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FILED

7/28/2016 8:51:09 AM
JOHN F. WARREN
COUNTY CLERK
DALLAS COUNTY

CC-16-03723-E

CAUSE NO. ----

INRE:
PETITION OF THOMAS HILL
REQUESTING PRE-SUIT
DEPOSITION UNDER RULE 202

IN THE COUNTY COURT


AT LAW NO. ----

DALLAS COUNTY,TEXAS

VERIFIED PETITION REQUESTING DEPOSITION DUCES TECUM BEFORE SUIT

TO THE HONORABLE COURT:


Petitioner, Thomas Hill (hereinafter referred to as "Hill" or "Petitioner") submits this
Verified Petition requesting authority to take the various depositions and obtain relevant
documents.
SUMMARY OF PETITION
1.

Hill was a longtime, loyal and productive employee of Baylor University

("Baylor"). But when the sexual-assaults by Baylor University Athletes became public, Baylor
rushed to judgment. Baylor summarily fired Hill, even though Hill did nothing wrong regarding
the sexual assaults that occurred at Baylor. While not to the same degree as the courageous
women who were victimized in this dark time in Baylor's history, Hill is yet another-and
unnecessary-victim of this controversy.

DEPOSITIONS SOUGHT
2.

Petitioner seeks the depositions of: Ronald D. Murff (hereinafter "Deponent

Murff'), Mark E. Lovvron (hereinafter "Deponent Lovvron"), and David H. Harper (hereinafter
"Deponent Harper"), as authorized by Texas Rule of Civil Procedure 202.
Verified Petition Requesting Deposition Before Suit

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All of these
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depositions collectively the "Depositions." Deponent Murff, Deponent Lovvron, and Deponent
Harper hereinafter collectively the "Deponents."

GROUNDS FOR RULE 202 PETITION


3.

Hill seeks to investigate facts involving the reasons he was fired and regarding

his employment with Baylor. Hill does not yet anticipate a suit.
Petitioner believes that at all relevant times, Deponents were on the Board

4.

of Regents at Baylor University (hereinafter "BOR"). Petitioner was told by Doug Welch that
the BOR voted to terminate Petitioner's employment with Baylor.
5.

On information and belief, Deponent Murff resides in Dallas County, Texas. On

information and belief, Deponent Lovvron resides in Dallas County, Texas. On information and
belief, Deponent Harper resides in Dallas County, Texas.
6.

On or about June 29, 2016, Petitioner's attorney sent a letter to Doug Welch and

requested documents and information from Baylor. A true and correct copy of said letter is
attached hereto as Exhibit "L." Baylor did not provide the information and documents
requested, or any response whatsoever.
7.

Petitioner seeks to investigate why Deponents and Baylor took various actions or

inactions against Petitioner, what actions were taken against Petitioner and exactly when such
actions occurred. Petitioner does not have the knowledge of same, or to the extent Petitioner
does have some knowledge, Deponents know many more details and have greater knowledge of
same. Petitioner is unable to obtain this information known to Deponents except through this
Rule 202 Petition.

Verified Petition Requesting Deposition Before Suit


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8.

Petitioner seeks to investigate potential claims involving: Baylor for wrongful

firing of Petitioner and/or defamation, fraud, misrepresentations, violation of due process and/or
fair procedure; and/or torts that Petitioner may have against Baylor and one or all of the
Deponents, and to resolve questions and unknowns that will better enable Petitioner to assess the
appropriateness of settlement discussions, whether Petitioner has a claim that should be pursued,
and the appropriateness of pursuing a claim and/or lawsuit and who, if anyone, should be sued.
9.

Petitioner anticipates that the Depositions will help resolve pending questions and

unknowns associated with actions Baylor and/or Deponents took against Petitioner, acts or
omissions associated with Baylor's firing of Petitioner, and/or the violation of Petitioner's rights.
Petitioner anticipates Petitioner will be in a better position to determine whether or not claims
should be prosecuted and/or a lawsuit should be filed against any person or entity. However,
Hill does not yet anticipate suit.
10.

Permitting the requested depositions benefits all concerned because it will likely

clear up any misunderstandings or inaccurate perceptions.


11.

Petitioner understands that after Rule 202 depositions have been ordered and/or

depositions have been taken and information is produced, and facts are clarified and/or revealed,
misunderstandings or misimpressions are clarified and/or resolved, many disputes are often
resolved amicably. Petitioner understands that providing such documents and information helps
clear up misunderstandings, which can lead to settlements and/or fewer lawsuits herein filed.
12.

Petitioner seeks to depose Deponent Murff, 88 Abbey Woods Lane, Dallas,

Texas, 75248, Dallas County, Texas. Deponent Murff s telephone number is (972) 380-8885.
As such, Petitioner intends to serve Deponent Murff with a copy of this Petition.

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13.

Petitioner seeks to depose Deponent Lovvron, 10 None Such Road, Dallas, Texas,

75214, Dallas County, Texas. Deponent Lovvron's telephone number is (214) 824-5579. As
such, Petitioner intends to serve Deponent Lovvron with a copy of this Petition.
14.

Petitioner seeks to depose Deponent Harper, 5630 Bent Tree, Dallas, Texas,

75248, Dallas County, Texas. Deponent Harper's telephone number is (214) 651-5247. As
such, Petitioner intends to serve Deponent Harper with a copy of this Petition.

SUBJECTS OF TESTIMONY
15.

The substance of the testimony Petitioner expects to elicit from Deponents

involves:
a. The documents, reports, (including any reports from Pepper Hamilton)
and information the BOR considered or reviewed regarding alleged
assaults, batteries or wrongdoings
committed by Baylor athletes against Baylor students prior to the time
the Baylor communicated to Petitioner that he was being fired.
b. The discussions the BOR had regarding the Petitioner and whether or
not to end Petitioner's employment with Baylor.
c. The discussions the BOR had regarding the knowledge Baylor Athletic
Department employees' had regarding any alleged wrongdoing by any
Baylor athletes.
d. The written and oral communications Baylor had with the Pepper
Hamilton law firm regarding alleged assaults, batteries or wrongdoings
committed by Baylor athletes against Baylor students.
e. The criteria and standards Baylor University used in determining
whether or not to fire any employee of the Baylor Athletic Department
regarding any alleged assaults, batteries or wrongdoings committed by
Baylor athletes against Baylor students.

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16.

Deponents possess unique and superior knowledge relevant to such subjects and

1 7.

Rule 202 provides the procedure for investigating potential claims and potential

issues.

defendants in the situation present in this request for 202 depositions. Although Petitioner has
reason to believe that the actions, inactions and/or omissions by Baylor and Deponents were
wrong and without justification, Petitioner does not wish to undertake the expense and burden of
pursuing a claim or to burden the court system with a lawsuit unless Petitioner is convinced he
has a valid claim.
18.

The benefit of allowing the depositions and production of the documents

requested outweigh the burden or expense of the procedure because Petitioner does not yet know
Baylor's position and the Deponents' position and the facts supporting that position with respect
to the issues and questions noted herein.
19.

Further, Deponents have unique, if not exclusive, knowledge of the facts and

circumstances regarding the issues and questions noted herein that is not obtainable from other
sources. Petitioner needs to conduct an investigation prior to determining the validity of
Petitioner's beliefs.

Likewise, Petitioner's counsel needs to conduct an investigation for

purposes of meeting various legal and ethical duties prior to determining whether or not there is a
basis for pursuing a claim and/or filing suit.
20.

It is more efficient to take the requested depositions and obtain the documents

requested to determine whether or not it would be appropriate for Petitioner to pursue claims
and/or a lawsuit against Baylor or one or more of the Deponents. Since most, if not all, of the
key facts are within the exclusive possession of Deponents, the Depositions need to occur and
the documents requested need to be produced.

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21.

Request is hereby made for the Court to issue an order stating that the likely

benefit of allowing the Petitioner to take the requested depositions and receive the documents
requested to investigate Petitioner's potential claims outweighs the burden or expense of the
procedure, and authorizing Petitioner to take the video and oral depositions of Deponents at a
time and place to be determined by the Court at the conclusion of the hearing.

DOCUMENTS REQUESTED
22.

Petitioner requests that Deponent Murff be required to produce for inspection and

copying the documents and items under Deponent Murff s care, custody, constructive possession
or control that are listed in Exhibit "D" hereto.
23.

Petitioner requests that Deponent Lovvron be required to produce for inspection

and copying the Documents and items under Deponent's care, custody, constructive possession
or control that are listed in Exhibit "D" hereto.
24.

Petitioner requests that Deponent Harper be required to produce for inspection

and copying the Documents and items under Deponent's care, custody, constructive possession
or control that are listed in Exhibit "D" hereto.

PRAYER
WHEREFORE, prayer is made that this Court set a date for hearing on this Petition and,
after the hearing, find that the likely benefit of allowing the requested depositions and ordering
production of the requested Documents to investigate potential claims outweighs the burden or
expense of the request of this procedure, and grant such other and further relief, general or
special, at law or in equity to which Petitioner is justly entitled.

Verified Petition Requesting Deposition Before Suit


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Respectfully submitted,

R. ROGGE DUNN
State Bar No. 06249500
Email: dunn@trialtested.com
BRIAN SHAW
State Bar No. 24053473
Email: shaw@clousedunn.com

CLOUSE DUNN LLP


1201 Elm Street, Suite 5200
Dallas, Texas 75270-2142
Telephone:
(214) 220-3888
(214) 220-3833
Facsimile:

Verified Petition Requesting Deposition Before Suit

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EXHIBIT "D"
INSTRUCTIONS
1.
Unless otherwise provided, the time-frame for the following Document requests are
January 1, 2011, to the present.
2.
Each request also is requesting versions and copies of the Document maintained as
electronic data, on computer disk or hard drive, cloud storage or on any other device which
stores or compiles data or information (collectively referred to as "Document(s)").
Please preserve all Documents, ESI and data compilations relating to our regarding the
3.
subject matters described in this Rule 202, Petition and cease any process of Document
destruction involving such Documents.
DEFINITIONS
1.

"BOR" shall mean the University of Baylor's Board of Regents.

2.
"Communications" shall mean shall mean any oral or written utterance, notation, or
statement of any nature whatsoever, by and to whomsoever made, including, but not limited to,
correspondence, conversations, dialogues, discussions, interviews, consultations, agreements,
and other understandings between or among two or more persons and transfer or exchange
between two or more persons of any information, whether through an intermediary or by written,
electronic, Computer or oral means, including, but not limited to, personal conversations,
meetings, telephone calls, correspondence, e-mails, Internet communications, telegrams, telexes,
cables, memoranda, and any other understandings between two or more people.
3.
"Computer" shall mean and include, but is not limited to, microchips, microcomputers
(also known as Personal Computers), laptop Computers, portable Computers, notebook
Computers, Blackberries, Blackberry Play Books, Kindles, Nooks, E-Readers, Joo Joo, HP Slate;
Dell Streak, Archos 9s, iPods, iPads, Treos, Palms, laptop Computers (also known as personal
digital assistants or PDA's), mobile telephones with internet capabilities, minicomputers and
mainframe computers.
4.
"Deponents" shall mean collectively Ronald D. Murff, Mark E. Lovvron, and David H.
Harper.
5.

"Documents" shall mean the definition in the Texas Rules of Civil Procedure.

6.
"E-mail" and "E-mails" shall mean electronic communications such as e-mails, tweets,
texts and instant messaging.
7.
"ESI" shall mean any electronically stored information or Data on magnetic, optical or
any type of storage media (e.g., hard drives or disks, backup tapes, CD-ROMs, DVD-RO Ms,
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JAZ and Zip drives, clouds and floppy disks) as an "active" file or files (i.e., readily readable by
one or more Computer applications or forensic software); any "deleted" but recoverable
electronic files on said media; any electronic file fragments (i.e., files that have been deleted and
partially overwritten with new data); and "slack" (i.e., data fragments stored randomly from
random access memory on said media during the normal operation of a Computer (RAM slacks)
or residual data left on said media after new data has overwritten some but not all of previously
stored data) ESI shall also mean any data ever placed into or stored on any storage devices
and/or cloud storage accounts, Documents, or information. Cloud storage accounts include, but
not limited to, any data, information (e.g. Amazon Cloud Drive, Dropbox, Google Docs, etc.),
internet or web-based service for storing electronic files.
8.
"Work For," "Works For," "Worked For" and "Working For" shall mean providing any
products, services, time, labor, advice or any other type of service to any person or entity
regardless if the person providing said services is an employee, agent, joint venturer, partner,
limited partner, owner, consultant, independent contractor or has no contractual relationship with
the person or entity to whom services are provided.
9.

"Baylor" shall mean Baylor University.


PLEASE PRODUCE THE FOLLOWING DOCUMENTS AND ESI

1. All Correspondence, E-mails, text messages, voicemails, notes or calendars (in paper or
electronic form) relating to the investigation of improper actions or inactions by anyone
working for the Baylor Athletic Department relating to or concerning Petitioner's firing.
2. All police or criminal charges and records reflecting or relating to alleged criminal or violent
behavior by any person in Baylor's Athletic Department.
3. Any contracts or agreements, executed or unexecuted, between or among Petitioner and
Deponents at any time.
4. The entire personnel files for Petitioner, Nick Joss, Nancy Post and Paul Bradshaw including
any peer review file or records of warnings, discipline, notices, reviews, performance
improvement instructions or plans, notes, E-mails, memos, Correspondence or other
Documents relating to Petitioner's duties, responsibilities and job performance.
5. Any Correspondence, E-mails, text messages, agendas, meeting notes, notes, calendars and
meeting minutes of the BOR (in paper or electronic form) relating to accusations about or
concerning Petitioner, or any adverse action concerning Petitioner's Work for Baylor.
6. Any Documents evidencing or referring to training, orientation or education provided to
Petitioner at any time concerning bylaws, rules, regulations, codes, policies or procedures
relating to Petitioner's alleged behavior and conduct.

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7. Any Documents reflecting or referring to conversations or meetings concerning Petitioner's


alleged behavior and conduct, and/or any adverse action relating to same.
8. All correspondence, E-mails, text messages, notes, calendars and similar Documents (in
paper or electronic form) relating to the ending of Petitioner's Work for Baylor.
This request includes, but is not limited to Documents reflecting or referring to conversations
or meetings concerning the ending of Petitioner's Work for Baylor.
9. All memos, reports, studies, analyses, findings, examinations, investigations, and similar
Documents regarding the alleged improper actions or inactions by Petitioner relating to
Petitioner's Work for Baylor.
10. The personnel files of: Nick Joss, Nancy Post and Paul Bradshaw.
11. All correspondence, E-mails, text messages, notes, calendars and similar Documents (in
paper or electronic form) relating to the termination of Petitioner's employment with Baylor.
This request includes, but is not limited to Documents reflecting or referring to conversations
or meetings concerning any of Petitioner's job terminations.
12. All memos, reports, studies, analyses, findings, examinations, investigations, and similar
Documents regarding the decision to end Petitioner's employment with Baylor.
13. All policies, procedures, guidelines and similar Documents Baylor has for firing employees.

Verified Petition Requesting Deposition Before Suit

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VERIFICATION
STATE OF TEXAS
COUNTY OF DALLAS

BEFORE ME, the w1dersigned Notary Public, on this day personally appeared Thomas
Hill (hereinafter "Affiant'), who is over the age of2I and of sound mind and body, who being.by
me duly sworn, on his oath deposed and said that he has read the foregoing Petition Requesting
Deposition Before Suit and that the statements of fact contained therein are within Affiant's
personal knowledge and are true and correct.

Further, Affiant stated that Affiant has this

personal knowledge because of Affiant's relationship and interaction with Baylor and the
Deponents as described in greater particularity in the foregoing Petition.

SUBSCRIBED AND SWORN TO BEFORE ME on this) day of

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20_)it_, to certify which witness my hand and official seal.


,,,..,'!',,,,

TINA M. VANDERBURG

'""'' Notary Public. Slate of Texas


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Verified Petition Requesting Depositions Before Suit


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Solo Page

R. ROGGE DUNN
130ARD CERTIFIED
TEXAS BD. Of LEGAL SPECIALIZATION:

1201 ELM ST., SUITE 5200


DALLAS, TEXAS 75270-2142
(214) 220-3888 FAX (214) 220-3833

CIVIL TRIAL LAW


LABOR & EMPLOYMENT l,\ W
WRITER'S DIRECT DIAL: (214 ) 220-0077
WRITER s E-MAIL: dunn@ri!!httowork.com

TRIAi. A'ITORNYS

June 29, 2016


Mr. Doug Welch, Esq.
Associate General Counsel
Baylor University
213 Pat Neff Hall
One Bear Place #97034
Waco, Texas 79798

Re:

Our File No.


Our File Name:

0 VIA OVERNIGHT

'yl, VIA FAX: 254.710.3843


VIA FIRST CLASS MAIL
?VIA EMAIL:

DOUG WELCll(a).8,\YLOR.EDU

VIA CERTIFIED MAJL/RRR

6142/55555
Hill/Baylor

Dear Mr. Welch:


FACTS

sense.

Tom was a long-term, productive and loyal Baylor employee. His firing does not make

Tom was fired from Baylor University (hereinafter "Baylor, You" or "Your") soon after
being interviewed by Pepper Hamilton. Tom was told only that the Baylor Board of Regents
(hereinafter "BOR") had decided to fire him. Tom asked what specific actions or reasons led to
BOR firing him, and he was told: "I am not at liberty to discuss the reasons why the BOR fired
you. If you have a lawyer, I may be able to discuss these issues with them."

EXHIBIT
I

II

L ,,

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INFORMATION AND DOCUMENTS WE NEED


When an individual approaches me regarding claims they believe they may have against
another person or entity, it is my standard practice to investigate the validity of what they tell me.
I hope such an investigation will enable me to determine whether or not the individual's story
makes sense, whether or not they have valid legal claims and whether or not they have suffered
any damages.
INFORMATION REQUESTED
As part of that investigation, I need to obtain documents, information and Baylor's
perspective on what occurred between Hill and Baylor. I need all documents, data and
information from Baylor concerning what occurred.
I have a number of questions:
1) What are all of the reasons the BOR voted to fire Tom?
2) What information was provided to the BOR regarding Tom?
3) What documents and data were provided to the BOR before it voted on whether or
not to fire Tom?
4) Who were the members of BOR who participated in the vote on whether or not to fire
Tom?
DOCUMENTS REQUESTED
Please produce the following docwnents:
1. The entire personnel files and any written warnings, performance reviews or
documents critiquing the work performance for the following individuals:
a.
b.
c.
d.

Thomas Hill;
Nick Joss;
Nancy Post; and
Paul Bradshaw.

2. The Pepper Hamilton Report and summaries of same.


3. All notes, memos, emails, summaries and similar documents exchanged between
Baylor and Pepper Hamilton regarding any alleged rape and/or sexual assault asserted
by any Baylor student against another Baylor student.
4. All notes, memos, emails summaries and similar documents made by any person
regarding Tom's interview with Pepper Hamilton.

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INTERVIEWS REQUESTED
We would like to make tape recorded interviews of:
1.
2.
3.
4.

S.

6.
7.
8.
9.

Jay Mike Allison:


Joel T. Allison;
Daniel Chapman;
David Harper;
Neal Jeffrey;
Ronald Dean Murff;
Mark Rountree;
Julie Hennansen Turner; and
Dennis Ray Wiles.
REQUEST FOR PRESERVATION OF EVIDENCE

We hereby request and demand that Baylor preserve-and not alter in any way--any
evidence regarding the Tom's employment with Baylor, the Pepper Hamilton report, the Pepper
Hamilton investigation, (including all of the notes, emails, summaries, reports, similar
docwnents) and the BOR's decision to fire Hill, (hereinafter the "Incident"). Also, preserve all
documents and data sent to or from the BOR regarding Hill, Pepper Hamilton's investigation,
Pepper Hamilton's report, any alleged rape, sexual assault or assault allegedly committed by any
Baylor student against another Baylor student.
This request for preservation of evidence includes, but is not limited to, preserving all
photographs, voice mails, e-mails, videotapes, memos, meeting agendas and notes,
investigations, incident reports, security tapes, logs, in/out records, local and long distance
telephone records, bills, statements, expense reports, notes, reports and interviews.
We also demand that You preserve all electronic data regarding the Incident, Thomas
Hill, The Pepper Hamilton report, the Pepper Hamilton investigation, the BOR's actions
regarding Hill, any alleged rape, sexual assault or assault allegedly committed by any Baylor
student against another Baylor student and anyone involved in reviewing, investigating or
evaluating the Incident. Be advised that we consider electronic data to be a valuable and
irreplaceable source of discoverable information. As You may know, electronic information is
subject to discovery in litigation and is admissible at trial.
ESI and Electronic data includes, but is not limited to, originals and all copies of
electronic mail ("e-mail"); activity listings of electronic mail receipts and/or transmittals;
voicemail; audio or video recordings of any kind; computer programs (whether private,
commercial or a work-in-progress); programming notes or instructions; output resulting from the
use of any software program, including word processing docwnents, spreadsheets, database files,
charts, graphs and outlines; operating systems; source codes of all types; PIP files; batch files;
ASCI files; and all miscellaneous electronic files and/or file fragments, regardless of the media
on which they are stored and regardless of whether the data resides in an active file, deleted file
or file fragment. Electronic data includes any and all information stored in hard disks, floppy
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disks, CD-ROM disks, Bernoulli disks and their equivalents, magnetic tapes of all kinds and
computer chips (including but not limited to EPROM, PROM, RAM and ROM). ESI and
Electronic data also includes the file, folder tabs, containers or labels appended to any storage
device containing electronic data.
Until You fully and completely backup all of Your electronic data regarding the Incident,
we request and demand that You not:
I.

Initiate any procedures that would alter any active, deleted or fragmented
electronic data. Such procedures may include, but are not necessarily limited to,
deleting or attempting to delete any electronic information, saving newly created
files to disks that already contain information, loading new software on such disks
or running data compression or de-fragmentation (optimization) routines on them;

2.

Rotate, alter or destroy any media that stores ESI or electronic data where such
activity could result in the alteration or loss of any electronic data;

3.

Dispose of any media that contains ESI or electronic data; and

4.

"Write over" any ESI electronic data.

If You will not or cannot comply with this request, please notify me in writing, via fax, of
Your refusal and explain why You are refusing.

DEADLINE FOR A RESPONSE


Please provide infom1ation with seven days to assist us in our investigation. If You do not
provide the infonuation or documents requested, we will take appropriate action to discover the
facts.
Very truly yoW's,

RoggeDwm
RRD:sr
cc: w/enc.

w/o enc.

Tina Vanderburg - Paralegal (our firm)

cc: w/enc.

w/o enc.

RRD's Work Files

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