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Colorado County

TPIA Request: CCSO Records — Former Deputy Tomas Ramirez — May 26, 2026

May 26, 2026 5 min read

Transmitted via email to Sheriff Justin Lindemann and Eugenia Behrens, Colorado County Sheriff’s Office, May 26, 2026. CC: J. Eric Magee (Allison Bass & Magee), Jay Johannes and Carolyn Olson (Colorado County).

TO: Sheriff Justin Lindemann / Eugenia Behrens, Colorado County Sheriff’s Office eugenia.behrens@co.colorado.tx.us | justin.lindemann@co.colorado.tx.us

CC: e.magee@allison-bass.com | jay.johannes@co.colorado.tx.us | carolyn.olson@co.colorado.tx.us

FROM: ████████████████████████████ DATE: May 26, 2026

RE: Texas Public Information Act Request — Records Concerning Former Deputy Tomas Ramirez

Sheriff Lindemann:

Pursuant to the Texas Public Information Act, Tex. Gov’t Code Chapter 552, I respectfully request copies of the following records held by the Colorado County Sheriff’s Office concerning former CCSO Deputy Tomas Ramirez and the conduct alleged to have occurred in or about September 2024 that resulted in his prosecution under Tex. Penal Code § 39.04 and deferred adjudication community supervision in or about 2025. Without limiting the foregoing, I specifically request:

  1. All CCSO incident, offense, and supplemental reports;
  2. All internal investigation files, supervisor reviews, and administrative investigation records;
  3. All body-worn camera, in-car camera, jail surveillance, and audio recordings related to the conduct, the response, or the investigation;
  4. All written, recorded, or transcribed witness statements, including those of inmates housed at the Colorado County Jail, CCSO personnel, and any third-party witnesses;
  5. All personnel-file records concerning Ramirez’s discipline, separation, suspension, or other employment action related to this conduct, including any TCOLE F-5 separation report;
  6. All communications (including email, text, and memoranda) between CCSO personnel and any external investigating agency — including but not limited to the Texas Department of Public Safety / Texas Rangers and the Colorado County Attorney’s Office — regarding Ramirez or the underlying conduct;
  7. All Prison Rape Elimination Act (PREA) screenings, intake records, complaint logs, investigative records, and reports related to the alleged conduct or the alleged victim;
  8. All policies, procedures, and training records in effect at CCSO at the time of the conduct regarding inmate-staff sexual contact, PREA compliance, supervision of female inmates, and reporting requirements;
  9. All remedial measures, policy revisions, training, or other corrective actions undertaken by CCSO following the disposition of the criminal case.

PUBLIC-COURT-RECORD CATEGORY. To the extent any responsive record has been filed with, attached to, introduced before, or otherwise made part of any court proceeding in this matter, that record is public information under Tex. Gov’t Code § 552.022(a)(17) and may not be withheld under § 552.108, § 552.103, or any other discretionary exception. See Open Records Decision Nos. 665 (2000), 664 (1999), and 177 (1977). The only exceptions that survive against subsection (a)(17) are mandatory confidentiality statutes (e.g., HIPAA, Tex. Code Crim. Proc. arts. 57 and 57A).

DEFERRED-ADJUDICATION CARVE-OUT, § 552.108(a)(2) AND (b)(2). The criminal investigation and prosecution of Mr. Ramirez resulted in deferred adjudication community supervision. By the plain text of Tex. Gov’t Code § 552.108(a)(2) and § 552.108(b)(2), records of an investigation that resulted in deferred adjudication are not excepted from disclosure under those subsections.

INTERFERENCE REBUTTAL, § 552.108(a)(1) AND (b)(1). The investigation closed upon entry of judgment. Disclosure of records of a completed prosecution cannot interfere with the detection, investigation, or prosecution of crime within the meaning of § 552.108(a)(1) or (b)(1). Probation enforcement and modification proceedings administered by the community supervision department are not “detection, investigation, or prosecution of crime” within the meaning of the statute. See Open Records Decision No. 549 (1990). To the extent CCSO contends (a)(1) or (b)(1) applies, please specifically identify the ongoing matter and the manner in which release would interfere.

LITIGATION-EXCEPTION REBUTTAL, § 552.103. Mr. Ramirez is not a party, potential party, or claimant in any pending or anticipated litigation by Requestor. The records sought relate to a completed prosecution from 2024–2025 that pre-existed any communication of a potential claim by Requestor. The records are sought for public-accountability journalism, not as a substitute for civil discovery. See Open Records Decision No. 588 (1991). The records sought here are equally subject to disclosure if requested by a journalist, civil-rights organization, or any unrelated citizen; the requestor’s identity does not alter their public status.

REDACTION DEFERENCE. I acknowledge that responsive records may contain information the responding entity is required by law to withhold or redact, including victim identifying information under Tex. Code Crim. Proc. arts. 57 and 57A; personally identifying information of officers and employees under Tex. Gov’t Code §§ 552.117, 552.130, and 552.147; medical information protected under federal HIPAA and Tex. Gov’t Code § 552.101; mental-health records protected under Tex. Health & Safety Code Ch. 611; and other information specifically made confidential by statute. I request that such legally required redactions be applied and the remainder of the records be produced. If any responsive record is withheld in its entirety, I request an itemized index identifying the document, the statutory basis asserted, and a brief description.

PUBLIC-INTEREST FEE WAIVER AND BINDING PUBLIC-RELEASE COMMITMENT. Pursuant to Tex. Gov’t Code § 552.267(a), I respectfully request that the responding entity furnish the responsive records without charge or at a reduced rate. All responsive records produced under this request will be made publicly available at aiether.info within seven (7) business days of receipt, with mandatory redactions applied. This commitment is binding and independent of any pending or anticipated claim by Requestor in any other forum.

AG RULING AND SEVERABILITY. If CCSO seeks an Attorney General ruling under Tex. Gov’t Code § 552.301, please provide the required notice and submission within the statutory 10-business-day period and provide me with a copy. If any single item is contested or denied, the remaining items are requested to be produced without delay pending resolution of any AG ruling on the contested item.

COST ESTIMATE. If full or partial waiver is denied, I am willing to pay reasonable charges as authorized by Tex. Gov’t Code §§ 552.261–552.275. Pursuant to § 552.2615, please provide an itemized cost estimate before production if charges are expected to exceed $40.

Sincerely,

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Correspondence #

Primary email correspondence for this record.

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