On November 12, 2015 a
Party Discovery
was filed
involving a dispute between
Attorney General Of Texas,
Smith, Carlos Allen,
Smith, Tamisika Kofi,
and
Fort Bend Independent School District,
Vingle, Lynae,
Smith, Carlos Allen,
Smith, Tamisika Kofi,
for Divorce - With Children
in the District Court of Fort Bend County.
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No. 15-DCV-227783
IN THE INTEREST OF § IN THE DISTRICT COURT
§
T.S., C.S., AND CS., § 328TH JUDICIAL DISTRICT
§
CHILDREN § FORT BEND COUNTY, TEXAS
RULE 11 AGREEMENT
The undersigned counsel for Carlos Smith and the undersigned counsel for Fort Bend
Independent School District (FBISD) and Lynae Vingle enter into this agreement pursuant to
Texas Rule of Civil Procedure 11 with regard to FBISD and Vingle’s motion for protective order
seeking to preserve their attorney-client privilege, which was filed with the Court on September
17, 2019.
Carlos Smith, his representatives and attorneys agree to refrain from asking questions,
soliciting testimony, or otherwise attempting to procure information from Vingle that concerns or
relates to any communications between Vingle and FBISD employees regarding any legal matters
or legal advice.
This Agreement is entered into to resolve FBISD and Vingle’s motion for protective order
and to preserve FBISD and Vingle’s attorney-client and attorney work product privileges.
,,_ Kanal
Jamie L. Houston, Attorney for FBISD and Vingle
State Bar No. 24097847
Dated: September 18, 2019
Ziysmeister, Attorney for Carlos Smith
State Bar No. 22277850
Document Filed Date
September 18, 2019
Case Filing Date
November 12, 2015
Category
Divorce - With Children
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No. 15-DCV-227783 IN THE INTEREST OF § IN THE DISTRICT COURT § T.S., C.S., AND CS., § 328TH JUDICIAL DISTRICT § CHILDREN § FORT BEND COUNTY, TEXAS RULE 11 AGREEMENT The undersigned counsel for Carlos Smith and the undersigned counsel for Fort Bend Independent School District (FBISD) and Lynae Vingle enter into this agreement pursuant to Texas Rule of Civil Procedure 11 with regard to FBISD and Vingle’s motion for protective order seeking to preserve their attorney-client privilege, which was filed with the Court on September 17, 2019. Carlos Smith, his representatives and attorneys agree to refrain from asking questions, soliciting testimony, or otherwise attempting to procure information from Vingle that concerns or relates to any communications between Vingle and FBISD employees regarding any legal matters or legal advice. This Agreement is entered into to resolve FBISD and Vingle’s motion for protective order and to preserve FBISD and Vingle’s attorney-client and attorney work product privileges. ,,_ Kanal Jamie L. Houston, Attorney for FBISD and Vingle State Bar No. 24097847 Dated: September 18, 2019 Ziysmeister, Attorney for Carlos Smith State Bar No. 22277850