Whether conditions precedent that are specified in both the Texas Open Meetings Act and the Texas Government Code must be met before county commissioners courts are authorized to expend public funds to retain legal counsel

QUESTIONS PRESENTED Plaintiffs claimed and provided documented evidence showing that multiple Defendants as members of commissioners courts from two Texas counties failed to comply with both the Texas Open Meetings Act (the “Act”) and the Chapter 551 of the Texas Government Code (the “Code”). The U.S. Court of Appeals for the Fifth Circuit chose not to address these violations. Regarding the removal of counsel from a local indigent appointment list, state statutes specifically mandate that indigent appointments be managed in a fair, neutral, and non-discriminatory manner. The questions presented are: 1. Whether conditions precedent that are specified in both the Act and in the Code must be met before county commissioners courts, when operating as governmental bodies, are authorized to expend public funds necessary to retain defensive legal counsel prior to filing responsive pleadings or motions under Federal Rule of Civil Procedure 12. 2. Whether the Fifth Circuit errored by failing to apply the facts of this case to the requirements from the Act, requirements from the Code, and to precedent in Smith Cty. v. Thornton, 726 S.W.2d 2, 3 (Tex. 1987) (holding that a Commissioners Court’s failure to comply with the Texas Open Meetings Act regarding initial general public notification requirements then resulted in subsequent related actions performed by that commissioners court to be void). li QUESTIONS PRESENTED—Continued 3. Whether the Circuit Court errored in holding that any due process property violation never occurred because Respondents had “discretion” on the removal of counsel from the various indigent court appointment lists even though the counties’ local rules do not contain the term “discretion” and state statutes require that a fair, neutral, and nondiscriminatory process be applied before removing counsel from such lists thus together signifying basic due process entitlements. iii LIST OF INTERESTED PARTIES The undersigned pro se Petitioners certify that this is a civil case and the persons having an interest in the outcome of this case are as follows: 1. Reynaldo A. De Los Santos; Pro Se 2. Ricardo De Los Santos; Pro Se 3. Hon. William Bosworth; Respondent-Appellee 4. Hon. John Neill; Respondent-Appellee 5. Hon. Sidney Hewlett; Respondent-Appellee 6. Hon. Wayne Bridewell; Respondent-Appellee 7. Hon. Robert Mayfield; Respondent-Appellee 8. Hon. Steve McClure; Respondent-Appellee 9. County Judge Roger Harmon; Respondent-Appellee 10. County Commissioner Rick Bailey; RespondentAppellee 11. County Commissioner Kenny Howell; RespondentAppellee 12. County Commissioner Jerry Stringer; RespondentAppellee 13. County Commissioner Larry Woolley; RespondentAppellee 14. County Judge Danny Chambers; RespondentAppellee 15. Commissioner Larry Hulsey; Respondent-Appellee 16. Commissioner Dwayne Johnson; RespondentAppellee iv LIST OF INTERESTED PARTIES—Continued 17. Commissioner Kenneth Wood; Respondent-Appellee 18. Commissioner Wade Busch; Respondent-Appellee 19. Commissioner David Evans; Respondent-Appellee 20. Johnson County, Texas 21. Somervell County, Texas RELATED CASES ¢ De Los Santos v. Bosworth, et al., No. 3:20-cv00461-C, U.S. District Court for the Northern District of Texas, Dallas Division. Judgment entered March 8, 2021. See App. B. ¢ De Los Santos v. Bosworth, et al., No. 21-10323, US. Court of Appeals for the Fifth Circuit. Judgment entered March 11, 2022. See App. D.