TO: State Board for Educator Certification
Texas Education Agency
1701 N. Congress Avenue
Austin, TX 78701-1494
Fax: (512) 475-3665
Email: complaintsmanagement@tea.texas.gov

In re: Complaints for Educator Misconduct for 3 educators
9-5-2019
I am David Olivas and represent my client.  I am filing this complaint with SBEC on 9-5-2019 on her behalf as she fears for the safety of her and her daughter’s life.  Please see the details of this complaint below.
This is a complaint about Educator Misconduct against Dr Curtis Amos, Superintendent of Everman ISD.  There are many dates and events in this complaint, so please bear with the length of this complaint.
Additionally, to assist with the chronology of events, a timeline is provided at the end of each item in this complaint.  There are Google drive link addendums for audio recordings and documents that are accompanying this complaint to substantiate the claims of Educator Misconduct in this complaint.
Item 1: Educator Misconduct on behalf of Dr Curtis Amos, Superintendent of Everman ISD, for failing to properly investigate and for failing to report an employee’s drug use to SBEC and Tx DPS.
The documents and recordings filed with this complaint will substantiate that Dr Curtis Amos botched an investigation into drug use by Business Teacher/Coach Gilbert Fuentez (G.F.) who uses cocaine and marijuana (and has for more than 17 years), and how Dr Amos protected G.F. during and after the investigation.
(Please see link below for picture of G.F., as he has taken down his social media recently)
As a result of Dr Amos’ unethical actions, G.F. threatened and harassed a co-worker to remain silent, destroy evidence and to impede an investigation into G.F’s drug use at Everman ISD and then committed terroristic threats on the co-worker’s daughter’s life when the co-worker told him she was not going to hide his criminal actions and drug use any longer and wanted to go reveal the proof that she had.
(See addendum for Arlington Police report who has received the audio recording of this threat and there is a pending criminal case and active investigation) (To protect the privacy of my client, this audio recording is not being released to the public while Arlington TX police department is investigating this matter)
G.F. has also driven his athletes around in a school bus while cocaine and marijuana was in his system. No complaint against his CDL was ever filed by Everman or self-reported by G.F. when he did not pass a drug test on 4-16-2019.
G.F. was given a “Settlement Agreement” on 5-4-2019 from Everman ISD even though he failed a drug test on 4-16-2019, which was “inconclusive for temperature”, and he refused to submit a 2nd sample that same day. G.F. was given 40 ounces of water and 2 hours to wait in the clinic lobby to submit a 2nd sample and refused to do so. The 1st sample he submitted was “inconclusive for temperature” . The co-worker was told by G.F. later in the evening by G.F. himself that he failed the drug test for temperature because one of his other 2 girlfriends, R.R., who is a nurse at a Harris Methodist, came to pick him up from the Everman Administration building and took him to the Workman’s comp clinic so he could submit a urine sample, but R.R. gave him a urine sample to submit, instead of G.F.’s, when she drove him to the clinic, and R.R. waited in the parking lot for him to come out.  At 1:45pm, R.R. drove G.F. back to the Administration building, where he met with Dr Amos for refusing to submit a 2nd sample.
Later in the evening on 4-16-2019, at G.F.’s apartment, he would admit to the co-worker that R.R. gave him a urine sample of her urine to use instead.
(There is a recording of this admission that has been handed over to Ft Worth police department who is conducting an active investigation on several issues, this one included)
After G.F. left the workman’s comp clinic at 145pm, he went to Dr Amos’ office where Dr Amos told G.F. that a tip came through to Everman ISD that an “ex-girlfriend said he did cocaine” and that that was the reason he was sent to the workman’s comp clinic.  No “ex-girlfriend” submitted a tip and this tip was NOT the catalyst event that sent G.F. to the workman’s comp clinic on 4-16-2019, but rather breaking up a student fight where his hand was injured.
Unfortunately, the specific “ex-girlfriend” that Dr Amos was referring to was a co-worker of G.F.’s. Additionally, G.F. and the co-worker were actively involved in a relationship as of 4-16-2019, and that relationship had not yet ended as of 4-16-2019.  G.F. and the co-worker’s relationship was on record with Everman ISD as of 3-7-2019, when the co-worker filed a Title IX complaint with Everman for sexual harassment against John Tinker (J.T)
(please see details about this item below).
G.F. told Dr Amos that the “ex-girlfriend”/co-worker was simply trying to get revenge for breaking up and she was psycho, lying and she had no proof.  This is blatantly false because, at the time on 4-16-2019, the co-worker and G.F. were still involved in a relationship and had no reason for revenge or to lie.  This relationship did not terminate until 7-2-2019. Proof can be provided to substantiate this.
Dr Amos believed G.F. about the lies he told about the “ex-girlfriend”/co-worker, and, in doing so, Dr Amos ruined the drug investigation into G.F. in the following ways:
1) by subjecting the co-worker to becoming a vulnerable target for harassment for weeks by G.F.,
 2) for blaming the co-worker as the initiating event of the drug investigation, even though it was understood by both G.F. and the co-worker that it was a workman’s comp injury and failed drug test that precipitated the drug investigation, and
3) by preventing the “ex-girlfriend”/co-worker from getting and turning in evidence regarding G.F.’s drug use to Everman once the co-worker became the suspected source of information at 1:45pm on 4-16-2019.
Additionally, G.F. was not placed on Administrative Leave to conduct an investigation into the failed drug test and drug use allegation until 4-23-2019, ONE FULL WEEK AFTER FAILING A DRUG TEST, and G.F. reported to work during this time, had full access to his students and his athletes to drive them in the bus to games. Then, on 5-4-2019, G.F. was given a full “Settlement Agreement” by Everman ISD that paid him out through his contract that ended naturally at the end of August 2019, with full pay, benefits, paid days that transfer, etc.
(Please see addendum for this “Settlement Agreement” and G.F.’s resignation dated 5-4-2019)
However, what Dr Amos could not have known is that G.F. had 3 active relationships as of 4-16-2019.  One, with the co-worker that ended 7-2-2019, one with V.L. in Austin that is still ongoing as of September 2019 (see more on V.L.'s role with Austin ISD below) and one with R.R. in Ft Worth that is still ongoing as of September 2019.
When G.F. left the Administration building at approximately 310pm on 4-16-2019, he texted the co-worker and told her to meet him at UEA, which is his teacher legal representation, which was about 4 miles away, and to call him and stay on the phone with him so she could not talk with anyone else about the situation.  At 330pm, this co-worker left campus, met G.F. at UEA and her phone was taken from her and G.F. proceeded to demand to see pictures, recordings and text messages on her phone, believing she tipped off Everman ISD, and he demanded she delete everything that could prove his drug use in an attempt to hinder the investigation and for her to accompany him inside to UEA and she was not allowed to leave the premises at UEA.
After leaving UEA, on 4-16-2019, the co-worker was made to pay $80 at Walgreens for 2 broad spectrum drug tests for G.F. and to accompany G.F. to his apartment in Ft Worth.
At G.F.’s apartment, the co-worker was subjected to 3 hours of physical intimidation, yelling and screaming by G.F., and was made to delete everything she could in her phone, screamed accusations at the co-worker, demands on her to find someway to help him test clean, harassment and interrogation before she was allowed to leave at 715pm.  However, the harassment, interrogation and intimidation did not stop after 4-16-2019 and went on for 3 more wks.
Fearing for her safety has never ended for the co-worker and for her daughter's life, due to Dr Amos’ statement to G.F. that the co-worker was the source of the drug use tip, SEVERAL HOURS AFTER the 1st failed drug test at the workman’s comp clinic, AND ONLY AS A MANUEVUR TO GET G.F. TO BREAK DOWN, CONFESS AND/OR RETURN TO GIVE A 2ND SAMPLE.  As a result of Dr Amos’ actions, the co-worker did not assist Everman ISD in their investigation voluntarily but did submit a statement on what little information the co-worker had about G.F.’s drug use and the fight between the students.
Dr Amos did not follow procedure when he did not require G.F. to return to the clinic to do a 2nd test to substantiate the 1st failed drug test that occurred after he was sent to the workman’s comp clinic earlier in the morning after he injured his hand breaking up a student fight.
Dr Amos had 3 reasons for not following this procedure:
1) as a means of protecting G.F. from any adverse action that Everman ISD would take against G.F.,
2) to protect Everman ISD from a scandal that could go public, and
3) for retaliation against the co-worker for filing a Title IX complaint in 3-7-2019, which led to the termination of a 16 year long employee and well-loved football coach John Tinker.  (Details below for Item 2)
No additional, substantial or tangible investigation was conducted by Everman ISD into the investigation or evidence that G.F. was using drugs.
A statement was demanded from the co-worker from Dr Donaldson, the Asst Superintendent, and, on 4-23-2019, after being subjected to days of intimidation, harassment and intimidation by G.F., the co-worker submitted a statement to Dr Donaldson that was 100% truthful, about what little information the co-worker could provide at that time on 4-23-2019.
Fearing personal retaliation and an unsafe work environment created by Dr Amos at Everman ISD, the co-worker immediately went to the parking lot after submitting her statement and, with the blessing of her attorney, submitted her resignation for Everman ISD on 4-23-2019, despite having no other jobs lined up and no plans to leave Everman ISD BEFORE Dr Amos sabotaged the investigation and recklessly and intentionally created a severe threat to the safety and well-being of the co-worker.
It would not have mattered anyway, as Dr. Amos, from the beginning, at the first meeting Dr Amos and G.F. had on 4-16-2019 at 145pm, Dr Amos believed, supported and protected G.F. during the 3 wks of investigation and believed G.F. that he was “being set up” by the “ex-girlfriend”/co-worker and G.F.'s lies.
The TEC states that the Superintendent has seven days to report educator misconduct and, but as of 7-29-2019, when the co-worker met with Dr. Amos and Dr Donaldson to discuss the following concerns the co-worker had, it was clear no one in Everman ISD had reported G.F. to SBEC, TEA or Texas DPS for the CDL.  The meeting on 7-29-2019 with Dr. Amos and Dr Donaldson were about the following items of concern:
1)  the botched drug investigation on G.F.,
2) the allegations by Dr. Amos that led to the co-worker’s harassment by G.F.,
3) the police reports regarding threats on the co-worker’s daughter’s life by G.F. when the co-worker threatened to reveal any proof she had of G.F.’s drug use, and
4) the documented history of violence that G.F. has against women with the vicious assault perpetrated by G.F. on 2nd girlfriend R.R. on 5-26-2018.
(Please see addendum for Ft Worth Police Department records, photos and recordings.  This investigation is an active, pending criminal case that is being handled out of the Domestic Violence Unit for Ft Worth PD)
Neither Dr. Amos nor Dr. Donaldson, nor anyone from Everman ISD, ever filed a complaint for educator misconduct with TEA, SBEC or Texas DPS, as they should have. It also became clear in this 7-29-2019 Dr. Amos’s wantonly disregarded for the safety of his employees and students by not reporting this incident and, additionally, he placed the co-worker and her child’s life in jeopardy.
By failing to report and to pursue the investigation, per the TEC, and by placing blame at the feet of the co-worker to deflect accountability away from Everman ISD and onto the co-worker, this was Dr Amos’ attempt contain this issue within Everman ISD and hide it from advancing any further from going public and going beyond from the few people within Everman ISD who knew about the issue.  It also became clear in this 7-29-2019 that Dr Amos did not care one bit at the danger he placed the co-worker in, nor Amos' obligations to report to the appropriate agencies
Hence, the failure to report by Everman ISD and Dr Amos is the catalyst for this complaint now being filed by the co-worker mentioned above in an effort to do the right thing.
(There is audio recording of the 7-29-2019 meeting between Amos, Donaldson and the co-worker where Amos defends and excuses away the behavior of G.F. amd where by Amos knows that G.F. had taken another position in Austin ISD, but for safety and privacy concerns, this recording will be redacted and can then be made publicly available)
Furthermore, in this 7-29-2019 meeting between Dr Amos, Dr Donaldson and the co-worker, Dr Amos proceeded to DEFEND and EXCUSE the behavior of G.F. away and turned the accusations and hostile comments against the co-worker, including harsh, negative comments about the co-worker’s character and personal life, especially towards the evidence she was trying to offer as an explanation to the harassment, violence and intimidation that she received from G.F. as a result of Dr Amos’ accusing the “ex-girlfriend”/co-worker of being the source of the tip to G.F. on 4-16-2019, and how Dr Amos continued to maintain this accusation for 3 weeks that the “ex-girlfriend”/co-worker was the source of the tip.
Again, the precipitating event that led to G.F.’s drug investigation was breaking up a fight on 4-16-2019 at 915am, injuring his hand, and being sent to the workman’s comp clinic 1 hour later where he was drug tested. This is standard protocol for Everman ISD in the case of a workplace injury.
However, beyond the 4-16-2019 accusation by Dr Amos that the co-worker was the source of the “cocaine use” tip, 2 other additional documented instances occurred that support that Dr Amos continuously placed the co-worker at blame as the “ex-girlfriend who said G.F. did cocaine”, without regard to the safety and well-being of the co-worker, both in her personal life and professional work environment.
The 2nd instance where Dr Amos continued to publicly maintain the co-worker was the source of the tip occurred with email exchanges between a) Jim Whitton, Attorney for Everman ISD, b) Jason, Attorney to G.F. and c) Shane Goetz, Attorney for the co-worker, between 4-16-2019 and 5-10-2019.  These emails provide proof numerous times that Dr Amos and Everman ISD was going to officially and publicly point to the co-worker of the source of the tip and, as a result, blame the co-worker of being the catalyst for being sent to the workman’s comp clinic where G.F. was drug tested.
The 3rd instance occurred when the 5-4-2019 “Settlement Agreement” meeting took place with G.F., his Attorney from UEA and Everman officials where an email was voluntarily printed and handed over to G.F., by Everman ISD officials, that was sent from the co-worker to Dr Donaldson on 4-16-2019 at 1055am, nearly 1.5 hours AFTER G.F. had already been called to the workman’s comp clinic for a drug test.
Even though this email contains ZERO reference about cocaine and in no way can this email from the co-worker be construed as the co-worker told Everman ISD that G.F. did cocaine, Dr Amos and Everman ISD officials asserted this email as “proof” that the “ex-girlfriend”/co-worker was the source of the drug use tip in the 5-4-2019 meeting with G.F. when they gave him the “settlement agreement” and ZERO adverse actions were taken towards G.F.
(This email can be submitted with an open records request, which has not yet occurred, as the co-worker is no longer employed by Everman ISD and has no access to her email account. A synopsis will be provided at the bottom of this complaint).
It is clear that Dr Amos engaged in illegal and unethical behavior in how he handled the investigation that began on 4-16-2019, and again at several points after the investigation began, and Dr Amos offered a “Settlement Agreement” to G.F. on 5-4-2019 when that should not have taken place, and Dr Amos did not report to the appropriate agencies at all.
As a result, G.F. was able to take a teaching/coaching position in Austin ISD in July 2019, and should not have been allowed to do so IF Dr Curtis Amos had filed the SBEC and TxDPS complaints, as he was required to by law.
G.F.'s 3rd girlfriend, V.L., out of Austin TX, whom G.F. has been in a relationship with for 9 years, later wrote a statement on behalf of G.F. in August 2019, when he was placed under investigation after only being employed by Austin ISD for a few weeks, and gave it to Austin ISD whereby she supported G.F. and denied to Austin ISD that G.F. did drugs, yet V.L. in text messages in September 2019 admitted she knew G.F. did drugs. Submitting a false statement to Austin ISD was V.L.'s attempt to help G.F. keep his job in Austin ISD.
On September 2nd, V.L. confirmed that Austin ISD did in fact terminate his employment anyway because G.F. lied on his employment application to Austin ISD that he had never been terminated or placed on administrative leave at Everman ISD and also did not disclose that he had failed a drug test in Everman ISD.
Had Everman ISD done the proper reporting to SBEC and TX DPS, G.F. would have been on record for Educator Misconduct and placed under investigation by SBEC and Austin ISD would have been aware of it and not hired him.
Dr Curtis Amos has a history of covering up scandals in Everman ISD and retaliating against and harassing employees who uncover wrong-doing
Item 2: Educator Misconduct on behalf of Dr Curtis Amos, Superintendent of Everman ISD, for failing to properly investigate a Title IX complaint, failing to report an employee’s sexual predation of female students to local law enforcement and CPS as a “mandatory reporter”, for retaliation against the co-worker for filing a Title IX complaint and for failing to report educator misconduct to SBEC
In the course of 1 single day on 2-16-2019, across 1200+ text messages between this same co-worker and beloved Everman football coach John Tinker (J.T), J.T. implicated the Everman School Board President, the Everman Athletic Coordinator, several administrators and male staff, and 3 fellow female staff in rampant sexual harassment practices or victimization across Everman ISD as well as grade manipulation via relationships between coaches and female staff members. J.T. admitted to grooming and sleeping with 4 female students of his, as well as a host of many other unethical and disgusting actions. The co-worker turned these 1200 messages in to Dr Amos and filed a Title IX complaint on 3-7-2019.
Instead, J.T. was given a “Settlement Agreement” by Dr Amos and sent along his way, with no complaints filed to SBEC for the football coach’s disgusting actions, and no other actions or investigation, including reporting to local law enforcement for possible sexual assault on 4 female students, nor to CPS, ever took place as to any other evidence against J.T., nor any of the other Everman ISD employees, for allegations of sexual predation on students nor into the documented sexual harassment of the co-worker or the other 3 female staff members, which included J.T. sending unsolicited nude photos of another female staff member to the co-worker without that female staff member's knowledge and consent, included all in a total of 23 items that were the subject of the Title IX complaint against J.T. and other Everman ISD male staff and district level administrators, i.e. the School Board President and the Everman ISD Athletic Coordinator.
J.T. has since gone on to take another teaching job in an unknown school district for the 2019-2020 school year because Dr Amos did not report J.T. to the appropriate agencies.
Instead, the co-worker was subjected to harassment on 3-8-2019 at 830am, by Dr Curtis Amos, when meeting about the complaint she filed on 3-7-2019, when Dr Amos accused her of notifying a local news station of the complaint filed just the night before, and pressured her to implicate either herself, G.F., her immediate supervisor, one of the women who was listed as a victim in the Title IX complaint or anyone else she could think of as the source of the press tip-off.
(There is a recording of this 3-8-2019 meeting to document Dr Amos' harassment and insults of the co-worker over her Title IX complaint but will be redacted for safety and privacy concerns before it can be released publicly)
The co-worker had no knowledge of how the press could have found out about this Title IX complaint filed only 12 hours earlier and Dr Amos was upset that the press found out about it and that the co-worker could not give him the source of the press tip.  He continued to pressure and interrogate the co-worker for more than 10 minutes in this 3-8-2019 meeting until the co-worker broke down in tears and he finally stopped talking about it.  Dr Curtis Amos was visibly upset with the co-worker and harsh in tone for this entire meeting.  The co-worker believes it was because of this Title IX complaint, and not knowing who tipped the press off about the complaint, that led her to lose support with Dr Curtis Amos and find herself the victim of retaliation by Dr Curtis Amos 6 wks later when this drug investigation happened with G.F.
Additionally, by covering up the Title IX investigation and refusing to pursue any responsibility and accountability against J.T, and by simply giving J.T. a “Settlement Agreement” and sending him on his way, Dr Amos demonstrates a pattern of covering up illegal and unethical behaviors of Everman ISD employees to avoid public scandal with Everman ISD and to protect his career.
Item 3:
There are 2 open criminal case investigations against G.F.:
1) Fort Worth PD: brutal, vicious assault with serious bodily injury on R.R. by G.F. on 5-26-2018.  Case #:  180046738
(See Addendum for documentation on this open investigation)
2) Arlington PD: terroristic threat on co-worker’s daughter’s life for retaliation if she exposed his drug use and assault to Everman ISD.  Case #: 2019-01650328
(See Addendum for documentation on this open investigation)


Item 4:
Timeline of events related to G.F. drug investigation:
4-16-2019:
915am: G.F. breaks up a student fight. Injures his hand.
1000am: G.F. is sent to workman’s comp clinic and ordered to complete a drug test
1055am: Email is sent to Dr Donaldson by co-worker (please see synopsis provided below)
11am-1pm: text messages are exchanged between G.F. and co-worker where he admits to using cocaine and marijuana aka “green”, where he admits to “having an idea” (later determined that he asked R.R. to come to clinic and give him a urine sample that he submitted but failed as “inconclusive for temperature” and she drove him back to admin building once he refused to submit to a 2nd drug test)
145pm: G.F. meets with Dr. Amos at admin building. Dr. Amos states that the co-worker is an “ex-girlfriend who has given Everman a tip that G.F. uses cocaine”. G.F. is NOT placed on administrative leave and is allowed to freely leave the building at 315pm without having to submit a 2nd sample.
305pm: G.F. leaves admin building and goes to UEA
330-350pm: co-worker drives to UEA, per G.F.’s directive. Upon arrival, co-worker’s phone is involuntarily taken from her by G.F. and gone through for texts, pictures, recordings, etc.
355-430pm: co-worker is made to sit at UEA and wait for G.F. to talk to his attorney
435pm: co-worker is made to pay $80 at Walgreens for 2 drug tests for G.F.
450-715pm: G.F. tests positive for cocaine and marijuana at his apartment. He threatens, harasses, yells, screams and accuses the co-worker and physically intimidates her into trying to get her to “confess” that she was “the source of the cocaine tip to Everman”. G.F. makes co-worker delete everything in her phone to destroy and hide evidence that could prove he uses drugs, which include the text messages earlier in the day where he admitted to using cocaine and marijuana to the co-worker while he was waiting at the clinic.
(Forensically, the co-worker was able to download a paid app called DiskDigger Pro several weeks later to recover the deleted text messages, but it was too late to submit to Everman, as G.F. had already received his “Settlement Agreement” on 5-4-2019 and Everman was not going to undo the Agreement.  These text messages are available for public release)
715pm: co-worker is allowed to leave after several hours of physical and verbal intimidation
4-17 through 4-18-2019: G.F. takes 2 personal days to allow cocaine to leave his system
4-19-2019: Good Friday, no school
4-22-2019: G.F. reports to work and works a full day
4-23-2019: G.F. reports to work but is placed on administrative leave by Dr. Amos, where a 2nd time Amos stands by his assertion that the “ex-girlfriend”/co-worker was the source of Everman’s knowledge that G.F. may be using drugs.
4-23-2019: Dr Donaldson requests meeting with co-worker, whom she knows is in relationship with G.F., via a Title IX complaint filed with Everman March 8th, 2019, to get the co-worker’s statement on any knowledge or evidence she may have that would implicate G.F. for drug use
4-23-2019: A meeting between Human Resources director, Gina Sanderson, Asst Superintendent Dr Felicia Donaldson and the co-worker took place.  A statement was given by the co-worker stating that, as of that date, she had never seen the drugs personally or had any proof that G.F. was under the influence at that time.  As of 4-23-2019, G.F. had only TOLD the co-worker, much as he did in texts on 4-16-2019 that she was made to delete, that he used cocaine and marijuana.
Later, on 5-7-2019, the co-worker would FINALLY see at least $500 worth of cocaine in G.F.’s possession in his apartment that he flushes down the toilet after he called the police when R.R.'s cousin came to G.F.'s apartment at 2am and slashed G.F.s tires for cheating on R.R. with the co-worker.  A recording of more than 4 hours long titled “Shumer Shuffle” is available to substantiate all of this that the co-worker recorded while at G.F.’s residence on 5-7-2019. This recording has been given to Ft Worth police department because it ALSO has G.F.'s detailed confession for the brutal assault on R.R. on 5-26-2018 that G.F. is under investigation for. (A redacted copy can be provided to protect the co-worker's safety and privacy
4-23-2019 through 5-4-2019: G.F. remains on administrative leave while nothing else occurs in the investigation. G.F. continues to verbally harass, intimidate and threaten co-worker into remaining quiet.
5-4-2019: Everman ISD gives G.F. “Settlement Agreement” with full contract pay, benefits, days, etc and G.F. submits his resignation effective for future date of 5-31-2019. Everman ISD gives G.F. email sent by co-worker on 4-16-2019 at 1055am as “proof” that the co-worker was the source of information that G.F. uses drugs.
(See synopsis of email below)
5-6-2019: Co-worker discovers there is a $5 paid app called DiskDigger Pro that can be used on Android devices to retrieve deleted items.  She pays and downloads the app and pulls up every text message and picture she was made to delete on 4-16-2019, which includes G.F.'s admission in texts that he had marijuana and cocaine in his system.
(These recovered text messages can be made available)
5-7-2019:
Co-worker downloads voice recording app and begins to record conversations after weeks of harassment, threats and intimidation by G.F.
945pm: Co-worker reveals her relationship with G.F. to his 2nd girlfriend R.R. after learning of the 2nd relationship with R.R. The co-worker had no knowledge of 3rd girlfriend, V.L. in Austin, until September 2019.  A 40 minute recording takes places, titled “Garage”, where
R.R. volunteers and describes that G.F. viciously assaulted her on 5-26-2018 and showed the co-worker gory, bloody pictures of her face where G.F. slammed her face into the doorway multiple times for asking about who this Linda person he was texting behind R.R.’s back
where R.R. and co-worker openly discuss G.F.’s drug use,
where R.R. is given a copy of the salvaged text messages from 4-16-2019 where G.F. admits his cocaine and marijuana use that the co-worker was able to retrieve forensically on 5-6-2019 after being made to delete them on 4-16-2019 at G.F.s apartment,
where R.R. states that G.F. has asked her numerous times to get him drugs from her job as a nurse at a Harris Methodist, and she admits to getting him “tramadol and other stuff”, and
where R.R. admits she was present at the time that G.F. submitted a urine sample that tested inconclusive for temperature and does not deny the co-worker’s allegation that R.R. gave G.F. the urine sample to submit instead of G.F’s own.
(There is a recording of this 40 minute conversation that can be redacted and released to protect the safety and privacy of the co-worker)
11pm to 3am, going into 5-8-2019: Co-worker goes to G.F.’s house. A 4 hour recording by the co-worker takes place where
G.F. details the facts of the assault he committed on R.R.,
admits to using drugs, and
where R.R.’s cousin slashes his tires at about 2am on 5-8-2019 for cheating with the co-worker on R.R. and G.F. calls the police for what he said was gun shots, and, during the time he is waiting on the police to arrive, he panics and flushes 100s of dollars of cocaine down the toilet in front of the co-worker on this 4 hour recording. Police never arrive as the call was timed out.
(This recording can be redacted to protect the safety and privacy of the co-worker and be released publicly)
5-8-2019 through 6-5-2019: G.F. alternates between harassment of the co-worker for threatening to “ out him” for the drug use, assault, etc and ignoring the co-worker to focus his efforts on intimidating R.R. so that she does follow through with Ft Worth police for being an assault victim and to pressure R.R.to not turn in the text messages to Everman where G.F. admits he is guilty of using cocaine and marijuana to the co-worker. Beginning 5-7-2019, it is during these few weeks that the co-worker begins recording conversations that take place between G.F. and the co-worker to document his threats, harassment and intimidation of the co-worker that had already been on-going for 3 weeks as a result of Dr Amos’ unethical botched investigation.
6-6-2019: G.F. and co-worker meet to discuss her plan to reveal his drug use, assault, etc.  A 70 minute recording, titled documents the following items in conversation,
G.F. admits to using drugs and
makes the terroristic threat on the co-worker’s daughter’s life if she exposed his drug use, assault etc publicly.
(This recording can be redacted for safety and privacy and released publically. It has been submitted to Arlington police department and an active investigation is ongoing for G.F.'s terroristic threat on the co-worker's daughter's life for retaliation)
6-14-2019: Co-worker files police report with Arlington PD (her city of residence) for terroristic threat against her daughter by G.F. and turns in the recordings. APD counsels her on what to do with other recordings, which includes submitting the 2 recordings of confessions of a serious bodily assault from 5-26-2018, where G.F. confesses to brutally beating R.R., to Ft Worth PD and where R.R. confesses that G.F. beat her and showed the co-worker's pictures that R.R. never gave to Ft Worth police to protect G.F.
6-19-2019: An 80 minute recording was taken during a meeting between the co-worker and G.F at a church in Burleson at G.F.'s instance that he and the co-worker meet to discuss everything.
G.F. states he wants to make amends and have peace with the co-worker after threats of violence and weeks of harassment and intimidation were not working to stop the co-worker from taking action against him and
G.F. and co-worker discuss the threat G.F. made on the co-worker’s daughter’s life and
where he again admits to using drugs.
(This recorded can be redacted for safety and privacy of the co-worker and be released publicly)
7-29-2019: Co-worker meets with Dr. Amos and Dr Donaldson from Everman. It is in this meeting that the co-worker discovers that neither Amos nor Donaldson filed a complaint with SBEC, TEA or TX DPS against G.F. and the co-worker finds out that no one at Everman ISD had done anything beyond the 5-4-2019 “Settlement Agreement” regarding the situation with G.F.
During this meeting, Dr. Amos does not want to hear any of the negative events that had befallen the co-worker at G.F.'s hands since Dr Amos botched G.F. investigation, Amos did not want to see the police reports, Amos denied that he ever told G.F. that the co-worker was the source of the tip, despite many documented incidents that contradict Amos’ claim about this, and where Dr. Amos engaged in cruel personal insults and attacks on the co-worker for trying to explain all of this to him.
In this meeting, it was discussed that G.F. had taken another teaching/coaching position in Austin ISD.  Dr. Amos expressed zero concern that G.F. had taken a position in Austin ISD and, instead DEFENDS and EXCUSES G.F’s drug use and violent behaviors away as “making a mistake”, for the “co-worker to leave G.F. and the situation alone” and was instructed by Amos to do nothing about the educator misconduct by both Amos and G.F.
Dr. Amos defended G.F. and verbally attacked the character of the co-worker instead and tried to cower her down into “not doing anything” about the G.F. situation and to just let it die.  It was clear to the co-worker that Amos wanted this G.F. situation to remain private and not have public complaints filed.  It was during the meeting, the co-worker decided to file the complaints herself because no complaint was filed by Amos or anyone in Everman.
(There is a recording of this meeting that can be redacted for safety and privacy of the co-worker and be released publicly to document Amos' actions of insults in an attemot to hide this scandal within Everman ISD)

Item 5:
Synopsis of the email sent from the co-worker to the Asst Superintendent Donaldson on 4-16-2019 at 1055am:
After speaking with Dr Donaldson on the phone at approximately 1045am on 4-16-2019 regarding the events of the fight that morning, where both the student and G.F. were injured when the student was taken down to the ground by G.F. for assaulting another student, the co-worker sent an email a few moments later to the effect of:
“Maybe if not drug screening through workman’s comp, then maybe through CDL and driving the buses? But, he’s been fired from coaching, so I don’t know if he would take the test then”
This email was the ONLY PROOF ever offered to G.F. that the co-worker was the source of the drug use tip earlier in the morning on 4-16-2019. And this email was sent AFTER G.F. had already arrived at the workman’s comp clinic for his injury and drug test.  The co-worker had no idea that G.F. was even at the workman’s comp clinic until after this email was sent.  This email was sent in re to the phone conversation at 1045am that the co-worker had with Dr Donaldson regarding the fight and G.F’s hand injury. This email was printed and voluntarily given to G.F. by Everman ISD officials at the 5-4-2019 “Settlement Agreement” meeting.
Item 6:  Timeline of events related to J.T. and the Title IX complaint, and the claims for Educator Misconduct by Amos

2-15-2019:

J.T receives co-worker’s phone number from group email related to planning dept breakfast the previous day

2-16-2019:

Begins texting co-worker at 10am.  Within minutes, propositioned co-worker for J.T.’s sexual attraction to co-worker.

Between 10am-1030pm: J.T and co-worker exchange 1200+ text messages regarding J.T’s sexual advances, continuous rebuffs of those sexual advances by the co-worker, confessions of educator misconduct and sexual predation on both 4 female students and 3 female staff members separate from the co-worker, and where by J.T. implicates numerous Everman ISD staff and administrators as being complicit in a culture of sexual predation.

2-18-2019 through 3-7-2019:

Co-worker works with her education attorney to draft complaint and gather evidence

3-7-2019: co-worker files Title IX complaint via email to Dr Felicia Donaldson at 645pm

(Please see addendum with Title IX complaint below that was filed with Everman ISD)

3-8-2019:

830am: Co-worker meets with Dr Donaldson and Superintendent Curtis Amos.  Co-worker runs through the 23 bulleted events leading to the complaint that arose out of the 2-16-2019 texts from J.T., which included having sex with 4 female students and a pervasive culture of sexual predation in Everman ISD. The last 15 minutes of this meeting she is harassed and interrogated by Dr Curtis Amos and accused of tipping off a news outlet about the Title IX complaint.  A 3-8-2019 645am email is printed by Dr Amos as proof that a news outlet was tipped off.  Co-worker defends herself, her fellow co-worker G.F. whom she is involved in a romantic relationship with at that time and who was mentioned in her Title IX complaint because G.F. was involved in those text messages between J.T. and the co-worker, a fellow female staff member who was a victim of the sexual harassment complaint and anyone else that Dr Amos could think of.  Co-worker denies any knowledge of how news came to be aware of the complaint.

1130am:  J.T. is removed from the Baseball field and asked to come to Administration building where he was placed on paid administrative leave due to Title IX complaint.

Sometime between 3-19-2019 and 3-27-2019: J.T. is given a “Settlement Agreement” that pays out the remaining 6 months of pay, keeps his leave days and retains health insurance through the district through August 2019. In reciprocation, J.T. agrees to resign effective the end of his contract and remain silent about the contents of the investigation and the “Settlement Agreement”. Essentially, Everman ISD "passed the trash of J.T." out of their district and allowed him to leave, did not report to the appropriate agencies and hid this scandal from the public.

3-19-2019:  Dr Donaldson meets with co-worker to give results of Title IX complaint.  22 out of the 23 allegations in the Title IX complaint are dismissed, including all unwanted advances towards co-worker, and only 1 item was found to justify the complaint.  The only item was the unsolicited nearly nude photo of another female co-worker that J.T. alleged he had sexual relations with that was sent to co-worker, and without the knowledge and consent of that female staff member.  No other items were granted, no matter how serious the allegations were that J.T. made for Everman ISD staff and administrators, nor for the students he had sexual relationships with

The 2.5 page summary of the denial of 22 out of 23 items in the complaint advances further by
blaming the co-worker for creating a sexual harassment situation and
falsely accuses the co-worker of instigating the sexual harassment texts and items in the complaint,
falsely alleges that the co-worker is guilty of sexual harassment also and
chides co-worker for participating in the texting with J.T.

Co-worker attempts to explain that J.T. began very early within minutes of texting the co-worker and began immediately divulging controversial and explicit information about many Everman ISD staff and, as a result, co-worker continued to text with J.T. to allow him space to continue to divulge information that co-worker quickly determined needed to be turned in to Everman ISD, especially the portion where J.T. admits to sleeping with 4 female students.

Co-worker attempts to address the blatant sexism coming from Dr Donaldson that is being used to justify the dismissal of the Title IX complaint: because the co-worker is a woman, Everman’s only acceptable preference of how the co-worker should have handled the sexual revelations coming from  J.T. about himself and Everman ISD staff, including multiple advances by J.T. that were declined by the co-worker, was for the co-worker to tell J.T. to shut up immediately and stop revealing these illegal and unethical things to the co-worker.

Everman ISD also uses the duration of 1 single day to deny that sexual harassment was “repeated” and “continuous” and, as a result, J.T.s actions and revelations did not constitute sexual harassment.  Title IX complaint is dismissed with the exception of 1 item and nothing else happens with any of the other Everman ISD staff members implicated for their contributions to a culture of nor any of the other victims that J.T. created, including the 4 female students he slept with.

Zero investigation is conducted into the allegation of J.T. having an erection in class in front of a class of all female students, in full view of those female students and the students exclaimed about his visible erection and that he went to the restroom to masturbate to relieve his erection.   NO STUDENTS FROM THAT CLASS PERIOD WERE EVER INTERVIEWED.

Zero investigation occurred into his admission that he had groomed and had sexual relations with 4 female students, instead Everman ISD merely took J.T. at his word that he lied about sleeping with those 4 female students. Interviewing the students would have caused public scandal for Everman ISD so Everman ISD chose not to investigate these.

(These 1200 text messages can be redacted for safety and privacy and released publicly)

It appears the motivation behind denying 22 out of the 23 items listed in the Title IX complaint and by conducting an improper investigation was to prevent a public scandal that could negatively affect Everman ISD’s reputation.

Everman accepted J.T’s excuses and lies at face value, as it was the easiest way to conclude the investigation.  Everman ISD CLAIMS that J.T. provided a completely irrational and outrageous excuse that he lied when he snitched on multiple Everman ISD staff, himself, sleeping with students and his affairs. Everman took the easy way out by taking his claims at face value instead of conducting a proper investigation and making the appropriate reporting to the agencies as Everman ISD should have.  Everman ISD insulted and affronted the co-worker’s dignity and reputation by accepting J.T.s lies that he was simply trying to impress the co-worker.  Everman made this co-worker feel completely demoralized and worthless.

It is beyond comprehension that this co-worker would find the following things J.T. told her to be acceptable or be impressed and, multiple times, the co-worker expressed dissatisfaction, upset, offense or shock at the following items in her texts to J.T.: 1) J.T. sleeping with 4 female students, 2) where J.T. claims the School Board President knew of J.T.'s sexual predation history because J.T. regularly drank beer with this person, 3) the multiple invasions of privacy that J.T. himself engages in with the co-worker’s and G.F.’s relationship, 4) the lewd comments that J.T. stated he wanted to do to the co-worker i.e. slap her butt in the hallway at work, 5) the lewd comments about her breasts, 6) lewd discussions that took place behind her back amongst J.T. and other Everman male staff members wanting to do a sexual things with her and remarks about her breasts, 7) 6 times she said no to J.T.'s requests for sexual relations with the co-worker, etc.  It is appalling and sickening that Everman ISD could ever affront the co-worker to such a degree as to accept the excuse that the co-worker was impressed by J.T. doing and saying these things, and to accept his lies outright as truth and fact, without doing a full and proper investigation into claims J.T. made that are criminal in nature i.e. sexual relations with 4 female students.

Everman ISD has a history of covering up scandals within their district and merely accepting J.T.’s lies as truth so that this Title IX claim could be dismissed is an example of what is routine procedural happenings in Everman ISD.  By claiming that J.T. was a poisoned source, all other claims he made were null and void with him.  As such, by removing J.T. from Everman, Everman claims it completed its due diligence into these allegations by removing the poisoned source.  However, that is absolutely unacceptable, unethical and illegal.  By not reporting J.T.’s educator misconduct to SBEC within 7 days and CPS and law enforcement about the 4 female students, Everman ISD was complicit in yet another attempt to cover up another scandal within it’s ranks.

In this 3-19-2019 meeting, Dr Donaldson was present with Gina Sanderson, Director of Human Resources and the co-worker to discuss the outcome of the Title IX investigation.  It was during this meeting that the co-worker re-asserted several times the 3 reasons why her 3-7-2019 Title IX complaint was valid and should be decided in her favor.  In the 2.5 page typed response received, AFTER this meeting, the co-worker was stunned to discover that not one of her 3 reasons given in this 3-19-2019 were taken seriously by Everman ISD and all 3 reasons were dismissed and 22 out if 23 items were ignored and dismissed.

(The full 3-7-2019 Title IX complaint can be redacted for safety and privacy and be released publicly)

(There is a recording of this meeting that can be redacted for safety and privacy and be released publicly)

No reports of Educator Misconduct were ever filed with SBEC regarding J.T.s own admission of unethical sexual predation, especially within 7 days after the conclusion of the Title IX investigation that Superintendent Dr Amos is bound to.  J.T.’s educator certification remains intact and he has been freely allowed to take a position in another school district due to the failure of Everman ISD and Dr Amos to properly investigate and respond with appropriate action in J.T.’s atrocious conduct, the conduct of other Everman ISD employees who engage in a culture of sexual predation nor into the victims identified as 4 total female staff members and 4 female students.

No reports were made by Everman ISD to CPS or to law enforcement as a mandatory reporter on the allegation that J.T. slept with 4 female students.  The only investigation into the allegation that J.T. slept with 4 female students was merely asking J.T. if he had done so, and the expected response from J.T. was to deny that he had done so, despite his texts bragging that he had done so.

In retaliation against the co-worker……

6 weeks later, when G.F., who was involved in a romantic relationship with the co-worker, failed a drug test after being sent to the workman’s comp clinic after injuring his hand breaking up a student fight, Dr Amos told G.F. that “an ex-girlfriend gave us a tip that you use cocaine” in an attempt to shake down G.F. to submit to a 2nd drug test or confess to hus drug use.  G.F. refused for 2 hours after the first failed drug test at the clinic and again for another 1.5 hours at the administration building when G.F. met with Dr Amos.

It is the co-worker’s sincerely held belief that Dr Amos pointed the blame at the co-worker in retaliation for filing a Title IX complaint.  The precipitating event that led to G.F. going to the workman’s comp clinic was the injury to his hand following breaking up a student fight, per Everman ISD policy and procedure.

It was wholly unnecessary that Dr Amos point the finger and blame the co-worker for G.F.s refusal to submit to a 2nd drug test, nor to use the co-worker as a pawn in the game Dr Amos was playing with G.F.  Dr Amos willfully and repeatedly placed the personal and professional life of the co-worker at risk for serious bodily injury, harassment and hostile work environment and the co-worker firmly believes it was simply for retaliation for filing a Title IX complaint 6 weeks prior.

Through this J.T. Title IX complaint, 6 weeks prior, Dr Amos knew that the co-worker and G.F. were involved in a romantic relationship and Dr Amos used that as a bargaining or interrogation chip to try to persuade, threaten or break down G.F. into giving a 2nd urine sample.  That strategy failed and G.F. never submitted to a 2nd urine sample but led to weeks of intimidation and harassment for the co-worker by G.F. and resulting in an eventual resignation by the co-worker on 4-23-2019 due to the continued hostile work environment created by Dr Amos when he engaged in retaliation against the co-worker.

Addendums and Items of Evidence:

1:  Arlington PD report for G.F. terroristic threat of harm to the co-worker’s daughter in retaliation for exposing his drug use or assault to Everman ISD

https://drive.google.com/file/d/1g-UobKcZ-OBsMnUfAhdYFKO45oE30BPy/view?usp=drivesdk

2: “Settlement Agreement” and “Resignation” of G.F. on 5-4-2019

https://drive.google.com/drive/folders/1hfneyBVBbADBZ5MK2NeiVGiQwdWnluwa?usp=sharing

3:  Pending criminal case against G.F. in Ft Worth resulting from serious bodily injury to R.R. 5-26-2018

https://drive.google.com/drive/folders/1eyH9jPWTSlyrtT2TdKDHG1ldri6MqxB-?usp=sharing


4: Text messages of G.F. admitting to using cocaine and marijuana on 4-16-2019 while at the workman’s comp clinic.  Later forensically retrieved on 5-6-2019 after co-worker was made to delete them and being harassed about them.

https://drive.google.com/folderview?id=1LDNmlyxxKaOfKmKYiv2irIfb6qbkoMxS

5:  Title IX complaint against J.T. by co-worker dated 3-7-2019

https://drive.google.com/file/d/1PoYZ21OjhYXQe6UIqQo7tcHcr9OpA3GN/view?usp=sharing

6:  Response letter from Everman ISD denying 22 of the 23 Title IX complaint items, where Everman ISD turns the blame on the victim and blames the victim for causing the Title IX complaint

https://drive.google.com/drive/folders/1N1K5BF6M54s9RSe79qmb7I2uyIoi7cxJ?usp=sharing


7:  SBEC certifications for J.T., G.F. and Dr Amos

https://drive.google.com/file/d/12pWzzvNBXIn-zv185XwHP3g0zRbmKMer/view?usp=sharing

8) Picture of G.F. as it appears in the Everman HS yearbook for 2018-2019 school year.

https://drive.google.com/file/d/12V0UExrKWFExvNyyIdEM6ePa4a0ZU7bx/view?usp=drivesdk

9)  Picture of John (Paula) Tinker as it appears on his public Facebook page

https://drive.google.com/file/d/1732Vmo_pat5cMNBQ3t7SPMs2h17_kk7H/view?usp=drivesdk


My client and I respectfully request an investigation into these matters concerning Dr Curtis Amos, John Tinker and Gilbert Fuentez.



								Sincerely,

							David Olivas
                                                                            3300 Oak Lawn Ave #700
                                                                            Dallas Tx 75219
                                                                            214-845-7570
                                                                            Lawyer@daveolivas.com
								***********