LeRoy Nellis
4845 Twin Valley Dr.
Austin, Texas 78731
Email: leroynellis2@gmail.com
Date: October 28, 2025
VIA CERTIFIED MAIL & EMAIL
Texas Medical Board
Public Information Coordinator
P.O. Box 2018
Austin, Texas 78768-2018
Email: open.records@tmb.state.tx.us
Subject: Public Information Request — Physician Records Related to Williamson County Jail,
Including Dr. Ghulam M. Khan and Dr. Alan Brooks
To the Custodian of Records:
Pursuant to the Texas Public Information Act, Texas Government Code §552.001 et seq.,
and the federal Freedom of Information Act principles of transparency,
I respectfully request access to and copies of the following public records maintained
by the Texas Medical Board (TMB):
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I. RECORDS REQUESTED
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1. Any and all physician licensing, disciplinary, or complaint records for Dr. Ghulam M. Khan
(also listed as “Ghulam M. Khan, M.D.”), believed to have held a psychiatric-services
contract with the Williamson County Jail, Georgetown, Texas, from approximately 2022–2025.
2. Any and all licensing, disciplinary, or complaint records for Dr. Alan Brooks
(also referenced as “Dr. Allen Brooks” in county records) associated with or employed by
the Williamson County Jail or its contractors from approximately 2023–2025.
3. A roster of all physicians, psychiatrists, or mid-level providers (M.D., D.O., P.A., or N.P.)
who have been listed, reported, or certified to the Texas Medical Board as practicing,
contracting, or supervising medical care within the Williamson County Jail or
“Williamson County Sheriff’s Office — Jail Medical Unit” between January 1, 2018, and October 28, 2025
4. Copies of any letters of agreement, supervision forms, or delegation filings
submitted to the Board that name the Williamson County Jail as a practice site
or supervision location during the above period.
5. Copies of any complaints, investigations, or enforcement actions opened or closed by the TMB during 2018–2025 involving the above-named physicians or the Williamson County Jail as
an affiliated site.
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II. FORMAT AND DELIVERY
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Please provide these materials in electronic form (PDF) by email to
leroynellis2@gmail.com if possible. If production in digital form is not feasible,
please mail paper copies to the address above.
If fees will exceed $50, please notify me in advance so that I may authorize or narrow
the request as needed.
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III. PUBLIC-INTEREST BASIS
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These records concern the provision of medical and psychiatric services to detainees in a
publicly funded facility and are matters of clear public interest. I am the subject of related
medical documentation held by Williamson County and expressly consent to release of any
records referencing my name or medical care.
Disclosure will assist in verifying professional licensure, supervision, and compliance with
state health-care standards under 37 Tex. Admin. Code §273.2 and applicable provisions of
the Texas Occupations Code.
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IV. CERTIFICATION
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This request is made in good faith for purposes of transparency, research, and oversight.
Please include in your response the **TMB reference number** assigned to this request
and an estimated date of completion per §552.221(d).
Respectfully submitted,
__________________________
LeRoy Nellis II
Complainant / Requestor
cc:
Texas Attorney General – Open Records Division (publicrecords@oag.texas.gov)
Civil Rights Division, U.S. Department of Justice (special.litigation@usdoj.gov)
LeRoy Nellis 
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