TITUS COUNTY · DISTRICT ATTORNEY
Kyle first contacted Titus County District Attorney Charles C. Bailey about an MPPD matter in October 2025. The later records complaints broadened the question: what did the reviewing office hold, what did it produce, and how did it evaluate the City’s conduct?
Collected by Kyle Douglas Moring · correspondence and determinations from 2025–2026
CURRENT STATUS · SEPTEMBER 25, 2026
On August 13, Kyle submitted two signed § 552.3215 complaints concerning the City: OAG ruling OR2026-018153 and the vendor-cybertheft matter, OR2026-027532. Bailey acknowledged the first and sent the second to Austin Beck that day. His August 26 replies said both remained under review while he awaited Beck’s response.
On September 13, Bailey asked Beck why he should not find that the rulings had not been followed and said they had discussed both matters in Mount Pleasant on August 28. Beck responded September 14. The City transmitted records on September 15 and 16. Receipt of those productions does not, by itself, decide their timeliness, completeness or the merits of the complaints.
Kyle’s status report, September 25: I still have not received a written determination on either complaint. If August 13 is the official filing date, more than 30 days have passed. I have also asked Bailey to confirm the filing dates.
Section 552.3215(g) describes a determination and written-notice period before the 31st day after a complaint is filed; subsection (h) separately addresses conflict notice. The filing-date premise remains expressly qualified here because Kyle requested confirmation and has not received it.
01 / WHO WAS BEING REVIEWED?
Section 552.3215 provides a civil-enforcement complaint process. A complaint against a district attorney’s office goes to the Attorney General. A PIA review is distinct from a criminal prosecution decision.
Read Texas Government Code § 552.3215 ↗Bailey’s May 29, 2026 letter states: I find no violation of the Texas Public Information Act in your complaint or in the supplemental material you provided relative to said complaint.
He says his office will bring no action against the City and adopts the OAG’s May 22 determination.
The OAG’s April 17 letter finds apparent violations concerning TCDA’s failure to provide a delayed-production certification and its failure to make a timely determination or give conflict notice on the City complaint. It declines action because the violations appear cured, relying in part on TCDA’s assurance that all responsive information had been released.
The letter allows revision on new, relevant and persuasive information. Kyle’s later submissions challenge the completeness premise.
Read the OAG determination and original complaint · PDF ↗02 / NOTICE, RESPONSE, FOLLOW-UP
Kyle asks Charles C. Bailey for intake and status information concerning an MPPD matter. Bailey replies that MPPD consulted him, that he requested further investigation, and that he requested a report. This investigative-status exchange is separate from the later public-records complaints.
Supporting correspondence · PDF ↗Kyle submits a § 552.3215 complaint to Bailey about the City’s public-information practices. Bailey’s later preliminary letter lists this submission and subsequent supplements.
Supporting correspondence · PDF ↗Bailey asks Kyle to send the records supporting the City-conduct and records-practices complaint. This begins the separate City-records review track.
Supporting correspondence · PDF ↗Kyle leaves a January 8 voicemail asking Bailey to return his call about the public-information correspondence. On February 9, TCDA Staff says Bailey has the documents but has not reviewed them and describes a court and trial backlog. The voicemail proves a message was left, not that Bailey heard it; the staff call records the status reported that day.
Listen to the reviewed calls and read the limitations ↗Kyle requests TCDA’s records on February 27, then files a March 30 complaint with the OAG about the response and incomplete production.
Supporting correspondence · PDF ↗Bailey says the release was all that was responsive, while explaining that he omitted Kyle’s own emails. Richardson says responsive correspondence should be released even if Kyle already has it. Later productions include the Bailey–MPPD exchange and attachments on April 5.
Supporting correspondence · PDF ↗Bailey issues a preliminary response on the City complaint. The next day, the OAG finds apparent violations by TCDA but declines action because it considers them cured.
Supporting correspondence · PDF ↗The OAG accepts the City’s completeness and rolling-production statements and closes its administrative review on the grounds stated in the letter. The letter is the determination Bailey later adopts.
Supporting correspondence · PDF ↗Bailey finds no PIA violation and adopts the OAG’s May 22 determination. Kyle challenges the scope of that review and the completeness of TCDA’s production.
Supporting correspondence · PDF ↗Bailey separately finds no Open Meetings Act violation and says his office will bring no action against the City.
Supporting correspondence · PDF ↗Kyle submits separate supplements about forwarded emails, review scope, and sensitive information in the April 5 production.
Supporting correspondence · PDF ↗Richardson considers the remaining actionable issues addressed, identifies another complaint route for response issues, excludes the disclosure issue from this review, and reports Bailey’s agreement to provide messages as attachments.
Supporting correspondence · PDF ↗Bailey asks City counsel why he should not find that the two OAG rulings were not followed and says he discussed both matters with Beck in Mount Pleasant on August 28. The City responds, then transmits records on September 15 and 16. Kyle reports that no written determination from Bailey has followed.
Supporting correspondence · PDF ↗The preliminary City letter was transmitted in April 2026 but prints “April 16, 2025” on its face. The source copy retains that discrepancy.
03 / THE SAME RECORDS IN DIFFERENT HANDS
The connection is documented correspondence between the offices, not simply their shared location.
In its January 20 response, MPPD answered several requested categories No such records exist.
For the DFPS/CPS item, it said there had been no communication between Detective Odom and DFPS or CPS and directed Kyle to that agency for its paperwork.
The February 5–6 exchange shows Bailey asking April Nipp for the referenced case material. Nipp replies that the complete report and attachments are attached and offers the videos. Bailey forwards that exchange to Kyle on April 5.
Kyle’s May 31 revision request identifies his own September 6 DFPS report in the attached case packet, together with a notification addressed to Mount Pleasant PD and a dismissal form that he says the City had not supplied. The displayed DFPS copy carries a local C:/Users/codom/Downloads/… path. That path supports that the displayed copy was opened or saved under that Windows user profile; it does not, by itself, identify the report’s author or establish every transmission step.
How were the DA-held City records reconciled with the City’s earlier answers before Bailey found no PIA violation? The January response’s statement about a named detective is narrower than a claim that no DFPS-related record existed anywhere in the department. The relevant comparison is the requested category, the actual answer and the particular record later produced.
04 / SENSITIVE INFORMATION
Kyle’s June 9 supplement identifies two third-party Social Security numbers, reporter-identifying information and an individual’s CPS/DFPS case-history information in the attachments Bailey forwarded. The DFPS report itself was Kyle’s report to DFPS. He asks whether the production was reviewed, what authorized its release, and what corrective or secure-handling action followed.
These are documented disclosure allegations and requests for review. The public evidence here is the correspondence describing and responding to the disclosure; private numbers, identities and identifying case histories are not reproduced. The comparison below includes a redacted excerpt showing the DFPS referral’s recipient, date and disposition.
The June 9 notice distinguishes the Social Security redaction concern from the separate claim that child-related information may be confidential. It requests confidential handling and does not ask the OAG to infer criminal intent from the forwarding event alone.
Read the June 9 notice · PDF ↗Richardson says the disclosure issue will not be considered in that complaint review because it concerns circumstances after the request was handled and a separate request. That is a scope decision. The letter does not decide whether the release was proper or direct corrective action. In the objection Richardson forwarded to Bailey on July 24, Kyle disputed that chronology: the disclosure occurred on April 5 in response to the February 27 request, before the April 17 determination.
Read the questions and numbered answers together · PDF ↗This April 5 DA production is separate from the City’s later disclosure of an unredacted police report discussed in the May–June Council correspondence. Follow the City disclosure notices ↗
MPPD · REQUEST SCOPE AND PRODUCTION HISTORY
This comparison addresses record possession, request scope and production chronology. It does not resolve the underlying allegations.
Two continuous excerpts from Kyle’s September 10 recording. Times refer to the original recording; the descriptions summarize the exchanges.
The exchange concerns whether the matter had been reported to MPPD earlier. It does not establish whether Walmart or anyone else reported it to a different authority.
Odom says he has the report Kyle filed with DFPS. The limited routing-header excerpt is linked above. The personal intake narrative is not reproduced.
The original City workbook confirms the selected rows below. Matching incoming and outgoing entries are both preserved in the 23-row source extract. The timeline groups those paired entries as one internal call event; separate timestamps remain separate calls. The logs identify telephone lines, timing and duration, not who answered or what was discussed.
Nipp’s January 20 response is timestamped 3:17 PM. The later supplement is timestamped January 22 at 10:37 AM. Bailey’s request for the file is dated February 5 at 9:53 AM; Nipp’s response is February 6 at 8:30 AM. A short logged connection does not establish a substantive conversation.
| Stored time (CST) | From → to | Duration | Original worksheet rows |
|---|---|---|---|
| 2026-01-20 02:27:22 PM CST | April Nipp → Cody Odom | 00:00:04 | User 31040, User 31041 |
| 2026-01-20 02:47:03 PM CST | Cody Odom → April Nipp | 00:01:44 | User 20187, User 20188 |
| 2026-01-20 02:49:20 PM CST | Cody Odom → April Nipp | 00:00:06 | User 20189, User 20190 |
| 2026-01-20 02:49:33 PM CST | Cody Odom → April Nipp | 00:00:04 | User 20191, User 20192 |
| 2026-01-20 02:51:12 PM CST | Cody Odom → April Nipp | 00:00:39 | User 20193, User 20194 |
| 2026-01-20 02:53:20 PM CST | Cody Odom → Private caller [redacted] | 00:00:46 | User 5083 |
| 2026-01-20 02:57:06 PM CST | Private caller [redacted] → Police Dept 4 | 00:00:05 | Group 9808 |
| 2026-01-20 02:58:03 PM CST | Private caller [redacted] → Cody Odom | 00:01:03 | User 31042 |
| 2026-01-22 09:35:31 AM CST | Private caller [redacted] → Cody Odom | 00:01:24 | User 31049 |
| 2026-02-05 10:13:31 AM CST | Cody Odom → April Nipp | 00:00:03 | User 20339, User 20340 |
| 2026-02-05 10:20:33 AM CST | Cody Odom → April Nipp | 00:00:02 | User 20343, User 20344 |
| 2026-02-05 10:30:31 AM CST | Cody Odom → April Nipp | 00:00:02 | User 20345, User 20346 |
| 2026-02-05 10:42:32 AM CST | Cody Odom → April Nipp | 00:00:06 | User 20347, User 20348 |
| 2026-02-06 10:53:53 AM CST | Senior Officer line → DA office number | 00:06:04 | User 6538 |
The January sequence was raised in Kyle’s April 7 recusal packet and April 8 Rangers submission. Read the redacted recusal packet. The sequence raises a question about handling and follow-up; timing alone does not prove improper coordination.
05 / FORMAT, METADATA & COMPLETENESS
Kyle’s June 6 submission explains why forwarding visible message text does not necessarily preserve the original message identifiers, complete headers, thread relationships or attachment relationships. His concern is whether the production can be checked for completeness, not merely whether the words can be read.
The resulting question is specific: how was native-file completeness and the metadata dispute evaluated before the determination when Bailey later said he did not know how to transmit protected native attachments and later needed IT assistance to complete an email audit?
JULY 24 · RICHARDSON COPIED ON BOTH MESSAGES
“I am not familiar with how to send you the other attachments in native form with attachments protected.”
Bailey offers to send the files if Kyle explains how and identifies any missing messages. Kyle replies that all three unredacted attachments were already embedded in the native email Bailey had just supplied. He identifies five missing original messages, distinguishes his audio files from the “videos” referenced in the exchange, and questions whether the materials were reviewed in sufficient detail before the City no-violation conclusion.
This is the specific exchange behind Kyle’s criticism of Bailey’s handling of native files. Bailey’s statement concerns sending native attachments with protected information; it does not establish that he knew nothing about electronic records.
Read both July 24 messages · 3 selected pages · PDF ↗The submission distinguishes an original message supplied as an attachment from a new email containing quoted text. In July, Kyle also reports receiving derivative scans despite requesting existing electronic files and available metadata. The OAG’s July 22 response reports Bailey’s agreement to provide the messages in question as attachments rather than forwards.
On August 26, Bailey says his office received an email audit from Bryan IT but could not perform the needed subject-line redactions. He reports asking Seth Bryan to identify dates of birth using a script and says the audit will be sent after the redactions are completed.
This email documents a specific technical limitation and the effort to address it. It supports examining the office’s production practices without assuming Bailey’s knowledge or intent.
Read Bailey’s August 26 explanation · page 1 · PDF ↗The City’s March 10 response separately describes Bryan IT performing complex mailbox searches. These records concern different offices and different tasks: mailbox searches for the City, and subject-line redactions for Bailey’s office. Neither statement establishes the other office’s capabilities or anyone’s intent.
Read the City’s March 10 description · E04, page 3 ↗06 / OPEN MEETINGS COMPLAINT
The Open Meetings Act complaint was a separate matter from the public-information complaint. Bailey’s June 6, 2026 letter states: I find no violation of the Texas Open Meeting Act in your complaint or in the supplemental material you provided relative to said complaint. Therefore, no action will be brought by this office against the City of Mount Pleasant.
The letter gives that conclusion without identifying the evidence analyzed or explaining how the specific allegations were resolved. It is Bailey’s no-action determination, not a court order dismissing a lawsuit.
Read the complete June 6 TOMA determination · PDF ↗The City-counsel correspondence below concerns the unredacted-record dispute. Its timing provides context for Kyle’s concern about independent review, but the correspondence does not establish that Ream directed the TOMA decision.
07 / REAM CORRESPONDENCE & INDEPENDENCE
Bailey’s April preliminary letter says his office is communicating with the City Attorney to evaluate the City’s responses. His May 29 production reply describes emails with Richardson but says he has no other communications with anyone concerning the complaint. Later on May 29, after Bailey’s PIA determination, Ream emails Bailey, copies Beck and asks to discuss issues raised regarding Kyle Moring.
The subsequent emails document attempts to schedule a call; they do not establish that the call occurred or what was discussed.
At the June 16 Council meeting, Kyle publicly described Ream’s May 29 contact with Bailey and contrasted it with Bailey’s April 5 production of unredacted material responsive to the complaint Bailey had rejected. The linked prepared statement identifies what Kyle intended to say; the official meeting video is the source for the delivered remarks.
On September 13, Bailey wrote that he and Beck had discussed both pending complaints in Mount Pleasant on August 28. That later statement documents an in-person discussion about both complaints and belongs in the contact chronology.
In an April 7 response to Kyle’s recusal request concerning the related police matter, Bailey rejects the premise: I represent the State of Texas. I do not have a conflict.
That response belongs alongside Kyle’s concern about a review involving records already held by the reviewer’s office.
Kyle filed the original mandamus petition on June 1. Judge Angela Saucier and a second presiding judge each signed an order recusing from the case on June 8 and requested reassignment. The orders document the recusals but state no reason; they do not establish that either judge agreed with Kyle’s allegations or connect the recusals to Bailey.
Read both June 8 recusal orders · 4 pages · PDF ↗08 / READ THE RECORD
Selected source pages retain the officials’ responses and Kyle’s submissions. Personal identifiers are removed. Page references refer to these reading copies.
KYLE’S QUESTION
I want an account of the records searched, the material considered, the conflicting responses reconciled, and the steps taken after sensitive information was disclosed. The letters show what was decided. The supporting records let readers assess whether those decisions answered the concerns.
Send a correction or an additional source ↗June 30 release ruling, September production and the related disclosure concerns →