Ms.

Sharen Wilson

ID: LSG-2016-TX-0008

Tarrant County District Attorneys Office

Tim Curry Criminal Justice Center
401 West Belknap
Fort Worth, Texas 76196
Sent via: In Person
April 26th, 2016
Re: Notice of Complaint
Ms. Sharen Wilson,
Please consider this letter a complaint against Mr. Keith Whetstone, who is the Public Information
Officer of Tarrant County College District, for violating the Texas Public Information Act. Based on the
facts stated below I am hereby requesting that you file criminal charges and to prosecute Mr. Keith
Whetstone and all other officials with Tarrant County College District who are responsible for this
violation. See Texas Government Code Ann. Sec. 552.353(e).
1. On March 24th, 2016 I submitted an open records request through the Texas Public Information
Act to Mr. Keith Whetstone who is the Public Information Office of Tarrant County College
District. I submitted the request to his email at: KEITH.WHETSTONE@tccd.edu and I also cced
the generic open records email address for TCCD at: records@tccd.edu. See Attachment A for a
copy of the letter that I emailed.
2. On April 7th, 2016 I filed a written complaint against Tarrant County College District for violating
the Texas Public Information Act with the Texas Attorney Generals Office. See Attachment B.
3. The Texas Attorney Generals Office sent Tarrant County College District a letter that is in
regards and pertaining to a complaint that I sent to the Texas Attorney Generals Office. See
Attachment C.
4. On April 25th, 2016 I sent the Texas Attorney generals Office a second complaint letter regarding
Tarrant County College District still not responding to my open records request and being
deliberately indifferent to abide by the law. See Attachment D.
5. Tarrant County College District and its officials that were responsible for responding to open
records requests were made aware through my letter to them that the Texas Public Information
Act requires that they "promptly produce" the requested records unless, within 10 days, they
have sought an Attorney General's Opinion. Twenty (20) days if my request requires substantial
programming or manipulation of data. See Tex. Govt Code Ann. Secs. 552.221(d) and 231(c).
6. The actions of Tarrant County College District were deliberate, intentional and they have thus
failed to abide by the law. They have demonstrated to have been deliberately indifferent to
abiding by the Texas Public Information Act.

As you may already know, violations of the Texas Public Information Act can result in a fine of up to
$1,000, imprisonment of up to six months, or both. See Tex. Govt Code Ann. Sec. 552.353(e). I am
therefore requesting the Tarrant County District Attorney Office to file criminal charges against Mr.
Keith Whetstone, Public Information Office for Tarrant County College District, and all other Tarrant
County College District officials who were in violating of the Texas Public Information Act.
It is imperative for officials to abide by the Texas Public Information Act and violations of the Texas
Public Information Act and deliberate indifference towards the law cannot be tolerated. All officials have
to be held accountable for their actions and all officials must abide by the law.
Please also note that all information contained in this letter is true and correct to the best to my
knowledge.

Contact methods:
If an employee with the Tarrant County District Attorneys Office would like to contact me, I would
request for it to be in writing. If your office needs any more information from me regarding this
complaint, I would be happy to send it to you guys. My email address is at: iscampaign@usa.com. You
can also send me correspondence that is in regards to my complaint at the following mailing address:
Isaiah X. Smith
Isaiah Smith Campaign
P.O Box 163411
Fort Worth, Texas, 76161
Respectfully,
Isaiah X. Smith
Isaiah Smith Campaign
P.O Box 163411
Fort Worth, Texas, 76161
www.isaiahxsmith.com

cc:

Texas Attorney Generals Office (Complaint ID# 614488)

ATTACHMENT A

Tarrant County College District

ID: SPIR-2016-TX-0007

Attention: Keith Whetstone

1500 Houston Street
Fort Worth, Texas 76102
KEITH.WHETSTONE@tccd.edu
Sent via: Electronic mail
March 24th, 2016
Re: Open Records Request
Mr. Whetstone,
Under the Texas Public Information Act, 6252-17a et seq., I am requesting an opportunity to obtain
copies of public records that Tarrant County College District has in its possession. I am hereby requesting
the following public records:
1. A copy of Mr. Mark Evans application for employment. Mr. Mark Evans is a teacher at the Trinity
River Campus of Tarrant County College District.
2. Mr. Mark Evans disciplinary file with Tarrant County College District.
Tarrant County College District is a public educational institution that receives federal financial
assistance. Mr. Mark Evans is a professor at a public educational institution and is thus employed by a
public educational institution in the State of Texas.
I would like to request a waiver of all fees associated with this request because the information is in the
public interest and will contribute significantly to the publics understanding of the individuals employed
by Texas public educational institutions, their non-confidential by law disciplinary file, their nonconfidential by law application for employment and et cetera.
The Texas Public Information Act requires that you "promptly produce" the requested records unless,
within 10 days, you have sought an Attorney General's Opinion. As provided by the Texas Public
Information Act, I will expect your response within ten (10) business days. Twenty (20) days if my
request requires substantial programming or manipulation of data. See Tex. Govt Code Ann. Secs.
552.221(d) and 231(c). If you expect a significant delay in responding to this request, please contact me
with information about when I might expect copies or the ability to inspect the requested records. You
can reach me via email at: iscampaign@usa.com.
If you deny any or all of this request, please provide a written explanation for the denial and cite each
specific statutory exemption(s) you feel justifies the refusal to release the information and notify me of
the appeal procedures available to me under the law. If your governmental body wants to seek the
Texas Attorney General's Opinion regarding any of our request, I ask that you immediately notify me and
Page 1 of 2

then seek a formal decision from the Texas Attorney General not later than ten (10) calendar days from
your receipt of this request, as required by the Texas Public Information Act. See Sec. 552.301. I would
then ask your governmental body to release to me all of the items in which you have not sought the
Attorney General's Opinion on. See Sec. 552.301, 302; see also Open Records Decision No. 664 (2000)(if
a governmental body concludes that no exceptions apply to the requested information, it must release
the information as soon as possible). If any party writes to the Texas Attorney Generals Office that is
in regards to my open records request, you must send me a copy of the correspondence.
As you may already know that violation of the open records law can result in a fine of up to $1,000,
imprisonment of up to six months, or both. See Tex. Govt Code Ann. Sec. 552.353(e). Litigation costs
and reasonable attorney fees may also be assessed against you. See Sec. 552.323.
It would be preferred if you would send me the requested information by electronic mail to:
iscampaign@usa.com. However if not I will be happy to come into the office to pick up the requested
records. Please tell me a date and time that I will be able to pick up my requested records if you will not
send me the requested records to me by electronic mail. I will be happy to provide a flash drive for the
information to be uploaded to. I will be happy to come in at the following address to pick up my
requested records as soon as possible:
Tarrant County College District
Administration Building
1500 Houston Street
Fort Worth, Texas 76102

Respectfully submitted,
Isaiah X. Smith

Isaiah Smith Campaign

P.O Box 163411
Fort Worth, Texas, 76161
www.isaiahxsmith.com

Page 2 of 2

ATTACHMENT B

Honorable Ken Paxton

ID: LSG-2016-TX-0003

Office of the Attorney General

Open Records Division
P.O. Box 12548
Austin, TX 78711
Sent via: Mail
April 7th, 2016
Re: Complaint against Tarrant County College District for violating the Texas Public Information Act
Honorable Ken Paxton,
My name is Isaiah X. Smith and I am sending you this letter as a complaint against Tarrant County
Community College District for violating the Texas Public Information Act. As you may already know,
Tarrant County College District is a public educational institution that operates in the State of Texas.
I.
Statement of the facts as to this complaint
1. On March 24th, 2016 I submitted an open records request through the Texas Public Information
Act to Mr. Keith Whetstone of Tarrant County Community College District by electronic mail. I
emailed Mr. Keith Whetstone at KEITH.WHETSTONE@tccd.edu the letter listed in Exhibit A.
2. Mr. Keith Whetstone is the Public Information Office of Tarrant County College District.
3. On March 24th, 2016 I made sure that I also sent another email to Mr. Keith Whetstone at
KEITH.WHETSTONE@tccd.edu and I also cced the generic email address for Tarrant County
College District that handles open records requests at records@tccd.edu. I made sure that I
included the same letter listed in Exhibit A as an attachment in the email.
4. By the end of the business day as to April 7th, 2016, I have not received any response as to my
open records request or any information pertaining to my request from Tarrant County College
District
5. In my sent open records request to Tarrant County College District I have included the
following information that can also be seen in Exhibit A:
A. Tarrant County College District is a public educational institution that receives
federal financial assistance. Mr. Mark Evans is a professor at a public educational
institution and is thus employed by a public educational institution in the State of
Texas.
B. I would like to request a waiver of all fees associated with this request because the
information is in the public interest and will contribute significantly to the publics
understanding of the individuals employed by Texas public educational institutions,
their non-confidential by law disciplinary file, their non-confidential by law
application for employment and et cetera.

C. The Texas Public Information Act requires that you "promptly produce" the
requested records unless, within 10 days, you have sought an Attorney General's
Opinion. As provided by the Texas Public Information Act, I will expect your
response within ten (10) business days. Twenty (20) days if my request requires
substantial programming or manipulation of data. See Tex. Govt Code Ann. Secs.
552.221(d) and 231(c). If you expect a significant delay in responding to this request,
please contact me with information about when I might expect copies or the ability
to inspect the requested records. You can reach me via email at:
iscampaign@usa.com.
D. If you deny any or all of this request, please provide a written explanation for the
denial and cite each specific statutory exemption(s) you feel justifies the refusal to
release the information and notify me of the appeal procedures available to me
under the law. If your governmental body wants to seek the Texas Attorney
General's Opinion regarding any of our request, I ask that you immediately notify
me and Page 2 of 2 then seek a formal decision from the Texas Attorney General not
later than ten (10) calendar days from your receipt of this request, as required by
the Texas Public Information Act. See Sec. 552.301. I would then ask your
governmental body to release to me all of the items in which you have not sought
the Attorney General's Opinion on. See Sec. 552.301, 302; see also Open Records
Decision No. 664 (2000)(if a governmental body concludes that no exceptions apply
to the requested information, it must release the information as soon as possible). If
any party writes to the Texas Attorney Generals Office that is in regards to my open
records request, you must send me a copy of the correspondence
E. As you may already know that violation of the open records law can result in a fine
of up to $1,000, imprisonment of up to six months, or both. See Tex. Govt Code
Ann. Sec. 552.353(e). Litigation costs and reasonable attorney fees may also be
assessed against you. See Sec. 552.323.
II.
Records that I have requested
6. I have requested to have a copy of Mr. Mark Evans application for employment. Mr. Mark Evans
is a teacher at the Trinity River Campus of Tarrant County College District. See Exhibit A.
7. I have requested a copy of Mr. Mark Evans disciplinary file with Tarrant County College District.
See Exhibit A.
III.
Actions of Tarrant County College
8. Tarrant County College District and its officials that were responsible for responding to open
records requests were made aware through my letter to them that the Texas Public Information
Act requires that they "promptly produce" the requested records unless, within 10 days, they
have sought an Attorney General's Opinion. Twenty (20) days if my request requires substantial
programming or manipulation of data. See Tex. Govt Code Ann. Secs. 552.221(d) and 231(c).

9. The actions of Tarrant County College District were deliberate, intentional and they have thus
failed to abide by the law. They have demonstrated to have been deliberately indifferent to
abiding by the Texas Public Information Act.

IV.
Requested action that I am requesting
10. To have the Texas Attorney Generals Office demand Tarrant County College District to respond
to my open records request as required by the Texas Public Information Act
11. To have the Texas Attorney Generals Office demand Tarrant County College District to produce
to me (Isaiah X. Smith) the requested records that I have a legal right to obtain free to charge
12. To fine Tarrant County College District for violating the Texas Public Information Act of up to one
thousand dollars ($1000). See Tex. Govt Code Ann. Sec. 552.353(e).
V.
Acknowledgement letter
13. Please send me all correspondence related to my complaint against Tarrant County College
District to the following mailing address for me:
Isaiah X. Smith
Isaiah Smith Campaign
P.O Box 163411
Fort Worth, Texas, 76161
14. I am also requesting a copy of all correspondence that the Texas Attorney Generals Office sends
to Tarrant County College District and all correspondence that the Texas Attorney Generals
Office receives from Tarrant County College District in response to my complaint against them.
Please send me all of the correspondence to me at the aforementioned mailing address.

Respectfully,
Isaiah X. Smith
Isaiah Smith Campaign
P.O Box 163411
Fort Worth, Texas, 76161
www.isaiahxsmith.com

EXHIBIT A

Tarrant County College District

ID: SPIR-2016-TX-0007

Attention: Keith Whetstone

1500 Houston Street
Fort Worth, Texas 76102
KEITH.WHETSTONE@tccd.edu
Sent via: Electronic mail
March 24th, 2016
Re: Open Records Request
Mr. Whetstone,
Under the Texas Public Information Act, 6252-17a et seq., I am requesting an opportunity to obtain
copies of public records that Tarrant County College District has in its possession. I am hereby requesting
the following public records:
1. A copy of Mr. Mark Evans application for employment. Mr. Mark Evans is a teacher at the Trinity
River Campus of Tarrant County College District.
2. Mr. Mark Evans disciplinary file with Tarrant County College District.
Tarrant County College District is a public educational institution that receives federal financial
assistance. Mr. Mark Evans is a professor at a public educational institution and is thus employed by a
public educational institution in the State of Texas.
I would like to request a waiver of all fees associated with this request because the information is in the
public interest and will contribute significantly to the publics understanding of the individuals employed
by Texas public educational institutions, their non-confidential by law disciplinary file, their nonconfidential by law application for employment and et cetera.
The Texas Public Information Act requires that you "promptly produce" the requested records unless,
within 10 days, you have sought an Attorney General's Opinion. As provided by the Texas Public
Information Act, I will expect your response within ten (10) business days. Twenty (20) days if my
request requires substantial programming or manipulation of data. See Tex. Govt Code Ann. Secs.
552.221(d) and 231(c). If you expect a significant delay in responding to this request, please contact me
with information about when I might expect copies or the ability to inspect the requested records. You
can reach me via email at: iscampaign@usa.com.
If you deny any or all of this request, please provide a written explanation for the denial and cite each
specific statutory exemption(s) you feel justifies the refusal to release the information and notify me of
the appeal procedures available to me under the law. If your governmental body wants to seek the
Texas Attorney General's Opinion regarding any of our request, I ask that you immediately notify me and
Page 1 of 2

then seek a formal decision from the Texas Attorney General not later than ten (10) calendar days from
your receipt of this request, as required by the Texas Public Information Act. See Sec. 552.301. I would
then ask your governmental body to release to me all of the items in which you have not sought the
Attorney General's Opinion on. See Sec. 552.301, 302; see also Open Records Decision No. 664 (2000)(if
a governmental body concludes that no exceptions apply to the requested information, it must release
the information as soon as possible). If any party writes to the Texas Attorney Generals Office that is
in regards to my open records request, you must send me a copy of the correspondence.
As you may already know that violation of the open records law can result in a fine of up to $1,000,
imprisonment of up to six months, or both. See Tex. Govt Code Ann. Sec. 552.353(e). Litigation costs
and reasonable attorney fees may also be assessed against you. See Sec. 552.323.
It would be preferred if you would send me the requested information by electronic mail to:
iscampaign@usa.com. However if not I will be happy to come into the office to pick up the requested
records. Please tell me a date and time that I will be able to pick up my requested records if you will not
send me the requested records to me by electronic mail. I will be happy to provide a flash drive for the
information to be uploaded to. I will be happy to come in at the following address to pick up my
requested records as soon as possible:
Tarrant County College District
Administration Building
1500 Houston Street
Fort Worth, Texas 76102

Respectfully submitted,
Isaiah X. Smith

Isaiah Smith Campaign

P.O Box 163411
Fort Worth, Texas, 76161
www.isaiahxsmith.com

Page 2 of 2

ATTACHMENT C

ATTACHMENT D

Honorable Ken Paxton

ID: LSG-2016-TX-0007

Office of the Attorney General

Open Records Division
P.O. Box 12548
Austin, TX 78711
Sent via: Mail
April 25th, 2016
Re: Complaint ID# 614488 against Tarrant County College District for violating the Texas Public
Information Act
Honorable Ken Paxton,
This is Isaiah X. Smith and I am sending you this letter again to make sure that the Texas Attorney
Generals Office is notified of the fact that since your government agency sent a letter on April 14th,
2016 to Tarrant County College District, to this date I have still received no responses from Tarrant
County College District regarding my open records request. Tarrant County College District has my
contact information and they have failed to send me my requested records.
I am still requesting the records that I have requested from Tarrant County College District by my open
records request. I urge the Texas Attorney Generals Office to take action against Tarrant County College
District for violating the Texas Public Information Act and to recommend a criminal investigating for a
violation of the Texas Public Information Act committed by officials with the Tarrant County College
District.
Tarrant County College District has violated the Texas Public Information Act and they are being
deliberately indifferent to abiding by the law.
Respectfully,
Isaiah X. Smith
Isaiah Smith Campaign
P.O Box 163411
Fort Worth, Texas, 76161
www.isaiahxsmith.com

Page 1 of 1