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Received and E-Filed for Record
6/6/2019 6:01 PM
Melisa Miller, District Clerk
Montgomery County, Texas
Deputy Clerk, Melissa Morris
NO. 15-12-13607
IN THE INTEREST OF § IN THE DISTRICT COURT
§
ROBERT JAMES CARLISLE, V, § 410TH JUDICIAL DISTRICT
LEIAH MICHELLE CARLISLE, §
SAMUEL JAMES CARLISLE, §
SARAH MARIE CARLISLE, AND §
MICHAEL JAMES CARLISLE §
§
CHILDREN § MONTGOMERY COUNTY, TEXAS
TEXAS RULE OF CIVIL PROCEDURE 205.2 NOTICE PRECEDING
ISSUANCE OF SUBPOENA DUCES TECUM
TO: Custodian of Records, Conroe Independent School District
Pursuant to Texas Rule of Civil Procedure 205.2, you are hereby notified that the
subpoena attached as Exhibit 1 will be issued no fewer than ten days from the date that this
notice is served.
Respectfully submitted,
Kaisand Law, PLLC
2219 Sawdust Road, Suite 1701
The Woodlands, Texas 77380
Tel: (832) 210-0092
Fax: (832) 210-0093
By:
Courtney A. Kaisand
State Bar No. 24060056
ckaisand@klawpllc.com
Attorney for Robert Carlisle, IV
Certificate of Service
I certify that a true copy of the above was served on each attorney of record, party, or
non-party in accordance with the Texas Rules of Civil Procedure on June 6, 2019.
Courtney A. Kaisand
NO. 15-12-13607
IN THE INTEREST OF § IN THE DISTRICT COURT
§
ROBERT JAMES CARLISLE, V, § 410TH JUDICIAL DISTRICT
LEIAH MICHELLE CARLISLE, §
SAMUEL JAMES CARLISLE, §
SARAH MARIE CARLISLE, AND §
MICHAEL JAMES CARLISLE §
§
CHILDREN § MONTGOMERY COUNTY, TEXAS
SUBPOENA DUCES TECUM
ISSUED IN THE NAME OF THE STATE OF TEXAS
ISSUED ON JUNE 16, 2019
TO ANY SHERIFF OR CONSTABLE OF THE STATE OF TEXAS OR OTHER PERSON
AUTHORIZED TO SERVE SUBPOENAS AS PROVIDED IN TEXAS RULE OF CIVIL
PROCEDURE 176.
YOU ARE HEREBY COMMANDED TO SUMMON THE FOLLOWING WITNESS:
Carrie Galatas, Custodian of Records
Conroe Independent School District
3205 West Davis
Conroe, Texas 77304
(936) 709-7752
Said witness is hereby commanded to produce at said time and place set forth above the items
contained within Exhibit A, attached on or before June 19, 2019.
Said witness need not personally appear at the time and place of production and may instead, to
the extent practicable, e-mail the requested records to ckaisand@klawpllc.com or fax said
records to 832-210-0093. Regardless of the method of production, the records must be
accompanied by a completed, signed, and notarized affidavit authenticating the records (such an
affidavit is attached hereto).
This subpoena is issued at the instance of Robert Carlisle, IV, Respondent in the above-styled
and numbered cause of action, by and through her attorney of record, Courtney A. Kaisand.
WARNING
FAILURE OF ANY PERSON WITHOUT ADEQUATE EXCUSE TO OBEY A
SUBPOENA SERVED ON THAT PERSON MAY BE DEEMED A CONTEMPT OF THE
COURT FROM WHICH THE SUBPOENA IS ISSUED OR A DISTRICT COURT IN
Subpoena Duces Tecum Page 1 of 3
THE COUNTY IN WHICH THE SUBPOENA IS SERVED, AND MAY BE PUNISHED
BY FINE, OR CONFINEMENT, OR BOTH.
This subpoena is issued by:
Kaisand Law, PLLC
2219 Sawdust Road, Suite 1701
The Woodlands, Texas 77380
Tel: (832) 210-0092
Fax: (832) 210-0093
By:
Courtney A. Kaisand
State Bar No. 24060056
ckaisand@klawpllc.com
Attorney for Robert Carlisle, IV
Subpoena Duces Tecum Page 2 of 3
EXHIBIT A
A. Any and all records and documents related in any way to the following children:
(1) Robert James Carlisle, V, (2) Leiah Michelle Carlisle, (3) Samuel James Carlisle,
(4) Sarah Marie Carlisle, and (5) Michael James Carlisle, including, but not limited
to:
1. Registration forms
2. Attendance records
3. Report cards
4. Progress reports
5. Evaluations
6. Standardized test scores
7. Behavioral reports or disciplinary actions taken
8. Teachers' comments or recommendations
9. Notations from parent-teacher conferences
10. Telephone records or other notations between any parent and the school,
including dates of the calls and contents
11. E-mails between teachers and/or school staff and either parent of the child
12. Counseling reports or counseling recommendations
13. Authorizations on file on persons who may pick up the child at school
14. Any written letters from a parent to the school as to specific instructions or
restrictions concerning the child, release of information concerning the child, or
notification of activities or conferences
15. School health records and school nurses' notes
16. Designations of persons to be contacted in an emergency
17. Records of admission, review, and dismissal (ARD)
B. Executed business records affidavit
Subpoena Duces Tecum Page 3 of 3
NO. 15-12-13607
IN THE INTEREST OF § IN THE DISTRICT COURT
§
ROBERT JAMES CARLISLE, V, § 410TH JUDICIAL DISTRICT
LEIAH MICHELLE CARLISLE, §
SAMUEL JAMES CARLISLE, §
SARAH MARIE CARLISLE, AND §
MICHAEL JAMES CARLISLE §
§
CHILDREN § MONTGOMERY COUNTY, TEXAS
AFFIDAVIT FOR BUSINESS RECORDS
______________________________ appeared before me today and stated under oath:
"My name is ______________________________. I am above the age of eighteen
years, and I am fully competent to make this affidavit. The facts stated in this affidavit are
within my personal knowledge and are true and correct.
"I am the custodian of the records of the office of Conroe Independent School District.
Attached to this affidavit are ______ pages of records from the office of Conroe Independent
School District. These pages of records are kept by the office of Conroe Independent School
District in the regular course of business, and it was the regular course of business of the
office of Conroe Independent School District for an employee or representative of the office
of Conroe Independent School District, with knowledge of the act, event, condition, opinion,
or diagnosis recorded, to make the record or to transmit information thereof to be included in
the record. The record was made at or near the time or reasonably soon thereafter. The
records attached to this affidavit are the original or exact duplicates of the original."
_____________________________________
Affiant
SIGNED under oath before me on _______________________.
_____________________________________
Notary Public, State of Texas
Subpoena Duces Tecum Page 4 of 3
Proof of Service
I, , accept service of the attached subpoena. I will
appear at the time and place directed in the subpoena.
Date: ___________________________
(Signature of witness)
I, , am over the age of eighteen years. I am not a party
in the above-entitled and -numbered cause of action. On at _________, I
served a subpoena, of which this is a true and correct copy, on
______________________________ by personally handing the subpoena to the named
individual or in accordance with rule 176.5(a) of the Texas Rules of Civil Procedure. I also
tendered to the witness the witness any fees required by law at the time the subpoena was
delivered.
Date: ___________________________
(Signature of person serving subpoena)
Subpoena Duces Tecum Page 5 of 3
Preview
Received and E-Filed for Record 6/6/2019 6:01 PM Melisa Miller, District Clerk Montgomery County, Texas Deputy Clerk, Melissa Morris NO. 15-12-13607 IN THE INTEREST OF § IN THE DISTRICT COURT § ROBERT JAMES CARLISLE, V, § 410TH JUDICIAL DISTRICT LEIAH MICHELLE CARLISLE, § SAMUEL JAMES CARLISLE, § SARAH MARIE CARLISLE, AND § MICHAEL JAMES CARLISLE § § CHILDREN § MONTGOMERY COUNTY, TEXAS TEXAS RULE OF CIVIL PROCEDURE 205.2 NOTICE PRECEDING ISSUANCE OF SUBPOENA DUCES TECUM TO: Custodian of Records, Conroe Independent School District Pursuant to Texas Rule of Civil Procedure 205.2, you are hereby notified that the subpoena attached as Exhibit 1 will be issued no fewer than ten days from the date that this notice is served. Respectfully submitted, Kaisand Law, PLLC 2219 Sawdust Road, Suite 1701 The Woodlands, Texas 77380 Tel: (832) 210-0092 Fax: (832) 210-0093 By: Courtney A. Kaisand State Bar No. 24060056 ckaisand@klawpllc.com Attorney for Robert Carlisle, IV Certificate of Service I certify that a true copy of the above was served on each attorney of record, party, or non-party in accordance with the Texas Rules of Civil Procedure on June 6, 2019. Courtney A. Kaisand NO. 15-12-13607 IN THE INTEREST OF § IN THE DISTRICT COURT § ROBERT JAMES CARLISLE, V, § 410TH JUDICIAL DISTRICT LEIAH MICHELLE CARLISLE, § SAMUEL JAMES CARLISLE, § SARAH MARIE CARLISLE, AND § MICHAEL JAMES CARLISLE § § CHILDREN § MONTGOMERY COUNTY, TEXAS SUBPOENA DUCES TECUM ISSUED IN THE NAME OF THE STATE OF TEXAS ISSUED ON JUNE 16, 2019 TO ANY SHERIFF OR CONSTABLE OF THE STATE OF TEXAS OR OTHER PERSON AUTHORIZED TO SERVE SUBPOENAS AS PROVIDED IN TEXAS RULE OF CIVIL PROCEDURE 176. YOU ARE HEREBY COMMANDED TO SUMMON THE FOLLOWING WITNESS: Carrie Galatas, Custodian of Records Conroe Independent School District 3205 West Davis Conroe, Texas 77304 (936) 709-7752 Said witness is hereby commanded to produce at said time and place set forth above the items contained within Exhibit A, attached on or before June 19, 2019. Said witness need not personally appear at the time and place of production and may instead, to the extent practicable, e-mail the requested records to ckaisand@klawpllc.com or fax said records to 832-210-0093. Regardless of the method of production, the records must be accompanied by a completed, signed, and notarized affidavit authenticating the records (such an affidavit is attached hereto). This subpoena is issued at the instance of Robert Carlisle, IV, Respondent in the above-styled and numbered cause of action, by and through her attorney of record, Courtney A. Kaisand. WARNING FAILURE OF ANY PERSON WITHOUT ADEQUATE EXCUSE TO OBEY A SUBPOENA SERVED ON THAT PERSON MAY BE DEEMED A CONTEMPT OF THE COURT FROM WHICH THE SUBPOENA IS ISSUED OR A DISTRICT COURT IN Subpoena Duces Tecum Page 1 of 3 THE COUNTY IN WHICH THE SUBPOENA IS SERVED, AND MAY BE PUNISHED BY FINE, OR CONFINEMENT, OR BOTH. This subpoena is issued by: Kaisand Law, PLLC 2219 Sawdust Road, Suite 1701 The Woodlands, Texas 77380 Tel: (832) 210-0092 Fax: (832) 210-0093 By: Courtney A. Kaisand State Bar No. 24060056 ckaisand@klawpllc.com Attorney for Robert Carlisle, IV Subpoena Duces Tecum Page 2 of 3 EXHIBIT A A. Any and all records and documents related in any way to the following children: (1) Robert James Carlisle, V, (2) Leiah Michelle Carlisle, (3) Samuel James Carlisle, (4) Sarah Marie Carlisle, and (5) Michael James Carlisle, including, but not limited to: 1. Registration forms 2. Attendance records 3. Report cards 4. Progress reports 5. Evaluations 6. Standardized test scores 7. Behavioral reports or disciplinary actions taken 8. Teachers' comments or recommendations 9. Notations from parent-teacher conferences 10. Telephone records or other notations between any parent and the school, including dates of the calls and contents 11. E-mails between teachers and/or school staff and either parent of the child 12. Counseling reports or counseling recommendations 13. Authorizations on file on persons who may pick up the child at school 14. Any written letters from a parent to the school as to specific instructions or restrictions concerning the child, release of information concerning the child, or notification of activities or conferences 15. School health records and school nurses' notes 16. Designations of persons to be contacted in an emergency 17. Records of admission, review, and dismissal (ARD) B. Executed business records affidavit Subpoena Duces Tecum Page 3 of 3 NO. 15-12-13607 IN THE INTEREST OF § IN THE DISTRICT COURT § ROBERT JAMES CARLISLE, V, § 410TH JUDICIAL DISTRICT LEIAH MICHELLE CARLISLE, § SAMUEL JAMES CARLISLE, § SARAH MARIE CARLISLE, AND § MICHAEL JAMES CARLISLE § § CHILDREN § MONTGOMERY COUNTY, TEXAS AFFIDAVIT FOR BUSINESS RECORDS ______________________________ appeared before me today and stated under oath: "My name is ______________________________. I am above the age of eighteen years, and I am fully competent to make this affidavit. The facts stated in this affidavit are within my personal knowledge and are true and correct. "I am the custodian of the records of the office of Conroe Independent School District. Attached to this affidavit are ______ pages of records from the office of Conroe Independent School District. These pages of records are kept by the office of Conroe Independent School District in the regular course of business, and it was the regular course of business of the office of Conroe Independent School District for an employee or representative of the office of Conroe Independent School District, with knowledge of the act, event, condition, opinion, or diagnosis recorded, to make the record or to transmit information thereof to be included in the record. The record was made at or near the time or reasonably soon thereafter. The records attached to this affidavit are the original or exact duplicates of the original." _____________________________________ Affiant SIGNED under oath before me on _______________________. _____________________________________ Notary Public, State of Texas Subpoena Duces Tecum Page 4 of 3 Proof of Service I, , accept service of the attached subpoena. I will appear at the time and place directed in the subpoena. Date: ___________________________ (Signature of witness) I, , am over the age of eighteen years. I am not a party in the above-entitled and -numbered cause of action. On at _________, I served a subpoena, of which this is a true and correct copy, on ______________________________ by personally handing the subpoena to the named individual or in accordance with rule 176.5(a) of the Texas Rules of Civil Procedure. I also tendered to the witness the witness any fees required by law at the time the subpoena was delivered. Date: ___________________________ (Signature of person serving subpoena) Subpoena Duces Tecum Page 5 of 3