Davidson Troilo Ream & Garza, P.C.

CHRONOLOGY

Key dates & context

1. October 30 & November 24, 2025Source record

   Early DA response and request for supporting documents

   On October 30 Bailey says MPPD consulted him, that he requested continued investigation and that he requested a report. Separately, his November 24 reply to Kyle’s November 17 City-conduct and records-practices complaint asks Kyle to forward documents for review.

   Context, limits & source references

   These are separate investigative-status and City-complaint exchanges. They document engagement; they do not establish completed review or identify the substance of a particular 2025 City Hall–DA call-log entry.

   • J001, October 30 response, page 1; J002, November 24 response and quoted complaint, pages 1–2
2. Dec 15, 2025Author’s account

   Kyle supplements the City complaint with inspection and records concerns

   Kyle sends a section 552.3215 supplement addressing the October 28 inspection, his October 29 request, omitted coordination records and electronic formats. This continues the November complaint and the submission of material for DA review.

   Context, limits & source references

   The submission documents the issues raised. An attachment icon does not establish that its full contents were reviewed by the DA or cleared in this audit.

   • J003, December 15 supplement, PDF page 1
3. Jan 8, 2026Recorded conversation

   January voicemail asks Bailey to return a call about TPIA correspondence

   The corrected handset screenshot shows an outgoing call to the DA main number, 903-577-6726, on January 8, 2026, at 11:57 AM for 56 seconds. Kyle confirms the office’s automated greeting, that he presses zero, and his message seeking a callback from Mr. Bailey about their correspondence regarding TPIA issues and concerns.

   Context, limits & source references

   Words and Kyle’s identity/action confirmed by Kyle on September 20. The opening contains only a mic test and the ending is background noise. The screenshot timezone and precise alignment of the 91-second recording with the handset’s 56-second call remain unverified. Leaving a message does not establish Bailey listened to it.

   • January 8 DA Phone Call (Voicemail), original audio
   • Corrected screenshot PDF, date-folder copy, page 1; County phone directory, District Attorney Office entry
4. Feb 9, 2026Recorded conversation

   TCDA Staff confirms receipt and says the documents have not yet been reviewed

   TCDA Staff says, “Sir? Yes he has them.” Kyle asks, “He still hasn’t reviewed them?” TCDA Staff answers, “No,” and describes court and trial backlog. Kyle says he will follow up next week; no review deadline is promised.

   Context, limits & source references

   The staff member reports receipt and the review status on February 9. The recording does not establish a conversation with Bailey, a promised review deadline or whether review occurred later.

   • February 9 Phone Call Transcript (TCDA Staff), PDF pages 1–5; relevant exchange 02:43–03:37
5. Mar 30, 2026Author’s account

   Escalation to OAG and a separate complaint against the DA

   Kyle’s March 12 submission recounts a February 24 mailed binder and more than 90 days without local enforcement; Intake confirms receipt and says an attorney will be assigned. On March 30 Kyle sends a complaint against TCDA. On April 2 Richardson separately directs the TOMA matter toward local law enforcement or the prosecutor.

   Context, limits & source references

   The binder mailing history is Kyle’s account; March 12 receipt is acknowledged. The City PIA complaint, complaint against TCDA and TOMA complaint have different scopes and dispositions.

   • March 12 complaint submission and intake acknowledgment; March 30 separate TCDA complaint transmittal; April 2 Richardson response on open-meetings routing.
6. Apr 17, 2026Source record

   OAG identifies two apparent TCDA violations, then declines action as cured

   OAG’s signed April 17 determination identifies an apparent missing section 552.221(d) certification and an apparent failure to determine the City complaint or provide a conflict notice within the stated period. It concludes these appeared cured and declines action, relying on TCDA’s production representation and preliminary determination.

   Context, limits & source references

   Both the adverse findings and the cure/no-action rationale belong in the account. This PIA determination does not decide every criminal allegation or establish independently that production was complete.

   • J036, April 17 determination, PDF pages 1–2; J006 transmittal
7. May 29, 2026Source record

   Bailey adopts OAG’s City findings and describes the scope of his review

   Bailey issues a City PIA no-violation/no-action letter adopting OAG’s May 22 findings. He separately says he holds the USB drives and reviewed the case file, then clarifies that PIA submissions were evaluated while no other evaluations were yet complete. OAG’s underlying determination explains its reliance on City completeness and rolling-production representations, separate ORD processes and jurisdictional limits.

   Context, limits & source references

   The PIA disposition contains an adopted rationale. It should not be described as no response or as a documented dismissal of every criminal or disclosure issue.

   • J021–J023, May 29; C201 pages 3–6, May 22 City determination; J017 transmittal
8. Jun 1, 2026Source record

   Ream and Beck’s contact with Bailey appears in produced correspondence

   On May 29 Ream, copying Beck, asks Bailey to discuss issues raised regarding Kyle in the unredacted-report thread. Bailey responds about availability; subsequent messages propose days and times. These records provide direct evidence of the counsel–DA exchange.

   Context, limits & source references

   The exchange does not establish that the proposed call occurred, its content, improper coordination or influence on a determination. It is a 2026 chain and does not explain the separate 2025 call-log entries.

   • J026 page 1 and J027 pages 1–2, May 29–June 1 scheduling chain; forwarded June 6
9. Jun 6, 2026Source record

   TOMA complaint receives a no-action letter without issue-specific analysis

   After acknowledging the complaint on May 8, Bailey’s June 6 letter states he finds no violation in the complaint or supplemental materials and will take no action. The letter does not explain how he resolved each allegation about the March 17 meeting.

   Context, limits & source references

   This supports the specific criticism that the TOMA letter lacks issue-by-issue explanation. It does not make the separate May 29 PIA disposition unexplained or establish that no review occurred.

   • J009, May 8 acknowledgment; J025, June 6 determination, page 1
10. Jun 22, 2026Records request / response

    First Amended Petition

    Moring’s amended pleading presents thirteen count-specific public-records disputes and asks for mandamus relief.

    Context, limits & source references

    These are the petitioner’s allegations, not findings that the City violated the law.

    • R001 · Cause 44437; First Amended Petition · Kyle Douglas Moring
11. Jul 22, 2026Source record

    Later OAG correspondence narrows what was closed and what was considered

    On July 7–8 Richardson closes further City review in deference to the mandamus case, leaving the May 22 determination operative unless amended. July 20–22 messages separately address the TCDA complaint, reported record completeness and section 552.328 routing. Richardson declines to consider a later disclosure issue within that complaint because it involved subsequent circumstances and a separate request.

    Context, limits & source references

    A scope decision is not a finding that the later disclosure was proper. The July procedural explanation should be presented alongside, rather than substituted for, the April 17 determination.

    • J037 pages 1–2; J033 page 1; J035 page 1
12. Aug 25, 2026Records request / response

    Follow-up after the August 10 hearing

    City counsel addresses selected requests discussed after the hearing, including production status and search information.

    Context, limits & source references

    A statement of completeness needs comparison with the underlying productions. This letter is not a judicial ruling.

    • R009 · Revised Exhibit Y; source Y01 · Austin R. Beck, for the City
13. Aug 27, 2026Records request / response

    Additional follow-up and clarification

    The letter answers Moring’s follow-up questions and discusses earlier productions and searches for the selected requests.

    Context, limits & source references

    The letter must be read alongside its attachments and the actual productions. Disputed dates or scope are not resolved by the letter alone.

    • R010 · Revised Exhibit AA; source AA01 · Austin R. Beck, for the City
14. Aug 28, 2026Records request / response

    The City’s Plea to the Jurisdiction

    The City invokes governmental immunity, disputes whether the requirements for mandamus relief are established and asks for dismissal.

    Context, limits & source references

    A request for dismissal is not an order dismissing the case. This eight-page copy does not include the separately retained exhibits.

    • R002 · Cause 44437; filed August 28, 8:49 a.m. · City of Mount Pleasant
15. Aug 30, 2026Records request / response

    Response to the plea and focused evidence

    Moring opposes the City’s jurisdictional arguments and identifies records and record families he says remain unsupplied. The filing includes the PR exhibit series.

    Context, limits & source references

    Filing acceptance does not mean every exhibit was admitted or every assertion accepted. Later productions may change an earlier omission claim.

    • R003 · Cause 44437; response with PR-A–PR-K · Kyle Douglas Moring
16. Sep 9, 2026Records request / response

    Notice of revised hearing exhibits

    The accepted notice describes the revised A–AD hearing set and maps earlier exhibit references to that set.

    Context, limits & source references

    An exhibit index does not establish admission. The notice is distinct from the exhibit files and reserved pages.

    • R004 · Cause 44437; September 9 notice · Kyle Douglas Moring
17. Sep 10, 2026Author’s account

    Separate follow-ups seek the DA’s written determinations

    Kyle followed up with Titus County DA Bailey about the August 13 complaints involving OR2026-018153 and OR2026-027532, requesting filing-date confirmation and written determinations.

    Context, limits & source references

    Each complaint remains separately identified. The emails’ deadline positions and claimed omissions are Kyle’s assertions.

    • Kyle’s two September 10 emails to Bailey
18. Sep 15, 2026Source record

    Beck transmits records under the Rodriguez ruling

    On September 15, Beck transmits what he describes as all responsive information deemed releasable under OR2026-018153. The quoted chain includes Bailey’s September 13 inquiry and Beck’s September 14 statement that the City had located the files and was separating withheld from releasable pages. This production follows the June 2 ruling, June 4 demand and August 13 complaint. Kyle’s September 16 notice separately describes the supplied pages and an October 23 Rodriguez email.

    Context, limits & source references

    The chronology documents production after the complaint and Bailey’s inquiry. Counsel’s completeness statement remains attributed to counsel; it does not independently resolve every requested category or establish why the earlier delay occurred.

    • Beck’s September 15 production email
    • Kyle’s September 16 supplemental notice transmittal
19. Sep 16, 2026Records request / response

    Supplemental notice of subsequent production

    Moring reports a subsequent production and identifies additional supporting material, while crediting earlier receipt of matching underlying plan content.

    Context, limits & source references

    The notice does not claim the underlying plan content was first received on September 15. Filing is distinct from admission.

    • R005 · Cause 44437; September 16 notice · Kyle Douglas Moring
20. Sep 17, 2026Source record

    Five production PDFs acknowledged; DTRG confirms 517 pages

    Kyle acknowledged five September 16 PDFs totaling 517 pages and said he located embedded attachments. A September 17 response bearing Lea Ream’s From header and Marla Dial’s signature confirmed that total and supplied a reading order. The response deferred remaining questions to Beck; Kyle maintained his completeness questions.

    Context, limits & source references

    This supersedes an unqualified statement that Part 1 remained undelivered. Receipt and the agreed page total do not establish that all responsive records were produced.

    • Kyle’s September 17 receipt and completeness email
    • Marla Dial’s September 17 response
21. Sep 18, 2026Author’s account

    Later mandamus update sent to OAG

    Kyle told OAG that he agreed to dismiss the mandamus proceeding based on the City’s agreement to rerun one identified search. He continued to dispute production completeness and the asserted chronology of the Chief’s phone screenshots.

    Context, limits & source references

    The email is Kyle’s account. A signed disposition and the search’s completion have not been verified in this update.

    • Kyle’s September 18 mandamus update to Kent Richardson