15-25-00220-CV ACCEPTED 15-25-00142-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS NO. 15-25-00142-CV 12/1/2025 12:00 AM CHRISTOPHER A. PRINE IN THE FIFTEENTH COURT OF APPEALS CLERK FILED IN 15th COURT OF APPEALS AUSTIN, TEXAS AUSTIN, TEXAS 12/1/2025 12:00:00 AM IN RE CHRISTOPHER A. PRINE Clerk ROBERT EDWARD BATTAILE, Relator

ADDENDUM TO SUPPLEMENTAL PETITION FOR WRIT OF MANDAMUS New Evidence – November 26, 2025 – Filed: November 28, 2025 TO THE HONORABLE JUSTICES OF THE FIFTEENTH COURT OF APPEALS: Relator submits this Addendum to provide newly emerging, time-critical evidence arising on November 26, 2025, after the filing of the November 25 Supplemental Petition for Writ of Mandamus. This incident directly reflects the same pattern of obstruction, denial of access, and staff-controlled manipulation of public processes described in Relator’s original Mandamus and prior Supplement.

I. NEW EVIDENCE (11/27/2025): OBSTRUCTION OF CORRESPONDENCE TO CHARTER REVIEW COMMISSION CHAIR On November 26, 2025, Relator attempted to deliver a Copy of the Supplemental Mandamus pleading to Daniel Mendoza, Chair of the City of Manor Charter Review

– 1 – 15-25-00142-CV Commission (“CRC”). Although the CRC not addressed in the original Mandamus, the obstruction encountered is identical in character to the TOMA-related barriers, public- participation restrictions, and staff interference previously documented for this Court.

In brief, at the reception window of City Hall, the receptionist stated: • She had been instructed not to accept any correspondence addressed to the CRC; • That “anything… has to be presented the day of the meeting”; • And that the instructions came directly from City Secretary Lluvia Almaraz, whom she had contacted by phone. City Secretary and City Attorney are CRC's only advisors at the unrecorded, unstreamed and unarchived video recording of four CRC meetings thus far.

When City Secretary, Lluvia Almaraz then stepped to the window, she: • Declined to notify the CRC Chair; • Declined to provide an email or any method of contact; • Stated: “We won’t see him until the day of the meeting.” • Responded dismissively and refused assistance, until begrudgingly accepting the letter.

This is Relator's transcript of the recorded two minute-14 second conversation. [00:00:01.660] – Robert: Okay, you're saying what now? [00:00:03.660] – Receptionist: I was notified that anything that you're going to be forwarding over to the commission, it just has to be presented the day of. I'm not able to mail anything or forward the documentation. It has to be presented the day of, which is

– 2 – 15-25-00142-CV what I was told. [00:00:17.460] – Robert: By who? [00:00:18.660] – Receptionist: I had to give a quick call to Lluvia. [00:00:20.800] – Robert: Pardon me? [00:00:21.290] – Receptionist: To Lluvia. [00:00:23.640] – Robert: She's the City Secretary. [00:00:25.780] – Receptionist: Right. Yes. I did have to get information because I wasn't too sure who this documentation was to be going over to. But if it's going to be going over to the commission, she did state it has to be presented to the day of city council meeting. [00:00:35.640] – Robert: Well, I already told the court I was going to deliver it to him here. [00:00:39.020] – Receptionist: Okay, yeah. So he doesn't have an office, right. We're not able to forward any documentation over to the commission. I had to I have a quick call to Lluvia. She did notify us that any documentation has to be presented the day of. [00:00:52.580] – Robert: Well, this is about a lawsuit. [00:00:55.000] – Receptionist: Yes, sir. So I, that's what I was told. [00:00:57.170] – Robert: I can't- Okay, yeah. I'm not trying. I'm not. Understand; I'm

– 3 – 15-25-00142-CV not upset at you. But it's just this is a secret commission meeting in secret, and I can't even give a letter for her to send to him. Is that what you're saying? [00:01:15.860] – Receptionist: So, I was just notified that I'm not able to accept anything that is going to be for the commission. It has to be presented the day of the meeting. [00:01:24.100] – Robert: Can you give me their email address? [00:01:26.160] – Receptionist: For who exactly? For you here? (points to addressee) [00:01:27.780] - Lluvia Almaraz, City Secty (walks up to front window) Hi. [00:01:28.540] – Robert: Yeah. [00:01:29.120] – Lluvia: Well, how may I help you? [00:01:30.460] – Robert: I'm trying to give something to the chairperson of the Charter Review Commission. [00:01:35.800] – Lluvia: What, so are you attending the last meeting? 'Cause you can, because just like you do regular council meetings, you- [00:01:41.700] – Robert: What's that got to do with it? [00:01:43.560] – Lluvia: I'm letting you know the process. For the commissioners. Just like P&Z (Planning & Zoning Commission), anything that you want to provide to them to provide- [00:01:49.060] – Robert: P&Z, I can send an email.

– 4 – 15-25-00142-CV [00:01:49.060] – Lluvia: You send an email to the group. [00:01:54.900] – Robert: I send P&Z Commission. [00:01:56.360] – Lluvia: Okay, so what do you want to do? [00:01:57.780] – Robert: I'd like this to be, to get to the chairperson of the Charter Review Commission. [00:02:01.640] – Lluvia: We won't see him until the day of the meeting. [00:02:03.160] – Robert: Why don't you call him and tell him you have it here? [00:02:05.080] – Lluvia: I'm not going to call him. Or let him know. [00:02:07.280] – Robert: I don't have a number for him. [00:02:09.260] – Lluvia: Okay. (exasperated) [00:02:10.060] – Robert: So I have no way- [00:02:10.820] – Lluvia: That's fine. We'll take it. [00:02:12.180] – Robert: Okay, thank you. [00:02:12.780] – Lluvia: Have a good day. [00:02:13.520] – Robert: You, too. (she leaves with the large envelope) NOTE REGARDING AUDIO FILE: Because eFileTexas does not accept audio formats, Relator cannot upload the original .m4a recording through the electronic filing system. Relator certifies that the full native – 5 – 15-25-00142-CV audio file of the November 27, 2025 interaction is preserved and is available for immediate submission to the Court upon request.

II. LEGAL SIGNIFICANCE Although the Charter Review Commission was not at issue in the original Mandamus, this new episode: • Demonstrates a continuing pattern of denial of access to public bodies; • Mirrors the same TOMA violations identified in prior filings (unrecorded meetings, suppressed public comments, refusal to accept participation); • Confirms that the harms described in this case are ongoing and expanding; • Reinforces the need for mandamus relief due to irreparable injury to Relator’s constitutional rights under Tex. Const. art. I §§ 8, 13, 19, and 27.

This conduct also violates the City’s Code of Ethics: •§12.02.032(a) – misuse of office;

•§12.02.032(b) – improper influence / denial of access;

•§12.02.032(c) – discourteous or hostile treatment;

•§12.02.032(d) – retaliation.

Relator additionally gives notice that a formal Ethics Commission Complaint will be – 6 – 15-25-00142-CV filed. Under Manor Code §12.02.041, the City Manager is required to convene the Ethics Commission upon receipt.

PRAYER Relator respectfully requests that this Court: 1. Accept this Addendum as part of the record in this Mandamus proceeding;

2. Consider Exhibits A in evaluating the ongoing, real-time nature of the harms described herein; 3. Enjoin a Reset with the same Charter Review Commission members; and 4. Grant such additional mandamus relief as justice may require.

Respectfully submitted this 28th day of November by, /s/ Robert Edward Battaile Robert Edward Battaile E. Eggleston St., Unit B, Manor, Texas 78653 [email protected] 512-662-2955

– 7 – 15-25-00142-CV CERTIFICATE OF SERVICE I certify that on November 28, 2025, a true and correct copy of this Addendum to the Supplemental Petition for Writ of Mandamus was served electronically through the State of Texas electronic filing system (eFileTexas) on all counsel and parties of record listed for Case No. 15-25-00142-CV in the Fifteenth Court of Appeals, including the Office of the Attorney General as counsel for the State of Texas.

In addition, consistent with TRAP 9.5 and standard municipal-representation practice, notice of this filing is also provided to: Daniel Mendoza, Chair of the Charter Review Commission, and the Charter Review Commission as a municipal body, via the City Attorney for the City of Manor (Knight Law Firm) through this eFiling.

/s/ Robert Edward Battaile Robert Edward Battaile, Relator Pro Se

– 8 – 15-25-00142-CV Automated Certificate of eService This automated certificate of service was created by the efiling system.

The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules.

Envelope ID: 108525170 Filing Code Description: Other Document Filing Description: ADDENDUM TO SUPPLEMENTAL PETITION FOR WRIT OF MANDAMUS Status as of 12/1/2025 11:46 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Jeffrey Hobbs 24012837 [email protected] 11/28/2025 11:03:59 AM SENT Michael Kabat 24050847 [email protected] 11/28/2025 11:03:59 AM SENT Joanna Salinas 791122 [email protected] 11/28/2025 11:03:59 AM SENT William Davidson 5447000 [email protected] 11/28/2025 11:03:59 AM SENT Gavin Villareal 24008211 [email protected] 11/28/2025 11:03:59 AM SENT Michael Roberts 24082153 [email protected] 11/28/2025 11:03:59 AM SENT Cynthia Veidt 24028092 [email protected] 11/28/2025 11:03:59 AM SENT Stephanie Serrano 24092655 [email protected] 11/28/2025 11:03:59 AM SENT Kevin O'Hanlon 15235500 [email protected] 11/28/2025 11:03:59 AM SENT Patrick Kelly 11228000 [email protected] 11/28/2025 11:03:59 AM SENT Tyler Ryska 24096597 [email protected] 11/28/2025 11:03:59 AM SENT Austin Jones 24116579 [email protected] 11/28/2025 11:03:59 AM SENT William Duncan 24124453 [email protected] 11/28/2025 11:03:59 AM SENT Roy Adams [email protected] 11/28/2025 11:03:59 AM SENT Victoria Gomez [email protected] 11/28/2025 11:03:59 AM SENT Lauren Bush 24142742 [email protected] 11/28/2025 11:03:59 AM SENT Anna Puff 24144206 [email protected] 11/28/2025 11:03:59 AM SENT Edward Smith 24037790 [email protected] 11/28/2025 11:03:59 AM SENT Robert EdwardBattaile [email protected] 11/28/2025 11:03:59 AM SENT Annette Bittick [email protected] 11/28/2025 11:03:59 AM SENT Patricia Muniz [email protected] 11/28/2025 11:03:59 AM SENT Raylynn Howell [email protected] 11/28/2025 11:03:59 AM SENT Automated Certificate of eService This automated certificate of service was created by the efiling system.

The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules.

Envelope ID: 108525170 Filing Code Description: Other Document Filing Description: ADDENDUM TO SUPPLEMENTAL PETITION FOR WRIT OF MANDAMUS Status as of 12/1/2025 11:46 AM CST Case Contacts Raylynn Howell [email protected] 11/28/2025 11:03:59 AM SENT Kim McBride [email protected] 11/28/2025 11:03:59 AM SENT Lea Ohrstrom [email protected] 11/28/2025 11:03:59 AM SENT Sneed Vine &Perry [email protected] 11/28/2025 11:03:59 AM SENT Stormy Downing [email protected] 11/28/2025 11:03:59 AM SENT Andy Soule [email protected] 11/28/2025 11:03:59 AM SENT Karah Powers [email protected] 11/28/2025 11:03:59 AM SENT Martha AnnAdams [email protected] 11/28/2025 11:03:59 AM SENT Benjamin C. Hunt [email protected] 11/28/2025 11:03:59 AM SENT Eldridge Burns [email protected] 11/28/2025 11:03:59 AM SENT Amy Botelho [email protected] 11/28/2025 11:03:59 AM SENT Carol Shipley [email protected] 11/28/2025 11:03:59 AM SENT Emily Hill [email protected] 11/28/2025 11:03:59 AM SENT Anne Weir [email protected] 11/28/2025 11:03:59 AM SENT Legal Counsel [email protected] 11/28/2025 11:03:59 AM SENT W Fusselman [email protected] 11/28/2025 11:03:59 AM SENT