IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF TEXAS

FORT WORTH DIVISION

MITCHELL RYAN §

 

Plaintiff, 

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§

v. §

§ Case No.: 4:21-cv-01075-P

GRAPEVINE COLLEYVILLE

INDEPENDENT SCHOOL 

DISTRICT and JORGE RODRIGUEZ 

in his official capacity as GCISD 

School Board President

§

§

§

§

§

 

Defendants.

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§

DEFENDANTS’ STATUS REPORT IN 

COMPLIANCE WITH THE COURT’S ORDER

Joseph F. Cleveland, Jr. 

State Bar No. 04378900

jcleveland@belaw.com

Sarah S. Flournoy

State Bar No. 24036575

sflournoy@belaw.com 

BRACKETT & ELLIS P.C.

100 Main Street

Fort Worth, Texas 76102-3090

Telephone: (817) 338-1700

Facsimile: (817) 870-2265 

ATTORNEYS FOR DEFENDANTS

GRAPEVINE COLLEYVILLE

INDEPENDENT SCHOOL DISTRICT and 

JORGE RODRIGUEZ in his official 

capacity as School Board President

Case 4:21-cv-01075-P Document 35 Filed 10/28/21 Page 1 of 4 PageID 523
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Defendants Grapevine-Colleyville Independent School District (GCISD or 

District) and Jorge Rodriguez (collectively Defendants) files this status report in 

compliance with the Court’s October 25, 2021 Order and in support would show as 

follows: 

1. The Board of Trustees for GCISD met on Monday, October 25, 2021. 

Among other matters, the Board considered and adopted by a vote of six to zero 

(with one absence) revisions to the Board Operating Procedures, attached hereto as 

Exhibit A-1. 

2. To explain the current Board Operating Procedure, GCISD 

implemented revised Board Secretary’s script for public comment (Ex. A-2); revised 

request to speak during public comment (Ex. A-3); and revised board meeting 

decorum protocols (Ex. A-4). These revised guidelines were used during the public 

comment period at the October 25, 2021 board meeting and conform with the Board 

Operating Procedures adopted by the Board on October 25, 2021. 

3. Plaintiff spoke at the Board meeting on October 25, 2021, and provided 

an opportunity for implementation of the revised forum policy. His comments can 

be found beginning at 3:44:00 of the meeting video 

(https://www.youtube.com/watch?v=lWil2igxt-Y) and a true and correct transcript

is attached hereto as Exhibit B. 

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4. Another speaker during public comment, used vulgar language in 

quoting from an alleged curriculum book triggering implementation of the revised 

forum policy. Her comments can be found beginning at 3:38:00 of the meeting video

and a true and correct transcript is attached hereto as Exhibit C.

Dated October 28, 2021.

Respectfully submitted,

/s/ Joseph F. Cleveland, Jr.

Joseph F. Cleveland, Jr. 

State Bar No. 04378900

Sarah S. Flournoy

State Bar No. 24036575

BRACKETT & ELLIS P.C.

100 Main Street

Fort Worth, Texas 76102-3090

Telephone: (817) 338-1700

Facsimile: (817) 870-2265 

ATTORNEYS FOR DEFENDANTS

Case 4:21-cv-01075-P Document 35 Filed 10/28/21 Page 3 of 4 PageID 525
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CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing document was 

forwarded this 28th day of October, 2021, by United States mail, postage prepaid 

via certified mail, return receipt requested, to all counsel of record as shown below 

pursuant to the Federal Rules of Civil Procedure:

Tony McDonald Via: Email

tony@tonymcdonald.com

1501 Leander Dr., Ste. B2

Leander, TX 78641

/s/ Joseph F. Cleveland, Jr.

Joseph F. Cleveland, Jr.

Case 4:21-cv-01075-P Document 35 Filed 10/28/21 Page 4 of 4 PageID 526