NOS.

416-81913-2015
416-82148-2015
416-82149-2015
STATE OF TEXAS
COURT
V.
DISTRICT
WARREN KENNETH PAXTON, JR.
TEXAS

IN THE DISTRICT

416th JUDICIAL

COLLIN COUNTY,

AFFIDAVIT OF SUSAN FLETCHER

Before me, the undersigned authority, personally appeared Susan Fletcher, who
first being duly sworn on her oath deposed and stated as follows:
1. I am duly qualified to make this Affidavit. I am over the age of 21. I have never been
convicted of a felony. I am personally acquainted with the facts recited below.
2. I agreed to provide this statement in lieu of being subpoenaed or otherwise being
compelled by a court order to do so.
3. I live in Frisco, Collin County, Texas. I serve as the Collin County Commissioner for
Precinct 1.
4. I have a personal friendship with Cissy Oldner. Cissy is married to Chris Oldner, the
presiding Judge of the 416th Judicial District Court of Collin County, Texas. Cissy
assisted with my campaign for election to County Commissioner.
5. I am longtime friends with Ken and Angela Paxton. Earlier this year while Mr. Paxton
was under criminal investigation, Cissy would occasionally make comments to me such
as, Your friend Ken Paxton hasnt had a good week. I understood Cissys comments to
mean that Mr. Paxtons case was not going well for him.
6. Several constituents posed questions to me regarding the expenses involved with Judge
Scott Beckers appointment of Houston-based special prosecutors to Mr. Paxtons
investigation. In response, I reached out to Judge Becker. Judge Becker told me that he
could not share the reasons behind the decision at that time. Rather, Judge Becker told me
that he would explain his reasoning once the matter was over.
7. On July 2, 2015, Cissy exchanged several texts with me regarding Mr. Paxtons
prosecution. A portion of our July 2 text exchange is reproduced below:

Affidavit of Susan Fletcher

11515800.1

Dat
e

7/2

Time

5:53
p

Oldner
Well I actually heard that he is not
running again because he is somehow
involved in Paxton's mess-- speaking
of--your friend Paxton has not had a
good week. . .

Yikes. I have no idea, but I owe Turner a

call. . .When I asked someone [remaining
text cut off]

Not listed

7/2

7:18
p

This is exactly what we told you was

going to happen to Paxton

7/2

7:18
p

It's worse though then we ever

thought. Over 100k. Ouch
You were right, bad mojo indeed. I'm
personally leary of [remaining text cut
off]

Not Listed
7/2

7:23
p

That sounds smart

7/2

7:25
p

And don't advise people to invest, take

a 30% commission you forget to tell
them about, and then watch them lose
their life savings

7/2

7:25
p

Sorry can't resist

7/2

7:26
p

7/2
7/2
7/2

7:27
p
7:27
p
7:29
p

Fletcher

[beginning text cut off] my agenda. No

worries there. And you know I've never
stopped you from venting. . .
This is really more gloating than
venting
Which is not nice
I understand.

Affidavit of Susan Fletcher

21515800.1

7/2

7:37
p

Who knows. Maybe the grand jury

will no bill. But they are presenting 2
different cases to 2 grand juries and
these are just the charges that are about
to run the statute of limitations,
apparently there are more to come.

True and accurate screen shots documenting these text exchanges are attached hereto as
Exhibit 1.
8. On July 28, 2015 at approximately 4:18 pm I received a phone call from Cissy while
talking on my cell with Ms. Andrea Stroh-Thompson, the Collin District Clerk. After Ms.
Stroh-Thompson hung up, I returned Cissys call at 4:47 p.m.
9. When Cissy answered, she immediately asked me, Did you hear? I responded, Hear
what? Cissy then told me the grand jury had just indicted Paxton that day, and the case
was assigned to her husbands (Judge Oldners) court. I replied that I was sorry to hear
about Mr. Paxtons indictment, but did not want to be involved in the matter. Cissy
reminded me that she had told me this was going to happen, and this is what she had
warned me about. I was surprised that the case was already assigned. I asked if Cissy was
certain that Mr. Paxtons case was in her husbands court. Cissy confirmed that the matter
was definitely in Judge Oldners court. I inquired if Judge Oldner was going to recuse
himself. Cissy commented that Judge Oldner would not recuse himself Mr. Paxton was
not a family member, it was his job to hear cases and there are many high profile cases.
Cissy also said that this would be a controversial case and people will be wondering if the
prosecution was politically motivated. Cissy hoped that I would remind everyone that this
is the process and the legal process needed to play out. Cissy continued that this was very
embarrassing for our county and for Texas. I told her again that I would prefer to step
back and not comment further.
10. My call with Cissy was interrupted with another call from Ms. Stroh-Thompson. I told
Cissy that I would call her back after concluding my conversation with Ms. StrohThompson. I told Ms. Stroh-Thompson that Cissy just told me about Mr. Paxtons
indictment and that the matter was assigned to Judge Oldners court. Ms. StrohThompson seemed to be surprised and commented that it was not protocol for that
information to be released prior to an arrest or the defendant turning himself in. Ms.
Stroh-Thompson would not confirm Cissys statements to me.
11. In addition to Ms. Stroh-Thompson, on July 28 I told my administrative assistant, Hilari
Monk, about Mr. Paxtons indictments so we could prepare for media contacts. I also told
Mr. Bill Bilyeu, Collin County Administrator, and suggested that he call County Judge
Affidavit of Susan Fletcher
31515800.1

Keith Self to let him know of Mr. Paxtons indictment in the event that Judge Self
received any calls.
12. I received a second cell phone call from Cissy at approximately 5:30 pm. Cissy told me
that I was not supposed to tell anyone about Mr. Paxtons indictment and that it could not
be discussed until the indictment was unsealed on August 14. I replied that I had already
spoken with several people about Mr. Paxtons indictment but would do what I could to
unring the bell and not tell anyone else. Cissy inquired who I told about Mr. Paxtons
indictment and whether Ms. Stroh-Thompson knew Cissy was the source of the
information. I told Cissy who I had spoken with, including Ms. Stroh-Thompson. I also
confirmed that Ms. Stroh-Thompson knew the information came from her (Cissy).
13. At approximately 6:00 p.m. I received a call from Mrs. Paxton. Mrs. Paxton explained
that she had heard I had received a phone call from Cissy informing me of Mr. Paxtons
indictment and that the matter was assigned to Judge Oldners court. Mr. Paxton and Mr.
Ben Williams also got on the phone during that call and told me that the indictments were
secret and no one was supposed to know. Mr. Williams asked me to take a few minutes to
write down what I recalled from my conversations with Cissy.
14. That evening, I prepared notes of the highlights of my conversations with Cissy. Later
that night, Mrs. Paxton, Mr. Williams, Mr. Williamss wife Christina, and a notary came
to my house. At Mr. Williamss urging, I signed a copy of the notes I had prepared in the
presence of the notary. Subsequently, I was asked to provide an affidavit regarding the
information I possessed, including any additional communications with Cissy (verbal,
text or e-mail) in which we discussed Mr. Paxtons case. I agreed to provide them in order
to avoid being subpoenaed.
____________________________________
Susan Fletcher
SWORN TO
November, 2015.

AND SUBSCRIBED

before me by Susan Fletcher on this ____ day of

_____________________________________
Notary Public

Affidavit of Susan Fletcher

41515800.1