Dallas ISD treated this non-existent report as if it were credible evidence. Its arguments
that my placement on leave, the Administrator’s Investigation, and the recommendation for
termination were lawful, non-discriminatory measures tied to student welfare are fatally
compromised by the missing CPS report. Without that document, the foundation of the
District’s asserted compliance with policy and state law collapses. Moreover, the District’s
court submissions which cites over fifty-seven references to a CPS report, over one-hundred
forty-six references to CPS, and over five-hundred references to investigations, rests on a
narrative of mandatory reporting that cannot be substantiated. Dallas ISD’s record even
flaunts its reliance on it with the following statements: “[This report] did not alter the
terms, conditions, or privileges of Bravo’s employment. There is no evidence that CPS ever
investigated the matter (DISD App. 734 at 192:9–11). CPS never contacted Dallas ISD
regarding the report or regarding any investigation (DISD App. 14, 403, 486–87). CPS never
contacted Bravo (DISD App. 734 at 191:22–23). Bravo admits there was no finding of any
misconduct by CPS (DISD App. 735 at 194:7–9). Bravo also testified that he does not believe
that anyone outside Dallas ISD or CPS even know a CPS report against him exists (DISD App.
734 at 191:24–192:8).”
As mentioned earlier, no statutorily compliant CPS report has ever been produced. Instead,
Dallas ISD only provides an eight-character alphanumeric reference (DISD App. 439, DISD
3372) that the Texas Department of Family Protective Services (DFPS) confirmed it does not
use and that does not exist. See
BRAVO 3883.