3 Months Ago 4-Year-Old Drake Pardo Was Illegally Removed,

KIDNAPPED BY THE STATE

Not by a drug cartel. Not by human traffickers.

He was ripped from his home...

by the State of Texas.

SIGN THE PETITION!
DONATE!
#BringDrakeHome

Not by a drug cartel. Not by human traffickers.

He was ripped from his home...

by The State of Texas.


SIGN THE PETITION!
DONATE!
#BringDrakeHome

Read Drake's story in...



Drake's Family is Just Like Yours

Drake was a happy 4-year-old with loving parents and 2 older siblings.

The Pardos live in East Texas. Drake's father, Daniel, is a mechanic and his mom, Ashley, homeschools all 3 children.

For Drake, life was happy. Until one day...

On June 20th Drake was Taken...

The State of Texas removed Drake claiming it was an emergency. They claimed he was in danger. Yet once the State got to court-- all of their claims fell apart.

Watch the Horrifying Cell Phone Video of Drake's Removal

On June 20th Drake was Taken...

The State of Texas removed Drake claiming it was an emergency. They claimed he was in danger. Yet once the State got to court— all of their claims fell apart.

Child Protective Services (CPS) claimed they had to remove Drake because his parents didn't attend a meeting with CPS and the Hospital on June 10th.

Truth: The Pardos didn't attend the meeting because they weren't invited.

Truth: The CPS caseworker admitted under oath that she intentionally didn't tell Drake's parents about the meeting.

Truth: CPS admitted under oath that they never met with Drake's parents before they removed Drake.

Truth: CPS admitted under oath that they never even met Drake before they removed him.

But CPS took Drake anyway?


CPS claimed they had to remove Drake because of a doctor's concerns.

Truth: The same doctor admitted under oath that she had never read all of Drake's medical records.

Truth: The same doctor admitted under oath that she had never even met Drake or seen him in person.

Truth: The same doctor admitted under oath that she never thought there was an emergency.

Truth: The same doctor admitted under oath that she had never asked for Drake to be removed.

But CPS took Drake anyway?


The judge helped CPS hide their lies and keep Drake away from his parents.

Corruption #1: The judge closed his eyes to the facts and to the law, and has now agreed to let CPS keep Drake for up to a year.

Corruption #2: The judge issued a gag order on the parents and prohibited them from speaking out publicly.

If they tell their friends, speak to the media, or even post on Instagram or Facebook about their son being taken away... they could be thrown in jail.


SIGN THE PETITION!
DONATE!
#BringDrakeHome


Drake Needs to Come Home

Drake is 4 years old... and he needs to be at home.

Not with a Texas government agency that has gone out of control and refuses to admit their error.

Drake needs his mom and dad who love him and who can care for him.

Drake needs to Come Home

Drake is 4 years old.. and he needs to be home.

Not with a Texas government agency that has gone out of control and refuses to admit their error.

Drake needs his mom and dad who love him and who can care for him.



Who Will Stand Up for Drake?

Drake's parents can't stand up, because there's a court gag order on them.

Drake can't stand up because he's 4 years old and being held in state custody.

CPS won't stand up for him. They're the ones who kidnapped him. They're the ones that are traumatizing him.

The State of Texas won't stand up for Drake. Because the State is who's holding him in custody.




SIGN THE PETITION!
DONATE!
#BringDrakeHome

WE ARE THE ONLY ONES LEFT
WHO CAN STAND UP FOR DRAKE



Leaders Who Have Joined the Call to #BringDrakeHome

Dr. James Dobson

National Radio Host, Psychologist

Tim Lambert

President, Texas Home School Coalition

Tim Wildmon

President, American Family Association

Andrew Brown

TX Public Policy Foundation – Center for Families and Children, Director

Bradley Pierce

Co-Founder, Heritage Defense Foundation

Trayce Bradford

President, Texas Eagle Forum

Dave Welch

Founder, Texas Pastor's Council

Ann Hettinger

State Director, Concerned Women for America, Texas

JoAnn Flemming

President, Grassroots America, We The People

Jim Graham

President, Texas Right to Life

Jonathan Saenz

President, Texas Values

Brandon Creighton

TX Senate Higher Education Chairman

Charles Perry

TX Senate Rural Affairs Chairman

Bob Hall

TX Senate Agriculture Chairman

Donna Campbell, MD

TX Senate Veteran Affairs & Boarder Security Chairwoman

Jose Menendez

TX State Senator

Pat Fallon

TX State Senator

Joe Moody

Texas House Speaker Pro Tempore

Jeff Leach

TX House Judiciary Chairman

Dan Huberty

TX House Education Chairman

Harold Dutton

TX House Juvenile Justice & Family Issues Chairman

James White

TX House Corrections Chairman

Jonathan Stickland

TX House Representative

Valoree Swanson

TX House Representative

Matt Schaefer

TX House Representative

Scott Sanford

TX House Representative

Steve Toth

TX House Representative

Mayes Middleton

TX House Representative

Matt Krause

TX House Representative

Briscoe Cain

TX House Representative

Candy Noble

TX House Representative

Mike Lang

TX House Representative

Bill Zedler

TX House Representative

Matt Shaheen

TX House Representative

Jared Patterson

TX House Representative

VIEW MORE



Timeline of Drake's Kidnapping

April 16-18, 2019

Dr. Anderson at Children’s Medical Center in Dallas refused to visit Drake Pardo (age 4), his patient, during a 3 day stay at the hospital.

Drake had been a patient at Children’s for several years. Immediately after this event, Ashley and Daniel Pardo, Drake’s parents, fired Dr. Anderson. Drake was reassigned to another doctor in the same office.

April 22

Ashley and Daniel filed an official complaint with Children’s Medical Center in Dallas over Dr. Anderson’s refusal to visit Drake while he was in the hospital.

April 22

Children's Medical Center issued a written response to the complaint from Ashley and Daniel, informing them that the complaint had been referred to the "Quality and Patient Safety Department" for review and that they would be contacted within 45 days with a written report to inform them of the result of the investigation.

Although Ashley and Daniel never heard from Children's again on the subject, on June 6 (day 45), Dr. Dakil from Children's Medical Center contacted CPS (Child Protective Services) to report the family.

Dr. Dakil would later testify under oath on July 2 that she had contacted CPS at the prompting of Dr. Anderson when he complained to her about the Pardo family after they fired him.

Dr. Dakil testified that, until July 2, she had been entirely unaware that Dr. Anderson was fired for refusing to visit Drake while he was in care. However, she testified that such refusal could be valid grounds for his termination.

June 6

In a call to CPS, Dr. Dakil asked CPS to facilitate a meeting with the family and Children’s on June 10 to evaluate the hospital’s concerns and discuss a treatment plan and possible feeding study with the family.

June 7

CPS first contacted the Pardo family by leaving a business card on the family's door.

June 9

The caseworker received a letter from Krista Mcintire, the Director of Family Rights Advocacy, indicating that she was acting as an advocate for the family.

June 10

The caseworker, Ashley Pardo, and the family advocate texted back and forth to set up a time to meet.

June 10

The June 10th meeting that was requested by Dr. Dakil never happened.

According to the caseworker's testimony, she intentionally never informed the family of the June 10 meeting requested by Children’s. The caseworker testified that her decision to not inform the family of this meeting was because the family’s attorney had been combative towards her.

However, the caseworker’s earliest conversation with the family’s attorney was not until he had been retained by the family on June 11.

June 10

Krista Mcintire referred the Pardos to Johana Scot, the Executive Director of the Parent Guidance Center. Johana spoke on the phone for several hours with the Pardos that night.

During their conversation the Pardos mentioned they were members of the Texas Home School Coalition. Johana recommended they call the Texas Home School Coalition immediately for legal representation.

June 11

The family first contacted Chris Branson, the CPS Special Counsel for the Texas Home School Coalition (THSC). Chris Branson emailed and spoke by phone with the CPS caseworker to inform her of his representation and to request a copy of the allegations against the family, as required by TAC 700.508 and the Federal CAPTA act, Section 5106(b)(2)(B)(xviii).

The caseworker declined to provide Mr. Branson with the allegations over the phone but informed him that if he would drive from Houston to Dallas to meet her in person, she would inform him of the allegations in person. As the Federal Department of Health and Human Services explains on their website, such a demand is a violation of federal law.

June 11

Chris Branson contacted the CPS program director, who also refused to provide him with the allegations against the family.

June 11

Chris Branson contacted the CPS regional attorney, who also refused to provide him with the allegations.

June 11

Chris Branson informed the CPS caseworker that until he was provided with a copy of the allegations, CPS would not be permitted to speak with the family.

June 19

CPS requested that Dr. Dakil provide them a written affidavit listing the concerns she had mentioned during her initial report on June 6.

In her written affidavit, Dr Dakil raised questions about a number of past medical treatments Drake had received, although she did not claim any had been unnecessary and stated that she was unaware of the history on several of them.

Dr. Dakil stated in her affidavit that she had only reviewed medical records available at Children’s, had not reviewed all of Drake’s medical records from other facilities, and had not spoken with all of the doctors outside of Children’s who had made the various recommendations and diagnoses she was raising questions about.

Uncontested testimony at the July 2 hearing revealed that, without exception, every medical test, procedure, or condition Drake had ever received was diagnosed or recommended by at least one, often multiple, specialists in the field.

In her affidavit, Dr. Dakil made no requests for the removal of Drake and no claims of any imminent danger to Drake.

Instead, her sole recommendation was that Drake receive “additional workup” in order to establish whether or not he needed additional surgery in the future, a surgery which had been recommended by 6 separate doctors and was being considered by the family, but with which Dr. Dakil disagreed.

June 20

CPS arrived at the Pardo family’s door unannounced, along with uniformed police officers, and conducted an “emergency” removal of Drake.

CPS provided a signed emergency order from Judge Tracy Gray as justification. Even as they were forcibly removing Drake from his home, CPS still refused to inform the family of the allegations against them.

June 25

THSC Policy Director Jeremy Newman spoke by phone with CPS Associate Commissioner Kristene Blackstone, who expressed surprise to learn no interviews with the family had been conducted before removal and promised to investigate the matter.

However, to this date, Blackstone and DFPS leadership have never followed up with THSC or the family.

June 27

Ashley and Daniel Pardo attended a meeting with Children’s Medical Center at the request of Dr. Dakil.

Dr. Dakil explained in the meeting that, in her opinion, the only thing Drake needed was for both his parents to attend his medical visits and for his doctors to have better communication with each other. The family agreed.

Immediately afterward, CPS entered the meeting. When informed of this agreement between Children’s and the family, CPS stated that it was not good enough and they would still need to keep Drake.

July 2

Judge Michael Chitty held an adversary hearing where he granted custody of Drake to CPS for up to a year, despite CPS having failed to prove every single legal requirement outlined in Texas law.

It is unclear why Judge Chitty conducted the hearing, rather than Judge Tracy Gray, who signed the original order of removal on June 20.

In testimony, CPS provided two justifications for their “emergency” removal of Drake:

Reason 1. The family had failed to attend the June 10 meeting with Children’s Medical Center. However, CPS testified they intentionally never informed the family of that meeting.

Reason 2. CPS claimed that the concerns listed by Dr. Dakil in her June 6 report justified an immediate need for removal of Drake. However, CPS did not remove Drake until two weeks later on June 20. Furthermore, Dr. Dakil testified that there was never an emergency, she had not asked for the removal of Drake, and she was not sure how her recommendations for Drake’s care could be met while he remained in state custody.

Uncontested testimony at the hearing revealed that, without exception, every medical test, procedure, or condition Drake had ever received was diagnosed or recommended by at least one, often multiple, specialists in the field.

Furthermore, CPS admitted under oath that they decided to remove Drake from his home knowing that they had not pursued numerous alternatives that could have resolved the situation peacefully. Nevertheless, Judge Michael Chitty allowed CPS to keep Drake for up to a year.

At the end of the hearing, Judge Chitty placed a gag order on Ashley and Daniel Pardo, forbidding them from making any public comments about the case or their son.

July 23

Ashley and Daniel Pardo met with CPS to construct a family service plan, as required by Texas law. A service plan is a list of items which a family is required to complete before having their child returned home.

The law requires that CPS and the family jointly construct the service plan. However, CPS attended the meeting with the plan already pre-written, dated, and finalized.

CPS ended the meeting after just 12 minutes when the family refused to answer questions completely unrelated to the service plan.

CPS subsequently submitted the service plan to the court, asking that it be made mandatory for the family.

August 2

The Pardo’s attorneys filed two motions seeking emergency intervention from the Fifth Court of Appeals in Dallas.

First, the family filed a Writ of Mandamus, detailing how Judge Chitty abused his discretion and violated the Pardo’s constitutional rights. The Writ asked the Court of Appeals to intervene and dismiss Judge Chitty’s order.

Second, the family filed a Motion To Suspend, asking that the court place an immediate hold on Judge Chitty’s order while the parties waited for the appellate court’s response to the mandamus.

The Court of Appeals replied within hours, ordering CPS to file a response to the Motion to Suspend by August 5 and a response to the Mandamus by August 12.

August 5

CPS filed its response to the Motion to Suspend at the Fifth Court of Appeals. In the response, CPS argued that Ashley and Daniel Pardo had nothing to complain about because CPS was giving Drake the same care that Ashley and Daniel would have been giving him.

August 9

The family appeared at a status hearing before Judge Tracy Gray, the same judge who had authorized the original emergency removal. Texas law restricts the items which can be discussed at a status hearing and only allows discussion of the family service plan.

In testimony, CPS asked that the court force Ashley and Daniel to make a complete admission of guilt and acknowledge “severe” mental health problems before they could have Drake returned to them.

Even though state law requires a service plan to be constructed collaboratively with the family, the CPS caseworker testified that at the time of her first service plan meeting with the family, she had already constructed and finalized the entire service plan.

When asked if CPS had followed their own guidelines, as well as state and federal law, in the process they used to construct the service plan, CPS responded “no.”

Judge Tracy Gray criticised CPS for including irrelevant and ridiculous requests in the service plan, eliminating all elements of the service plan objected to by the Pardo family’s attorneys.

Additionally, Judge Gray ordered CPS to start allowing the family to bring witnesses to their regular visitation meetings with Drake, something CPS was doing for themselves but which they were prohibiting the family from doing.

The Attorney Ad Litem asked Judge Gray to prohibit THSC from posting any information about the Pardo case on social media. Judge Gray refused, reminding the Ad Litem that there was no prohibition on THSC posting information about the case. As a non-party to the litigation, THSC cannot be bound regardless.

August 12

CPS filed its response with the Fifth Court of Appeals to the Pardo’s emergency Writ of Mandamus, again asking that the court allow CPS to keep Drake. In the response, CPS again acknowledged that Ashley and Daniel Pardo intend to give Drake the exact same medical care he has received in CPS care.

August 12

The Texas Public Policy Foundation, joined by Senator Bob Hall and Representatives Valoree Swanson, Matt Krause, Mayes Middleton, Scott Sanford, and Matt Schaefer, filed an amicus brief in support of the Pardos with the Fifth Court of Appeals. The brief details numerous violations of state and federal law by CPS.

August 14

Texas Home School Coalition filed an amicus brief in support of the Pardos, detailing the extensive constitutional violations perpetrated by CPS throughout the course of the Pardo case and explaining how the entire situation was caused by CPS’ refusal to follow state law. The brief was joined by a coalition of 14 organizations and lawmakers, including:

- Texas Eagle Forum

- Texas Pastor Council

- Concerned Women for America - Texas

- Texas Right to Life

- Texas Values

- TX Senator Bob Hall, Agriculture Committee Chair

- TX Senator Donna Campbell, Veteran Affairs and Border Security Chair

- TX House Judiciary Chairman Jeff Leach

- TX Representative Matt Schaefer

- TX Representative Scott Sanford

- TX Representative Steve Toth

- TX Representative Mayes Middleton

- TX Representative Jonathan Stickland

- TX Representative Valoree Swanson

August 14

The Pardo's legal team filed a reply to CPS' August 12 brief regarding the family's Writ of Mandamus.

The reply details how CPS has repeatedly admitted that their only justification for keeping Drake, “rides on Dr. Dakil's admittedly-unfounded speculation that there may be a physician out there, somewhere, who will somehow be convinced by Ashley Pardo to perform surgical procedures on KDP that this mystery physician also believes are not necessary. Pure speculation has never been better described.”

The brief explains further how CPS could have resolved the entire situation at the very beginning by simply informing the family of the June 10 meeting requested by Children’s, which Children’s requested in order to agree on a treatment plan for Drake with Ashley and Daniel.

Instead, CPS testified under oath that they intentionally did not inform the family of the June 10 meeting, claiming that the family’s attorney was too “hostile” towards them.

However, as explained in the family's reply brief, “allegations that the June 10 events were somehow thwarted by Mr. Branson, the Pardos' attorney, are fanciful because Mr. Branson did not begin to assist the Pardos until June 11.”

CPS has yet to explain the impossibility of why they intentionally never informed the family of a June 10 meeting because of a conversation CPS had with the family's attorney on June 11. At the July 2 hearing, CPS testified that the family's failure to attend the June 10 meeting was a major reason for the removal of Drake.

August 22

The Fifth Court of Appeals rejected the Pardo's request for emergency relief without explaining how the trial court’s abuse of the Pardo family was justified. Given the makeup of the Fifth Court of Appeals, this was expected by the family’s attorneys, who plan to take the case to the TX Supreme Court.

August 30

The Pardo family's attorneys filed an emergency Writ of Mandamus with the Texas Supreme Court, asking the Court to intervene and put a stop to the abuses of the family being allowed by the district court. The petition asks the court to immediately return Drake to his family because the district court failed to follow the law when, at the July 2 hearing, it refused to return Drake home.

The family's brief to the Texas Supreme Court explains, "The law is settled: parents enjoy Constitutionally-protected rights to the possession, care, custody, and control of their minor children. Even temporary and partial interference in a parent’s custody of his or her child has serious, Constitutional ramifications. In order for the State to interfere in those rights, the State is required to follow Constitutional and statutory requirements to the letter, which did not happen in this case."

The family's attorneys also filed an emergency Motion To Suspend, asking the Texas Supreme Court to halt enforcement of the district court's July 2 order while the Supreme Court considers arguments on the mandamus.

August 30

The Texas Home School Coalition filed an amicus (friend of the court) brief on behalf of the Pardo family. The brief was signed by a bipartisan coalition of 22 lawmakers and 5 prominent statwide and national organizations, all asking the Texas Supreme Court to order the immediate return of Drake to his family. The following lawmakers signed the brief supporting the Pardo family:

- State Senator Brandon Creighton, Chair of Higher Education

- State Senator Donna Campbell, Chair off Veteran Affairs and Border Security

- State Senator Charles Perry, Chair of Rural Affairs

- State Senator Bob Hall, Chair of Agriculture

- State Senator José Menéndez

- State Senator Pat Fallon

- State Representative Dan Huberty, Chair of Education

- State Representative Harold V. Dutton Jr., Chair of Juvenile Justice and Family Issues

- State Representative Jeff Leach, Chair of Judiciary and Civil Jurisprudence

- State Representative James White, Chair of Corrections

- State Representative Matt Krause

- State Representative Briscoe Cain

- State Representative Jonathan Stickland

- State Representative Mayes Middleton

- State Representative Valoree Swanson

- State Representative Candy Noble

- State Representative Mike Lang

- State Representative Bill Zedler

- State Representative Scott Sanford

- State Representative Matt Schaefer

- State Representative Steve Toth

- State Representative Matt Shaheen

The brief was also signed by 5 statewide and national organizations:

- Texas Eagle Forum

- Texas Pastor’s Council

- Grassroots America, We the People,

- Texas Values

- Concerned Women of America

The brief details the long history of the constitutional right of parents to raise their children and explains the state's utter failure to follow the constitutionally required rules to protect that right, concluding that "Private citizens cannot be allowed to use CPS as a weapon to settle their disputes. . . . The laws in question have been designed to protect this first and most important relationship in a child’s life. If they are not enforced, then they are nothing more than great, but impotent ideas buried in dusty books in a law library. To avoid the pervasive attitude that there is little risk in ignoring statutory requirements and violating parents’ rights in these cases, mandamus must be granted swiftly to correct the erroneous rulings in this case."

September 2

CPS filed a response brief to the family's Motion to Suspend. The brief claims that CPS should be allowed keep Drake in state custody based primarily on the testimony of Dr. Dakil, even though Dr. Dakil testified repeatedly that she had not requested removal of Drake, didn't believe there was any emergency requiring such a removal, and didn't know how her medical recommendations could be met while Drake remained in CPS care.

Throughout the brief, CPS explains in detail how Ashley and Daniel Pardo were already planning to give Drake the same medical care that CPS has given Drake. CPS details in their argument how Ashley and Daniel are "more than happy to continue and follow" the medical advice of their doctors and would "absolutely respect" the medical recommendations of those doctors. However, rather than concluding that this means Drake should be returned home, CPS argues that Ashley and Daniel have nothing to complain about so long as Drake receives the care they would have given him."[T]hey fail to demonstrate how providing the child with the medical care they agreed to support at the adversary hearing now requires an emergency stay of the trial court’s temporary orders pending resolution of the petition for mandamus."

September 4

The Texas Solicitor General, representing the State of Texas, was invited to file a brief in the case to explain the state's view of the relevant law. An invitation to the Solicitor General only happens 1-5 times per year and indicates that the court is taking the issue very seriously. It does not indicate which direction the court may be leaning. CPS, although it is a state agency, represents itself and is not represented by the Solicitor General.

September 4

Heritage Defense Foundation filed an amicus brief on behalf of the Pardo family. The brief explains in detail how CPS manufactured the alleged "emergency" which CPS then relied on as grounds for removing Drake from his home.

"In this case, the urgency relied upon by the Department to justify removal was unlawfully and unreasonably created by the Department in two ways. First, the Department violated state and federal law by refusing to notify Relators of the allegations against them. Second, the Department failed to inform Relators of a request of the reporting doctor and then used Relators’ inevitable “noncompliance” to falsely convince the doctor that the family was being uncooperative, thereby prompting the doctor to immediately prepare the affidavit which the Department then used to justify removal. . . . Because the alleged urgency which served as grounds for removal was manufactured, the Department failed to demonstrate that an urgent need for protection required the immediate removal of the child. Additionally, the Department’s misconduct also constituted failure to make reasonable efforts to eliminate or prevent the child’s removal. Consequently, the child must be returned to his parents."

September 16

The Texas Solicitor General requested a 30-day extension to file a brief in the Pardo case. The Solicitor General additionally mentions his intention of attempting to negotiate a solution between the family and CPS that would avoid the need for the Texas Supreme Court to intervene.

September 17

Alliance Defending Freedom (ADF), a national non-profit organization, filed an amicus brief in support of the Pardo family, arguing that the Texas Supreme Court must intervene to overturn the unconstitutional gag order placed on Ashley and Daniel by the district court.

In the brief, ADF explains how no notice was given that the gag order would be sought and points out that "The gag order must be stricken because no evidence whatsoever was introduced to show that the order was needed, nor did the trial court make the required specific findings to justify a gag order."

The brief summarizes the issue by stating: "If the attorney ad litem met her burden of proof that a gag order was needed; if the trial court made specific findings explaining the need; if the evidence and findings demonstrated an imminent, irreparable harm to the judicial process; if there were not post-speech remedies available; and if the resulting gag order stopped the harm to the judicial process by the least restrictive means, then, and only then, should this Court affirm the gag order. But not one “if” was satisfied. Instead, the precious free speech birthright of all Texans, forged in the fire of revolution and carefully protected by this Court through the ensuing generations of Texans, has been unjustly denied to Ashley and Daniel Pardo. Meanwhile, their family unity hangs in the balance. Under article I, section 8 of the Texas Constitution, this Court should vacate the trial court’s unconstitutional gag order."

September 17

The Texas Supreme Court granted the September 16 request of an extension of time by the Solicitor General, setting a new deadline of October 18 for the Solicitor General to submit a brief in the case. The court also indicated that further requests for additional time would be denied. This extension of time means that a ruling from the Texas Supreme Court will likely not come until near the end of October, forcing the family to suffer continued abuse by CPS until that time and to continue pursuing expensive litigation at the trial court level.

September 18

The Texas Public Policy Foundation (TPPF) filed an amicus brief in support of the Pardo family. The brief details how CPS violated both state and federal law by refusing to disclose the allegations to the family and subsequently fabricating an emergency as a justification for the removal of Drake.

The brief opens by explaining how, "The record in this case clearly shows that not only did DFPS fail to meet the statutory burden imposed upon it by Texas law, its conduct of the investigation into the allegations against Ashley and Daniel Pardo violated both state and federal laws intended to protect the Pardos’ constitutional rights in the care, custody, and control of K.D.P." TPPF then demonstrates in detail how CPS's conduct violated both state and federal law. "During questioning, Ms. Sims and her supervisor, Ms. Erica Larry admitted that they both had, on multiple occasions, refused to provide the Pardos or their attorney, Mr. Chris Branson, with notice of the allegations. Ms. Sims further testified that the reason for the refusal to provide the allegations was a Department policy that requires caseworkers to only discuss allegations in a face-to-face meeting. This policy violates both Texas and federal law."

The brief was signed by a bipartisan list of 12 state lawmakers, including:

- Senator Bob Hall, Chair of Agriculture

- Senator Donna Campbell, Chair of Veteran Affairs & Border Security

- State Representative Joe Moody, TX House Speaker Pro Tempore

- State Representative Valoree Swanson

- State Representative Matt Krause

- State Representative Mike Lang

- State Representative Jeff Leach, Chair of Judiciary and Civil Jurisprudence

- State Representative Mayes Middleton

- State Representative Candy Noble

- State Representative Scott Sanford

- State Representative Matt Schaefer

- State Representative Matt Shaheen

September 18

CPS filed a request for a 10-day extension on the deadline to submit a brief to the Texas Supreme Court.