811 Main Street Suite 1100 Houston Texas 77002-6111 Telephone 7137511600 Facsimile 7137511717

Attorney for Defendant The Honorable Judge Mark Henry

Exhibit AP p 34

I hereby certify that a true and correct copy of the foregoing Notice of Appeal was sent to all counsel of record by email and facsimile on this 13th day of July 2015 as follows

s Edward L Friedman Attorney for Defendant The Honorable Judge Mark Henry

Ex hi bit n A p 44II

MEMORANDUM

TO Kevin Walsh Galveston County Treasurer

FROM Mark Henry Galveston County Judge

DATE July 16 2015

RE Payroll for Unfunded and Unauthorized County Positions

As you are aware the County may not payor authorize salary disbursements to individuals who are neither county employees nor hold positions for which the county has not authorized payment I have attached for your review a copy of the certified minutes from the Commissioners Court meeting held on June 13 2015 As you can see from these minutes the Commissioners Court voted for and issued an order removing from the budget the salary and position of Director of Judicial Administration Previously Ms Bonnie Quiroga had been dismissed from that position also by vote and order passed by the Commissioners Court

Although ancillary orders from District Courts have issued those orders are suspended by the application of Tex Civ Rem amp Prac Code sectsect 6001(b)(4) and 51014(a)(8) and (b) and Tex R App 291 (b) Additionally the Commissioners Court has not voted to reinstate Ms Quiroga her salary or the position of Director of Judicial Administration As one member of the Commissioners Court may not revoke or reverse the express order of a prior decision of the Commissioners Court the county should not disburse any payment salary or funds whatsoever to Ms Quiroga until such time as the entire Court has voted and ordered to do so To date a vote to alter the Commissioners Court orders of June 132015 has not occurred

UBJECTION TO MEDIATION~lxhibi t B

2199867vl 9999991114011

AFFIDAVIT OF MONICA GRACIA REGARDING MEETING WITH HUMAN RESOURCES DIRECTOR FOR

GALVESTON COUNTY

Monica Gracia appeared in person before me today and stated under oath

My name is Monica Gracia I am currently employed as the Administrative Specialist in the department

of Justice Administration in Galveston County

On Wednesday September 2nd Peri Bluemer Director of Human Resources called me at my office and

requested a meeting for that afternoon She did not indicate what the meeting was about We made

arrangements to meet at 130 pm in her office I contacted David Walker and asked him to sit with me

during the meeting and he agreed

We met Peri in her office and she began the conversation by stating that as I was probably aware that

as of October 1 2015 the Office ofJustice Administration was no longer included in the county budget

That meant that my position as Administrative Specialist would no longer be funded She went on to say

that in a meeting back in June the Commissioners Court created a new Court Administration office at

the request of the Administrative judges Included in that office were the administrative positions that

she assumed the Judges would just transfer us over to as of that day they remained open She said

that she had reached out to the Administrative Judges a couple of weeks earlier and asked them to let

HR know who they wanted to fill those positions but they have not responded Peri said that she would

hate for us to come in to work on October 1st and find out that we were not longer employed so she

was meeting with the five employees ofJustice Administration that day and informing us of the current

situation Ms Bluemer expressed concern over me being let go since it seemed to her that I was the

one running the show for the last year in Justice Administration Ms Bluemer indicated that Judge

Henry gave her the go ahead to give the five of us preferential consideration for any open positions that

we may be interested in in the County Ms Bluemer said she would personally speak with that

Department Head to keep me from having a break in service with the County Ms Bluemer also

indicated that 1need to get her my resume as soon as possible so that she can start working on it for me

Ms Bluemer stated that she was sorry that I was being put in this kind of situation knowing the

previous battle t had with a former Judge but that she would help in any way she could She then asked

me if I had any questions I told Ms Bluemer that currently the Office of Justice Administration had 5

employees not including the Directors position I asked her if all of those positions were accounted for

in the newly created office She indicated that yes there were 5 total positions and that the Director

pOSition was separate from those five

About an hour and a half later I was in my office and Ms Bluemer called again She said that she

made a HUGE mistake when we spoke earlier and only realized her mistake when she was in a meeting

with Roger another Justice Administration employee She said that she confirmed with Bob Boerner

that there were only 5 positions created for the new department and that INCLUDED the Director I

responded so what youre telling me is that someone will lose their job on October 1 SI no matter

what7 5he said yes

Further affiant sayeth not

SIGNED under oath before me on 5 ceh 0 lt-- d-O is

Mko4Pamp Jt~ Notary Public State of Texas

AFFIDAVIT OF CLINT PURCELL

STATE OF TEXAS

COlJNTY OF GALVESTON

BEFORE ME the undersigned Notary Public came on to be sworn Clint Purcell who being sworn deposes and states as follows

1 My name is Clint Purcell I am above the age of 18 years and am competent in all respects to make this oath All statements herein are true and correct and are based on my personal knowledge

2 I hold a peace officers license and have worked for approximately 2 years for the Galveston County Department of Justice Administration Before that I worked for the Galveston County Sheriffs department for about 5 years As a peace officer I have 19 years experience

3 My supervisor at Justice Administration is Bonnie Quiroga 4 I am the same Clint Purcell who is mentioned in the Temporary

Injunction order signed by Judge Sharolyn Wood on July 6 2015 and specifically at page 9 Paragraph 6 of that Order

5 On June 232015 at about 826 am I received a call from Peri Bluemer who is the Director ofHuman Resources for Galveston County Ms Bluemer stated that she had just got off the phone with Tyler (Drummond) at the County Judges office Tyler Drummond is Judge Henrys chief of staff Peri stated that Tyler told her as ofFriday [June 26] my position as judicial compliance officer would be gone Peri stated 5 positions were created and would be under Judge Cox supervision Peri said go talk to Judge Cox and see if he would keep me in the new position with the same pay Peri then stated that Commissioner Dennard talked to SheriffTrochessett and said if I didnt want to be with Judg e Cox I could go back to corrections or another position at the Sheriffs Office I advised Peri No Im going to stay with my current job and my commission is with the Galveston County Sheriffs Office and not Constable Brown any more Peri then stated that Wayne Brown (Constable Pct 1) is till your Supervisor I did not respond to comment

Peri then said if she doesnt hear back from me by the end of Thursday

June 25 she would draw up my termination papers I advised Peri I

would speak with Judge Cox and get back to her

6 On July 232015 pm I got a call from Peris cell number I tried to call

back but could not get an answer That was at 1 22 pm

7 It is my understanding that my situation was made known to Judge Sharolyn Wood who later (July 6) mentioned me in her Temporary

Injunction as one of the specific individuals who were not to be fired

8 During the last week of August I got a call from Ms Bluemer directing e

to come to her office at 722 Moody in Galveston I attended a meeting

with Ms Bluemer on September 8 2015 at about 3 30 pm

9 Ms Bluemer greeted me and asked if my attorney (Mark Stevens) was

going to be there and that Mr Stevens had told her he wanted the

meeting recorded Peri started offby saying you know whats going oin As of September 30 (Peri said) you wont have a job unless the judges

pick you for the 5 positions they have It is under their budget and I dont

want you to go without ajob Peri said if there is any job in the county

you like let me know I can (Peri said) plug you in there until the judges

pick for those positions then I have no problem putting you back over there I fyou dont want to go to correctiosn I will help you do your

resume and find another job Peri said call me any time day or night Im

here for y all Per made reference about when I switched back to the

GCSO to hold my commission Peri said since I didnt have a boss thats

why I tried to move you to probation (that is the previous June) Peri said I wasnt trying to get you fired I wanted you to keep your job Peri

said look at y eyes I am not lying I just tell the truth Peri then said she

would talk to Sheriff Trochessett on my behalf I said no I would do that

myself if I needed to talk with SheriffTrochessett Peri then said all she

needed was a paper from the judges saying that they put me in the administrative officer position

101t was my perception at the September 8 meeting that Ms Bluemer was

doing a scare tactic in order to pressure the employees (including me) to take a job with the county outside of Justice Administration or else to

pressure the judges into agreeing to hire me and the others at the rates set

by the County

11 During the conversation of September 8 the topic of salary came up Ms Bluemer said that got on the county website human resources page and found ajob I liked then she could plug me in there and that salary

could be modified I do not remember her exact terms 12The hearings between Judge Cox and County Judge Henry began on

June 192015 and went on to and through June 23 2015 on which date testimony was ended before Judge Sharolyn Wood

SWORN TO and subscribed by the aforesaid Clint Purcell on the b tJay of September 2015

AFFIDAVIT

BEFORE ME the undersigned authority personally appeared Susan Elizabeth Criss

who being by me duly sworn stated the following under oath

On September 2 2015 I accompanied Latressa Dupuis to a meeting with the Galveston County Chief of Human Resources Peri Bluemer in Ms Bluemers office at Mrs Dupuiss request Ms Bluemer and Kathy Branch were present Ms Bluemer made the following statements

1 All of the bad things being about Judge Cox Bonnie Quiroga Darren Bertin her county attorney Mark Henry were unfair and untrue

2 She had the go ahead from Mark Henry and Ryan Dennard to speak to the 5 Justice Administration employees

3 As of October 1 their jobs no longer existed 4 Each county position has a unique number 5 The new budget did not include the numbers that correspond

their jobs 6 She explained their letter and number system of

classifying jobs 7 She said that if the judges (referring to ones other than

Henry) did not 5 positions commissioners created for them then the five would not employed

8 The oommissioners took Bonnie Quirogas position and her five staff positions and recreated five positions for the

bullbull fI judges to fill at a much lower pay 9 She held her th11lfib and index finger close together to

emphasize how small the pay was 10 If any chose to apply for other jobs in the county she

would help them bypass regular process and ask Commissi0ners Court to bump up the pay Two on the court told her she could expect such pay requests to be granted

11 If any of these employees wanted to seek employment outside the county she would in time off work with resumes and mock interviews

12 The two positions available were human resources receptionist and something in the road

13 If she could wave a magicw-and she put all of the Justice Administration jobs back under the Commissioners Court (I explained they were never under the commissioner court)

14 It was not fair that these employees were caught in middle She was an expert in motorcycles and employment law

I expressed my opinions about how wrong this tactic was I used curse words So she began to use some as well I explained I knew she was just the messenger so my anger was not directed at her She said she understood that Our tones toward each other remained cordial I corrected her misunderstandings or misstatements of the history of these events She said she would like to talk to me at a cocktail party but this was about Mrs Dupius I asked if she understood they were under court orders not to

these people that until a higher court decided otherwise those orders were in effect and knowing judge woods as i do they would all go to jail if they proceeded with this She did not appear concerned She was upbeat and cheerful the entire meeting The meeting ended at 400 pm

My name is Susan Elizabeth

herein are true and correct

contained

SWORN and SUBSCRIBED before me the undersigned authority on this day of __

~~nv2015

KATHY JO FOUNTAIN Notary Publlc State 01 Texas

MV Commission Expiras Novemb$l 14 2015

COURT OF ApPEALS FOR THE

FIRST DISTRICT OF TEXAS AT HOUSTON

Appellate case name In re Honorable Lonnie Cox

Appellate case number 01-15-00797-CV

Trial court case number 15CV0583

Trial court 56th District Court of Galveston County

On September 17~ 2015~ relator~ the Honorable Lonnie Cox filed in this Court a Petition for a Writ of Injunction and Emergency Request for Temporary Relief This Court requested that respondents file a response to the petition and emergency request no later than Wednesday September 23 2015 On September 18 2015 respondent the Honorable Mark Henry County Judge of Galveston County filed a motion to extend the time to file a response to September 29 2015 Relator has filed a response to respondents motion

In his petition relator alleges that respondents have conduct[ed] a campaign of economic coercion against employees of the Galveston County Department of Justice Administration and threatened their employment to force them to abandon their current jobs dismantle the department and moot respondents related appeal in Cause No 01-15-00583-CV The Honorable Mark Henry County Judge of Galveston County v The Honorable Lonnie Cox Relator supports his petition with three affidavits containing testimony regarding the employees meetings with the Director of Human Resources for Galveston County

The allegations presented in the petition and supporting affidavits are serious See eg TEX Loc GOVT CODE ANN sect 151004 (Vernon 2008) (The commissioners court or a member of the court may not attempt to influence the appointment of any person to an employee position authorized by the court under

this subchapter) TEX PENAL CODE ANN sectsect 3605 (felony offense of Tampering with Witness) 3606 (felony offense of Obstruction or Retaliation) 3902 (offense of Abuse of Official Capacity) (Vernon 2011) 3903 (offense of Official Oppression) (Vernon Supp 2014)

Given the seriousness of the allegations presented in the petition and the supporting affidavits as well as the time constraints in this proceeding and the related appeal respondents request for an extension of time is denied

It is so ORDERED

Judges signature lsi Terry Jennings [8] Acting individually [J Acting for the Court

Date September 21 2015

Insert from Bpdf

Insert from coxcontemptmtncombinedpdf
coxcontemptmtn
coxti070615
coxnixonltr
coxhenrymemo071615
coxgraciaaffidavit
coxclintaffidavit
coxcrissaffidavit
coxwritorder092115

plea to the jurisdiction Henry v Cox --- SW3d ---- No 01-15-00583-CV (Dec

22 2015)1 Justice Harvey Brown concurred in part and dissented in part2 Justice

Brownrsquos dissent implicates issues concerning the trial courtrsquos subject matter

jurisdiction

2 On December 22 2015 the First Court of Appeals also issued its

mandate with the opinion and judgment3 The issuance of the mandate caused the

court of appealsrsquo judgment to take effect immediately for a trial on a permanent

injunction TEX R APP P 186 511(b) The court of appeals issued its mandate

instantaneously even though the dissenting opinion on its face triggers this Courtrsquos

appellate jurisdiction TEX GOVrsquoT CODE sect 22225(c)

3 Petitioner desires to file a petition for review with this Court to seek

review of the court of appealsrsquo judgment and opinion Because the court of

appeals already issued its mandate a permanent injunction is certain to issue

before the partiesrsquo briefing in this Court can be completed and before any decision

by this Court can be rendered invoking potential mootness issues

1 The court of appeals issued a corrected opinion the next day on December 23 2015 Thecorrected majority opinion dated December 23 2015 is attached to Petitionerrsquos EmergencyMotion at Stay the Court of Appealsrsquo Mandate at Tab A2 Justice Brownrsquos concurring and dissenting opinion is attached to Petitionerrsquos EmergencyMotion at Stay the Court of Appealsrsquo Mandate at Tab B3 The mandate is attached to Petitionerrsquos Emergency Motion at Stay the Court of AppealsrsquoMandate at Tab C

Updated Information

Requested Relief

Prayer for Relief

be justly entitled

s N Terry Adams Jr

s Nicholas D Stepp

Nicholas D Stepp

s N Terry Adams Jr

N Terry Adams Jr

No15CV0583

15mdash00583-CV

mandate

October 1 2015

be discussed

Prayer

TBN 19184300 P Box 8118

County of Galveston

____Mark W Stevens_______________________

Day of January 2016

s Mark W Stevens

Attachments

Monday June 222015

i bull

I r bull1

be hired

the judiciary

Exhibit C

Drummond salary

against Ms Quiroga

injunction

County

Procedure

-b---cot

SUITE 2500

July 14 2015

Dear Mr Stevens

Very truly yours

2198919v19999991114011 EXHIBIT A P 14

CAUSE NO lS-CV-0583

PLAINTIFF sect sect

NOTICE OF APPEAL

EXHIBIT vAP P 24

281(b)

Exhibit AP p 34

MEMORANDUM

DATE July 16 2015

2199867vl 9999991114011

GALVESTON COUNTY

what7 5he said yes

STATE OF TEXAS

by the County

AFFIDAVIT

contained

~~nv2015

It is so ORDERED

Insert from Bpdf

coxcontemptmtn
coxti070615
coxnixonltr
coxhenrymemo071615
coxgraciaaffidavit
coxclintaffidavit
coxcrissaffidavit
coxwritorder092115

Updated Information

Requested Relief

Prayer for Relief

be justly entitled

s N Terry Adams Jr

s Nicholas D Stepp

Nicholas D Stepp

s N Terry Adams Jr

N Terry Adams Jr

No15CV0583

15mdash00583-CV

mandate

October 1 2015

be discussed

Prayer

TBN 19184300 P Box 8118

County of Galveston

____Mark W Stevens_______________________

Day of January 2016

s Mark W Stevens

Attachments

Monday June 222015

i bull

I r bull1

be hired

the judiciary

Exhibit C

Drummond salary

against Ms Quiroga

injunction

County

Procedure

-b---cot

SUITE 2500

July 14 2015

Dear Mr Stevens

Very truly yours

2198919v19999991114011 EXHIBIT A P 14

CAUSE NO lS-CV-0583

PLAINTIFF sect sect

NOTICE OF APPEAL

EXHIBIT vAP P 24

281(b)

Exhibit AP p 34

MEMORANDUM

DATE July 16 2015

2199867vl 9999991114011

GALVESTON COUNTY

what7 5he said yes

STATE OF TEXAS

by the County

AFFIDAVIT

contained

~~nv2015

It is so ORDERED

Insert from Bpdf

coxcontemptmtn
coxti070615
coxnixonltr
coxhenrymemo071615
coxgraciaaffidavit
coxclintaffidavit
coxcrissaffidavit
coxwritorder092115

Prayer for Relief

be justly entitled

s N Terry Adams Jr

s Nicholas D Stepp

Nicholas D Stepp

s N Terry Adams Jr

N Terry Adams Jr

No15CV0583

15mdash00583-CV

mandate

October 1 2015

be discussed

Prayer

TBN 19184300 P Box 8118

County of Galveston

____Mark W Stevens_______________________

Day of January 2016

s Mark W Stevens

Attachments

Monday June 222015

i bull

I r bull1

be hired

the judiciary

Exhibit C

Drummond salary

against Ms Quiroga

injunction

County

Procedure

-b---cot

SUITE 2500

July 14 2015

Dear Mr Stevens

Very truly yours

2198919v19999991114011 EXHIBIT A P 14

CAUSE NO lS-CV-0583

PLAINTIFF sect sect

NOTICE OF APPEAL

EXHIBIT vAP P 24

281(b)

Exhibit AP p 34

MEMORANDUM

DATE July 16 2015

2199867vl 9999991114011

GALVESTON COUNTY

what7 5he said yes

STATE OF TEXAS

by the County

AFFIDAVIT

contained

~~nv2015

It is so ORDERED

Insert from Bpdf

coxcontemptmtn
coxti070615
coxnixonltr
coxhenrymemo071615
coxgraciaaffidavit
coxclintaffidavit
coxcrissaffidavit
coxwritorder092115

s Nicholas D Stepp

Nicholas D Stepp

s N Terry Adams Jr

N Terry Adams Jr

No15CV0583

15mdash00583-CV

mandate

October 1 2015

be discussed

Prayer

TBN 19184300 P Box 8118

County of Galveston

____Mark W Stevens_______________________

Day of January 2016

s Mark W Stevens

Attachments

Monday June 222015

i bull

I r bull1

be hired

the judiciary

Exhibit C

Drummond salary

against Ms Quiroga

injunction

County

Procedure

-b---cot

SUITE 2500

July 14 2015

Dear Mr Stevens

Very truly yours

2198919v19999991114011 EXHIBIT A P 14

CAUSE NO lS-CV-0583

PLAINTIFF sect sect

NOTICE OF APPEAL

EXHIBIT vAP P 24

281(b)

Exhibit AP p 34

MEMORANDUM

DATE July 16 2015

2199867vl 9999991114011

GALVESTON COUNTY

what7 5he said yes

STATE OF TEXAS

by the County

AFFIDAVIT

contained

~~nv2015

It is so ORDERED

Insert from Bpdf

coxcontemptmtn
coxti070615
coxnixonltr
coxhenrymemo071615
coxgraciaaffidavit
coxclintaffidavit
coxcrissaffidavit
coxwritorder092115

s N Terry Adams Jr

N Terry Adams Jr

No15CV0583

15mdash00583-CV

mandate

October 1 2015

be discussed

Prayer

TBN 19184300 P Box 8118

County of Galveston

____Mark W Stevens_______________________

Day of January 2016

s Mark W Stevens

Attachments

Monday June 222015

i bull

I r bull1

be hired

the judiciary

Exhibit C

Drummond salary

against Ms Quiroga

injunction

County

Procedure

-b---cot

SUITE 2500

July 14 2015

Dear Mr Stevens

Very truly yours

2198919v19999991114011 EXHIBIT A P 14

CAUSE NO lS-CV-0583

PLAINTIFF sect sect

NOTICE OF APPEAL

EXHIBIT vAP P 24

281(b)

Exhibit AP p 34

MEMORANDUM

DATE July 16 2015

2199867vl 9999991114011

GALVESTON COUNTY

what7 5he said yes

STATE OF TEXAS

by the County

AFFIDAVIT

contained

~~nv2015

It is so ORDERED

Insert from Bpdf

coxcontemptmtn
coxti070615
coxnixonltr
coxhenrymemo071615
coxgraciaaffidavit
coxclintaffidavit
coxcrissaffidavit
coxwritorder092115

No15CV0583

15mdash00583-CV

mandate

October 1 2015

be discussed

Prayer

TBN 19184300 P Box 8118

County of Galveston

____Mark W Stevens_______________________

Day of January 2016

s Mark W Stevens

Attachments

Monday June 222015

i bull

I r bull1

be hired

the judiciary

Exhibit C

Drummond salary

against Ms Quiroga

injunction

County

Procedure

-b---cot

SUITE 2500

July 14 2015

Dear Mr Stevens

Very truly yours

2198919v19999991114011 EXHIBIT A P 14

CAUSE NO lS-CV-0583

PLAINTIFF sect sect

NOTICE OF APPEAL

EXHIBIT vAP P 24

281(b)

Exhibit AP p 34

MEMORANDUM

DATE July 16 2015

2199867vl 9999991114011

GALVESTON COUNTY

what7 5he said yes

STATE OF TEXAS

by the County

AFFIDAVIT

contained

~~nv2015

It is so ORDERED

Insert from Bpdf

coxcontemptmtn
coxti070615
coxnixonltr
coxhenrymemo071615
coxgraciaaffidavit
coxclintaffidavit
coxcrissaffidavit
coxwritorder092115

No15CV0583

15mdash00583-CV

mandate

October 1 2015

be discussed

Prayer

TBN 19184300 P Box 8118

County of Galveston

____Mark W Stevens_______________________

Day of January 2016

s Mark W Stevens

Attachments

Monday June 222015

i bull

I r bull1

be hired

the judiciary

Exhibit C

Drummond salary

against Ms Quiroga

injunction

County

Procedure

-b---cot

SUITE 2500

July 14 2015

Dear Mr Stevens

Very truly yours

2198919v19999991114011 EXHIBIT A P 14

CAUSE NO lS-CV-0583

PLAINTIFF sect sect

NOTICE OF APPEAL

EXHIBIT vAP P 24

281(b)

Exhibit AP p 34

MEMORANDUM

DATE July 16 2015

2199867vl 9999991114011

GALVESTON COUNTY

what7 5he said yes

STATE OF TEXAS

by the County

AFFIDAVIT

contained

~~nv2015

It is so ORDERED

Insert from Bpdf

coxcontemptmtn
coxti070615
coxnixonltr
coxhenrymemo071615
coxgraciaaffidavit
coxclintaffidavit
coxcrissaffidavit
coxwritorder092115

No15CV0583

15mdash00583-CV

mandate

October 1 2015

be discussed

Prayer

TBN 19184300 P Box 8118

County of Galveston

____Mark W Stevens_______________________

Day of January 2016

s Mark W Stevens

Attachments

Monday June 222015

i bull

I r bull1

be hired

the judiciary

Exhibit C

Drummond salary

against Ms Quiroga

injunction

County

Procedure

-b---cot

SUITE 2500

July 14 2015

Dear Mr Stevens

Very truly yours

2198919v19999991114011 EXHIBIT A P 14

CAUSE NO lS-CV-0583

PLAINTIFF sect sect

NOTICE OF APPEAL

EXHIBIT vAP P 24

281(b)

Exhibit AP p 34

MEMORANDUM

DATE July 16 2015

2199867vl 9999991114011

GALVESTON COUNTY

what7 5he said yes

STATE OF TEXAS

by the County

AFFIDAVIT

contained

~~nv2015

It is so ORDERED

Insert from Bpdf

coxcontemptmtn
coxti070615
coxnixonltr
coxhenrymemo071615
coxgraciaaffidavit
coxclintaffidavit
coxcrissaffidavit
coxwritorder092115

mandate

October 1 2015

be discussed

Prayer

TBN 19184300 P Box 8118

County of Galveston

____Mark W Stevens_______________________

Day of January 2016

s Mark W Stevens

Attachments

Monday June 222015

i bull

I r bull1

be hired

the judiciary

Exhibit C

Drummond salary

against Ms Quiroga

injunction

County

Procedure

-b---cot

SUITE 2500

July 14 2015

Dear Mr Stevens

Very truly yours

2198919v19999991114011 EXHIBIT A P 14

CAUSE NO lS-CV-0583

PLAINTIFF sect sect

NOTICE OF APPEAL

EXHIBIT vAP P 24

281(b)

Exhibit AP p 34

MEMORANDUM

DATE July 16 2015

2199867vl 9999991114011

GALVESTON COUNTY

what7 5he said yes

STATE OF TEXAS

by the County

AFFIDAVIT

contained

~~nv2015

It is so ORDERED

Insert from Bpdf

coxcontemptmtn
coxti070615
coxnixonltr
coxhenrymemo071615
coxgraciaaffidavit
coxclintaffidavit
coxcrissaffidavit
coxwritorder092115

October 1 2015

be discussed

Prayer

TBN 19184300 P Box 8118

County of Galveston

____Mark W Stevens_______________________

Day of January 2016

s Mark W Stevens

Attachments

Monday June 222015

i bull

I r bull1

be hired

the judiciary

Exhibit C

Drummond salary

against Ms Quiroga

injunction

County

Procedure

-b---cot

SUITE 2500

July 14 2015

Dear Mr Stevens

Very truly yours

2198919v19999991114011 EXHIBIT A P 14

CAUSE NO lS-CV-0583

PLAINTIFF sect sect

NOTICE OF APPEAL

EXHIBIT vAP P 24

281(b)

Exhibit AP p 34

MEMORANDUM

DATE July 16 2015

2199867vl 9999991114011

GALVESTON COUNTY

what7 5he said yes

STATE OF TEXAS

by the County

AFFIDAVIT

contained

~~nv2015

It is so ORDERED

Insert from Bpdf

coxcontemptmtn
coxti070615
coxnixonltr
coxhenrymemo071615
coxgraciaaffidavit
coxclintaffidavit
coxcrissaffidavit
coxwritorder092115

October 1 2015

be discussed

Prayer

TBN 19184300 P Box 8118

County of Galveston

____Mark W Stevens_______________________

Day of January 2016

s Mark W Stevens

Attachments

Monday June 222015

i bull

I r bull1

be hired

the judiciary

Exhibit C

Drummond salary

against Ms Quiroga

injunction

County

Procedure

-b---cot

SUITE 2500

July 14 2015

Dear Mr Stevens

Very truly yours

2198919v19999991114011 EXHIBIT A P 14

CAUSE NO lS-CV-0583

PLAINTIFF sect sect

NOTICE OF APPEAL

EXHIBIT vAP P 24

281(b)

Exhibit AP p 34

MEMORANDUM

DATE July 16 2015

2199867vl 9999991114011

GALVESTON COUNTY

what7 5he said yes

STATE OF TEXAS

by the County

AFFIDAVIT

contained

~~nv2015

It is so ORDERED

Insert from Bpdf

coxcontemptmtn
coxti070615
coxnixonltr
coxhenrymemo071615
coxgraciaaffidavit
coxclintaffidavit
coxcrissaffidavit
coxwritorder092115

be discussed

Prayer

TBN 19184300 P Box 8118

County of Galveston

____Mark W Stevens_______________________

Day of January 2016

s Mark W Stevens

Attachments

Monday June 222015

i bull

I r bull1

be hired

the judiciary

Exhibit C

Drummond salary

against Ms Quiroga

injunction

County

Procedure

-b---cot

SUITE 2500

July 14 2015

Dear Mr Stevens

Very truly yours

2198919v19999991114011 EXHIBIT A P 14

CAUSE NO lS-CV-0583

PLAINTIFF sect sect

NOTICE OF APPEAL

EXHIBIT vAP P 24

281(b)

Exhibit AP p 34

MEMORANDUM

DATE July 16 2015

2199867vl 9999991114011

GALVESTON COUNTY

what7 5he said yes

STATE OF TEXAS

by the County

AFFIDAVIT

contained

~~nv2015

It is so ORDERED

Insert from Bpdf

coxcontemptmtn
coxti070615
coxnixonltr
coxhenrymemo071615
coxgraciaaffidavit
coxclintaffidavit
coxcrissaffidavit
coxwritorder092115

Prayer

TBN 19184300 P Box 8118

County of Galveston

____Mark W Stevens_______________________

Day of January 2016

s Mark W Stevens

Attachments

Monday June 222015

i bull

I r bull1

be hired

the judiciary

Exhibit C

Drummond salary

against Ms Quiroga

injunction

County

Procedure

-b---cot

SUITE 2500

July 14 2015

Dear Mr Stevens

Very truly yours

2198919v19999991114011 EXHIBIT A P 14

CAUSE NO lS-CV-0583

PLAINTIFF sect sect

NOTICE OF APPEAL

EXHIBIT vAP P 24

281(b)

Exhibit AP p 34

MEMORANDUM

DATE July 16 2015

2199867vl 9999991114011

GALVESTON COUNTY

what7 5he said yes

STATE OF TEXAS

by the County

AFFIDAVIT

contained

~~nv2015

It is so ORDERED

Insert from Bpdf

coxcontemptmtn
coxti070615
coxnixonltr
coxhenrymemo071615
coxgraciaaffidavit
coxclintaffidavit
coxcrissaffidavit
coxwritorder092115

County of Galveston

____Mark W Stevens_______________________

Day of January 2016

s Mark W Stevens

Attachments

Monday June 222015

i bull

I r bull1

be hired

the judiciary

Exhibit C

Drummond salary

against Ms Quiroga

injunction

County

Procedure

-b---cot

SUITE 2500

July 14 2015

Dear Mr Stevens

Very truly yours

2198919v19999991114011 EXHIBIT A P 14

CAUSE NO lS-CV-0583

PLAINTIFF sect sect

NOTICE OF APPEAL

EXHIBIT vAP P 24

281(b)

Exhibit AP p 34

MEMORANDUM

DATE July 16 2015

2199867vl 9999991114011

GALVESTON COUNTY

what7 5he said yes

STATE OF TEXAS

by the County

AFFIDAVIT

contained

~~nv2015

It is so ORDERED

Insert from Bpdf

coxcontemptmtn
coxti070615
coxnixonltr
coxhenrymemo071615
coxgraciaaffidavit
coxclintaffidavit
coxcrissaffidavit
coxwritorder092115

Attachments

Monday June 222015

i bull

I r bull1

be hired

the judiciary

Exhibit C

Drummond salary

against Ms Quiroga

injunction

County

Procedure

-b---cot

SUITE 2500

July 14 2015

Dear Mr Stevens

Very truly yours

2198919v19999991114011 EXHIBIT A P 14

CAUSE NO lS-CV-0583

PLAINTIFF sect sect

NOTICE OF APPEAL

EXHIBIT vAP P 24

281(b)

Exhibit AP p 34

MEMORANDUM

DATE July 16 2015

2199867vl 9999991114011

GALVESTON COUNTY

what7 5he said yes

STATE OF TEXAS

by the County

AFFIDAVIT

contained

~~nv2015

It is so ORDERED

Insert from Bpdf

coxcontemptmtn
coxti070615
coxnixonltr
coxhenrymemo071615
coxgraciaaffidavit
coxclintaffidavit
coxcrissaffidavit
coxwritorder092115

Monday June 222015

i bull

I r bull1

be hired

the judiciary

Exhibit C

Drummond salary

against Ms Quiroga

injunction

County

Procedure

-b---cot

SUITE 2500

July 14 2015

Dear Mr Stevens

Very truly yours

2198919v19999991114011 EXHIBIT A P 14

CAUSE NO lS-CV-0583

PLAINTIFF sect sect

NOTICE OF APPEAL

EXHIBIT vAP P 24

281(b)

Exhibit AP p 34

MEMORANDUM

DATE July 16 2015

2199867vl 9999991114011

GALVESTON COUNTY

what7 5he said yes

STATE OF TEXAS

by the County

AFFIDAVIT

contained

~~nv2015

It is so ORDERED

Insert from Bpdf

coxcontemptmtn
coxti070615
coxnixonltr
coxhenrymemo071615
coxgraciaaffidavit
coxclintaffidavit
coxcrissaffidavit
coxwritorder092115

i bull

I r bull1

be hired

the judiciary

Exhibit C

Drummond salary

against Ms Quiroga

injunction

County

Procedure

-b---cot

SUITE 2500

July 14 2015

Dear Mr Stevens

Very truly yours

2198919v19999991114011 EXHIBIT A P 14

CAUSE NO lS-CV-0583

PLAINTIFF sect sect

NOTICE OF APPEAL

EXHIBIT vAP P 24

281(b)

Exhibit AP p 34

MEMORANDUM

DATE July 16 2015

2199867vl 9999991114011

GALVESTON COUNTY

what7 5he said yes

STATE OF TEXAS

by the County

AFFIDAVIT

contained

~~nv2015

It is so ORDERED

Insert from Bpdf

coxcontemptmtn
coxti070615
coxnixonltr
coxhenrymemo071615
coxgraciaaffidavit
coxclintaffidavit
coxcrissaffidavit
coxwritorder092115

I r bull1

be hired

the judiciary

Exhibit C

Drummond salary

against Ms Quiroga

injunction

County

Procedure

-b---cot

SUITE 2500

July 14 2015

Dear Mr Stevens

Very truly yours

2198919v19999991114011 EXHIBIT A P 14

CAUSE NO lS-CV-0583

PLAINTIFF sect sect

NOTICE OF APPEAL

EXHIBIT vAP P 24

281(b)

Exhibit AP p 34

MEMORANDUM

DATE July 16 2015

2199867vl 9999991114011

GALVESTON COUNTY

what7 5he said yes

STATE OF TEXAS

by the County

AFFIDAVIT

contained

~~nv2015

It is so ORDERED

Insert from Bpdf

coxcontemptmtn
coxti070615
coxnixonltr
coxhenrymemo071615
coxgraciaaffidavit
coxclintaffidavit
coxcrissaffidavit
coxwritorder092115

I r bull1

be hired

the judiciary

Exhibit C

Drummond salary

against Ms Quiroga

injunction

County

Procedure

-b---cot

SUITE 2500

July 14 2015

Dear Mr Stevens

Very truly yours

2198919v19999991114011 EXHIBIT A P 14

CAUSE NO lS-CV-0583

PLAINTIFF sect sect

NOTICE OF APPEAL

EXHIBIT vAP P 24

281(b)

Exhibit AP p 34

MEMORANDUM

DATE July 16 2015

2199867vl 9999991114011

GALVESTON COUNTY

what7 5he said yes

STATE OF TEXAS

by the County

AFFIDAVIT

contained

~~nv2015

It is so ORDERED

Insert from Bpdf

coxcontemptmtn
coxti070615
coxnixonltr
coxhenrymemo071615
coxgraciaaffidavit
coxclintaffidavit
coxcrissaffidavit
coxwritorder092115

be hired

the judiciary

Exhibit C

Drummond salary

against Ms Quiroga

injunction

County

Procedure

-b---cot

SUITE 2500

July 14 2015

Dear Mr Stevens

Very truly yours

2198919v19999991114011 EXHIBIT A P 14

CAUSE NO lS-CV-0583

PLAINTIFF sect sect

NOTICE OF APPEAL

EXHIBIT vAP P 24

281(b)

Exhibit AP p 34

MEMORANDUM

DATE July 16 2015

2199867vl 9999991114011

GALVESTON COUNTY

what7 5he said yes

STATE OF TEXAS

by the County

AFFIDAVIT

contained

~~nv2015

It is so ORDERED

Insert from Bpdf

coxcontemptmtn
coxti070615
coxnixonltr
coxhenrymemo071615
coxgraciaaffidavit
coxclintaffidavit
coxcrissaffidavit
coxwritorder092115

Drummond salary

against Ms Quiroga

injunction

County

Procedure

-b---cot

SUITE 2500

July 14 2015

Dear Mr Stevens

Very truly yours

2198919v19999991114011 EXHIBIT A P 14

CAUSE NO lS-CV-0583

PLAINTIFF sect sect

NOTICE OF APPEAL

EXHIBIT vAP P 24

281(b)

Exhibit AP p 34

MEMORANDUM

DATE July 16 2015

2199867vl 9999991114011

GALVESTON COUNTY

what7 5he said yes

STATE OF TEXAS

by the County

AFFIDAVIT

contained

~~nv2015

It is so ORDERED

Insert from Bpdf

coxcontemptmtn
coxti070615
coxnixonltr
coxhenrymemo071615
coxgraciaaffidavit
coxclintaffidavit
coxcrissaffidavit
coxwritorder092115

injunction

County

Procedure

-b---cot

SUITE 2500

July 14 2015

Dear Mr Stevens

Very truly yours

2198919v19999991114011 EXHIBIT A P 14

CAUSE NO lS-CV-0583

PLAINTIFF sect sect

NOTICE OF APPEAL

EXHIBIT vAP P 24

281(b)

Exhibit AP p 34

MEMORANDUM

DATE July 16 2015

2199867vl 9999991114011

GALVESTON COUNTY

what7 5he said yes

STATE OF TEXAS

by the County

AFFIDAVIT

contained

~~nv2015

It is so ORDERED

Insert from Bpdf

coxcontemptmtn
coxti070615
coxnixonltr
coxhenrymemo071615
coxgraciaaffidavit
coxclintaffidavit
coxcrissaffidavit
coxwritorder092115

injunction

County

Procedure

-b---cot

SUITE 2500

July 14 2015

Dear Mr Stevens

Very truly yours

2198919v19999991114011 EXHIBIT A P 14

CAUSE NO lS-CV-0583

PLAINTIFF sect sect

NOTICE OF APPEAL

EXHIBIT vAP P 24

281(b)

Exhibit AP p 34

MEMORANDUM

DATE July 16 2015

2199867vl 9999991114011

GALVESTON COUNTY

what7 5he said yes

STATE OF TEXAS

by the County

AFFIDAVIT

contained

~~nv2015

It is so ORDERED

Insert from Bpdf

coxcontemptmtn
coxti070615
coxnixonltr
coxhenrymemo071615
coxgraciaaffidavit
coxclintaffidavit
coxcrissaffidavit
coxwritorder092115

County

Procedure

-b---cot

SUITE 2500

July 14 2015

Dear Mr Stevens

Very truly yours

2198919v19999991114011 EXHIBIT A P 14

CAUSE NO lS-CV-0583

PLAINTIFF sect sect

NOTICE OF APPEAL

EXHIBIT vAP P 24

281(b)

Exhibit AP p 34

MEMORANDUM

DATE July 16 2015

2199867vl 9999991114011

GALVESTON COUNTY

what7 5he said yes

STATE OF TEXAS

by the County

AFFIDAVIT

contained

~~nv2015

It is so ORDERED

Insert from Bpdf

coxcontemptmtn
coxti070615
coxnixonltr
coxhenrymemo071615
coxgraciaaffidavit
coxclintaffidavit
coxcrissaffidavit
coxwritorder092115

-b---cot

SUITE 2500

July 14 2015

Dear Mr Stevens

Very truly yours

2198919v19999991114011 EXHIBIT A P 14

CAUSE NO lS-CV-0583

PLAINTIFF sect sect

NOTICE OF APPEAL

EXHIBIT vAP P 24

281(b)

Exhibit AP p 34

MEMORANDUM

DATE July 16 2015

2199867vl 9999991114011

GALVESTON COUNTY

what7 5he said yes

STATE OF TEXAS

by the County

AFFIDAVIT

contained

~~nv2015

It is so ORDERED

Insert from Bpdf

coxcontemptmtn
coxti070615
coxnixonltr
coxhenrymemo071615
coxgraciaaffidavit
coxclintaffidavit
coxcrissaffidavit
coxwritorder092115

-b---cot

SUITE 2500

July 14 2015

Dear Mr Stevens

Very truly yours

2198919v19999991114011 EXHIBIT A P 14

CAUSE NO lS-CV-0583

PLAINTIFF sect sect

NOTICE OF APPEAL

EXHIBIT vAP P 24

281(b)

Exhibit AP p 34

MEMORANDUM

DATE July 16 2015

2199867vl 9999991114011

GALVESTON COUNTY

what7 5he said yes

STATE OF TEXAS

by the County

AFFIDAVIT

contained

~~nv2015

It is so ORDERED

Insert from Bpdf

coxcontemptmtn
coxti070615
coxnixonltr
coxhenrymemo071615
coxgraciaaffidavit
coxclintaffidavit
coxcrissaffidavit
coxwritorder092115

-b---cot

SUITE 2500

July 14 2015

Dear Mr Stevens

Very truly yours

2198919v19999991114011 EXHIBIT A P 14

CAUSE NO lS-CV-0583

PLAINTIFF sect sect

NOTICE OF APPEAL

EXHIBIT vAP P 24

281(b)

Exhibit AP p 34

MEMORANDUM

DATE July 16 2015

2199867vl 9999991114011

GALVESTON COUNTY

what7 5he said yes

STATE OF TEXAS

by the County

AFFIDAVIT

contained

~~nv2015

It is so ORDERED

Insert from Bpdf

coxcontemptmtn
coxti070615
coxnixonltr
coxhenrymemo071615
coxgraciaaffidavit
coxclintaffidavit
coxcrissaffidavit
coxwritorder092115

-b---cot

SUITE 2500

July 14 2015

Dear Mr Stevens

Very truly yours

2198919v19999991114011 EXHIBIT A P 14

CAUSE NO lS-CV-0583

PLAINTIFF sect sect

NOTICE OF APPEAL

EXHIBIT vAP P 24

281(b)

Exhibit AP p 34

MEMORANDUM

DATE July 16 2015

2199867vl 9999991114011

GALVESTON COUNTY

what7 5he said yes

STATE OF TEXAS

by the County

AFFIDAVIT

contained

~~nv2015

It is so ORDERED

Insert from Bpdf

coxcontemptmtn
coxti070615
coxnixonltr
coxhenrymemo071615
coxgraciaaffidavit
coxclintaffidavit
coxcrissaffidavit
coxwritorder092115

SUITE 2500

July 14 2015

Dear Mr Stevens

Very truly yours

2198919v19999991114011 EXHIBIT A P 14

CAUSE NO lS-CV-0583

PLAINTIFF sect sect

NOTICE OF APPEAL

EXHIBIT vAP P 24

281(b)

Exhibit AP p 34

MEMORANDUM

DATE July 16 2015

2199867vl 9999991114011

GALVESTON COUNTY

what7 5he said yes

STATE OF TEXAS

by the County

AFFIDAVIT

contained

~~nv2015

It is so ORDERED

Insert from Bpdf

coxcontemptmtn
coxti070615
coxnixonltr
coxhenrymemo071615
coxgraciaaffidavit
coxclintaffidavit
coxcrissaffidavit
coxwritorder092115

SUITE 2500

July 14 2015

Dear Mr Stevens

Very truly yours

2198919v19999991114011 EXHIBIT A P 14

CAUSE NO lS-CV-0583

PLAINTIFF sect sect

NOTICE OF APPEAL

EXHIBIT vAP P 24

281(b)

Exhibit AP p 34

MEMORANDUM

DATE July 16 2015

2199867vl 9999991114011

GALVESTON COUNTY

what7 5he said yes

STATE OF TEXAS

by the County

AFFIDAVIT

contained

~~nv2015

It is so ORDERED

Insert from Bpdf

coxcontemptmtn
coxti070615
coxnixonltr
coxhenrymemo071615
coxgraciaaffidavit
coxclintaffidavit
coxcrissaffidavit
coxwritorder092115

CAUSE NO lS-CV-0583

PLAINTIFF sect sect

NOTICE OF APPEAL

EXHIBIT vAP P 24

281(b)

Exhibit AP p 34

MEMORANDUM

DATE July 16 2015

2199867vl 9999991114011

GALVESTON COUNTY

what7 5he said yes

STATE OF TEXAS

by the County

AFFIDAVIT

contained

~~nv2015

It is so ORDERED

Insert from Bpdf

coxcontemptmtn
coxti070615
coxnixonltr
coxhenrymemo071615
coxgraciaaffidavit
coxclintaffidavit
coxcrissaffidavit
coxwritorder092115

281(b)

Exhibit AP p 34

MEMORANDUM

DATE July 16 2015

2199867vl 9999991114011

GALVESTON COUNTY

what7 5he said yes

STATE OF TEXAS

by the County

AFFIDAVIT

contained

~~nv2015

It is so ORDERED

Insert from Bpdf

coxcontemptmtn
coxti070615
coxnixonltr
coxhenrymemo071615
coxgraciaaffidavit
coxclintaffidavit
coxcrissaffidavit
coxwritorder092115

MEMORANDUM

DATE July 16 2015

2199867vl 9999991114011

GALVESTON COUNTY

what7 5he said yes

STATE OF TEXAS

by the County

AFFIDAVIT

contained

~~nv2015

It is so ORDERED

Insert from Bpdf

coxcontemptmtn
coxti070615
coxnixonltr
coxhenrymemo071615
coxgraciaaffidavit
coxclintaffidavit
coxcrissaffidavit
coxwritorder092115

MEMORANDUM

DATE July 16 2015

2199867vl 9999991114011

GALVESTON COUNTY

what7 5he said yes

STATE OF TEXAS

by the County

AFFIDAVIT

contained

~~nv2015

It is so ORDERED

Insert from Bpdf

coxcontemptmtn
coxti070615
coxnixonltr
coxhenrymemo071615
coxgraciaaffidavit
coxclintaffidavit
coxcrissaffidavit
coxwritorder092115

GALVESTON COUNTY

what7 5he said yes

STATE OF TEXAS

by the County

AFFIDAVIT

contained

~~nv2015

It is so ORDERED

Insert from Bpdf

coxcontemptmtn
coxti070615
coxnixonltr
coxhenrymemo071615
coxgraciaaffidavit
coxclintaffidavit
coxcrissaffidavit
coxwritorder092115

what7 5he said yes

STATE OF TEXAS

by the County

AFFIDAVIT

contained

~~nv2015

It is so ORDERED

Insert from Bpdf

coxcontemptmtn
coxti070615
coxnixonltr
coxhenrymemo071615
coxgraciaaffidavit
coxclintaffidavit
coxcrissaffidavit
coxwritorder092115

STATE OF TEXAS

by the County

AFFIDAVIT

contained

~~nv2015

It is so ORDERED

Insert from Bpdf

coxcontemptmtn
coxti070615
coxnixonltr
coxhenrymemo071615
coxgraciaaffidavit
coxclintaffidavit
coxcrissaffidavit
coxwritorder092115

by the County

AFFIDAVIT

contained

~~nv2015

It is so ORDERED

Insert from Bpdf

coxcontemptmtn
coxti070615
coxnixonltr
coxhenrymemo071615
coxgraciaaffidavit
coxclintaffidavit
coxcrissaffidavit
coxwritorder092115

AFFIDAVIT

contained

~~nv2015

It is so ORDERED

Insert from Bpdf

coxcontemptmtn
coxti070615
coxnixonltr
coxhenrymemo071615
coxgraciaaffidavit
coxclintaffidavit
coxcrissaffidavit
coxwritorder092115

AFFIDAVIT

contained

~~nv2015

It is so ORDERED

Insert from Bpdf

coxcontemptmtn
coxti070615
coxnixonltr
coxhenrymemo071615
coxgraciaaffidavit
coxclintaffidavit
coxcrissaffidavit
coxwritorder092115

contained

~~nv2015

It is so ORDERED

Insert from Bpdf

coxcontemptmtn
coxti070615
coxnixonltr
coxhenrymemo071615
coxgraciaaffidavit
coxclintaffidavit
coxcrissaffidavit
coxwritorder092115

It is so ORDERED

Insert from Bpdf

coxcontemptmtn
coxti070615
coxnixonltr
coxhenrymemo071615
coxgraciaaffidavit
coxclintaffidavit
coxcrissaffidavit
coxwritorder092115

It is so ORDERED

Insert from Bpdf

coxcontemptmtn
coxti070615
coxnixonltr
coxhenrymemo071615
coxgraciaaffidavit
coxclintaffidavit
coxcrissaffidavit
coxwritorder092115

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