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 INTERROGATORIES TO DEFENDANTS

COMES NOW Plaintiff Richard D. Young, pro se, serves this first set of interrogatories,
pursuant to Texas Rule of Civil Procedure 190.3, to Defendants Dallas Independent School
District and Zachary Hall, by and through their counsel of record, on this twenty-fifth day of
January, 2016.

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

INTERROGATORIES

Interrogatory no. 1: State all staff members whom were placed on growth plans during the
2014-2015 school term at Foster Elementary.
Response:
Interrogatory no. 2: State all staff members whom received letters of concern during the
2014-2015 school term at Foster Elementary.
Response:
Interrogatory no. 3: State all staff members whom received written reprimands during the
2014-2015 school term at Foster Elementary.
Response:
Interrogatory no. 4: State all staff members whom were disciplined, written or verbal, for
tardiness during the 2014-2015 school term at Foster Elementary.
Response:
Interrogatory no. 5: State all staff members whom were placed on Administrative Leave
during the 2014-2015 school term at Foster Elementary.
Response:
Interrogatory no. 6: State all staff members whom were recommended for non-renewal or
contract termination during the 2014-2015 school term at Foster Elementary.
Response:
Interrogatory no. 7: State all staff members whom separated from Foster Elementary from
September 1, 2014-August 31, 2015 and their reasons for separation.
Response:
Interrogatory no. 8: State all district-wide employees, with their name and title, whom filed
grievances or any other internal complaints from September 1, 2014-August 31, 2015.
Response:
Interrogatory no. 9: State all staff members from Foster Elementary whom taught while
belonging to an Alternative Certification Program at any time during the 2014-2015 school
term.
Response:

Interrogatory no. 10: State the complete number of spot observation evaluations Plaintiff
received during the 2014-2015 school term.
Response:
Interrogatory no. 11: State any and all reasons why Plaintiff received low scores during his
forty-five minute mid-year evaluation in 2015.
Response:
Interrogatory no. 12: State any and all reasons why Zachary Hall did not return for the
mid-year re-evaluation as he stated to Plaintiff in 2015.
Response:
Interrogatory no. 13: State any and all reasons that evidence Plaintiff was not retaliated
against when he spoke to Romeal Johnson in Employee Relations in November 2014,
regarding the harassment and disparate treatment he received from Zachary Hall.
Response:
Interrogatory no. 14: State any and all reasons that evidence Plaintiff was not retaliated
against when he notified law enforcement officials that there were teens trespassing and
jumping off the roof of Foster Elementary after hours.
Response:
Interrogatory no. 15: State any and all reasons that evidence Plaintiff was not retaliated
against, with wanton or mens rea, when he was informed of his involuntary dismissal ten
days after he filed a grievance.
Response:
Interrogatory no. 16: State any and all reasons that evidence Plaintiff was not
discriminated against when he was racially segregated from the other kindergarten
teachers during group-wide lesson plan submission.
Response:
Interrogatory no. 17: State in full what Zachary Hall stated to Plaintiff regarding creating
his own lesson plan during the time Plaintiff was placed on a growth plan.
Response:
Interrogatory no. 18: State any and all reasons why Hebert DaSilva utilized videotaping
Plaintiff teaching his students, against his will during his first growth plan as a means of
punishment.
Response:

Interrogatory no. 19: State any and all reasons why Plaintiffs kindergarten position was
never posted when Plaintiff was involuntarily relieved of his teaching duties.
Response:
Interrogatory no. 20: State any and all reasons why Plaintiff was demoted to teaching
assistant while his teaching certificate was still valid in March 2015.
Response:
Interrogatory no. 21: State how Plaintiff legally met requirements, under the Individuals
with Disabilities Education Act, to serve as a special education assistant when demoted in
2015 at Foster Elementary.
Response:
Interrogatory no. 22: State any and all reasons why Zachary Hall and Timothy Hise
refused to take action on the payment confirmation, emailed from the Texas Education
Agency, indicating payment of probationary teacher certification extension of the Plaintiff.
Response:
Interrogatory no. 23: Fully state how Plaintiff highly and legally qualified for the new
Intervention Teacher position created for him.
Response:
Interrogatory no. 24: State any and all reasons why Defendant did not provide a
curriculum, instructional materials, supplies, and technology to Plaintiff for his students
when he was reassigned to teach Intervention in 2015.
Response:
Interrogatory no. 25: State any and all decision-maker(s), by name and title, whom played
any role to create Intervention Teacher position for Plaintiff.
Response:
Interrogatory no. 26: State any and all decision-maker(s), by name and title, whom played
any role to release Plaintiff from the district.
Response:
Interrogatory no. 27: Fully state how Zachary Hall highly qualified for his position as
building principal at Foster Elementary.
Response:

Interrogatory no. 28: State the name of the staff member whom replaced Plaintiff in his
kindergarten classroom in March 2015.
Response:
Interrogatory no. 29: State the experience and qualifications of the staff member whom
replaced Plaintiff in his kindergarten classroom in March 2015.
Response:
Interrogatory no. 30: State all district-wide employees whom filed with the Texas
Workforce Commission-Civil Rights Division from September 1, 2014-August 31, 2015.
Response:
Interrogatory no. 31: State all district-wide employees whom filed with the Equal
Employment Opportunity Commission from September 1, 2014-August 31, 2015.
Response:
Interrogatory no. 32: State all district-wide employees whom filed with the Department of
Labor from September 1, 2014-August 31, 2015.
Response:
Interrogatory no. 33: State all district-wide employees whom filed with the NAACP from
September 1, 2014-August 31, 2015.
Response:
Interrogatory no. 34: State all district-wide policies governing students running around in
the classroom.
Response:
Interrogatory no. 35: State all district-wide policies governing staff members yelling at
students.
Response:
Interrogatory no. 36: State all district-wide policies governing staff members having fastfood remains in the classroom.
Response:
Interrogatory no. 37: State all district-wide policies governing staff members submitting
lesson plans.
Response:

Interrogatory no. 38: State all district-wide policies governing required times that teachers
are to clock-in each morning.
Response:
Interrogatory no. 39: State any and all reasons why Plaintiff was released from the district.
Response:
Interrogatory no. 40: Fully State how Plaintiff was protected under Texas Education Code
Chapter 21.
Response:
Interrogatory no. 41: State how district employees are protected from whistleblowing
retaliation.
Response:
Interrogatory no. 42: State how district employees are protected from discrimination.
Response:
Interrogatory no. 43: Fully state the districts whistleblowing grievance process.
Response:
Interrogatory no. 44: Fully state the districts discrimination grievance process.
Response:
Interrogatory no. 45: State the exact date Zachary Hall was certified to evaluate teachers
using the TEI rubric.
Response:
Interrogatory no. 46: State the exact date Hebert DaSilva was certified to evaluate teachers
using the TEI rubric.
Response:
Interrogatory no. 47: Fully state the financial agreement to be spent on this litigation.
Response:
Interrogatory no. 48: Fully state the maximum amount in U.S. dollars to be spent on this
litigation (if not stated in Interrogatory no. 47).
Response:

CERTIFICATE OF SERVICE
Pursuant to Texas Rule of Civil Procedure 21(a), I hereby certify that a true and exact
copy of the foregoing document was forwarded to Defendants Dallas Independent School
District and Zachary Hall, by and through their counsel of record via U.S. regular postal mail, on
this
day of January, 2016, to the Thompson & Horton LLP, Ross Tower, 500 North
Akard Street, Suite 2550, Dallas, TX, 75201.

Respectfully Submitted,

Richard D. Young (pro se)