IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF TEXAS

FORT WORTH DIVISION

Chasity Congious, by and through )

her Guardian, Kimberly Hammond, )

on behalf of herself and as Mother and )

Next Friend of Z.C.H., Deceased, )

)

Plaintiff, )

)

v. ) Case No. 4:22-cv-00092-O 

)

City of Fort Worth, et al., )

)

Defendants. )

APPENDIX IN SUPPORT OF PLAINTIFF’S REPLY BRIEF FOR

MOTION FOR RELIEF FROM JUDGMENT

Dated: May 7, 2024 Respectfully submitted,

/s/ Jarrett Adams

Jarrett Adams, Esq.

LAW OFFICES OF JARRETT ADAMS, PLLC

40 Fulton St., Floor 28

New York, New York 10038

T: 646.880.9707

F: 646.880.9707

E: JAdams@JarrettAdamsLaw.com

Attorney for Plaintiff

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TABLE OF CONTENTS

Declaration of Jarrett Adams..............................................................................3

Certificate of Service.........................................................................................5

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1

IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF TEXAS

FORT WORTH DIVISION

Chasity Congious, by and through )

her Guardian, Kimberly Hammond, )

on behalf of herself and as Mother and )

Next Friend of Z.C.H., Deceased, )

)

Plaintiff, )

)

v. ) Case No. 4:22-cv-00092-O 

)

City of Fort Worth, et al., )

)

Defendants. )

DECLARATION OF JARRETT ADAMS IN SUPPORT OF 

PLAINTIFF’S REPLY BRIEF FOR MOTION FOR RELIEF FROM JUDGMENT

1. I am one of the attorneys for Plaintiff in the above-captioned case.

2. I make this declaration in support of Plaintiff’s reply brief for motion for

relief from judgment.

3. Prior to commencing this case, Plaintiff’s counsel sought and obtained

Chasity Congious’s medical records from JPS Health Network, including but not 

limited to records pertaining to Chasity Congious giving birth at the Tarrant County Jail 

on May 17, 2020. The email to Defendant Dr. Aaron Ivy Shaw on May 17, 2020 at 7:29 

AM was not included in the medical records produced to Plaintiff’s counsel by JPS 

Health Network. 

4. Prior to commencing this case, Plaintiff’s counsel sought and obtained

records via an open records request to the Tarrant County Sheriff’s Office (“TCSO”) for 

records pertaining to Chasity Congious giving birth at the Tarrant County Jail on May 

3

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2

17, 2020. The email to Defendant Dr. Aaron Ivy Shaw on May 17, 2020 at 7:29 AM was 

not included in the records produced to Plaintiff’s counsel by the TCSO. 

5. Defendant Tarrant County disclosed its responsive expert designations on

November 13, 2023. 

6. I had a two-week trial in the Southern District of New York in January

2024. 

7. I was on paternity leave in March and April 2024 due to the birth of my

first child. 

Pursuant to Title 28, United States Code Section 1746, I declare under penalty of 

perjury that the foregoing is true and correct. 

Dated: May 7, 2024 Respectfully submitted,

/s/ Jarrett Adams

Jarrett Adams, Esq.

LAW OFFICES OF JARRETT ADAMS, PLLC

40 Fulton St., Floor 28

New York, New York 10038

T: 646.880.9707

F: 646.880.9707

E: JAdams@JarrettAdamsLaw.com

Attorney for Plaintiff

4

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CERTIFICATE OF SERVICE

I hereby certify that on May 7, 2024, I electronically filed the foregoing pleading 

with the United States District Court for the Northern District of Texas using the 

CM/ECF system, which will automatically serve a true and complete copy upon all 

counsel of record. 

/s/Jarrett Adams

Jarrett Adams, Esq.

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