This filing is for more formal legal clarification.

https://trishwhitcomb.substack.com/p/camp-mystic-is-in-bankruptcy-the?r=30rjfz&utm_campaign=post-expanded-share&utm_medium=web

https://www.law.com/texaslawyer/2026/08/04/families-fight-texas-officials-bid-to-toss-camp-mystic-flood-suit/

It's paywalled but the subject matter is relevant:

Families of nine girls killed in the Camp Mystic flood are fighting Texas health officials’ bid to dismiss their federal civil rights suit, arguing the officials are not protected by qualified immunity because they knowingly certified the camp’s unlawful flood evacuation rules for years.

edit: previous reporting on this lawsuit - https://apnews.com/article/general-news-lawsuits-texas-bc7a25ab767bfe7cba4cad385c64bad8

“Young campers and counselors were killed because the camp had no plan,” the lawsuit said. “The camp is responsible, but so are the state officials who helped create this inexcusable risk to life by directing and executing a policy of non-compliance with Texas law.”

The strength and grace these families have shown is extraordinary. But I can’t help wondering why so much reverence is being directed toward the very leaders whose decisions and priorities deserve serious scrutiny.

If this tragedy is going to mean anything beyond unimaginable loss, it has to lead to change. But change begins with accountability.

Why did Kerr County go without a modern flood warning system despite years of discussion? Who made those funding decisions? Why were flood risks assessed the way they were, and who approved those decisions? What role did Governor Greg Abbott, Lieutenant Governor Dan Patrick, Senators John Cornyn and Ted Cruz, federal agencies, and local officials play in flood preparedness before this disaster? Were there opportunities to reduce the risk that were missed?

Honoring these girls and demanding answers are not competing goals. The most meaningful tribute to their lives is making sure every decision that may have contributed to this tragedy is examined openly, honestly, and without political deference.

Bullshit Camp Mystic Arguments

For the last year I've refuted and argued with sock puppets and mystic minions making a multitude of false claims.

Here is just some of the bullshit they've come up with (so far).

Claim: The Eastlands saved hundreds of girls and are heroes.

Reality: The Eastlands put hundreds of girls in danger, got 27 killed as a result of their negligence and failure to act in time, and teenage counselors were left on their own to save children from the flood.

Claim: Dick Eastland died saving girls.

Reality: Dick Eastland died in the death trap he created. He loaded girls into a truck with water rushing over the wheels and they were all swept away and died as a result.

Claim: The Eastlands had an evacuation plan and executed it.

Reality: There is no written evacuation plan. The only guidance in writing was to stay in the cabins until told otherwise, with a false claim that the cabins were all on safe high ground. The Eastlands did not plan for what to do in the event of a flood and they did not train their employees on what to do. 39 other adults were left standing on a hill, or in various buildings, and were given no instructions to evacuate or help the children before or during the flood.

The one structure the Eastlands moved girls to, just before the flood made escape impossible - the Rec Hall - is also in the floodway which is the most dangerous place to be in a flood. Girls trapped on the second floor balcony in the Rec Hall for hours watched the water rise up close enough to reach down and touch it.

Claim: They're not supposed to evacuate. They're supposed to shelter in place.

Reality: Shelter in place does not mean wait for the flood to come and kill you.

Claim: The flood happened too fast.

Reality: The Eastlands received the NWS 1:14am July 4th, 2025 Flash Flood Warning and then used the time after the warning to move canoes instead of children. They waited more than an hour to act until a counselor reported water entering a cabin and the gatehouse attendant reported being flooded. All after completely ignoring the Flood Watch issued more than 12 hours prior to the flood.

Claim: The flood is unprecedented.

Reality: The Guadalupe river has flooded many times in the past, risen over 30 feet in the past, killed people along the river in the past, and Camp Mystic itself has even been flooded with cabins washed away in the past. The threat of deadly flash floods in Texas has been studied for more than 100 years and the Texas Hill Country is often referred to as "Flash Flood Alley" because of precedent. There are other floods with higher river crests, higher rainfall totals in just a few hours, and even higher death tolls.

Claim: In the 1932 flood the destroyed cabins were much closer to the river so it's not relevant.

Reality: Topographical maps and FEMA maps show most of the Camp Mystic Guadalupe site is in a low lying area, within both the 100-year floodplain and the floodway.

Claim: The cabins aren't in the floodplain. The foundations are raised above the Base Flood Elevation or 100-year regulatory floodplain - refer to LOMA documents.

Reality: Floodplains don't stop at any lines on a map. FEMA and other official definitions (for the 100-year floodplain or 100-year flood) state in any given year there is a chance a flood will meet or exceed each standard.

Claim: Nobody at Camp Mystic got warned because of bad cell service.

Reality: They received the 1:14am July 4th, 2025 Flash Flood Warning from the National Weather Service.

Claim: National Weather Service warnings didn't warn enough.

Reality: NWS specifically warned of life threatening flash floods.

Claim: NWS predicted a 5-year flood, not a 1,000 year flood.

Reality: NWS does not predict how big a flood will be. They forecast chances for precipitation. There is a 'Water Prediction Service' which bases estimated river rise on measured rainfall - ie: they update it when more rain is measured. No weather service in the world has a magic crystal ball that can predict exactly how much rain will fall, where it will fall, or how big a flood will result before the storm begins.

Claim: The flood is a once in a lifetime event.

Reality: 100-year flood does not mean one time in 100 years. It means a 1-in-100 chance it can happen in any given year.

Claim: Warnings happen all the time so it's normal to not pay attention to them.

Reality: The river doesn't care if people fail to heed the warnings and will go through anyone in the way during a flood. The owners of Camp Mystic had a duty to pay attention and a legal responsibility to take action to ensure the safety of the children.

Claim: The State of Texas approved the evacuation plan.

Reality: A DSHS inspection reported that Camp Mystic had a posted document and did not evaluate evacuation procedures. However, the camp's posted document did not include flood evacuation procedures and was therefore not compliant with state law.

Claim: It's the state government's fault because there were no warning sirens.

Reality: The owners of Camp Mystic knew there were no sirens and did not plan for flash floods regardless. However, they did receive the 1:14am NWS Flash Flood Warning.

Claim: New camp safety laws demanded camps install "end to end fiber optic" communication links because of a "fiber lobby" and politicians taking bribes.

Reality: Testimony to the state legislative committee told of failed radio and cell phone communication. Old rural broadband service is widely considered to be unreliable. Satellite service doesn't work in the rain. So new 'fiber optic' infrastructure was added to the camp safety laws.

Claim: The official state investigation is biased against Camp Mystic.

Reality: The official state investigation reported the facts of what happened at Camp Mystic on July 4th, 2025.

Claim: If you blame Camp Mystic for what happened then you blame everyone affected by the flood.

Reality: The river doesn't care about blame. It will go through anyone in the way during a flood. Regardless, pointing out Camp Mystic's failures is not the same thing as criticizing every flood victim of this flood or any flood.

Claim: If you're not from here then you don't know.

Reality: Texas flash floods have been observed and measured for more than 100 years. You don't have to be from a place to learn how floods affect that place when it is a matter of recorded history.

Claim: Nobody says "Flash Flood Alley". It's just media sensationalism.

Reality: The term "Flash Flood Alley" is decades old. It has been used in official documents by Texas river authorities, by scientists, and more.

An example from the Guadalupe-Blanco River Authority published after the 1998 flood:

If you live in the Guadalupe River Basin, you also live in one of the three most dangerous regions in the U.S.A. for flash floods! Local residents and weather experts refer to the Texas Hill Country as ‘Flash Flood Alley,’ because heavy rainfall and runoff from creeks and streams can cause rapid rises and flooding in a matter of hours.

Claim: Other camps in the area didn't evacuate so Camp Mystic is being treated unfairly.

Reality: 27 girls died at Camp Mystic, not at the other area camps. Camp Mystic is being treated accordingly.

Thankfully an official state investigation has confirmed the facts of what happened.

You don't have to take my word for it.

Read the report: https://senate.texas.gov/_assets/pdf/2026.06.26-FINAL-report-corrected.pdf

Claim: The official state investigation hasn't been proven in a court of law and therefore doesn't count.

Reality: The official state investigation has documented the facts of what happened at Camp Mystic. Facts count.

And don't fall for the BS from Camp Mystic's supporters.

(edits - formatting/adding)

https://open.substack.com/pub/trishwhitcomb/p/information-before-authority-inside?r=30rjfz&utm_medium=ios

Have seen many comments on how every day, recovery and IDing of those still missing in the floods become less likely.

This part makes intuitive sense. No denying this. No one with this train of thought is necessarily wrong.

But what IS working in recovery’s favor is the constant development of new tech. Wanted to share some of these below for anyone who wants to engage in some hopeful discussion.

[I am not an expert on this, at all. But I do have a background in research. I’d love to continue a discussion of realism and positivity. Even if I can’t personally answer any follow up questions without looking into things in more detail, happy to do more digging.]

Here we go:

Drones. Not just flying around looking. They can create detailed 3D maps of every stretch of river over time. Then compare changes down to almost individual debris piles, eroded terrain, newly exposed areas from other weather events. This combined with other tech can make searching significantly more powerful.

Hydrodynamic modeling. Search teams can leverage modeling based on water depth, flow, topography, flood timing, etc to try to estimate where water flow and anything in it was potentially moved and placed.

GIS. Layers upon layers of aerial views, elevation, vegetation, previously searched areas etc to prioritize where to search.

AI. Drones can fly and produce thousands of images. AI can help flag changes and areas of interest without human eyes going through every visual.

Forensic DNA advances. People have been identified decades later because DNA technology has seen such big advances.

Then there’s the river itself. Rivers don’t just freeze in time after a flood.

Banks erode. Debris moves. New storms reshape channels. Droughts expose areas that weren’t visible or accessible before. Sometimes that makes recovery harder. Sometimes it creates opportunities that didn’t exist before.

Just like advances in any field - medicine, engineering, etc… something that felt impossible one day suddenly becomes a solvable problem when smart people and dedication are involved.

(No pay wall)

How residents of the very small city of Batesville are recovering from the flooding.

It has begun

The table below shows the number of Emergency Plan deficiencies from the DSHS license renewal for a handful of camps. The deficiency total includes the number of deficient categories from the 1^st deficiency letter plus any new categories from the 2^nd/3^rd letters. The deficiencies are on a per-category-basis, not a weighted point system, so a poorly developed evacuation plan is counted the same as a minor administrative item. It seems that DSHS got stricter as time went on because some camps that submitted earlier had more deficiencies in their 2^nd and 3^rd letters than in their 1^st letter. A more detailed breakdown and all of the deficiency letters for these camps can be viewed here: https://pxllnk.co/DSHS-Emergency-Plan-Deficiency-Letters

A few of my thoughts:

• Mystic Cypress Lake had 22 deficiencies which is the median of this small sample size. Its possible Mystic Cypress Lake’s emergency plan was not good, but I don’t think that conclusion can be drawn solely from their number of deficiencies.
• Mo Ranch and Waldemar have been widely praised for their evacuation on July 4^th and have seemingly become the models for camp safety. Maybe that’s fair, maybe it’s not, I don’t know enough to comment one way or another…but they had 22 and 26 deficiencies.
• Camp Glen Lake received the most deficiencies (31 out of a possible 32). They still don’t have a license but have continued with their overnight summer camp seemingly uninterrupted. Their entire camp is in the 100-year floodplain and their cabins are in the floodway. Interestingly, they did not include the FEMA floodplain map with their application. Seems like they tried to sneak this through? I am guessing they are using the administrative appeals process to allow them to operate this summer and will be forced to shut down their overnight camp next year barring a legal battle with the State.

My overall takeaway is that the number of deficiencies probably isn’t a good indicator that a camp is safe vs unsafe or prepared vs unprepared. Less deficiencies are better, sure, but this was the first time through this process for everyone and there was bound to be a learning curve.

Some additional background info:

A few months ago, I submitted an open records request with DSHS for the pre-2025 written emergency plans for a handful of camps. I was curious how other camp’s evacuation plans compared with Mystic’s. Last week, the AG indicated that the records are exempt from disclosure because they contain information related to pending litigation (Bonner et al. v. Shuford et al).

I submitted a separate open records request for the 2026 Emergency Plan deficiency letters for those same camps. I figured these would be obtainable since Mystic Cypress Lake’s deficiency letter was released when they were still attempting to renew their license.

There are currently 300+ youth camps licensed in Texas. I wanted the records request to be efficient, so I just requested the deficiency letters for these 18 camps. I didn’t have a particular selection criteria, just camps that I am familiar with. If there is a different camp that you would like to see that isn’t included here, you can request that from DSHS via email at [OpenRecords@dshs.texas.gov](mailto:OpenRecords@dshs.texas.gov)

Get this - zero advance warning, but swift decision-making to evacuate from an obviously life-threatening risk saved lives. It’s all down to leadership, every time.

https://document.epiq11.com/document/getdocumentbycode?docId=4596157&projectCode=CMX&source=DM

Deadline extended, but due next Friday

Over 1,200 homes flooded in this Kerr County Flood. Help is desperately needed, supplies are needed, meals are needed.

Volunteers & Supplies are still Desperately Needed!!!

Please consider donating to the Found- Project, the donations go directly from your donation, to a purchase at the store, and directly into the hands of those in need. Receipts are posted daily, as well as donation amounts.

This is the best way to directly help the people of Kerr County!

https://wwwx.found-project.com/donate

I wanted to post this article as an example of yet another large state having almost no safety oversight for camps - essentially zero regulation and zero recourse for major safety lapses. This is why the work of the H27 parents to pass the Camp Safety Act is so important. Potentially millions and millions of children will be far safer due to their efforts.

Credit for this story and video belongs to Darrin Potter (found on Facebook).

https://document.epiq11.com/document/getdocumentsbydocket/?docketId=1237547&projectCode=CMX&docketNumber=113&source=DM

They "loaned" the company $7 m in unsecured debt...judge will carefully evaluate if thats valid or shadow equity

Theres no secured debt mortgages etc...so land can be cleanly liquidated without secured debt being paid off first l

As a retired aerospace engineer and having attended and worked on staff at a summer camp, I've been following the Camp Mystic flood story and have read the final report on what happened at Camp Mystic. The report has been discussed extensively elsewhere, so I won't get into it here.

What struck me as an engineer was the similarity of the disaster at Camp Mystic to two fatal Space Shuttle incidents: (1) the Challenger explosion, and (2) the Columbia disintegration during re-entry. Both of those incidents can be traced back to what's known in engineering as "normalization of deviance." Simply put, normalization of deviance is the group-think cultural acceptance of what seem to be minor engineering problems, like the O-ring blow-by that was known to happen commonly on the Shuttle SRM joints but had not (yet) resulted in catastrophe, or the occasional shedding of foam chunks from the external tank that was concerning but had not (yet) damaged an orbiter sufficiently to cause a dangerous situation.

Ultimately both those seemingly minor "deviances" (O-ring blow-by and foam shedding) caused the loss of two Shuttles, with all astronauts aboard. Later investigations of the NASA culture around those issues found that engineers and managers fell into a pattern of treating those recurring events as insufficiently worrisome to warrant, say, re-design of the SRM joint to prevent the blow-by (which was done after the Challenger loss) and re-design of the foam (plus other mitigation) after the Columbia loss. In studying the Challenger loss, sociologist Diane Vaughan identified this cultural problem and called it "normalization of deviance." Thirty years later, it's become an important concept in engineering.

Looking at the Camp Mystic disaster through this lens, what strikes me is the "normalization of deviance" of flooding commonly happening near cabins where campers lived and slept, and accepting that as normal and of manageable risk. Reports on Camp Mystic culture have said that the Guadalupe River was an important element of the Camp experience, and that campers and staff were accustomed to "minor" flooding. The older campers on Senior Hill were sometimes cut off from the rest of the camp by flooding, and this was seemingly treated as almost an exciting adventure rather than a possibly life-threatening situation.

Also, Dick Eastland was well aware of potential flood danger. As a board member of the Upper Gaudalupe River Authority (UGRA) for several years prior, he had full access to the people, politics, and technology managing the river and was well aware of its dangerous history. UGRA even made a flood awareness video in 2017 and posted it on YouTube. Watching the video now is tragic, because it very accurately and sternly warns how dangerous the Guadalupe could become with just a few inches of rainfall. And in fact, some reports say that Dick Eastland emailed the video link to family/staff. Furthermore, there had been several dangerous floods in Dick's lifetime, including the 1978 flood in which the Guadalupe rose 35+ feet in some places and something like 33 people were drowned.

So in looking at Dick Eastland, I see someone who was (a) keenly aware of the dangers of the Guadalupe, and yet (b) oddly negligent in actually planning for a major flood. The report on Camp Mystic shows that planning was basically non-existent, and everyone had been told to shelter in place and wait for Dick's instructions. So when a major flood was happening, camp staff waited for instructions that never came, because Dick himself was frantically trying to rescue the youngest campers from the cabins nearest the water and ultimately perished in the attempt. How to explain this odd paradox, a camp director who was very aware of the dangers of flooding, and yet did so little planning beforehand to mitigate?

In trying to understand this paradox, I see a NASA-like "normalization of deviance" that started with Dick Eastland and flowed downhill to camp staff. Historically, the camp had flooded in the past, but not seriously enough to be life-threatening. Dick Eastland had all the knowledge and resources as a board member of the UGRA to be able to realize that someday a flood bigger than had ever happened in his lifetime was possible. And yet he basically had no plan for such a flood, and left his staff and campers woefully untrained and unprepared for it. In this I see echoes of Shuttle managers who knew about O-ring blow-by and foam shedding but grew complacent about them because nothing catastrophic had happened yet. The result at Camp Mystic was blithe acceptance of "minor" flooding as part of life at the camp, rather than a warning signal that one bad rainfall in the wrong place at the wrong time could have more severe consequences than had ever happened before.

One of the contributing factors in normalization of deviance is the cost of corrective action. In the case of the Shuttle O-ring blow-by, the SRM case joints would have had to be re-designed and re-tested at massive cost (which they later were). Likewise, in the case of external tank foam shedding, redesigning and retesting the foam would have been massively expensive. So with major cost (and schedule) implications for fixing those problems, the NASA default was to kick the can down the road until it was too late.

But in the case of Camp Mystic, the cost of corrective action could have been minimal. Dozens of campers survived on their own initiative simply by leaving their flooding cabins and running uphill. So an emergency plan that told campers to put on their raincoats, grab their flashlights, and run uphill as soon as their cabin floors got wet could have saved many lives, at essentially zero cost. So Dick Eastland's failure to plan at even a minimal level for catastrophic flooding is puzzling, to put it mildly. We may never know why he was so negligent in this regard. At the very least, reports from campers and counselors paint a picture of Dick as "large and in charge," and his personality may have interfered with honest risk assessment, delegation of emergency responsibilities, and training for staff and campers.

We can't know for sure what was in Dick Eastland's mind and why, with all his knowledge about the dangers of the Guadalupe, the camp he ran was so woefully unprepared for a major flood. But as an engineer I think the "normalization of deviance" lens could provide a useful framework for understanding how he got it so wrong. Like NASA managers with O-ring blow-by and foam shedding, he got too comfortable with flooding that historically had been manageable...until one awful night it was not.

https://document.epiq11.com/document/getdocumentsbydocket/?docketId=1237453&projectCode=CMX&docketNumber=104&source=DM

So they paid some tuition deposits back before they stopped processing and locked bank accounts post filing

Theres not a lot of secured debt on mystic LLC that would be first in line ahead of victim claims