On April 06, 2023 a
Hearing
was filed
involving a dispute between
Mitchell, Robert Wayne,
and
Tdc, Id, Bryan Collier,
for OTHER (CIVIL)
in the District Court of Dallas County.
Preview
FILED
2/23/2024 4:12 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Brandon Keys DEPUTY
CAUSE NO. DC-23-04417
ROBERT WAYNE MITCHELL, § IN THE DISTRICT COURT
TDCJ # 02373453, §
§
Plaintiff, §
§
v. § 298TH JUDICIAL DISTRICT
§
BRYAN COLLIER, EXECUTIVE §
DIRECTOR, TEXAS §
DEPARTMENT OF CRIMINAL §
JUSTICE, §
§
Defendant. § DALLAS COUNTY, TEXAS
NOTICE OF HEARING ON DEFENDANT’S PLEA TO THE JURISDICTION
AND EMERGENCY MOTION FOR STAY OF TRIAL PROCEEDINGS
TO THE HONORABLE JUDGE OF SAID COURT:
NOTICE IS HEREBY GIVEN that Defendant Bryan Collier has filed in the above-
styled and -numbered case a (1) Plea to the Jurisdiction, and (2) Emergency Motion
for Stay of Trial Proceedings Pending Determination of Jurisdiction. Hearing has
been set to consider the Plea to the Jurisdiction and Emergency Motion for Stay on:
Thursday, February 29, 2024 at 9:00 A.M.
(via ZOOM videoconference)
Please be advised that this Notice of Hearing has been submitted this day to
comport with Rule 2.11 of the Local Rules for the Civil Courts of Dallas County and
Rule 21(b) of the Texas Rules of Civil Procedure. Upon receipt of the videoconference
hearing information from the Court (e.g. Zoom hearing link, Zoom Meeting ID, etc.),
Defendant’s Counsel will immediately forward the same to Plaintiff and his attorney,
unless the Court has already published the information needed for the participants
to participate in this proceeding on the Dallas County, Texas Courts Portal.
DATED this 23rd day of February, 2024.
Respectfully submitted,
KEN PAXTON
Attorney General of Texas
BRENT WEBSTER
First Assistant Attorney General
JAMES LLOYD
Deputy Attorney General for Civil Litigation
SHANNA MOLINARE
Chief, Law Enforcement Defense Division
/s/ Jordan D. Ninh
JORDAN D. NINH
Assistant Attorney General
Texas State Bar No. 24121036
Attorney-in-Charge
Office of the Attorney General
Law Enforcement Defense Division
P.O. Box 12548, Capitol Station
Austin, Texas 78711-2548
(512) 936-0808 / Fax (512) 370-9814
Jordan.Ninh@oag.texas.gov
ATTORNEYS FOR DEFENDANT
CERTIFICATE OF SERVICE
I, JORDAN D. NINH, Assistant Attorney General of Texas, certify that on
February 23, 2024, a true copy of the foregoing has been served on all counsel of
record via the Electronic Case Filing System of Dallas County, Texas.
/s/ Jordan D. Ninh
JORDAN D. NINH
Assistant Attorney General
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.
Jordan Ninh on behalf of Jordan Ninh
Bar No. 24121036
jordan.ninh@oag.texas.gov
Envelope ID: 84859761
Filing Code Description: Notice Of Hearing / Fiat
Filing Description: ON PLEA TO THE JURISDICTION AND MOTION TO
STAY
Status as of 2/25/2024 11:32 PM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Margaret Espino Margaret.Espino@oag.texas.gov 2/23/2024 4:12:01 PM SENT
Associated Case Party: ROBERTWAYNEMITCHELL
Name BarNumber Email TimestampSubmitted Status
Taj Warren twarren@warrenlawpllc.com 2/23/2024 4:12:01 PM SENT
Document Filed Date
February 29, 2024
Case Filing Date
April 06, 2023
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Preview
FILED 2/23/2024 4:12 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Brandon Keys DEPUTY CAUSE NO. DC-23-04417 ROBERT WAYNE MITCHELL, § IN THE DISTRICT COURT TDCJ # 02373453, § § Plaintiff, § § v. § 298TH JUDICIAL DISTRICT § BRYAN COLLIER, EXECUTIVE § DIRECTOR, TEXAS § DEPARTMENT OF CRIMINAL § JUSTICE, § § Defendant. § DALLAS COUNTY, TEXAS NOTICE OF HEARING ON DEFENDANT’S PLEA TO THE JURISDICTION AND EMERGENCY MOTION FOR STAY OF TRIAL PROCEEDINGS TO THE HONORABLE JUDGE OF SAID COURT: NOTICE IS HEREBY GIVEN that Defendant Bryan Collier has filed in the above- styled and -numbered case a (1) Plea to the Jurisdiction, and (2) Emergency Motion for Stay of Trial Proceedings Pending Determination of Jurisdiction. Hearing has been set to consider the Plea to the Jurisdiction and Emergency Motion for Stay on: Thursday, February 29, 2024 at 9:00 A.M. (via ZOOM videoconference) Please be advised that this Notice of Hearing has been submitted this day to comport with Rule 2.11 of the Local Rules for the Civil Courts of Dallas County and Rule 21(b) of the Texas Rules of Civil Procedure. Upon receipt of the videoconference hearing information from the Court (e.g. Zoom hearing link, Zoom Meeting ID, etc.), Defendant’s Counsel will immediately forward the same to Plaintiff and his attorney, unless the Court has already published the information needed for the participants to participate in this proceeding on the Dallas County, Texas Courts Portal. DATED this 23rd day of February, 2024. Respectfully submitted, KEN PAXTON Attorney General of Texas BRENT WEBSTER First Assistant Attorney General JAMES LLOYD Deputy Attorney General for Civil Litigation SHANNA MOLINARE Chief, Law Enforcement Defense Division /s/ Jordan D. Ninh JORDAN D. NINH Assistant Attorney General Texas State Bar No. 24121036 Attorney-in-Charge Office of the Attorney General Law Enforcement Defense Division P.O. Box 12548, Capitol Station Austin, Texas 78711-2548 (512) 936-0808 / Fax (512) 370-9814 Jordan.Ninh@oag.texas.gov ATTORNEYS FOR DEFENDANT CERTIFICATE OF SERVICE I, JORDAN D. NINH, Assistant Attorney General of Texas, certify that on February 23, 2024, a true copy of the foregoing has been served on all counsel of record via the Electronic Case Filing System of Dallas County, Texas. /s/ Jordan D. Ninh JORDAN D. NINH Assistant Attorney General 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. Jordan Ninh on behalf of Jordan Ninh Bar No. 24121036 jordan.ninh@oag.texas.gov Envelope ID: 84859761 Filing Code Description: Notice Of Hearing / Fiat Filing Description: ON PLEA TO THE JURISDICTION AND MOTION TO STAY Status as of 2/25/2024 11:32 PM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Margaret Espino Margaret.Espino@oag.texas.gov 2/23/2024 4:12:01 PM SENT Associated Case Party: ROBERTWAYNEMITCHELL Name BarNumber Email TimestampSubmitted Status Taj Warren twarren@warrenlawpllc.com 2/23/2024 4:12:01 PM SENT