CAUSE NO.

DC-15-14846
RICHARD D. YOUNG
Plaintiff,
V.
DALLAS INDEPENDENT SCHOOL
DISTRICT and Zachary Hall,
Individually,
Defendants.

IN THE DISTRICT COURT OF

101st

JUDICIAL DISTRICT

DALLAS COUNTY, TEXAS

PLAINTIFFS FIRST REQUEST FOR PRODUCTION OF DOCUMENTS

COMES NOW, Plaintiff Richard D. Young, pro se, serves this first Request for Production of
Documents to Defendants Dallas Independent School District (DISD) (the district), and
Zachary Hall (Hall), by and through their counsel of record, pursuant to Texas Rule of Civil
Procedure 196.

Respectfully Submitted,

Richard D. Young (pro se)

3810 Inwood Rd. #116
Dallas, TX 75209
Cell (972)201-6681
Home (469)914-2240
YoungRichardD@yahoo.com

Requests for Production

Request for Production no. 1:
Please produce the complete personnel file of Plaintiff.
Response:
Request for Production no. 2:
Please produce the complete personnel file of Zachary Hall.
Response:
Request for Production no. 3:
Please produce the complete personnel file of Kathleen Dunn.
Response:
Request for Production no. 4:
Please produce the complete personnel file of Veronica Miranda
Response:
Request for Production no. 5:
Please produce the complete personnel file of Susan Clark
Response:
Request for Production no. 6:
Please produce the complete personnel file of Maria Rodriguez
Response:
Request for Production no. 7:
Please produce the complete personnel file of Nicole Brown
Response:
Request for Production no. 8:
Please produce the complete personnel file of David Villegas
Response:
Request for Production no. 9:
Please produce the complete personnel file of Maria Scully
Response:

Request for Production no. 10:

Please produce the complete personnel file of Marco Cabrera
Response:
Request for Production no. 11:
Please produce the complete personnel file of Geraldine Stolar-Harrison
Response:
Request for Production no. 12:
Please produce the complete personnel file of Mario Perez
Response:
Request for Production no. 13:
Please produce the complete personnel file of Johanna Bahena
Response:
Request for Production no. 14:
Please produce the complete personnel file of Hebert DaSilva
Response:
Request for Production no. 15:
Please produce the complete personnel file of Stacia MacLeod
Response:
Request for Production no. 16:
Please produce the complete personnel file of Adrian Noria
Response:
Request for Production no. 17:
Please produce the complete personnel file of Tammy Cyra
Response:
Request for Production no. 18:
Please produce the complete personnel file of Pamela Shealy
Response:

Request for Production no. 19:

Please produce the complete personnel file of DeLauren Kruzel
Response:
Request for Production no. 20:
Please produce the complete personnel file of Douglas Burak
Response:
Request for Production no. 21:
Please produce the complete personnel file of Etta Spivey
Response:
Request for Production no. 22:
Please produce the complete personnel file of Lisa Smith
Response:
Request for Production no. 23:
Please produce the complete personnel file of Jose Amesty Reyes
Response:
Request for Production no. 24:
Please produce the complete personnel file of the staff member whom replaced Plaintiff
Response:
Request for Production no. 25:
Please produce Plaintiffs time sheets from January 1, 2015-February 28, 2015
Response:
Request for Production no. 26:
Please produce the time sheets of the staff member whom replaced Plaintiff in March 2015
Response:
Request for Production no. 27:
Please produce the time sheets of Veronica Miranda from January 1, 2015-February 28, 2015
Response:

Request for Production no. 28:

Please produce the time sheets of Nicole Brown from January 2, 2015-February 28, 2015
Response:
Request for Production no. 29:
Please produce the time sheets of Marco Cabrera from January 2, 2015-February 28, 2015
Response:
Request for Production no. 30:
Please produce the time sheets of Geraldine Stolar-Harrison from January 2, 2015-February 28,
2015
Response:
Request for Production no. 31:
Please produce the time sheets of Samuel Perfecto-Cordova from January 2, 2015-February 28,
2015
Response:
Request for Production no. 32:
Please produce the time sheets of Takeila Berkins from January 2, 2015-February 28, 2015
Response:
Request for Production no. 33:
Please produce the time sheets of Nestor Hernandez from January 2, 2015-February 28, 2015
Response:
Request for Production no. 34:
Please produce the time sheets of SaBrina Gonzalez from January 2, 2015-February 28, 2015
Response:
Request for Production no. 35:
Please produce the time sheets of Pedro Perez from January 2, 2015-February 28, 2015
Response:
Request for Production no. 36:
Please produce the time sheets of Mario Perez from January 2, 2015-February 28, 2015
Response:

Request for Production no. 37:

Please produce the time sheets of Jose Amesty-Reyes from January 2, 2015-February 28, 2015
Response:
Request for Production no. 38:
Please produce the time sheets of Juan Chaves from January 2, 2015-February 28, 2015
Response:
Request for Production no. 39:
Please produce the time sheets of Shaunnia Williams from January 2, 2015-February 28, 2015
Response:
Request for Production no. 40:
Please produce any and all grievances and complaints filed against Zachary Hall during the
2014-2015 school year.
Response:
Request for Production no. 41:
Please produce any and all grievances and complaints filed against Hebert DaSilva during the
2014-2015 school year.
Response:
Request for Production no. 42:
Please produce any and all grievances and complaints filed against Susan Clark during the 20142015 school year.
Response:
Request for Production no. 43:
Please produce any and all grievances and complaints filed against DeLauren Kruzel during the
2014-2015 school year.
Response:
Request for Production no. 44:
Please produce any and all emails that were sent to Plaintiff, received by any Defendant from
Plaintiff, or mention Plaintiff, by name or title, from September 1, 2014-August 31, 2015.
Response:

Request for Production. 45:

Please produce any and all instant messages that mention Plaintiff, by name or title, from
September 1, 2014-August 31, 2015.
Response:
Request for Production no. 46:
Please produce the complete paper copy of the 2014-2015 Employee Handbook
Response:
Request for Production no. 47:
Please produce the complete paper copy of the 2014-2015 Principal Handbook
Response:
Request for Production no. 48:
Please produce the complete paper copy of the TEI scoring rubric used to score Plaintiffs
performance.
Response:
Request for Production no. 49:
Please produce the complete list of any and all staff members whom were placed on Growth
Plans at Foster Elementary during the 2014-2015 school year.
Response:
Request for Production no. 50:
Please produce the complete list of any and all staff members whom filed grievances or
complaints at Foster Elementary during the 2014-2015 school year.
Response:
Request for Production no. 51:
Please produce the complete list of any and all staff members whom were placed on
administrative leave or suspended from Foster Elementary during the 2014-2015 school year.
Response:
Request for Production no. 52:
Please produce the complete list of any and all staff members whom had contract terminations,
or were fired, non-renewed, or involuntarily dismissed from Foster Elementary during or after
the close of the 2014-2015 school year.
Response:

Request for Production no. 53:

Please produce the complete list of any and all staff members whom resigned in lieu of contract
termination or non-renewal during or after the 2014-2015 school year.
Response:
Request for Production no. 54:
Please produce the complete list of any and all staff members whom voluntarily resigned or
retired from Foster elementary during or after the 2014-2015 school year and their reason.
Response:
Request for Production no. 55:
Please produce the complete list of any and all staff members whom transferred to another
location within the district, or were involuntarily reassigned during or after the 2014-2015 school
year.
Response:
Request for Production no. 56:
Please produce Plaintiffs 2014-2015 score card for his evaluation and performance.
Response:
Request for Production no. 57:
Please produce Zachary Halls concerted efforts to reduce and prevent whistleblowing retaliation
on the campus.
Response:
Request for Production no. 58:
Please produce any and all documents that evidence why Plaintiff received all zeroes on his midyear evaluation.
Response:
Request for Production no. 59:
Please produce any and all documents that evidence, that the TEI evaluation is not biased,
subjective, or moot in any way that affects the Plaintiff or his evaluation.
Response:

Request for Production no. 60:

Please produce any and all documents that evidence that the Growth Plan provisions are relevant
and consistent with the domains and categories on the TEI evaluation in which Plaintiff received
low scores.
Response:
Request for Production no. 61:
Please produce the complete investigative report by the districts Professional Standards Office
on Plaintiffs allegations against Zachary Hall including, but not limited to, all written reports,
administrative statements, witness statements, emails, instant messages, findings, decisions, etc.
Response:
Request for Production no. 62:
Please produce any and all documents that evidence why Plaintiff was placed on a Growth Plan
three calendar days after notifying law enforcement officials and Zachary Hall there were teens
trespassing and jumping off the roof of the campus.
Response:
Request for Production no. 63:
Please produce any and all documents that evidence why Plaintiff was emailed a directive to
report to work on time one day after notifying law enforcement officials and Zachary Hall there
were teens trespassing and jumping off the roof of the campus.
Response:
Request for Production no. 64:
Please produce any and all documents that evidence Defendant did not retaliate by placing
Plaintiff on a Growth Plan one school day after notifying law enforcement officials and Zachary
Hall there were teens trespassing and jumping off the roof of the campus.
Response:
Request for Production no. 65:
Please produce any and all documents that evidence Defendant did not retaliate against Plaintiff
by emailing Plaintiff directive to report to work on time one day after notifying law enforcement
officials and Zachary Hall that there were teens jumping off the roof of the campus.
Response:
Request for Production no. 66:
Please produce the termination notice by Zachary Hall notifying Plaintiff of his dismissal.
Response:

Request for Production no. 67:

Please produce any and all documents that evidence that Zachary Hall did not retaliate in any
way when Plaintiff filed a Level I Grievance ten days before notification of his dismissal from
Foster Elementary.
Response:
Request for Production no. 68:
Please produce any and all documents that evidence that Zachary Hall did not retaliate in any
way when Plaintiff filed a complaint with the districts Legal Department ten days before
notification of his dismissal from Foster Elementary.
Response:
Request for Production no. 69:
Please produce any and all documents that evidence Defendant did not violate constitutional
rights of Plaintiff when he notified law enforcement officials and Zachary Hall that there were
teens jumping off the roof of the campus.
Response:
Request for Production no. 70:
Please produce any and all documents that evidence Defendant did not violate constitutional
rights of Plaintiff when he filed a complaint with the districts Legal Department.
Response:
Request for Production no. 71:
Please produce any and all documents that evidence why Plaintiff was demoted to Special
Education Teaching Assistant immediately following spring break.
Response:
Request for Production no. 72:
Please produce any and all documents that evidence why Plaintiff was involuntarily reassigned to
Reading and Math Intervention Teacher.
Response:
Request for Production no. 73:
Please produce any and all documents that evidence Plaintiff qualified as the Special Education
Teaching Assistant when he was demoted.
Response:

Response for Production no. 74:

Please produce any and all documents that evidence Plaintiff qualified as the Reading and Math
Intervention Teacher.
Response:
Request for Production no. 75:
Please produce any and all documents that evidence Defendant, to the highest level possible,
made full training, classroom, and staff preparations when Plaintiff was involuntarily moved into
the Autism unit March 2015.
Response:
Request for Production no. 76:
Please produce any and all documents that evidence Defendant, to the highest level possible,
made full training, curriculum, classroom, and staff preparations when Plaintiff was reassigned to
his new role as Intervention Teacher.
Response:
Request for Production no. 77:
Please produce any and all documents that evidence any Defendant did not violate any statute or
provision of the Individuals with Disabilities Education Act when Plaintiff was demoted and
moved into the Autism unit March 2015.
Response:
Request for Production no. 78:
Please produce any and all documents that evidence why Plaintiff received a notice of
administrative leave two days after he was already dismissed from the campus.
Response:
Request for Production no. 79:
Please produce the complete written and recorded communications, information, and reports
from, and by, Defendant and Texas Workforce Commission-Civil Rights Division regarding
Plaintiffs complaint mailed to the Texas Workforce Commission May 2015.
Response:

Request for Production no. 80:

Please produce any and all documents that evidence Defendant responded in any way, written,
electronic, or verbal, when Plaintiff emailed Zachary Hall and Timothy Hise a payment
confirmation from TEA/SBEC that he renewed his state probationary teaching certificate before
the expiration date.
Response:
Request for Production no. 81:
Please produce any and all documents that evidence why Zachary Hall refused to issue a written
recommendation for Plaintiff for his probationary teaching certificate renewal.
Response:
Request for Production no. 82:
Please produce any and all documents that evidence why Plaintiff was placed on administrative
leave.
Response:
Request for Production no. 83:
Please produce any and all documents that evidence why Plaintiffs contract was terminated at
the end of the contract term.
Response:
Request for Production no. 84:
Please produce any and all documents that evidence any Defendant utilized conflict resolution
management with Plaintiff at any time.
Response:
Request for Production no. 85:
Please produce any and all documents that evidence Zachary Hall was qualified in his capacity
as Building principal, including the criteria used to promote him to Building Principal.
Response:
Request for Production no. 86:
Please produce any and all documents that evidence Zachary Hall was qualified to monitor,
assess, and evaluate Plaintiffs performance.
Response:

Request for Production no. 87:

Please produce any and all documents that evidence Hebert DaSilva was qualified to monitor,
assess, and evaluate Plaintiffs performance.
Response:
Request for Production no. 88:
Please produce any and all of the observations, evaluations, and performance appraisals of
Zachary Hall.
Response:
Request for Production no. 89:
Please produce any and all documents that evidence Plaintiffs teaching contract was not violated
by Defendant in any way.
Response:
Request for Production no. 90:
Please produce any and all documents that evidence why Defendant, by and through its counsel,
advertently lied to the School Board Trustees subcommittee during the Level III Grievance
Hearing, by stating Plaintiff was an at-will employee.
Response:
Request for Production no. 91:
Please produce the complete listing of all district-wide employees whom filed Whistleblower
lawsuits against the district from November 2012-August 2015.
Response:
Request for Production no. 92:
Please produce the complete listing of all district-wide employees whom filed complaints with
the Texas workforce Commission-Civil Rights Division from November 2012-August 2015.
Response:
Request for Production no. 93:
Please produce the complete listing of any and all district-wide employees whom filed
complaints with the U.S. Equal Opportunity Commission from November 2012-August 2015.
Response:

Request for Production no. 94:

Please produce any and all documents that display the Defendants current net worth.
Response:
Request for Production no. 95:
Please produce the Defendants financial and time frame agreement to be spent on this litigation.
Response:
Request for Production no. 96:
Please produce any and all documents that indicate the agreement of the maximum amount, in
U.S. dollars, to be spent on this litigation.
Response:
Request for Production no. 97:
Please produce any and all organizational charts of the Defendant for the 2014-2015 school year.
Response:
Request for Production no. 98:
Please produce any and all Common Assessments, ACP, and STAAR scores of the Plaintiff.
Response:
Request for Production no. 99:
Please produce any and all Common Assessments, ACP, and ITBS scores and results of the staff
member whom replaced Plaintiff in 2015.
Response:
Request for Production no. 100:
Please produce any and all 2014-2015 Common Assessments, ACP, and DRA scores and results
of Maria Rodriguez.
Response:
Request for Production no. 101:
Please produce any and all 2014-2015 Common Assessments, ACP, and DRA scores and results
of Nicole Brown.
Response:

Request for Production no. 102:

Please produce any and all 2014-2015 Common Assessments, ACP, and DRA scores and results
of Marco Cabrera.
Response:
Request for Production no. 103:
Please produce any and all 2014-2015 Common Assessments, ACP, and DRA scores and results
of Geraldine Stolar-Harrison.
Response:
Request for Production no. 104:
Please produce any and all 2014-2015 Common Assessments, ACP, and DRA scores and results
of Veronica Miranda.
Response:
Request for Production no. 105:
Please produce any and all 2014-2015 Common Assessments, ACP, and DRA scores and results
of Pamela Shealy.
Response:
Request for Production no. 106:
Please produce the complete 2014-2015 TEI evaluation of Pamela Shealy.
Response:
Request for Production no. 107:
Please produce the complete 2014-2015 TEI evaluation of Lisa Smith.
Response:
Request for Production no. 108:
Please produce the complete 2014-2015 TEI evaluation of Maria Rodriguez
Response:
Request for Production no. 109:
Please produce the complete 2014-2015 TEI evaluation of Nicole Brown
Response:

Request for Production no. 110:

Please produce the complete 2014-2015 TEI evaluation of Marco Cabrera
Response:
Request for Production no. 111:
Please produce the complete 2014-2015 TEI evaluation of Geraldine Stolar-Harrison
Response:
Request for Production no. 112:
Please produce the complete 2014-2015 TEI evaluation of Veronica Miranda
Response:
Request for Production no. 113:
Please produce the complete personnel file of Catherine Jernigan
Response:
Request for Production no. 114:
Please produce the complete personnel file of Jennifer Ice
Response:

CERTIFICATE OF SERVICE
Pursuant to Texas Rule of Civil Procedure 21(a), the undersigned certifies that on the
day of January, 2016, a true and correct copy of the foregoing was forwarded via regular U.S.
postal mail to Defendants Dallas Independent School District, and Zachary Hall, by and through
their counsel of record.
Respectfully Submitted,

Richard D. Young (pro se)