LTISD Info

An “affidavit” is defined as:

“Any written document in which the signer swears under oath before a notary public or someone authorized to take oaths (like a county clerk) that the statements in the document are true. In many states, a declaration under penalty of perjury, which does not require taking an oath, is the equivalent of an affidavit.”

Interesting. It would seem that the LTISD has some affidavits which are shaky at best.

Let’s also note that affidavits are NOT supposed to be based on “hearsay.“

“Hearsay” is defined as:

“Testimony given by a witness who is not telling what he or she knows personally, but what others have said.”

How can you attest to alleged facts in an affidavit if they are based on hearsay?

Just ask Lisa McBride of the Thompson & Horton law firm. Apparently Lisa McBride doesn’t seem to know about “hearsay,” but then again, let’s not ask Lisa about the truth either.

Let’s delve into some recent affidavits made by employees of the LTISD in the recent Meadows v. Lake Travis Independent School District case.

Here we have an excerpt from an affidavit signed by Allison Cobb, Principal of Serene Hills Elementary School:

“I have spoken with Serene Hills receptionist, Ms. Patty Noble, and have learned that she asked Mr. Lovelace for his driver’s license, and he refused to give it to her. She then asked him to show it to her. He again refused. Finally, he let her see the license. Ms. Noble asked to see his license because he was asking to take a student from campus.”

Seems that Allison’s statement is based on “hearsay.” Would Patty Noble have given a different story? Why wasn’t Patty Noble asked to provide an affidavit?

I would hope that Allison was confused about what Patty Noble told her, because it was not true, but that is not what Allison swore in her affidavit. That’s the problem with “hearsay.”

Why did Lisa McBride submit Allison Cobb’s affidavit when it attests to events in which she did not have first hand knowledge?

Another affidavit comes from Debra Aceves, Principal of Hudson Bend Middle School who swears that:

“On April 3, 2009, David Lovelace came to HBMS to attend an event in one of his son’s classes. On that clay, the class was presenting math games that they had created, and had invited parents, While he was in the front office, Mr. Lovelace did not provide his driver’s license to Ms. Margarita Plymire, the HBMS Receptionist. Ms. Plymire entered Mr. Lovelace’s name into the Raptor System, and the system printed a sticker name tag for Mr. Lovelace, Because Mr. Lovelace’s driver’s license had been scanned into the Raptor System before, the information was stored, so the name tag generated by the system contained a scanned version of his driver’s license photo and his name.”

(Note: My driver’s license has only been scanned at the Lake Pointe Elementary School some years earlier and it has not been scanned since, nor has it been scanned at any other district campus.)

Debra Aceves goes on to say (as does Allison Cobb and Heidi Gudelman) that:

“For parents whose driver’s licenses have already been scanned into the Raptor System. I do not require that their licenses be scanned again, because their information is stored in the system. Instead, the parent’s name is manually typed into the Raptor System, and the system generated a sticker name tag that displays the person’s name and photograph. The parent is required to wear the name tag while on campus.”

Was Debra Aceves confused about what was printed on my badge?

Funny thing, I kept my badge that was issued to me on April 3, 2009 and low and behold I have a copy of it here:

Interesting, but my driver’s license picture was NOT on the badge issued to me on April 3, 2009!

What does this mean that Debra Aceves affidavit was not true? Sure would seem so, but then again, Debra’s affidavit statements were based on “hearsay.”

I would hope that Debra Aceves got Margarita Plymire’s story confused, but nonetheless, she swore to the truthfulness of the story. Is it possible that if Margarita Plymire had signed a sworn affidavit, she would have sworn to something different, something along the lines of what really happened?

Again, why didn’t Lisa McBride have Margarita Plymire swear to an affidavit about events that Margarita allegedly took part?

Why did Lisa McBride submit Debra Aceves’ affidavit when it attests to events in which she did not have first hand knowledge?

Hey, this gets even better.

I visited Hudson Bend Middle School on October 13, 2009 and see my visitor badge:

Look! I now have a picture! How did that happen?!

Why didn’t my April 3, 2009 badge have a picture like Debra Aceves says it did, but now my badge includes a picture?

Unfortunately for the district, I kept my April 3, 2009 visitor badge which makes it look like someone went back and changed things after the fact. How else could this have happened?

Now if that weren’t interesting enough, you need to know about my visit to Serene Hills, two days after my visit to Hudson Bend.

I went to Serene Hills to have lunch with my son on October 15th. I even tried to enter my name into the Raptor System and guess what? My name was not in the district’s Raptor system?!

So much for Allison Cobb’s sworn affidavit stating “For parents whose driver’s licenses have already been scanned into the Raptor System. I do not require that their licenses be scanned again …”

So much for anyone at the district really knowing anything about Raptor and how it works, but that doesn’t seem to stop them from swearing to things that aren’t playing out like they swear they do. Perhaps the stories they told “weren’t true in reality?”

The best affidavit of the lot has to be from Heidi “it was not true in reality” Gudelman, Principal of the Lake Pointe Elementary School:

“On a day after he had had his licensed scanned and had gone through the Raptor System sign-in process, Mr. Lovelace came to the campus for a meeting with campus staff, which he attended. He did not enter the building through the front door, and he did not sign-in through the Raptor system. Each and every outside door to the building other than the front doors were locked that day.”

Just one question Heidi, did I walk through a wall to get in?

Was I just a figment of Heidi’s imagination that day?

Perhaps Heidi Gudelman’s sworn affidavit was “not true in reality?”

Did Rocky appoint Heidi Gudelman to be principal of an elementary school?

Let’s face it, Allison and Debra were swearing to hearsay and got their stories wrong, but Heidi’s sworn affidavit is really out there, way out there.

Remember it was Heidi Gudelman who left her Las Vegas vacation pictures on the computer that the district assigned to my son.

By the way, Heidi Gudelman did say in sworn testimony during a due process hearing: “it was not true in reality.”

So, what does Lisa McBride say about all this?

Do you think Lisa McBride would quibble about what “what the meaning of the word ‘is’ is?“

No, but Lisa does say:

“Much of your clients’ concern with the affidavits of Cobb, Aceves, and Gudelman appears to derive from conclusions your clients have reached concerning the intent and/or meaning behind the witnesses’ statements, not the content of the statements themselves.”

What?!

I would like to ask Lisa McBride: Aren’t affidavits supposed to contain TRUE statements or in the case of Heidi Gudelman’s affidavit, a plausible story?

Note the affidavits of Allison Cobb, Debra Aceves and Heidi Gudelman that Lisa McBride filed with the court all contain this sentence:

“I have personal knowledge or every statement made in this affidavit, all of which are true and correct”

Having read the affidavits and the definition of “hearsay” wouldn’t you say that the sworn statement of Allison Cobb and Debra Aceves: “I have personal knowledge or every statement made in this affidavit” is not true?

“What is truth?”

-Pontius Pilate

Isn’t it considered “perjury” when an affidavit contains false information?

Nevertheless Lisa McBride says:

“The District stands behind the veracity of the affidavit testimony of Allison Cobb, Debra Aceves, and Heidi Gudelman, as well as the affidavit testimony of the District’s other witnesses.”

And they say that the captain of the Titanic went down with the ship!

For all that it’s worth, Lisa McBride does have a great sense of humor, just read the motions she filed with the court in case of Meadows v. Lake Travis Independent School District.