On May 27, 2021 a
Stipulation,Agreement
was filed
involving a dispute between
Evans, Megan Rynn, Dr.,
and
Clear Creek Independent School District,
Morath, Mike,
for Contract - Employment
in the District Court of Galveston County.
Preview
Filed: 9/24/2021 11:47 AM
JOHN D. KINARD - District Clerk
Galveston County, Texas
Envelope No. 57576836
By: Rolande Kain
9/24/2021 11:52 AM
CAUSE NO. 21-CV-0717
DR. MEGAN EVANS, § IN THE DISTRICT COURT OF
Plaintiff §
§
v. §
§ GALVESTON COUNTY, TEXAS
CLEAR CREEK INDEPENDENT §
SCHOOL DISTRICT and MIKE §
MORATH, in his individual capacity as §
Texas Commissioner of Education, § 56TH JUDICIAL DISTRICT
Defendants. §
§
RULE 11 AGREEMENT ON BRIEFING SCHEDULE
In this administrative appeal, Defendants Clear Creek Independent School District and
Mike Morath (Defendants), through their counsel, and Plaintiff, Dr. Megan Evans, through her
counsel, now file this agreed agreement:
1. The parties’ briefing schedule is as follows:
• Plaintiff’s Trial Brief, shall be filed on or before Wednesday, November 17,
2021;
• Defendant’s Trial Brief, shall be filed on or before Friday, December 17,
2021; and
• Plaintiff’s Reply Brief, if any, shall be due on or before Thursday, January
7, 2022.
2. The Hearing on the Merits shall be held on February 24, 2022 at 10:00 a.m.
3. The Signatures below reflect this is a Rule 11 Agreement and enforceable upon
filing with the court. Tex. R. Civ. P. 11.
DATED: September 24, 2021.
Agreed:
/s/ H. Julian Frachtman /s/ Clay Grover /s/ Clay Watkins
H. Julian Frachtman Clay Grover CLAYTON R. WATKINS
State Bar No.2408753 State Bar No. 08550280 Assistant Attorney General
THE LAW OFFICES OF H. Alexa Gould State Bar No. 24103982
JULIAN FRACHTMAN State Bar No. 24109940 OFFICE OF THE ATTORNEY
3100 Richmond, Suite 203 ROGERS MORRIS & GROVER, GENERAL OF TEXAS
Houston, Texas 77098 LLP Administrative Law Division
(832) 499-0611 5718 Westheimer Road, Suite P.O. Box 12548, Capitol
facsimile (713) 651-0819 1200 Station
Hfrachtmanlaw@gmail.com Houston TX 77057 Austin, Texas 78711-2548
(713) 960-6000 Telephone: (512) 475-3204
Attorney for Plaintiff Facsimile (713) 6025 Facsimile: (512) 320-0167
cgrover@rmgllp.com Clayton.Watkins@oag.texas.
agould@rmgllp.com gov
Attorneys for Defendant Counsel for Defendant
Clear Creek Independent Mike Morath, Texas
School District Education Commissioner
Cause No. 21-CV-0717; Evans v. Clear Creek ISD, et al
Rule 11 on Briefing Schedule Page 2 of 2
Automated Certificate of eService
This automated certificate of service was created by the efiling system.
The filer served this document via email generated by the efiling system
on the date and to the persons listed below. The rules governing
certificates of service have not changed. Filers must still provide a
certificate of service that complies with all applicable rules.
Laura Kiick on behalf of Clayton Watkins
Bar No. 24103982
laura.kiick@oag.texas.gov
Envelope ID: 57576836
Status as of 9/24/2021 11:52 AM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Clay T.Grover CGrover@rmgllp.com 9/24/2021 11:47:07 AM SENT
Hirsh Frachtman 24087536 hfrachtmanlaw@gmail.com 9/24/2021 11:47:07 AM SENT
Alexa Gould agould@rmgllp.com 9/24/2021 11:47:07 AM SENT
Associated Case Party: Mike Morath
Name BarNumber Email TimestampSubmitted Status
Laura Kiick laura.kiick@oag.texas.gov 9/24/2021 11:47:07 AM SENT
Clayton Watkins clayton.watkins@oag.texas.gov 9/24/2021 11:47:07 AM SENT
Document Filed Date
September 24, 2021
Case Filing Date
May 27, 2021
Category
Contract - Employment
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Preview
Filed: 9/24/2021 11:47 AM JOHN D. KINARD - District Clerk Galveston County, Texas Envelope No. 57576836 By: Rolande Kain 9/24/2021 11:52 AM CAUSE NO. 21-CV-0717 DR. MEGAN EVANS, § IN THE DISTRICT COURT OF Plaintiff § § v. § § GALVESTON COUNTY, TEXAS CLEAR CREEK INDEPENDENT § SCHOOL DISTRICT and MIKE § MORATH, in his individual capacity as § Texas Commissioner of Education, § 56TH JUDICIAL DISTRICT Defendants. § § RULE 11 AGREEMENT ON BRIEFING SCHEDULE In this administrative appeal, Defendants Clear Creek Independent School District and Mike Morath (Defendants), through their counsel, and Plaintiff, Dr. Megan Evans, through her counsel, now file this agreed agreement: 1. The parties’ briefing schedule is as follows: • Plaintiff’s Trial Brief, shall be filed on or before Wednesday, November 17, 2021; • Defendant’s Trial Brief, shall be filed on or before Friday, December 17, 2021; and • Plaintiff’s Reply Brief, if any, shall be due on or before Thursday, January 7, 2022. 2. The Hearing on the Merits shall be held on February 24, 2022 at 10:00 a.m. 3. The Signatures below reflect this is a Rule 11 Agreement and enforceable upon filing with the court. Tex. R. Civ. P. 11. DATED: September 24, 2021. Agreed: /s/ H. Julian Frachtman /s/ Clay Grover /s/ Clay Watkins H. Julian Frachtman Clay Grover CLAYTON R. WATKINS State Bar No.2408753 State Bar No. 08550280 Assistant Attorney General THE LAW OFFICES OF H. Alexa Gould State Bar No. 24103982 JULIAN FRACHTMAN State Bar No. 24109940 OFFICE OF THE ATTORNEY 3100 Richmond, Suite 203 ROGERS MORRIS & GROVER, GENERAL OF TEXAS Houston, Texas 77098 LLP Administrative Law Division (832) 499-0611 5718 Westheimer Road, Suite P.O. Box 12548, Capitol facsimile (713) 651-0819 1200 Station Hfrachtmanlaw@gmail.com Houston TX 77057 Austin, Texas 78711-2548 (713) 960-6000 Telephone: (512) 475-3204 Attorney for Plaintiff Facsimile (713) 6025 Facsimile: (512) 320-0167 cgrover@rmgllp.com Clayton.Watkins@oag.texas. agould@rmgllp.com gov Attorneys for Defendant Counsel for Defendant Clear Creek Independent Mike Morath, Texas School District Education Commissioner Cause No. 21-CV-0717; Evans v. Clear Creek ISD, et al Rule 11 on Briefing Schedule Page 2 of 2 Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules. Laura Kiick on behalf of Clayton Watkins Bar No. 24103982 laura.kiick@oag.texas.gov Envelope ID: 57576836 Status as of 9/24/2021 11:52 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Clay T.Grover CGrover@rmgllp.com 9/24/2021 11:47:07 AM SENT Hirsh Frachtman 24087536 hfrachtmanlaw@gmail.com 9/24/2021 11:47:07 AM SENT Alexa Gould agould@rmgllp.com 9/24/2021 11:47:07 AM SENT Associated Case Party: Mike Morath Name BarNumber Email TimestampSubmitted Status Laura Kiick laura.kiick@oag.texas.gov 9/24/2021 11:47:07 AM SENT Clayton Watkins clayton.watkins@oag.texas.gov 9/24/2021 11:47:07 AM SENT