CAUSE NO. D-1-GN-18-008721 HALCY MARTIN DEAN, § — INTHE98™ DISTRICT Plaintiff, 8 § § Vv. § COURT OF ; STETSON ROANE, IN HIS § INDIVIDUAL CAPACITY ONLY, § Defendant § TRAVIS COUNTY, TEXAS PLAINTIFF'S FIRST AMENDED ORIGINAL PETITION TO THE HONORABLE JUDGE OF SAID COURT: HALCY MARTIN DEAN, Plait iff, files this First Amended Original Petition, complaining of STETSON ROANE, Defendant, in his individual capacity only, and would respectfully show the Court and Jury as follows: I. DISCOVERY CONTROL PLAN AND CLAIM FOR RELIEF Ll Plaintiff intends to conduct discovery under Level 3 of Texas Rule of Civil Procedure 190.4, and hereby requests thatthe Court enter a discovery control order under Rule 1904 12 Plaintiff seeks monetary relief in excess of $200,000 but less than $1,000,000, including damages of any kind, penalties, court costs, expenses, prejudgment interest, and attomey fees IL. PARTIES 2.1 Plaintiff HALCY MARTIN DEAN is an individual residing at SUUMEMIINS, Seguin, “Texas 78155. The last three digits of Plaintif's Texas driver's license number are WB ‘The last three digits of Plaintiff's Social Security number are WR PLAINTIFF'S FIRST AMENDED ORIGMAL PETITION Page |22 Defendant STETSON ROANE is an individual domiciled in Willacy County, Texas, who has been served with process and has already filed an answer herein, No further citation or service of process is needed at this time ‘I. JURISDICTION AND VENUE 3.1 This Court has jurisdiction over this case, in that Plaintiff's damages exceed the minimum jurisdictional limits of the Court. Venue is proper in Travis County, Texas, because all or a substantial part of Plaintiff's cause of action accrued in Travis County, Texas. IV. EACIS 41 Atall times material to this case, Plaintiff Halcy Martin Dean (“Plaintiff” or “Halcy") has been continuously employed as the Director of Special Education for Seguin Independent School District in Seguin, Texas. On or about January 17, 2017, Haley was attending a professional conference in Austin, Texas, presented by the Texas Council of the Administrators of Special Education (TCASE). This convention was for special education staff, 42 At that time, Defendant Roane was the Superintendent of the Seguin Independent School District in Seguin, Texas and also one of Haley’s bosses. Defendant Roane’s wife was Haloy’s immediate supervisor, and Defendant Roane was Mrs. Roane’s immediate supervisor. 43 For reasons unknown to Halcy initially, Defendant Roane had previously decided that he wanted to attend the January 2017 TCASE convention in Austin, He had requested that Haley get him a hotel room, He also indicated that he did not want to register for or attend the conference itself, but simply that he wanted a hotel room in Austin, during the same time Halcy was to be there. Haley was puzzled as to why Defendant Roane wished to attend PLAINTIFF'S FIRST AMENDED ORIGINAL PETITION Page?the convention, but she felt she had been given a directive to book him a hotel room, so she did. Prior to the convention and conference, Haley remarked to several others that she did not know why Defendant Roane was attending the conference, and she booked Defendant Roane’s hotel room at a separate hotel from her own. At the conference, however, she certainly found out why. 44 Onthe night of January 17, 2017, Defendant Roane arrived at the conference after 5:00 pam, He did not attend any conference sessions. He arranged a business dinner for Haley and several of her colleagues. 4.5 Afterdinner, Defendant Roane insisted on walking Haley to her cab oruber. Rather than saying good night, however, and over Haley’s insistence that it was not necessary, Defendant Roane insisted on “ensuring” Halcy got back to her own hotel “safely.” Halcy stated several times that she was fine and did not need assistance getting back to her hotel, but Defendant Roane insisted. Because Defendant Roane held a position of authority and power over Haley at the Seguin Independent School District, Haley did not wish to offend Defendant Roane, and she did not want to be rude to him, even though he was clearly (and boorishly) beginning to step outside the scope of his duties as superintendent and outside the scope of their working relationship, 4.6 Upon arrival at Haley’s hotel, Defendant Roane next insisted on walking Haley to het room. Roane then insisted on entering Haley's room, at which point he began to disrobe. Defendant Roane discussed his “stress level,” and his need for “release.” He discussed how attractive Haley was and how he needed someone like her to “work with him.” He talked about how they could do great things together and “be powerful.” 4.7 Haley attempted to redirect Defendant Roane, by talking to him about how much Halcy liked Mr. Roane’s wife, Denise. Plaintiff reminded Defendant Roane that Denise was PLAINTIF#’S FinsT AMENDED ORIGINAL PETITION Pace3