Cedric M. Scott, PhD v. General Land Office of the State of Texas

ACCEPTED
15-25-00217-CV
FIFTEENTH COURT OF APPEALS
AUSTIN, TEXAS
12/9/2025 11:48 PM
CHRISTOPHER A. PRINE
CLERK
FILED IN
IN THE FIFTEENTH COURT OF APPEALS
15th COURT OF APPEALS
AUSTIN, TEXAS
AT AUSTIN, TEXAS 12/9/2025 11:48:12 PM
CHRISTOPHER A. PRINE
Clerk

Case No. 15-25-00217-CV
(Transferred from the Third Court of Appeals)

CEDRIC M. SCOTT, PhD
Appellant, Pro Se

v.

GENERAL LAND OFFICE OF THE STATE OF TEXAS
Appellee

On Appeal from the 250th Judicial District Court of Travis County, Texas
Trial Court Cause No. D-1-GN-25-000006

APPELLANT’S REPLY TO APPELLEE’S RESPONSE IN
OPPOSTION TO APPELLANT’S MOTIONS TO STRIKE AND
FOR SANCTIONS

Cedric M. Scott, PhD
Appellant, Pro Se
Email: cedricscott41@gmail.com
TO THE HONORABLE FIFTEENTH COURT OF APPEALS:

Appellant respectfully submits this Reply to ensure the Court has a clear and

accurate record concerning the issues raised in the Motion to Strike and for

Sanctions.

I. GLO Does Not Dispute Its Failure to Answer the Second Amended
Petition

GLO’s response attempts to deflect from a central procedural defect:

GLO never answered Appellant’s Second Amended Petition that added new

allegations—including conflicts of interest, retaliation, constitutional violations,

and corroborated whistleblower disclosures—none of which were addressed by

GLO’s prior general denial.

Under Texas law, a general denial does not automatically answer new

matters in amended pleadings. Courts require defendants to answer new allegations

so that issues are properly framed and notice is preserved. See Kostecki v. Fairway

Pines, 371 S.W.3d 862, 872 (Tex. App.—Houston [14th Dist.] 2012).

GLO’s silence is therefore a judicial admission, not a procedural technicality.

II. GLO Misstates Rule 92 and Its Effect

GLO asserts that Texas Rule of Civil Procedure 92 excuses its failure to

answer. This is incorrect. Rule 92 applies to defensive matters already placed at

issue, not to new allegations of constitutional violations, conflicts of interest,

whistleblower retaliation, or procedural misconduct. New facts and new causes of
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action require a responsive pleading. See Stoner v. Thompson, 578 S.W.2d 679,

683 (Tex. 1979).

III. GLO Ignores the Void-Order Problem and Its Own Conflicts

GLO’s response conspicuously avoids addressing the decisive issue:

the fact that Judge Cory R. Liu was constitutionally disqualified from the moment

he presided over the case based on his prior representation of GLO in HUD-related

matters. A constitutionally disqualified judge lacks authority to act, and any orders

entered are void. Tex. Const. art. V, § 11; Buckholts I.S.D. v. Glaser, 632 S.W.2d

146, 148 (Tex. 1982).

Appellant documented Judge Liu’s prior representation of GLO in HUD-

related matters while at Ashcroft Law Firm and Butler Snow—matters directly

related to CDBG-DR oversight. No responsive pleading from GLO disputes these

facts. This is not a procedural preference—it is a matter of constitutional structure

and public confidence in the judiciary.

IV. GLO Avoids Its Own Internal Audit Report No. 25-01

GLO again avoids confronting the most substantial evidence in the record:

GLO’s Internal Audit Report No. 25-01 corroborates Appellant’s protected

disclosures and contradicts GLO’s statements at the October 29, 2025 hearing

that “no such audit exists.” Yet, the audit report:

• Was completed in September 2025,

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• Findings were not disputed by GLO,

• Was transmitted to oversight agencies, and

• Acknowledges the same systemic noncompliance Appellant reported

internally and externally to the appropriate law enforcement authorities.

This contradiction goes unaddressed. GLO’s refusal to acknowledge the

audit—after denying its existence at the October 29 hearing—raises serious

concerns about candor to the tribunal. This omission goes directly to the credibility

of GLO’s litigation posture and further supports the need for sanctions.

V. GLO’s Characterization of Appellant’s Filings Is Baseless

GLO attempts to portray Appellant’s filings as frivolous. This is a familiar

tactic used against whistleblowers, particularly where the record shows:

• Repeated protected disclosures,

• Ensuing adverse actions,

• Corroboration by independent audit findings,

• Appellee’s failure to answer Appellant’s live operative pleading, and

• Judicial conflict that required recusal months earlier, and judicial rulings that

were void.

Appellant’s filings are supported by evidence, statute, and the Texas Constitution.

As such, these issues strike at the heart of judicial integrity and the orderly

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administration of justice. Bringing them forward is neither frivolous nor improper;

it is required to ensure the Court has an accurate record.

VI. PRAYER

Appellant respectfully asks this Court to:

1. Strike GLO’s improper filings,

2. Recognize GLO’s failure to answer the live petition,

3. Address the void-order issue and audit contradictions, and

4. Grant such other and further relief to which Appellant is entitled.

Respectfully submitted,

/s/ Cedric M. Scott

Cedric M. Scott, PhD
Appellant, Pro Se
Email: cedricscott41@gmail.com

Date: December 9, 2025

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CERTIFICATE OF SERVICE

I certify that a true and correct copy of the foregoing Appellant’s Reply To

Appellee’s Response In Opposition To Appellant’s Motion to Strike and For

Sanctions was served on counsel for the Appellee, in accordance with Texas Rule

of Appellate Procedure 9.5, on December 9, 2025 by electronic service (e-Filing).

Counsel for the General Land Office

Sara Labashosky
State Bar No. 24129467
slabashosky@bickerstaff.com

Gunnar P. Seaquist
State Bar No. 24043358
gseaquist@bickerstaff.com

Bickerstaff Heath Delgado Acosta LLP
3711 S. MoPac Expressway
Building One, Suite 300
Austin, Texas 78746
(512) 472-8021

/s/ Cedric M. Scott
Cedric M. Scott, PhD
Appellant, Pro Se

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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: 108916290
Filing Code Description: Response
Filing Description: Appellant's Reply to GLO's Response
Status as of 12/10/2025 7:29 AM CST

Case Contacts

Name BarNumber Email TimestampSubmitted Status

Gunnar Seaquist gseaquist@bickerstaff.com 12/9/2025 11:48:12 PM SENT

Jeffrey Moore jmoore@bickerstaff.com 12/9/2025 11:48:12 PM SENT

Sara Labashosky slabashosky@bickerstaff.com 12/9/2025 11:48:12 PM SENT

Cedric M.Scott cedricscott41@gmail.com 12/9/2025 11:48:12 PM SENT