Professional Documents
Culture Documents
2. Copies of Austin High School senior cumulative files audited for possible
fraud or error by Vanessa Foreman of the EPISD, when such information is
provided by Ms. Foremans attorney, or is found. If no one claims to know
where the audited files are and no one claims to have a copy, the defense
moves for a hearing with Ms. Foreman and others as witnesses, to determine
how the files disappeared.
3. The 2015-2016 audit of Austin High School conducted by EPISD IA titled
Attendance audit of attendance data and coding during Fall 2014 semester,
formerly available on EPISD IA website but recently removed, if the
Government has a copy.
4. Medical, physical, and mental reports or records on Damon Murphy for the
past three (3) years, specifically including psychiatric and psychological
records.
For the foregoing reasons, Defendant Tanner respectfully requests that this Court
grant the requested discovery in all respects.
Respectfully submitted,
/s/ Elizabeth Rogers
ELIZABETH ROGERS
State Bar No. 17165400
509 N. 6th Street
Alpine, Texas 79830
lizrogersalpine@yahoo.com
432-538-7070
432-386-6567 - fax
/s/ Thomas W. Mills, Jr.
THOMAS W. MILLS, JR.
State Bar No. 14167500
MILLS & WILLIAMS, L.L.P.
Premier Place, Suite 980
5910 N. Central Expressway
Dallas, Texas 75206-5141
tmills@millsandwillilams.com
214-265-9265
214-363-3167 - fax
ATTORNEYS FOR DEFENDANT
CERTIFICATE OF SERVICE
I hereby certify that on this 15th day of December, 2016, I electronically filed the
foregoing instrument, using the ECF system of this Court. A copy of this instrument is being
provided to all counsel of record via the ECF system of the court.
/s/ Thomas W. Mills, Jr.
THOMAS W. MILLS, JR.