Personal Injury
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Tagged “filing”

Defendant Celina ISD's Original Answer

Doe Families I—XII v. Celina Indep. Sch. Dist. et al., No. 471-08453-2025 (471st Dist. Ct., Collin County, Tex.).

Celina ISD appeared and answered in our civil suit through its attorney, pleading a general denial of all of Plaintiffs’ allegations, requiring them to prove their case at trial. Tex. R. Civ. P. 83 (Answer), 92 (General Denial). Celina ISD further raised an affirmative defense of governmental immunity for those acts or omissions occurring before the date that the law for suing schools for teacher sexual misconduct became effective, September 1, 2025. See Tex. R. Civ. P. 94; Tex. Civ. Prac. & Rem. Code ch. 118.

Federal Criminal Indictment

United States v. William Caleb Elliott, No. 4:25-cr-00226-ALM-BD (E.D. Tex.).

In a separate criminal suit, the United States government presented an indictment to a federal grand jury, which signed and returned the true bill, indicting Caleb Elliott on eight counts of sexual exploitation of children a/k/a production of child pornography or the attempt thereof, in violation of 18 U.S.C. §§ 2251(a) and (e).

In federal criminal practice, a grand jury is 16–23 people, summoned by the court. Fed. R. Crim. P. 6. Grand jury proceedings are secret, and one-sided, where the prosecutor convinces the grand jury to indict the defendant, without the defendant or his attorney present. Id. A criminal defendant is entitled to notice of charges against him, this generally occurs by indictment or information. For a misdemeanor, an information is all that is necessary. Fed. R. Crim. P. 7(a)(2); 58(b)(1). An information is “an accusation…without an indictment…made by a public prosecutor, without the intervention of a grand jury.” U.S. Dep’t of Just., Crim. Res. Manual § 1-499.201 (quoting Information, Black’s Law Dictionary (6th ed. 1990)). A felony, however, must be prosecuted on indictment. Fed. R. Crim. P. 7(a)(1) ; U.S. Const. amend. V. An indictment is “an accusation in writing…originating with a prosecutor and issued by a grand jury…An indictment is referred to as a ‘true bill,’ whereas failure to indict is called a ‘no bill.’” U.S. Dep’t of Just., Crim. Res. Manual § 1-499.201 (quoting Indictment, Black’s Law Dictionary (6th ed. 1990)).

Defendant William Caleb Elliott's Original Answer

Doe Families I—XII v. Celina Indep. Sch. Dist. et al., No. 471-08453-2025 (471st Dist. Ct., Collin County, Tex.).

William Caleb Elliott appeared and answered in our civil suit through his attorney, pleading a general denial of all of Plaintiffs’ allegations, requiring them to prove their case at trial. Tex. R. Civ. P. 83 (Answer), 92 (General Denial).

Plaintiffs' Original Petition

Doe Families I–III v. Celina Indep. Sch. Dist. et al., No. 471-08453-2025 (471st Dist. Ct., Collin County, Tex.).

A Petition by parents from three separate families, as next friends of their three minor children, against Celina ISD and William Caleb Elliott, alleging Elliott’s intrusion upon seclusion and intentional infliction of emotional distress, and alleging the ISD was grossly negligent in hiring, supervising, or employing that professional school employee. This is necessary to overcome governmental immunity under Chapter 118 of the CPRC, enacted by HB 4623. Filed in Collin County District Court to start the lawsuit.

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