Case 4.18-cv-00775 Document 33-1 Filed in TXSD on 04/11/18 Page 4 of 8 SubIed Fwd: Hours From To brook555(ho(l@yahootom Date Thursday, February 9, 2017 07 25 3I AM PST Forwarded message From Blocks Dale: Dec 10' 2016 a|12 24 AM Sub ecI Hou T01-- --. Forwarded message --. --. From JARED WOODFILL Dale: Sar. Dec 10. 2016 al1210 AM Subject Re: Hours To: Brooks Sonou Bmoksy I oburoust feeI InaI Ihe oonduoI you described by Judge PressIer is unacceptable He does nonork for Ine firm and you never have to speak io nIm again. wiII address II wilh hIm srnoe have known mm for many years. W'Ilh respecllo serious Issues IIke IhIs. I suggest you come sIraIgnI to me Instead of Ken I IhInk you naue a 01 sirengIns and Inai can be furlher developed. Brooks. my door Is aIways open Io you and I IMII aIways ireaIyou respeciMIy even men we disagree on an Issue IerI raise your saIary by $104300 and make sure Ken sIans you on insurance. I suggesI we sian on January 1 due to me sIan o! a new year We oonIInue lo ade your salary as your hours Increase Remember. I am Ior you and wani you Io succeedI Jared Seni Irom my IPnone PM, Brooks Scholt -- wroIe Mr. Woodfillr I appreciate everyImng you have done and I apprecraIe you addressing inese Issues I do noi mean any drsrespeoI to you, Inis nas been a nignIy siressIuI Ior me IIook Ionuard Io addressing Inese Issues With you In person aI your earlresI convenience. On Fri, Dec 9. 2015 aI II 40 PM, JARED WOODFILL --wroie BmokSy FirsI. Paul rs noi my Iaw banner anymore and has noi been Ior many years. Second. lhis 85 year oId man has never made any rnapproprIaie oommenIs or acirons ioward me or any one I know of I will address your commenIs with him IerI aIso address Ken's oommenis wriII nIm Third. lhe tone of your email is inappropnaIe In my opInion Ii Is a direcl on me and I am shocked you wouId Case 4.18-cv-00775 Document 33-1 Filed in TXSD on 04/11/18 Page 5 of 8 even allude to the (act lhal some how deceived you respect to someone I have knawn slnce 1995 and has always been appropriate with me I am willing to give you a raise, but have been stuck in a bad move situation i have gone out or my way to help you get experience and contacts Again, address the situation .tudge Pressler It appears you are unhappy the firm and we need to dlscuss Ihis Jared Senl lrom my iPhone On Dec 9,2016ial11 21 PM, Brooks Schott-- wrote Mr Woodfil'i There has been a situation at the law firm that needs to be addressed by you immediately when lwentto lunch with your partner and mentor Paul Pressler he made inappropriate sexual advances towards me. He told me a lew lewd stories about being naked on beaches with young men and then he invited me out to his farm to go naked hot-tubing with him. He asked me ill would be comfortable doing that which I told him I was not The tollovnng day your office manager Ken asked me how my lunch Pressler went He expressed his dislike of Pressler and how he had made advances towards young men in the past. He then asked me if Pressler invited me into his hot-tub naked With him There is no way that Ken would ask me that question unless this situation had arisen belore. I told Keri lhal Pressler had made inappropriate sexual advances towards me liken knew or Pressler's pasl inappropriate sexual behavior find it hard to believe that you did not know about it Second when you originally offered me a job you told me that would be put on the health insurance plan You also told me that I would start at a salary ol$65i000 and that upon passing the bar that would gel a raise When started working at the firm in August there was no health insurance plan I passed the baron November 3' 2016 ll is now December 9' 2015 and I have not reoeived a raise nor have you communicated whether I will get a raise in the near luture i moved from Washington to Texas based on the promises you made I also moved to Texas because I share the same conservalive values as you and respect and admlre the causes that you champion Your brother is my pastor and i love his lamily Your parents are wondertul people. For everyone's sake I need you to address this and make it right sincerely, Blanks Scholl On Fri Dec 9' 2015 at 47 PM, JARED What CPS trial? Senl from my iPhone Case Document 33-1 Filed in TXSD on 04/11/18 Page 1 of 8 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION GARELD DUANE ROLLINS, JR., Plainti?; H. PAUL PRESSLER NANCY PRESSLER, PAIGE PATTERSON, JARED WOODF ILL, THE WOODF ILL LAW FIRM, WOODF ILL PRESSLER, L.L.P., SOUTHWESTERN BAPTIST THEOLOGICAL SEMINARY FIRST BAPTIST CHURCH OF HOUS- TON, SOUTHERN BAPTIST CON- VENTION, AND SECOND BAPTIST CHURCH OF HOUSTON, CIVIL ACTION NO. 4: 1 8?cv-00775 REMOVED FROM THE 127TH DIST. COURT OF HARRIS COUNTY, TX CASE NO. 2017-69277 Defendants. AFFIDAVIT OF BROOKS SCHOTT THE STATE OF WASHINGTON COUNTY OF SPOKANE BEFORE ME, THE UNDERSIGNED AUTHORITY, on this day personally appeared BROOKS SCHOTT, known by me by presentation of his government issued photo ID. to be the person whose signature appears below, and who, being by me duly sworn, did depose as follows: ?My name is BROOKS SCHOTT. I am over the age of 18 years, mentally competent, and not otherwise disquali?ed by law from making an af?davit. In the above captioned removed case, under its Rule 194 Disclosures, I am listed as a person with knowledge of relevant facts. This af?davit makes explicit the ?relevant facts reference? to me in the state court Disclosures that I feel are relevant to this matter in federal court. Those relevant facts that follow are within my ?rst hand knowledge and are true and correct. am 27 years old. I live in Spokane, Washington where I was raised. I attended university at Eastern Washington University in Cheney, Washington. After I completed my undergraduate studies, I attended law school at Willamette College of Law in Salem, Oregon. ?rst met Jared Wood?ll in 2016 while still in my third year of law school. I visited Houston at the suggestion of my father through a religious pastoral connection. My -1- Case 4:18?cv?OO775 Document 33-1 Filed in TXSD on 04/11/18 Page 2 of 8 father is a pastor of a non-denominational church in Spokane who had the occasion to preach at a church in The Woodlands, the pastor of which is Matt Wood?ll, the brother of Jared Wood?ll. At a service at which my father preached, he met Jared Wood?ll who apparently then learned of my law school status. Upon information and belief, an invitation was made to me through my father to travel to Houston to explore the possibility of employment in Wood?ll Law Firm after graduation. ?Based on an exploratory visit in March 2016, Jared Woodfill offered me a job after graduation. Consequently, I took the Texas Bar Exam in July of 20 6 rather than in Washington State. After the exam, I then changed my domicile to Texas and, in August of 2016, began to work for the Wood?ll law ?rm as a law clerk. Then, upon successful admission in Texas in November 4, 2016, I became a junior associate upon passing the Texas Bar Exam. ?During my time working for the Woodfill law firm, Jared Wood?ll had me accompany him to a number of political events. On one such occasion, I was introduced to Former Judge Paul Pressler. Jared Wood?ll told me that Pressler was his former law partner and mentor for over 25 years. He told me that Pressler was a ?hero of the faith? and a ?great man.? I saw Pressler at a number of subsequent political dinners. ?Sometime in October of 2016, I was instructed to make a copy of a settlement agreement between Rollins and Pressler. I was concerned about its contents because they did not coincide with the high praise Jared had heaped on Pressler. When I asked Jared about the discrepancy, he told me that Pressler had opened his heart and home to Rollins, but Rollins took advantage of Pressler and attempted to extort money from him. At that time I believed his explanation. ?In December of 2016, at a political fund-raiser held at Dr. Steven Hotze?s home, Pressler sought me out and invited me to go to lunch ?to get to know one another better.? I asked Jared whether it was a good idea for me to go to lunch with Pressler and he encouraged me to do so in spite of what I knew about the settlement agreement. Consequently, the following week, I met Pressler at his house to pick him up for lunch. When I rang the doorbell, Pressler opened the door but was not fully clothed. He was not wearing any trousers and told me that he was running late and had trouble dressing himself due to his poor health. After Pressler had dressed himself, he gave me a tour of his office and showed me pictures of all the ?important people? he had met. He then asked me about my family ancestry. Upon learning that I was German and Danish, Pressler told me a story about going swimming naked in Denmark with other young men when he was younger. ?At lunch, Pressler told me about his ranch and all of its amenities including a ten person hot tub. Pressler then told me that ?when the ladies are not around, us boys all go in the hot tub completely naked.? He then invited me to go naked hot tubbing with him at his ranch. This invitation was clearly made in anticipation that I would engage in sexual activity with him on the pretext of a hot tub experience. It was -2- Case 4:18?cv?OO775 Document 33-1 Filed in TXSD on 04/11/18 Page 3 of 8 clearly a solicitation. I was embarrassed but as politely as possible, I replied that I was not interested in going to his ranch. ?After lunch I returned to the Wood?ll Law ?rm and informed the of?ce manager, Ken Kennedy, what had happened. He informed me that this was not the ?rst time that Pressler had acted inappropriately around young men. ?On December 9, 2016, I sent an email to Jared informing him of Presslers lewd behavior at the lunch (see email chain, attached incorporated herein by reference). Jared denied any knowledge of Pressler behaving in this manner in the past. Jared also assured me that he would talk to Pressler about his behavior and that I would never have to see Pressler again. Over the next few months, the entire of?ce learned about Pressler soliciting me. I also discovered that Pressler had a long history of such behavior even going as far as bringing scantily clad young men and parading them around the of?ce. resigned from the Wood?true and correct copy of my resignation letter is attached. I bring it to this Court?s attention since it involves state court judges? awareness of Pressler?s behavior. As a lawyer, licensed in Texas, I have read the Motion to Remand in this case on PACER. I note that the fourth prong of cited test requires that ?federal jurisdiction will not disturb the balance of federal and state judicial responsibilities.? I believe that what happened to me involves attorney misconduct and further, reveals that there is widespread knowledge about Wood?ll and Pressler in the Harris County judicial community. Consequently, it is my opinion that what happened to me is pre-eminently a state judicial responsibility such that retention of federal jurisdiction would arguably disturb the balance of federal and state judicial responsibilities.? SCHOTT, Af?ant - SWORN TO AND SUBSCRIBED BY BROOKS SCHOTT this a 7day of . 2018 to certify which witness below my hand and seal of of?ce. AFFIANT SAYS NOTHING FURTHER. mummz s??cWAfPUBLIC IN AND FOR 5- a 3 THE STATE OF WASHINGTON ?35 0le 26?5"" =3 WAS ?Ian" I