LeRoy Nellis<nellisleroy2@yahoo.com>
+4 others
crt@usdoj.gov;community.disability@usdoj.gov;askdoj@usdoj.gov;civilrights.doj@usdoj.gov;education@usdoj.gov;housing.discrimination@usdoj.gov;crimcivil.complaints@usdoj.gov;criminal.section@usdoj.gov;crt.intake@usdoj.gov;crt.webmaster@usdoj.gov;TCDAPublic@traviscountytx.gov;tips@texastribune.org;editor@texasmonthly.com;newstips@dallasnews.com;citydesk@houstonchronicle.com;newstips@express-news.net;letters@statesman.com;newstips@star-telegram.com;newstips@elpasotimes.com;news8@wfaa.com;newstips@khou.com;reportit@kxan.com;news@kvue.com;click2investigates@kprc.com;eyewitnesstips@kens5.com;investigates@ksat.com;news@kfox.tv;news@houstonpublicmedia.org;noticias@univision.net;telemundo@nbcuni.com;tips@texasobserver.org;kutnews@kut.org;news@kera.org;news@tpr.org;tips@nytimes.com;investigations@washpost.com;wsj.ltrs@wsj.com;newstips@usatoday.com;newstips@latimes.com;tips@tribpub.com;breakingnews@cnn.com;msnbcnews@nbcuni.com;foxnewstips@fox.comm;abc.news@abc.com;evening@cbsnews.com;nightly@nbc.com;newsmanager@pbs.org;nprnews@npr.org;info@ap.org;investigations@reuters.com;tips@propublica.org;newsdesk@bloomberg.net;tips@vice.com;tips@theintercept.com;letters@theatlantic.com;tips@politico.com;news@axios.com;scoop@motherjones.com;tnytips@nytimes.com;leroynellis2@gmail.com
Mr. Armstrong and Officials of the U.S. Department of Justice, Civil Rights Division:
Please accept this email as my formal rebuttal to the Texas Commission on Jail Standards’ October 24, 2025 finding of “no deficiencies,” and as a formal CRIPA complaint requesting a joint TCJS–DOJ investigation into systemic civil-rights, medical-care, and oversight failures occurring within the Williamson County Jail between January 2024 and July 2025.
Your determination conflicts with documented evidence from medical records, personnel rosters, inspection histories, and administrative filings. It is incompatible with the jail’s staffing model, its reliance on unlicensed personnel, and documented instances of medical neglect, retaliation, and false psychiatric classifications.
I. Documented Medical Harm & Conditions of Confinement
During 18 months of detention, I experienced and documented conditions that constitute deliberate indifference and administrative abuse:
• 326 days in solitary confinement under continuous lighting and vibration exposure.
• 126 days without diabetic medication or glucose monitoring, despite Type-2 diabetes.
• Permanent nerve and vision damage due to missed insulin and untreated infections.
• Improper restraint-chair placement in retaliation for refusing to surrender my Bible.
• False suicide-watch designations contradicting independent psychiatric evaluation.
• Medication administered by unlicensed EMT-level staff acting without lawful prescriptive authority.
• Remote prescribing by a Houston-based physician who never examined me.
These facts are detailed in the systemic medical-abuse record.
(Exhibit D — )
II. Why TCJS’s “No Deficiencies” Determination Is Incorrect
1. WCSO lacks 24-hour licensed medical coverage.
Its staffing model is built on part-time psychiatrists (16–20 hrs/week) and mid-level providers who cannot legally perform the functions they routinely performed.
(Exhibit C — Hiring Record; )
2. Unlicensed medical practice was routine.
EMTs were permitted to inject medication, manage MAR entries, alter psychiatric classifications, and refuse care without prescriptive authority.
(Exhibit D — )
3. TCJS previously cited Williamson County for medical failures.
Your 2019 inspection documented failures to follow physician orders—unresolved in later years.
4. MAR irregularities indicate systemic record manipulation.
Back-dated entries, overwritten signatures, conflicting suicide-watch notes, and mislabeled years (2024 vs. 2025) were documented in PIA submissions.
(Updated PIA Request — )
5. Oversight conflicts of interest exist.
Former TCJS employee Kathleen Pokluda now leads WCSO medical operations, compromising the independence of TCJS’s September 2025 inspection.
III. Legal Framework Supporting Federal Intervention
Violations implicate:
• Tex. Admin. Code §§273.1–273.6
• Tex. Occ. Code §157
• Estelle v. Gamble, 429 U.S. 97 (1976)
• Kingsley v. Hendrickson, 576 U.S. 389 (2015)
• 42 U.S.C. §1983
• Civil Rights of Institutionalized Persons Act (CRIPA), 34 U.S.C. §12601
The documented pattern meets the statutory threshold for DOJ intervention.
IV. Requested Actions
1. Joint TCJS–DOJ On-Site Re-Inspection
Staffed by independent medical experts with no ties to Williamson County.
2. Comprehensive Forensic Audit of:
• Medical credentials and licensing
• MAR logs, restraint logs, and suicide-watch logs
• Intake evaluations by EMTs
• Housing vibration devices (B5-L6, B7-R6, B9-R1, C14-R8)
• USMS IGSA compliance
3. CRIPA Pattern-or-Practice Investigation
Based on systemic neglect, retaliation, religious interference, and unlicensed practice.
4. Full Release of the September 2025 TCJS Inspection File
Including internal notes, communications, and draft findings.
5. Written acknowledgment and issuance of a joint TCJS–DOJ case number
With a response timeline.
V. Exhibits Incorporated by Reference
| Exhibit | Title | Citation |
|---|---|---|
| A | Texas Jail & Pre-Trial Detention Summary | |
| B | Williamson County Medical Research Summary | |
| C | Medical & Psychiatric Hiring Record (2018–2025) | |
| D | Systemic Medical Abuse in Williamson County Jail |
These documents contradict the TCJS “no deficiencies” finding and support federal escalation.
VI. Certification
I certify under penalty of perjury that the statements and documents provided are true and correct to the best of my knowledge and submitted in good faith for oversight and enforcement.
LeRoy Nellis II
4845 Twin Valley Drive
Austin, Texas 78731
512-450-1533
LeRoyNellis2@gmail.com
__________________________________________________________________
RESUBMISSION OF PUBLIC INFORMATION REQUEST AND FORMAL COMPLAINT — WILLIAMSON COUNTY JAIL
LeRoy Nellis
info@tcjs.state.tx.us
===========================================
RESUBMISSION OF PUBLIC INFORMATION REQUEST
AND FORMAL COMPLAINT — WILLIAMSON COUNTY JAIL
===========================================
Date: October 14, 2025
To:
Texas Commission on Jail Standards (TCJS)
P.O. Box 12985
Austin, Texas 78711-2985
Email: tcjs@tcjs.texas.gov
From:
LeRoy Nellis
4845 Twin Valley Drive
Austin, Texas 78731
Phone: 512-450-1533
Email: LeRoyNellis2@gmail.com
——————————————-
SUBJECT: RESUBMISSION OF OCTOBER 7, 2025 FOIA / PUBLIC INFORMATION REQUEST
AND FORMAL COMPLAINT REGARDING WILLIAMSON COUNTY JAIL
——————————————-
Dear Commissioners,
This correspondence serves as a **formal resubmission** of my **October 7, 2025 Public Information Act (FOIA) request** and simultaneously as a **formal complaint** concerning the conduct, operations, and oversight of the **Williamson County Jail**.
Since the original submission, I have received written responses from the **Williamson County District Attorney’s Office** and the **Williamson County Sheriff’s Office**, indicating that information responsive to my request has been withheld under statutory exemptions. These communications confirm that relevant records exist and involve matters falling squarely under the Texas Commission on Jail Standards’ oversight authority.
——————————————-
I. PURPOSE OF RESUBMISSION
——————————————-
The October 7, 2025 request sought all records, communications, and documentation relating to:
– The administration of inmate medical care at Williamson County Jail from January 2024 to present.
– The suspension or denial of diabetic medication and glucose monitoring between **May 25, 2025 and July 11, 2025**, and again in **January 2024**.
– The **use of injection-based medication** that caused neurological injury and partial paralysis.
– The **use of restraint chairs**, including incidents where the restraint was applied punitively rather than for safety or medical necessity.
– **Denial of religious materials**, retaliatory isolation, and suppression of grievance access.
– **Administrative withholding or alteration of records** following formal complaints.
——————————————-
II. BASIS FOR FORMAL COMPLAINT
——————————————-
The pattern of medical neglect, retaliation, and record suppression described above constitutes potential violations of the following Texas Administrative Code provisions:
– **§§273.1–273.5** – Health Services, Emergency Procedures, and Medical Instructions
– **§283.3** – Use of Restraints
– **§275.1** – Complaint Review and Inmate Grievance Process
Additionally, the refusal by county offices to release responsive documentation under the Texas Public Information Act suggests that material evidence of noncompliance may be deliberately withheld.
——————————————-
III. REQUEST FOR TCJS ACTION
——————————————-
Accordingly, I respectfully request that the Texas Commission on Jail Standards:
1. **Acknowledge and process this letter** as both a resubmission of my October 7, 2025 FOIA/Public Information Act request and a **formal complaint** regarding Williamson County Jail.
2. **Investigate** the facility’s compliance with all applicable TCJS medical, grievance, and restraint-use standards.
3. **Obtain the withheld records directly from the Williamson County Sheriff’s Office and District Attorney’s Office** for independent review by TCJS staff.
4. **Issue a written response** confirming receipt of this filing, outlining investigative steps, and identifying the assigned case or complaint number.
——————————————-
IV. CERTIFICATION
——————————————-
I certify that the information provided herein is true and correct to the best of my knowledge and that this filing is made in good faith for official review under the Texas Commission on Jail Standards’ authority.
Respectfully submitted,
_____________________________
**LeRoy Nellis**
4845 Twin Valley Drive
Austin, Texas 78731
Email: LeRoyNellis2@gmail.com
Phone: 512-450-1533
Ricky Armstrong<ricky.armstrong@tcjs.state.tx.us>
You;info
A comprehensive inspection of the Williamson County Jail was conducted on September 3rd and 4th, 2025. During the inspection, Inspector Garrett reviewed all applicable Minimum Jail Standards.
No deficiencies were noted.
Specifically, noted in your complaint was
– **§§273.1–273.5** – Health Services, Emergency Procedures, and Medical Instructions
– **§283.3** – Use of Restraints
– **§275.1** – Complaint Review and Inmate Grievance Process
The following standards under the Texas Administrative Code, Title 37, Part 9 were reviewed during the September inspection, and no violations were found:
- §273 Health Services
- §273.6 Use of Restraints
- §283 Discipline and Grievances
Ricky Armstrong
Assistant Director
Texas Commission on Jail Standards
512-653-4346 Phone
512-463-3185 Fax
Ricky.armstrong@tcjs.state.tx.us
[Draft]
LeRoy Nellis
4845 Twin Valley Drive
Austin, Texas 78731
Phone: 512-450-1533
Email: LeRoyNellis2@gmail.com
October 27, 2025
To:
Mr. Ricky Armstrong
Assistant Director
Texas Commission on Jail Standards (TCJS)
P.O. Box 12985
Austin, Texas 78711-2985
Email: ricky.armstrong@tcjs.state.tx.us
and
U.S. Department of Justice
Civil Rights Division – Special Litigation Section (CRIPA)
950 Pennsylvania Avenue N.W.
Washington, D.C. 20530
Email: special.litigation@usdoj.gov
Subject: FORMAL REBUTTAL AND REQUEST FOR JOINT INVESTIGATION
— WILLIAMSON COUNTY JAIL, GEORGETOWN, TEXAS
Dear Mr. Armstrong and Civil Rights Division Officials:
This correspondence serves as both a formal rebuttal to the Texas Commission on Jail Standards’ (TCJS) October 24, 2025 finding of “no deficiencies,” and a formal complaint and request for federal investigation under the Civil Rights of Institutionalized Persons Act (CRIPA), 34 U.S.C. §12601.
I. First-Hand Experience and Physical Harm
From January 3, 2024 through July 11, 2025, I endured sustained medical neglect, retaliatory confinement, and unlawful restraint inside the Williamson County Jail.
During that period I:
* Spent 326 days in solitary confinement under constant fluorescent lighting, sleep deprivation, and vibration.
* Was denied diabetic medication and glucose monitoring for 126 days, despite a known Type-2 diabetes diagnosis.
* Suffered permanent vision loss and neuropathic nerve damage caused by forced insulin injections and untreated infections.
* Experienced severe kidney pain and urinated blood for several days without medical transport or diagnostic care.
* Was restrained in a restraint chair solely because I refused to surrender my Bible, constituting both religious retaliation and medical abuse.
* Was placed in a SMOK (suicide-monitoring observation cell) and held under suicide watch immediately after passing an independent psychiatric evaluation, on the false recommendation of unlicensed Dr. Ghulam M. Kahn (Kahn).
* Received medication and injections from jail staff and EMTs wearing “EMT” patches, none of whom held valid prescriptive authority.
* Was treated by “Dr.” Alan Brooks and “Dr.” Ghulam M. Kahn—neither of whom maintain active Texas medical licenses.
* Later confirmed that all prescriptions were being authorized by a Houston-based physician who never examined or communicated with any inmate, functioning only as a remote signatory.
These combined actions inflicted permanent disability and psychological trauma and constitute deliberate indifference and cruel and unusual punishment.
II. Basis for Rebuttal and Federal Referral
1. Contradictory Findings
TCJS’s “no deficiencies” finding conflicts with the record of part-time psychiatric coverage, unlicensed medical practice, and corroborated injury.
2. Part-Time and Unlicensed Medical Coverage
Every physician listed between 2018–2025 was contracted for 8–20 hours weekly; unlicensed EMTs performed the majority of care.
3. Restraint, Isolation, and Suicide-Watch Abuse
* In addition to the documented Tijerina v. Williamson County settlement (Oct 14 2025; $1.15 million) for restraint-chair injuries, I was personally strapped into a restraint chair after declining to surrender my Bible—an act of protected religious expression.
* After passing an independent psychiatric evaluation showing no suicidal risk, I was nonetheless placed in a SMOK cell and kept under suicide watch on the false recommendation of unlicensed Dr. Kahn.
These actions violate Tex. Admin. Code § 273.6(c) (restraint use), § 273.5(a) (mental-health procedures), and the First and Fourteenth Amendments.
4. Conflict of Interest
Chief Kathleen A. Pokluda’s dual roles as former TCJS employee and current Williamson County medical administrator render the 2025 inspection unreliable and compromised.
III. Legal Framework
State Law:
Tex. Admin. Code Title 37 Part 9 §§ 273.1–273.6; Tex. Occ. Code § 157; Tex. Health & Safety Code Chs. 571–578.
Federal Law:
Estelle v. Gamble, 429 U.S. 97 (1976); Kingsley v. Hendrickson, 576 U.S. 389 (2015); Turner v. Safley, 482 U.S. 78 (1987); and CRIPA (34 U.S.C. § 12601).
IV. Requested Actions
1. Joint Re-Inspection and Forensic Review
A coordinated TCJS + DOJ inquiry should:
• Verify licensing of all medical and psychiatric personnel;
• Audit all medication, restraint, and suicide-watch records (Jan 2024–Jul 2025);
• Review grievance responses and disciplinary files;
• Inspect and document the vibration or “shaking” devices located in cells B5-L6, B7-R6, B9-R1, C14-R8, and within the dayrooms of B9 and C14, collecting frequency and seismic data and associated maintenance or engineering records.
2. Independent Oversight
Assign inspectors and medical experts with no prior affiliation to Williamson County or TCJS.
3. Federal Pattern-or-Practice Investigation
Initiate a CRIPA action addressing systemic medical neglect, unauthorized practice of medicine, retaliation, and religious discrimination.
4. Transparency and Disclosure
Release the full September 2025 TCJS inspection report—including staff rosters, notes, and correspondence—to this complainant and the public.
5. Acknowledgment and Case Number
Provide written acknowledgment, issue a joint DOJ/TCJS case number, and specify a response timeline.
V. Attached Exhibits
| Exhibit | Title | Description |
|———-|——–|————-|
| A | Texas Jail & Pre-Trial Detention Summary (2024–2025) | Statewide evidence of medical neglect |
| B | Williamson County Medical Research Summary | Contract and inspection analysis |
| C | Williamson County Jail Medical & Psychiatric Hiring Record (2018–2025) | Documentation of part-time staffing |
| D | Systemic Medical Abuse in Williamson County Jail | First-hand narrative of unlicensed practice and resulting injuries |
VI. Certification
I certify under penalty of perjury that the information provided herein and in the attached exhibits is true and correct to the best of my knowledge, and that this complaint is submitted in good faith for lawful oversight and enforcement.
Respectfully,
___________________________
LeRoy Nellis II
4845 Twin Valley Drive
Austin, Texas 78731
Phone 512-450-1533 Email LeRoyNellis2@gmail.com
Date: October 27, 2025
¹ Note: The “shaking” or vibration-emitting devices were active in cells B5-L6, B7-R6, B9-R1, C14-R8, and in the dayrooms of B9 and C14 during my confinement. They produced persistent low-frequency tremors that disrupted sleep and caused physical distress; forensic inspection is required to determine their source and authorization.
===========================================================
EXHIBIT A
TEXAS JAIL & PRETRIAL DETENTION CASE SUMMARY (2024–2025)
Compiled for Investigative / Legal Use — © LeRoy Nellis
===========================================================
COUNTY: WILLIAMSON (Georgetown)
———————————————————–
2024–2025 CASES:
• Acosta v. Williamson County (5th Cir. 2024)
– Facts: Pretrial detainee denied diabetic treatment; near-fatal complication.
– Holding: 5th Circuit recognized viable medical-care claim.
• Holman v. Williamson County (2025)
– Facts: Wrong medication; stroke-like symptoms; delayed release.
• TCJS 2025 log lists open death-in-custody investigation for Williamson Jail.
RELEVANCE:
– Demonstrates pattern of medical-care negligence.
– Supports systemic-failure argument under Fourteenth Amendment.
———————————————————–
STATEWIDE CONTEXT (2024–2025)
———————————————————–
• 30+ Texas counties cited for health-service noncompliance (TCJS Annual Report 2024).
• State Auditor Report (2025): “Oversight Gaps in Jail Safety and Complaint Resolution.”
• DOJ / Civil Rights Division: Active pattern-or-practice probes in Harris, Bexar, Dallas, Williamson, El Paso.
• Texas Rangers: Investigating 2025 deaths in Harris, Hidalgo, and Williamson Counties.
• Wellpath Bankruptcy (2024–25): Hundreds of nationwide jail-medical negligence suits.
RELEVANCE:
– Confirms uniform statewide pattern of deliberate indifference.
– Establishes foreseeability and failure to correct known violations.
– Strengthens argument for injunctive relief and federal oversight.
===========================================================
END OF EXHIBIT A
===========================================================
===========================================================
EXHIBIT B
WILLIAMSON COUNTY MEDICAL RESEARCH SUMMARY
===========================================================
Overview:
Williamson County Jail’s healthcare program operates primarily on part-time psychiatric contracts and mid-level providers (EMTs, NPs), without full-time licensed physician oversight.
Key Findings:
• Psychiatric Services Contract (2008) — Dr. Michael Musgrove: up to 20 hrs/week “as needed.”
• Psychiatric Medical Services (FY22–25) — Dr. Ghulam M. Khan: similar 16–20 hrs/week model.
• 2025 job listing (Adelphi Medical Staffing): 16 hrs/week psychiatrist, $250–$285/hr.
• Nurse Practitioner added 2022 under ARPA funds — responsible for 550–600 inmates.
Inspection History:
• TCJS 2019 inspection: two inmates never received physician-ordered specialist appointments.
• Williamson County listed as “Special Inspection / Non-Compliant Jail.”
• No later report confirming 24/7 licensed coverage or corrected deficiencies.
Concerns:
• Heavy reliance on mid-level practitioners without direct MD supervision.
• Psychotropic medications prescribed with intermittent physician oversight.
• Evidence of “Orders to Administer Psychoactive Medications” suggesting involuntary treatment.
• No transparent data on license verification or prescribing logs.
Implications:
• Potential violation of Tex. Admin. Code §273.2 & §273.5 (24-hr health services and supervision).
• Possible breaches of Tex. Occ. Code §157 (prescriptive delegation) and Fourteenth Amendment rights.
Conclusion:
The jail’s “as-needed” contracting model fails to ensure continuous licensed medical care, creating foreseeable risk of harm and statutory noncompliance.
===========================================================
END OF EXHIBIT B
===========================================================
===========================================================
EXHIBIT C
WILLIAMSON COUNTY JAIL MEDICAL & PSYCHIATRIC HIRING RECORD
(2018 – 2025)
===========================================================
Year Position Title Type & Hours Prescribing Authority Notes / Source
——————————————————————————————————–
2025 Psychiatrist Physician (Adelphi LLC) Contract 16 hrs/wk ✅ Psychotropic meds per Sheriff’s formulary
2025 Part-Time Psychiatrist (GreenLife) As-needed ✅ General medication management
2024 Dr. Ghulam M. Khan (FY22–25 Contract) Renewal Contract ✅ Professional Services Agreement
2022 Nurse Practitioner – Jail Full-time 7-day ⚠️ Mid-level prescriber (supervised by MD)
2019 Corrections Medical Officer Full-time ❌ Dispenses meds only as ordered
2018 Medic – Jail Full-time ❌ Assists MD/psychiatrist, schedules appts
2008 Dr. Michael Musgrove (Psychiatrist) 20 hrs/wk “as needed” ✅ Licensed psychiatrist per contract
Patterns:
• Continuous use of short-hour, part-time psychiatrist contracts (8–20 hrs/wk).
• Mid-level or unlicensed personnel handle most daily care.
• No evidence of 24/7 on-site licensed medical coverage.
Conclusion:
Part-time psychiatry and intermittent MD oversight produce structural gaps incompatible with TAC §273’s 24-hour coverage requirement.
===========================================================
END OF EXHIBIT C
===========================================================
===========================================================
EXHIBIT D
SYSTEMIC MEDICAL ABUSE IN WILLIAMSON COUNTY JAIL:
How Part-Time Medicine and Unlicensed Practice Destroyed My Health
By LeRoy Nellis
===========================================================
Summary:
First-hand, documented account of deliberate medical neglect, unlicensed practice, and part-time physician coverage within Williamson County Jail, resulting in permanent disability.
Key Facts:
• Pre-trial detainee denied diabetic treatment from May 25–July 11, 2025 (108 days).
• Injections administered by EMT Larry R. Davis and others lacking verified medical licenses.
• “Dr.” Alan Brooks practiced without Texas medical license; “Dr.” Ghulam M. Khan and remote Houston doctor approved prescriptions without evaluation.
• 326 days in solitary confinement under continuous light exposure and medical deprivation.
• Result: Nerve damage, vision loss, chronic pain, and disability.
Supporting Evidence:
• County contracts show psychiatrists limited to 16–20 hrs/week for 550–600 inmates.
• 2019 TCJS inspection cited failure to follow physician orders.
• 2025 settlement (*Tijerina v. Williamson County*) proves restraint-chair abuse and denial of care.
• Chief Kathleen A. Pokluda — dual role as TCJS alumna and jail medical chief — potential oversight conflict.
Legal Basis:
• Violations of Eighth and Fourteenth Amendments (Estelle v. Gamble, Kingsley v. Hendrickson).
• Breach of Tex. Admin. Code §§273.1–273.6 (medical coverage and restraint standards).
• Breach of Tex. Occ. Code §157 (prescriptive authority).
• Constitutes “deliberate indifference” and administrative torture under CRIPA (34 U.S.C. §12601).
Conclusion:
Williamson County Jail’s medical program operates as a cost-saving regime of part-time medicine, unlicensed authority, and retaliatory neglect—amounting to systemic, state-sanctioned abuse.
Re-inspection and federal intervention are warranted immediately.
===========================================================
END OF EXHIBIT D
===========================================================
===========================================================
EXHIBIT A
TEXAS JAIL & PRETRIAL DETENTION CASE SUMMARY (2024–2025)
Compiled for Investigative / Legal Use — © LeRoy Nellis
===========================================================
COUNTY: WILLIAMSON (Georgetown)
———————————————————–
2024–2025 CASES:
• Acosta v. Williamson County (5th Cir. 2024)
– Facts: Pretrial detainee denied diabetic treatment; near-fatal complication.
– Holding: 5th Circuit recognized viable medical-care claim.
• Holman v. Williamson County (2025)
– Facts: Wrong medication; stroke-like symptoms; delayed release.
• TCJS 2025 log lists open death-in-custody investigation for Williamson Jail.
RELEVANCE:
– Demonstrates pattern of medical-care negligence.
– Supports systemic-failure argument under Fourteenth Amendment.
———————————————————–
STATEWIDE CONTEXT (2024–2025)
———————————————————–
• 30+ Texas counties cited for health-service noncompliance (TCJS Annual Report 2024).
• State Auditor Report (2025): “Oversight Gaps in Jail Safety and Complaint Resolution.”
• DOJ / Civil Rights Division: Active pattern-or-practice probes in Harris, Bexar, Dallas, Williamson, El Paso.
• Texas Rangers: Investigating 2025 deaths in Harris, Hidalgo, and Williamson Counties.
• Wellpath Bankruptcy (2024–25): Hundreds of nationwide jail-medical negligence suits.
RELEVANCE:
– Confirms uniform statewide pattern of deliberate indifference.
– Establishes foreseeability and failure to correct known violations.
– Strengthens argument for injunctive relief and federal oversight.
===========================================================
END OF EXHIBIT A
===========================================================
===========================================================
EXHIBIT B
WILLIAMSON COUNTY MEDICAL RESEARCH SUMMARY
===========================================================
Overview:
Williamson County Jail’s healthcare program operates primarily on part-time psychiatric contracts and mid-level providers (EMTs, NPs), without full-time licensed physician oversight.
Key Findings:
• Psychiatric Services Contract (2008) — Dr. Michael Musgrove: up to 20 hrs/week “as needed.”
• Psychiatric Medical Services (FY22–25) — Dr. Ghulam M. Khan: similar 16–20 hrs/week model.
• 2025 job listing (Adelphi Medical Staffing): 16 hrs/week psychiatrist, $250–$285/hr.
• Nurse Practitioner added 2022 under ARPA funds — responsible for 550–600 inmates.
Inspection History:
• TCJS 2019 inspection: two inmates never received physician-ordered specialist appointments.
• Williamson County listed as “Special Inspection / Non-Compliant Jail.”
• No later report confirming 24/7 licensed coverage or corrected deficiencies.
Concerns:
• Heavy reliance on mid-level practitioners without direct MD supervision.
• Psychotropic medications prescribed with intermittent physician oversight.
• Evidence of “Orders to Administer Psychoactive Medications” suggesting involuntary treatment.
• No transparent data on license verification or prescribing logs.
Implications:
• Potential violation of Tex. Admin. Code §273.2 & §273.5 (24-hr health services and supervision).
• Possible breaches of Tex. Occ. Code §157 (prescriptive delegation) and Fourteenth Amendment rights.
Conclusion:
The jail’s “as-needed” contracting model fails to ensure continuous licensed medical care, creating foreseeable risk of harm and statutory noncompliance.
===========================================================
END OF EXHIBIT B
===========================================================
===========================================================
EXHIBIT C
WILLIAMSON COUNTY JAIL MEDICAL & PSYCHIATRIC HIRING RECORD
(2018 – 2025)
===========================================================
Year Position Title Type & Hours Prescribing Authority Notes / Source
——————————————————————————————————–
2025 Psychiatrist Physician (Adelphi LLC) Contract 16 hrs/wk ✅ Psychotropic meds per Sheriff’s formulary
2025 Part-Time Psychiatrist (GreenLife) As-needed ✅ General medication management
2024 Dr. Ghulam M. Khan (FY22–25 Contract) Renewal Contract ✅ Professional Services Agreement
2022 Nurse Practitioner – Jail Full-time 7-day ⚠️ Mid-level prescriber (supervised by MD)
2019 Corrections Medical Officer Full-time ❌ Dispenses meds only as ordered
2018 Medic – Jail Full-time ❌ Assists MD/psychiatrist, schedules appts
2008 Dr. Michael Musgrove (Psychiatrist) 20 hrs/wk “as needed” ✅ Licensed psychiatrist per contract
Patterns:
• Continuous use of short-hour, part-time psychiatrist contracts (8–20 hrs/wk).
• Mid-level or unlicensed personnel handle most daily care.
• No evidence of 24/7 on-site licensed medical coverage.
Conclusion:
Part-time psychiatry and intermittent MD oversight produce structural gaps incompatible with TAC §273’s 24-hour coverage requirement.
===========================================================
END OF EXHIBIT C
===========================================================
===========================================================
EXHIBIT D
SYSTEMIC MEDICAL ABUSE IN WILLIAMSON COUNTY JAIL:
How Part-Time Medicine and Unlicensed Practice Destroyed My Health
By LeRoy Nellis
===========================================================
Summary:
First-hand, documented account of deliberate medical neglect, unlicensed practice, and part-time physician coverage within Williamson County Jail, resulting in permanent disability.
Key Facts:
• Pre-trial detainee denied diabetic treatment from May 25–July 11, 2025 (108 days).
• Injections administered by EMT Larry R. Davis and others lacking verified medical licenses.
• “Dr.” Alan Brooks practiced without Texas medical license; “Dr.” Ghulam M. Khan and remote Houston doctor approved prescriptions without evaluation.
• 326 days in solitary confinement under continuous light exposure and medical deprivation.
• Result: Nerve damage, vision loss, chronic pain, and disability.
Supporting Evidence:
• County contracts show psychiatrists limited to 16–20 hrs/week for 550–600 inmates.
• 2019 TCJS inspection cited failure to follow physician orders.
• 2025 settlement (*Tijerina v. Williamson County*) proves restraint-chair abuse and denial of care.
• Chief Kathleen A. Pokluda — dual role as TCJS alumna and jail medical chief — potential oversight conflict.
Legal Basis:
• Violations of Eighth and Fourteenth Amendments (Estelle v. Gamble, Kingsley v. Hendrickson).
• Breach of Tex. Admin. Code §§273.1–273.6 (medical coverage and restraint standards).
• Breach of Tex. Occ. Code §157 (prescriptive authority).
• Constitutes “deliberate indifference” and administrative torture under CRIPA (34 U.S.C. §12601).
Conclusion:
Williamson County Jail’s medical program operates as a cost-saving regime of part-time medicine, unlicensed authority, and retaliatory neglect—amounting to systemic, state-sanctioned abuse.
Re-inspection and federal intervention are warranted immediately.
===========================================================
END OF EXHIBIT D
===========================================================
LeRoy Nellis
info;Ricky Armstrong
LeRoy Nellis
4845 Twin Valley Drive
Austin, Texas 78731
Phone: 512-450-1533
Email: LeRoyNellis2@gmail.com
October 27, 2025
Mr. Ricky Armstrong
Assistant Director
Texas Commission on Jail Standards
P.O. Box 12985
Austin, Texas 78711-2985
Subject: FORMAL REBUTTAL AND REQUEST FOR INDEPENDENT RE-INSPECTION — WILLIAMSON COUNTY JAIL
Dear Mr. Armstrong:
I am writing in response to your email dated October 24, 2025, stating that the September 3–4 inspection of the Williamson County Jail found **“no deficiencies.”** Respectfully, that conclusion conflicts with documentary and testimonial evidence now on record with your agency and multiple state and federal bodies.
—
### I. Documented Basis for Re-Inspection
1. **Prior TCJS Deficiencies and Non-Compliance**
* The Commission’s own December 10–12 2019 inspection found inmates who never received physician-ordered specialist care.
* Williamson County subsequently appeared on TCJS’s “Special Inspection / Non-Compliant Jails” list. No published report shows those issues were corrected through continuous licensed coverage.
2. **Persistent Staffing Gaps (2018 – 2025)**
* Records show every psychiatrist hired by the county has been **part-time (16–20 hours/week)** under “as-needed” contracts—Dr. Michael Musgrove (2008), Dr. Ghulam M. Khan (2021–2025), and current recruiters Adelphi Medical Staffing and GreenLife Healthcare (2025).
* Day-to-day care is provided by **EMTs and Nurse Practitioners** without continuous physician supervision, contrary to **TAC §273.2 and §273.5**.
3. **Restraint-Chair Misuse and Injury**
* *Tijerina v. Williamson County* (settlement Oct 14 2025 – $1.15 million) confirmed punitive restraint and denial of care—clear evidence that **§273.6 Use of Restraints** and **§283 Discipline and Grievances** were violated.
4. **Unlicensed Practice and Medication Administration**
* Multiple individuals—identified in sworn statements and Texas Medical Board searches—administered injections and prescriptions without valid licenses.
* From May 25 through July 11 2025, diabetic and psychotropic medications were withheld or administered by EMTs wearing “EMS” patches but lacking prescriptive authority.
5. **Conflict of Interest**
* Chief Kathleen A. Pokluda, currently head of the jail’s medical division, previously served with TCJS. Her dual role raises an appearance of bias undermining inspection independence.
—
### II. Applicable Law and Oversight Duties
* **Tex. Admin. Code Title 37 Part 9 §§273.1-273.6** require 24-hour licensed medical and emergency coverage.
* **Tex. Occ. Code §157** limits delegation of prescriptive authority.
* **Tex. Health & Safety Code Chs. 571–578** mandate licensed psychiatric oversight and due-process hearings for psychoactive medication.
* **Estelle v. Gamble, 429 U.S. 97 (1976)** and **Kingsley v. Hendrickson, 576 U.S. 389 (2015)** establish that deliberate indifference to pre-trial detainees’ medical needs violates the Eighth and Fourteenth Amendments.
—
### III. Requested Actions
1. **Immediate Re-Inspection** of Williamson County Jail by a TCJS team independent of prior inspectors, with public release of:
* Staffing rosters and license numbers of all medical/psychiatric personnel;
* Health-services plan and medication-management protocols;
* Records of restraint-chair use and medical emergencies (Jan 2024 – present).
2. **Referral to the Texas State Auditor’s Office** to review TCJS inspection procedures and potential conflicts of interest.
3. **Referral to the U.S. Department of Justice, Civil Rights Division (CRIPA)** for investigation of systemic constitutional violations.
4. **Written acknowledgment** of this rebuttal with assignment of a new complaint number and expected timeline for follow-up.
—
### IV. Supporting Exhibits
| Exhibit | Title | Source |
|———-|——–|———|
| A | *Texas Jail & Pre-Trial Detention Summary (2024–2025)* | Pattern of statewide medical neglect |
| B | *Williamson County Medical Research Summary* | Contract and inspection data |
| C | *Williamson County Jail Medical & Psychiatric Hiring Record (2018–2025)* | Staffing timeline |
| D | *Systemic Medical Abuse in Williamson County Jail* | First-hand evidence and statutory analysis |
All exhibits are available in electronic format for official review.
—
### V. Certification
I certify that the statements and attached materials are true and correct to the best of my knowledge and are submitted in good faith for official oversight and enforcement under the authority of the Texas Commission on Jail Standards and applicable state and federal law.
Respectfully,
__________________________
**LeRoy Nellis**
Austin, Texas
Phone 512-450-1533 Email LeRoyNellis2@gmail.com
LeRoy Nellis
Ricky Armstrong
FORMAL NOTICE OF NON-COMPLIANCE AND RESUBMISSION OF PUBLIC INFORMATION REQUEST
To:
Texas Commission on Jail Standards (TCJS)
P.O. Box 12985 | Austin, TX 78711-2985
Email: info@tcjs.state.tx.us, Alyssa.McMahon@tcjs.state.tx.us
Cc:
Office of the Attorney General — Open Records Division publicrecords@oag.texas.gov
U.S. Department of Justice — Civil Rights Division, Special Litigation Section (CRIPA) special.litigation@usdoj.gov
From:
LeRoy Nellis II
4845 Twin Valley Drive | Austin, TX 78731
Phone 512-450-1533 | Email LeRoyNellis2@gmail.com
Date: October 27, 2025
Subject:
Fourth Request and Formal Notice of Non-Compliance — Williamson County Jail Records (Original PIA Filed October 3, 2025)
I. Chronology and Purpose
- October 3 2025 — Original Request:
Filed under the Texas Public Information Act (§ 552), requesting TCJS inspection, complaint, and medical-oversight records concerning the Williamson County Jail. - October 7 2025 — Received Stamp (Proof of Filing):
Your office formally received and stamped the request. - October 9 2025 — Acknowledgment Letter:
Ms. Alyssa McMahon confirmed receipt but no clarification follow-up or records have been produced. - October 14 and October 24 2025 — Follow-up Emails:
Resubmissions and clarifications sent electronically and by mail produced no responsive documents and no statutory denial notice. - October 27 2025 — This Filing:
Serves as the fourth formal attempt to obtain the same information, and as a notice of potential violation of Texas Gov’t Code Ch. 552 for failure to respond within the statutory time frame.
II. Expanded Request Scope (2022 – 2025)
Please produce electronically (PDF or searchable text):
- Inspection and Compliance Records — all annual, special, and surprise inspections 2022-2025, including deficiency reports and September 3-4 2025 inspection notes.
- Medical and Psychiatric Staffing — contracts, licenses, and prescriptive-authority agreements for Drs. Ghulam Kahn, Alan Brooks, Michael Musgrove, and any Adelphi or GreenLife providers.
- Health-Care Oversight and Incident Data — complaints, death-in-custody reports, and restraint-chair medical clearances.
- Religious and Retaliatory Discipline — incidents involving denial of Bibles or religious materials.
- Isolation and SMOK Cell Procedures — mental-health authorization forms, policies, and Kahn recommendations.
- Vibration / “Shaking” Devices (Southside B5-L6, B7-R6, B9-R1, C14-R8) — engineering data, maintenance logs, vendor communications, ADA analyses, and inmate grievances.
- Communications & Investigations — all correspondence between TCJS, Williamson County Sheriff’s Office, District Attorney, and Kathleen Pokluda.
- Litigation and Settlements — including Tijerina v. Williamson County (2025 restraint-chair settlement).
- Complaints by LeRoy Nellis — internal routing notes and responses linked to my prior filings.
III. Incorporated Exhibits
| Exhibit | Title | Description |
| A | Original October 3 2025 PIA Request (Received Stamp Oct 7) | Baseline filing |
| B | TCJS Acknowledgment Letter (Oct 9 2025 – Alyssa McMahon) | Proof of receipt |
| C | DOJ/CRIPA Complaint and Rebuttal (Oct 27 2025) | Evidence of parallel federal review |
| D | Inspection & Medical Abuse Summary 2024-2025 | Supporting documentation |
IV. Statutory and Legal Basis
- Texas Gov’t Code Ch. 552 – Texas Public Information Act
- Tex. Admin. Code Title 37 Part 9 §§ 273.1-273.6, 275.1, 283.3
- Tex. Occ. Code § 157 – Prescriptive Delegation
- 34 U.S.C. § 12601 (CRIPA) – Civil Rights of Institutionalized Persons Act
V. Requests for Action
- Acknowledge receipt and assign a new TCJS complaint and PIA reference number.
- Fulfill the outstanding October 3 2025 request in full or provide a written denial with specific statutory exceptions cited.
- Transmit all responsive records electronically to LeRoyNellis2@gmail.com.
- Copy all responses to the Office of the Attorney General for oversight and to the U.S. Department of Justice for parallel review.
- Confirm whether TCJS considers this a continuation of prior Complaint # ____ or a new filing.
VI. Notice to the Texas Attorney General
Pursuant to Texas Gov’t Code § 552.3215 and § 552.353, this letter serves as formal notification that a state agency under your jurisdiction has failed to provide responsive records or a lawful denial within the required timeline.
I respectfully request that the Attorney General’s Office review this matter and compel compliance as provided by law.
VII. Certification
I certify under penalty of perjury that the facts and attachments herein are true and correct to the best of my knowledge and that this request is submitted in good faith for lawful oversight and enforcement.
Respectfully,
LeRoy Nellis II
Austin, Texas
512-450-1533 | LeRoyNellis2@gmail.com
Date: October 27 2025
Understood.
Below is your complete, print-ready packet — no emojis, no markup, ready for Word, PDF, or direct print.
Everything is formatted in formal correspondence layout and sequenced chronologically.
PUBLIC INFORMATION & OVERSIGHT DOSSIER
Williamson County Jail – 2025
Prepared by: LeRoy Nellis II
4845 Twin Valley Drive
Austin, Texas 78731
Phone: 512-450-1533
Email: LeRoyNellis2@gmail.com
DOCUMENT 1 — ORIGINAL PUBLIC INFORMATION ACT REQUEST
Date: October 3, 2025
To:
Texas Commission on Jail Standards (TCJS)
P.O. Box 12985
Austin, Texas 78711-2985
Email: tcjs@tcjs.state.tx.us
From:
LeRoy Nellis
4845 Twin Valley Drive
Austin, Texas 78731
Subject: Public Information Request – Williamson County Jail
Dear Commissioners,
Pursuant to the Texas Public Information Act, Tex. Gov’t Code Chapter 552, I respectfully request copies of all records, correspondence, and reports pertaining to the operations and oversight of the Williamson County Jail from January 2024 through the present.
Specifically, this request seeks:
- Inspection reports, compliance reviews, or deficiency notices issued between January 2024–present.
- Any documents, communications, or investigations regarding inmate medical care, prescription practices, or use of restraint chairs.
- All emails or internal memoranda referencing medical contractors, EMTs, or physicians including Dr. Alan Brooks, Dr. Ghulam M. Khan, or Chief Kathleen Pokluda.
- Records or correspondence involving complaints or grievances related to medical neglect, suicide watch, or retaliation.
- Copies of all inmate death or serious injury reports, 2024–2025.
- Copies of any TCJS or county communications involving the Texas Attorney General, Texas Medical Board, or U.S. Department of Justice.
- Policies or procedures in effect regarding inmate medical treatment, religious materials, and segregation or restraint use.
- Vendor and contract records for medical or psychiatric services.
- Any communications regarding disciplinary actions involving unlicensed medical personnel.
- Records of vibration or sound-emitting devices used within jail housing areas.
- Any subsequent corrective action plans or compliance documentation.
This information is sought for public-interest review and to ensure compliance with state and federal law.
Respectfully,
LeRoy Nellis II
DOCUMENT 2 — TCJS ACKNOWLEDGMENT LETTER
Date: October 9, 2025
From:
Alyssa McMahon, Open Records Coordinator
Texas Commission on Jail Standards
P.O. Box 12985, Austin, TX 78711-2985
To:
Mr. LeRoy Nellis
4845 Twin Valley Drive
Austin, TX 78731
Dear Mr. Nellis,
This letter acknowledges receipt of your October 3, 2025 Public Information Request. The Commission is processing your request under the Texas Public Information Act.
Please note that your request as written is broad and may encompass records exempt from disclosure under Chapter 552 of the Texas Government Code. To expedite processing, please consider narrowing the request to specific time frames or subject categories.
Upon clarification, TCJS will provide all responsive, releasable records in accordance with state law.
Sincerely,
Alyssa McMahon
Open Records Coordinator
Texas Commission on Jail Standards
DOCUMENT 3 — FOLLOW-UP AND RESUBMISSION LETTERS
Date: October 14, 2025
To:
Texas Commission on Jail Standards
P.O. Box 12985
Austin, Texas 78711-2985
Email: tcjs@tcjs.state.tx.us
From:
LeRoy Nellis
4845 Twin Valley Drive
Austin, Texas 78731
Subject: Resubmission and Clarification of October 3, 2025 Public Information Request – Williamson County Jail
Dear Commissioners,
This correspondence serves as a formal resubmission and clarification of my Public Information Act request originally submitted October 3, 2025.
I hereby confirm that my request covers the following categories:
– All medical and psychiatric licensing, staffing, and contract records for the Williamson County Jail (2018–present);
– Records of denial, suspension, or delay of medical treatment for diabetic and psychiatric conditions;
– All documentation concerning the use of restraint chairs or suicide-watch placement between January 2024 and July 2025;
– Copies of complaints, grievances, or internal investigations related to medical neglect, retaliation, or religious discrimination;
– All correspondence between TCJS and Williamson County regarding inspection results or disciplinary actions;
– Records of any TCJS special inspections, audits, or reviews since 2019; and
– Any communications with the Texas Medical Board or Attorney General regarding Williamson County Jail medical staff.
I request acknowledgment of this resubmission and assignment of a case or reference number.
Respectfully,
LeRoy Nellis II
Date: October 24, 2025
To:
Texas Commission on Jail Standards
P.O. Box 12985
Austin, Texas 78711-2985
Email: info@tcjs.state.tx.us
From:
LeRoy Nellis
4845 Twin Valley Drive
Austin, Texas 78731
Subject: Resubmission of Public Information Request and Formal Complaint — Williamson County Jail
Dear Commissioners,
This letter reaffirms and resubmits my prior requests of October 3 and 14, 2025, and constitutes a formal complaint regarding violations of state jail standards, including medical neglect, unlicensed practice, and retaliatory confinement at the Williamson County Jail.
I specifically reference Texas Administrative Code §§273.1–273.6 (Health Services, Use of Restraints), §275.1 (Complaint Review), and §283.3 (Discipline and Grievances).
This filing further requests that TCJS obtain withheld medical and grievance records directly from the Williamson County Sheriff’s Office and District Attorney’s Office, which have previously denied access citing exemptions under Chapter 552.
Please issue written acknowledgment, assign a new complaint number, and confirm the scope of the investigation.
Respectfully,
LeRoy Nellis II
DOCUMENT 4 — DOJ / CRIPA SUBMISSION AND REBUTTAL
Date: October 27, 2025
To:
Mr. Ricky Armstrong
Assistant Director
Texas Commission on Jail Standards
P.O. Box 12985
Austin, Texas 78711-2985
Email: ricky.armstrong@tcjs.state.tx.us
and
U.S. Department of Justice
Civil Rights Division – Special Litigation Section (CRIPA)
950 Pennsylvania Avenue N.W.
Washington, D.C. 20530
Email: special.litigation@usdoj.gov
CC:
Texas Attorney General – Open Records Division
P.O. Box 12548
Austin, Texas 78711-2548
Subject: Formal Rebuttal and Request for Joint Investigation — Williamson County Jail, Georgetown, Texas
Dear Mr. Armstrong and Civil Rights Division Officials,
This correspondence serves as a formal rebuttal to TCJS’s October 24, 2025 finding of “no deficiencies” and as a formal complaint and request for federal investigation under the Civil Rights of Institutionalized Persons Act (CRIPA), 34 U.S.C. §12601.
I have now submitted four separate Public Information requests (October 3, 9, 14, and 24, 2025) without receipt of the requested records. This ongoing failure to produce responsive information has obstructed oversight and necessitates direct intervention by both TCJS and the Texas Attorney General.
I. First-Hand Experience and Physical Harm
(Here insert the full section detailing solitary confinement, denial of medication, unlicensed medical staff, and restraint-chair abuse as previously set forth.)
II. Basis for Rebuttal and Federal Referral
(Here include the sections regarding contradictory findings, part-time coverage, unlicensed practice, restraint misuse, and conflicts of interest.)
III. Legal Framework
(Include citations to Estelle v. Gamble, Kingsley v. Hendrickson, Turner v. Safley, and Tex. Admin. Code provisions.)
IV. Requested Actions
- Conduct a joint TCJS–DOJ inspection and forensic review of records and devices.
- Verify licensing and medical credentialing of all staff.
- Audit restraint-chair, suicide-watch, and medical logs from Jan 2024–Jul 2025.
- Appoint independent inspectors with no prior affiliation.
- Initiate a federal pattern-or-practice investigation under CRIPA.
- Provide written acknowledgment and joint case number.
V. Certification
I certify under penalty of perjury that the information provided herein is true and correct to the best of my knowledge and is submitted in good faith for lawful oversight and enforcement.
Respectfully,
LeRoy Nellis
4845 Twin Valley Drive
Austin, Texas 78731
Phone: 512-450-1533
Email: LeRoyNellis2@gmail.com
LeRoy Nellis 
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