Wrongful Death Lawsuit Filed on behalf of Family that Lost  Eight-Year Old Daughter in Camp Mystic Flooding 

November 14, 2025

Gilmer, Texas – Tefteller Law, PLLC has filed a wrongful death lawsuit in Travis County, Texas in  connection with the devastating floods that swept over Camp Mystic during the early morning hours of July  4, 2025 and drowned 8-year old Eloise “Lulu” Peck. 27 girls from Camp Mystic perished in those horrifying  floodwaters. The lawsuit is brought by the parents of Eloise Peck, Timothy and Melissa Peck, as well as the  Estate of Eloise “Lulu” Peck.” Representing the Peck family along with Tefteller Law are Ron Armstrong,  II of The Armstrong Firm, PLLC (Boerne, Texas) and Randy Howry of Howry Breen & Herman, LLP  (Austin, Texas).

“LuLu’s parents, Timothy and Melissa Peck, entrusted Camp Mystic with the obligation to protect and  safeguard her well-being,” Jarom Tefteller said. “Regrettably, the actions of Camp Mystic demonstrate that  it failed to appropriately act upon flood warnings and advisories issued by the State of Texas and the National  Weather Service in the days and hours leading up to the deadly incident. Camp Mystic knew it was housing  vulnerable children in what the Kerr County Judge has called ‘the most dangerousriver valley in the United  States’ and it knew the camp itself had a long history of seriousflood events,” according to Tefteller. “Despite  this knowledge, and the warnings of imminent danger, Camp Mystic had no real flood evacuation or  emergency plan in place. Rather, the camp instructed the counselors and campers to shelter in place in their  cabins as the flood waters kept rising,” stated Tefteller. “Then, when Camp Mystic finally decided to act, long after the National Weather Service issued its flood warning, Camp Mystic chose to waste valuable time

prioritizing the securement of camp equipment rather than evacuating children out of harm’s way,” per Jarom  Tefteller. “In doing so, Camp Mystic betrayed not only LuLu and her grief-stricken parents, but all of the  other 26 Camp Mystic victims and their families as well,” Jarom Tefteller noted.

As Jarom Tefteller explained, “the lawsuit we filed speaks for itself. Lulu did not lose her life on account of  momentary inadvertence. To the contrary, LuLu’s death stems from the Defendants’ display of conscious  indifference toward the safety and welfare of these girls despite knowing the camp’s demonstrated flood risk  and despite warnings that the flood was coming.”

By taking legal action, the Peck family seeks to hold Camp Mystic responsible for its actions – and thereby  send a strong message to Camp Mystic, along with others who are charged with the responsibility for  protecting the precious lives of young campers.

Tefteller Law focuses on cases involving serious personal injuries and wrongful deaths. Although the firm is  based in East Texas, it regularly represents people situated throughout the state. “We represent the ‘little guy’ in cases that are brought against large businesses and insurance companies who hurt or victimize others,” Jarom Tefteller said.

By holding bad actors accountable, Tefteller Law helps promote a culture of safety, the effects of which  benefit people from all walks of life. At Tefteller Law, it is our mission to help people who have been  traumatized by the actions of others – and we are passionate about the work we do.

CAUSE NO.

D-1-GN-25-009983

11/10/2025 1:08 PM Velva L. Price

District Clerk

Travis County

D-1-GN-25-009983 Ruben Tamez

ELOISE “LULU” PECK, DECEASED, by

and through TIMOTHY PECK,

Individually and on Behalf of the Estate of

ELOISE “LULU” PECK, DECEASED

MINOR, and MELISSA PECK,

Individually and on Behalf of the Estate of

ELOISE “LULU” PECK, DECEASED

MINOR.

IN THE DISTRICT COURT OF

Plaintiffs, §

1. § ________ JUDICIAL DISTRICT §

CAMP MYSTIC, LLC, MYSTIC CAMPS

FAMILY PARTNERSHIP, LTD., MYSTIC

CAMPS MANAGEMENT, LLC,

NATURAL FOUNTAINS PROPERTIES,

INC., WILLETTA EASTLAND.

Defendants. § TRAVIS COUNTY, TEXAS PLAINTIFFS’ ORIGINAL PETITION 

TO THE HONORABLE JUDGE OF SAID COURT:

COMES NOW Eloise “Lulu” Peck, Deceased, by and through Timothy Peck, Individually  and on Behalf of the Estate of Eloise “LuLu” Peck, Deceased Minor, and Melissa Peck,  Individually and on Behalf of the Estate of Eloise “LuLu” Peck, Deceased Minor, hereinafter  referred to individually by name, or collectively as Plaintiffs, and complains of Camp Mystic,  LLC, Mystic Camps Family Partnership, Ltd., Mystic Camps Management, LLC, Natural  Fountains Properties, Inc., and Willetta Eastland hereinafter referred to individually by name or  collectively as Defendants, and for cause of action would respectfully show unto the Court as  follows:

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DISCOVERY CONTROL PLAN 

1. Plaintiffs intend that discovery be conducted under LEVEL 3 OF RULE 190.4 of the TEXAS  RULES OF CIVIL PROCEDURE.

PARTIES 

2. Plaintiff, Eloise “Lulu” Peck, Deceased, was an eight-year-old minor child residing in  Dallas County, Texas. She is represented in this cause of action by and through her biological parents, Timothy and Melissa Peck.

Figure 1 Shown Above: Photograph of Decedent, Lulu (Eloise), taken prior to her death. 

3. Plaintiff, Timothy Peck, Individually, and on Behalf of the Estate of Eloise “Lulu” Peck,  Deceased Minor, is an individual residing in Dallas County, Texas.
4. Plaintiff, Melissa Peck, Individually, and on Behalf of the Estate of Eloise “Lulu” Peck,  Deceased Minor, is an individual residing in Dallas County, Texas.
5. Defendant, Camp Mystic, LLC, is a domestic limited liability company whose registered  office is located in Kerr County at 2689 Highway 39, Hunt, Texas 78024, and may be served with  process by serving the Texas Secretary of State at 1019 Brazos Street, Austin, Texas 78701, as its

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agent for service because defendant is required by the TEXAS BUSINESS ORGANIZATIONS CODE § 5.201 to maintain a registered agent in Texas but has failed to do so.

6. Defendant, Mystic Camps Family Partnership, Ltd., is a partnership whose registered office  is located in Travis County at 2404 Scenic Drive, Austin, Texas 78703, and may be served with  process by serving the Texas Secretary of State at 1019 Brazos Street, Austin, Texas 78701, as its  agent for service because defendant is required by the TEXAS BUSINESS ORGANIZATIONS CODE §

5.201 to maintain a registered agent in Texas but has failed to do so.

7. Defendant, Mystic Camps Management, LLC, is a domestic limited liability company  whose registered office is located in Travis County at 2404 Scenic Drive, Austin, Texas 78703,  and may be served with process by serving the Texas Secretary of State at 1019 Brazos Street,  Austin, Texas 78701, as its agent for service because defendant is required by the TEXAS BUSINESS  ORGANIZATIONS CODE § 5.201 to maintain a registered agent in Texas but has not done so.
8. Defendant, Natural Fountains Properties, Inc., is a Texas corporation whose registered  office is located in Kerr County at 2689 Highway 39, Hunt, Texas 78024, and may be served with  process by serving the Texas Secretary of State at 1019 Brazos Street, Austin, Texas 78701, as its  agent for service because defendant is required by the TEXAS BUSINESS ORGANIZATIONS CODE §

5.201 to maintain a registered agent in Texas but has failed to do so.

9. Defendant, Willetta Eastland, is an individual residing in Travis County, Texas and may  be served at her usual place of abode at 2404 Scenic Drive, Austin, Texas 78703, or wherever she  may be found.
10. In the event any parties are misnamed or not included herein, Plaintiffs contend this was  the result of a misidentification, misnomer, and/or such parties are or were alter egos of parties

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named herein. Alternatively, Plaintiffs contend any such “corporate veils” should be pierced to  hold such parties properly included in the interest of justice.

III. 

JURISDICTION & VENUE 

11. Plaintiffs allege and incorporate by reference all paragraphs referenced above for all  purposes, the same as if set forth herein verbatim.
12. This Court has jurisdiction over the Defendants because they are residents of and/or do  business in the State of Texas, and the amounts sought herein are within the jurisdictional limits  of this court.
13. Venue is proper in Travis County pursuant to TEX. CIV. PRAC. & REM.CODE § 15.002(a)(2) because Defendant Willetta Eastland is a natural person and resides in Travis County. According  to property records the property listed as her homestead exemption is located in Travis County. 14. Venue is proper in Travis County pursuant to TEX. CIV. PRAC. & REM.CODE § 15.002(a)(3)  because Defendant, Mystic Camps Family Partnership Ltd., is not a natural person and its principal  office is located in Travis County.
14. Additionally, Defendant, Mystic Camps Management, Ltd., is not a natural person and its  principal office is located in Travis County.
15. Pursuant to TEX. CIV. PRAC. & REM. CODE § 15.005, because Plaintiffs have established  proper venue against at least one Defendant and all claims in this lawsuit arise out of the same  transaction, occurrence, or series of transactions or occurrences, venue is proper in Travis County  against all Defendants.

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FACTS 

17. There is no greater trust than when a parent entrusts the care of their child to another.  Parents don’t send their children to summer camp to die. They are told and trust that the camp will  protect the child in their care and love the child as if it were their own. Camp Mystic (sometimes  hereinafter referred to as the “Camp”) and the people who ran it betrayed that trust. Camp Mystic’s  shocking betrayal of that trust caused the horrific, tragic and needless deaths of twenty-seven

innocent young girls, including Eloise “Lulu” Peck. This case seeks accountability for that betrayal  and to send a message to other camps – protect the kids in your care.

18. Camp Mystic is a summer camp for girls located in Kerr County, Texas, near the  Guadalupe River. Richard “Dick” Eastland and Willetta Eastland were the owners and executive  directors of Camp Mystic and became directly involved in operations of the Camp in 1974. The  Camp had been in the family since 1939, and Richard and Willetta Eastland were the third  generation to manage Camp Mystic. Since July 1932, Camp Mystic knew that cabins that housed  defenseless little girls sat in the bullseye of potential flood waters from the Guadalupe River and  never said a word about it to trusting parents. Since that date, Camp Mystic continued to play  Russian Roulette with the lives of the little girls, disregarding what Camp Mystic knew would be  an unspeakable tragedy when the flood hit those cabins.
19. On July 4, 2025, the unspeakable happened when at least twenty-seven campers and  counselors from Camp Mystic were killed after, predictably, the river rapidly rose, and floodwaters  swept through what Camp Mystic knew was a vulnerable and low-lying area of the Camp (hereinafter referred to as “the Incident”). Lulu Peck was among those horrifically swept away and  killed.

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Figure 2 Shown Above: River of Angels memorial wall for the victims of the Texas Hill Country flood.1 20. These terrifying last moments and then deaths were proximately caused by the negligence

and gross negligence of Defendants. Defendants knew that Camp facilities were located in a flood  zone, knew of the history of flash flooding in Kerr County, knew of repeated prior flood events at  the Camp, and received warnings from family members about flood risk.

1. Location in Flood Zone 
2. The Guadalupe-Blanco River Authority states that the Guadalupe River Basin is one of the  three most dangerous regions in the entire United States for flash floods. This is the same river  authority that Richard “Dick” Eastland was a board member of for several years. Camp Mystic  itself has been impacted by these flash floods on numerous prior occasions placing Defendants on  repeated notice of the serious and foreseeable risk of catastrophic flooding.
3. Camp Mystic’s facilities were situated within, and immediately adjacent to, a known  floodplain. Several of the cabins that were hit hardest in the July 2025 flood were in an area

1 Courtesy of World Central Kitchen, CC BY 4.0 <https://creativecommons.org/licenses/by/4.0>, via Wikimedia Commons. No changes made.

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identified by the Federal Emergency Management Agency (FEMA) as the highest-risk location for  flooding. FEMA has different types of floodplain designations; (1) the floodway, (2) the 1% (100- year) floodplain, (3) and the 0.2% (500-year) floodplain. The floodway is the channel of a river  and the adjacent land areas. In a flood event, the floodway fills with water and functions as part of  the waterway and is considered the most at- risk area. The 1% (100-year) floodplain has a 1%  chance of being flooded in any given year. Statistically, the 1% (100-year) floodplain event has  about a 26% chance of occurring during a 30-year period. It is a misconception that the 100-year  floodplain only floods once every hundred years. The 0.2% (500-year) floodplain event has a 0.2%  chance of occurring every single year. Statistically this means the 0.2% (500 year) floodplain event

has a 6% chance of occurring during a 30-year period. It is a misconception that the 0.2%  floodplain only floods once in 500 years.

23. In the mid-2010s, Camp Mystic undertook a major multi-million-dollar expansion of its  facilities, including the development of a new site known as “Cypress Lake.” Additional cabins, a  dining hall, recreation spaces, and other amenities were constructed in close proximity to the South  Fork Guadalupe River and Cypress Creek.
24. Even as the Camp built new cabins in a less-risky flood zone elsewhere on its property,  nothing was done to relocate the older buildings that were in the most danger, including the Bubble  Inn Cabin where little Lulu was housed. Some of the cabins were so close to the banks of the  Guadalupe River that they were considered part of the river’s floodway.

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Figure 3 Shown Above: FEMA Flood map of Camp Mystic Structures 

25. Camp Mystic owners knew that its facilities were designated as being in a flood zone by  FEMA but leveraged appeals to FEMA to have the “100-year floodplain” designation removed  from dozens of buildings. In 2013, after an appeal from Camp Mystic, FEMA amended the flood  map to remove fifteen of the Camp’s Guadalupe buildings from the hazard area. In 2019 and 2020,  FEMA removed fifteen more structures of the Camp’s Cypress Lake facility from the designation.

Although several structures were successfully removed, many of Camp Mystic’s buildings  remained listed on the flood designation. Camp Mystic’s requests to amend the FEMA map were an attempt to hide this safety risk from the public including the campers and their parents, avoid

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the requirement to carry flood insurance, lower the Camp’s insurance premiums, and pave the way  for expanding structures under less costly regulations. Defendants’ conduct reflects a conscious  decision to prioritize money and profits over the lives of children and transparency to parents. B. History of Flooding 

26. In July 1932, a massive and deadly flood swept through the area surrounding the Guadalupe  River, inundating Camp Mystic and its surrounding grounds. The floodwaters destroyed several  of Camp Mystic’s cabins, sweeping away the girls’ personal belongings. At the time, campers  were inside the mess hall eating lunch when the Camp director ordered them to evacuate to higher  ground behind the building. Moments after the girls evacuated, floodwaters surged through the  mess hall, reaching a depth of approximately one foot. It was later observed that had any of the  girls attempted to exit through the mess hall’s front doors, they likely would have been swept away down the slope toward the river. Although no campers lost their lives during this event, both local  authorities and Camp management acknowledged that the outcome could have been far more tragic  if the flooding had occurred at night. Several fatalities were reported in the surrounding area,  underscoring the deadly and well documented flood risk of the region.
27. In August 1978, severe flooding killed thirty-three people in Kerr County. At Camp  Mystic, the program director and staff hauled over 100 campers in station wagons to higher ground  in the dead of night. Several Camp Mystic employees reported their vehicles were swept away into  the Guadalupe River. Camp Mystic itself was severely damaged and was forced to suspend  activities for several days. Peak discharges at several streamflow stations exceeded the historic  peaks, and the flood magnitude and frequency data for the Guadalupe River indicated that this

flood had a recurrence interval in excess of 100 years, or a 1% chance of an event of that magnitude  occurring or being exceeded during any year.

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28. In the summer of 1984, flooding once again struck the Guadalupe River in the area  surrounding Camp Mystic, cutting off road access to and from the property. Rising floodwaters  overtook nearby roadways, stranding campers and staff on site. During this event, Willetta  Eastland experienced a medical emergency but was unable to be evacuated by ground and was  ultimately forced to be airlifted from Camp Mystic by helicopter. This incident further underscores  the Eastland’s long-standing knowledge of the recurrent and life-threatening flood risks posed by  the Guadalupe River and the surrounding terrain.
29. On July 16, 1987, just miles from Camp Mystic, a catastrophic flash flood swept through  the Pot O’ Gold Ranch, a Christian youth camp situated along the Guadalupe River. As severe  storms pummeled the area, Pot O’ Gold camp staff initiated a rushed night-time evacuation of the  children. In the chaos, a bus carrying campers was overtaken by rapidly rising floodwaters. The  powerful current swept the vehicle downstream, resulting in the deaths of ten young campers and  injuring many others. The event made national headlines and became one of the deadliest youth

camp flood disasters in Texas history, serving as a widely publicized warning about the extreme  and recurring flash-flood dangers along the Guadalupe River.

30. Additionally, in a previous legal dispute among Camp Mystic owners, minority  shareholders, who were also the Eastland’s family members, testified that certain parts of the  property were unsuitable for recreation because “it floods.”
31. All of these events eerily foreshadowed the deadly July 2025 flooding at Camp Mystic,  illustrating a clear and continuing pattern of foreseeable danger that went unaddressed. Despite  this clear history, Camp Mystic continued operating in the floodplain without implementing  adequate warning systems, evacuation infrastructure, or modernized flood-safety protocols to  protect the children in its care. The Defendants knew of the dangers of extreme flooding in the

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area, but despite this knowledge, Defendants were reckless and failed to act reasonably in response  to the rising water levels. These failures left campers and counselors trapped and unable to reach  higher ground resulting in severe injury and death.

1. Kerr County Warning System 
2. After the 1987 flood event, a Kerr County flood warning system was championed by then Sheriff, Rusty Hierholzer, and later by Richard “Dick” Eastland while he sat on the board for the  Upper Guadalupe River Authority. The Upper Guadalupe River Authority and others eventually  developed a computer-powered system of gauges along the river and its tributaries, but by 1999,  the system became outdated and was deemed unreliable. Richard “Dick” Eastland sat on the  Guadalupe river’s authority board and knew about the faultiness in the flood warning systems. He  knew that the government warning system had become outdated and inadequate and couldn’t be  relied on. He advocated to the county for a new warning system shortly before the July 2025 flood,  but did not take any steps to ensure that Camp Mystic had any type of warning system of its own

in place for its campers.

33. Despite the absence of any official flood warning from local authorities, camp officials at  Mo-Ranch, a nearby Presbyterian Camp, took swift and decisive action on their own initiative.  Recognizing the rising danger, they relocated approximately seventy children and adults who had  been staying overnight in a building near the river. Their proactive measures ensured the safety of  all campers and staff, sparing Mo-Ranch from the devastating tragedy that struck Camp Mystic.
34. Camp Mystic’s decision for its emergency flood plan to rely on outdated flood detection  technology, despite knowing it was obsolete and inadequate to address current flood risks,  constitutes gross negligence. By failing to implement modern safety measures or update its own

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flood protocols in light of known dangers, Camp Mystic recklessly endangered the lives of the  young girls entrusted to its care.

1. Camp Mystic’s Emergency Instructions 
2. Camp Mystic’s emergency preparedness was grossly inadequate and demonstrated a  reckless disregard for camper safety. Despite spending millions of dollars on new construction  projects, Camp Mystic had limited to no flood defense. The Camp’s written emergency  instructions to campers consisted of only a single page addressing all emergencies, with a mere  seven sentences devoted to flood procedures despite Camp Mystic’s location being in one of the  most flood-prone river corridors in Texas. By contrast, a neighboring Guadalupe River camp,  which was devastated by the 1987 Pot O’ Gold flood that killed ten campers, implemented detailed  and comprehensive emergency protocols. Yet, Camp Mystic chose not to update or modernize its  own procedures.
3. Camp Mystic’s seven-sentence emergency flood plan instructed children to await  instructions over a loudspeaker, even though the Camp knew that flash floods regularly caused  power failures. On July 4th, the power did fail and the loudspeaker didn’t work, and many teenage  counselors left in charge of the dormitories lost contact with adult supervisors. They were then  forced to make instant life and death decisions for themselves and their young campers on their  own. Having access to little to no emergency equipment, some of the older campers resorted to  shining flashlights from the cabins in an attempt to attract the attention of rescuers.
4. Additionally, despite the location of cabins knowingly being in a flood zone and the cabins  themselves flooding in prior years, Camp Mystic emergency instructions advised other staff and  campers to “stay in their cabins… All cabins are constructed on high, safe locations.”

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Figure 4 Shown Above: Excerpt from Camp Mystic Emergency Instructions 

38. Thankfully, on the night of the flood some teenage counselors disregarded these emergency  instructions. On the evening of July 3, 2025, into the early morning of July 4, 2025, the Giggle  Box cabin housed three teenage counselors and sixteen campers, eight to ten years old. Around 2  a.m. one of the counselors saw older campers from a different cabin running to higher ground with  blankets and pillows in hand. Despite this, the Giggle Box counselors were instructed by Camp

staff to stay put. In a desperate attempt to obey these instructions, the counselors had their campers  put their belongings on the highest bunks, put on their shoes and raincoats, and put trunks against  the cabin’s front door to block the water that was seeping in. One of the counselors used a  porchlight her father had given her to look out the window and was shocked to see a foot of water  outside. After seeing the dangerously high-water levels, she decided to disregard instructions from  Camp staff and evacuated the campers through a window in the cabin. She led them all to a dry  pavilion about thirty feet away. On this pavilion, they could hear screams for help from campers  in a nearby cabin, but the water had risen too high and there was nothing they could do. The  floodwater rose, and the girls were forced to leave the pavilion and climb up a steep rocky hill to  higher ground. They had to climb higher and higher throughout the night as the water continued

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to rise, until finally daylight broke and the water receded. The teenage counselors’ quick,  independent actions saved many lives.

39. This conscious decision to rely on a plan the Eastlands knew was outdated, unworkable,  and incapable of protecting children in a predictable flood event illustrates a blatant indifference  to the lives of the girls entrusted to their care.
40. The Flood 
41. On July 2, 2025, the Texas Division of Emergency Management (“TDEM”) publicly  announced the activation of state emergency response resources in anticipation of significant flood  threats expected over the upcoming holiday weekend. This activation was prompted by forecasts  from the National Weather Service (“NWS”), which predicted that heavy rainfall would begin on  July 2, 2025, and continue for several days, creating conditions likely to result in flash flooding  across the region. These official warnings, issued and widely shared two days before July 4, 2025,  placed Camp Mystic on clear notice of the imminent and substantial risk of flash flooding.
42. On July 3, 2025, at approximately 1:18 p.m., the National Weather Service (“NWS”) issued  a Flood Watch for the south-central Texas region, including Kerr County where Camp Mystic is  located. This Flood Watch expressly warned that conditions were favorable for flash flooding and  that the area faced an increased and specific risk of dangerous flood events. This official notice  should have placed the Defendants on heightened alert, particularly given their familiarity with the  region’s flood risk, and their actual knowledge of how rapidly the Guadalupe River can rise on the  Camp Mystic property based on prior flooding events.

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42. Despite these clear warnings and their awareness of the imminent danger, Defendants  failed to take reasonable precautions, including timely evacuation of campers and staff. As a result  of this failure, the Defendants allowed otherwise preventable injuries and deaths to occur when the  river’s waters overtook the campgrounds.
43. On July 4, 2025, the predictable happened. The sudden rise of the Guadalupe River  triggered additional flash flood warnings issued by the National Weather Service. Mystic  prevented campers and counselors from having mobile phones while at the Camp, leaving them  unable to see the emergency alerts themselves. Camp Mystic Directors, Richard “Dick” Eastland

and Willetta Eastland, received the flash flood warnings but failed to act in a timely manner.  Instead, on the night of the deadly flood, Richard Eastland spent time conferring with family  members, some of whom lived and worked at the Camp. It was reported that Richard Eastland  received the flash flood warning early at 1:14 a.m., but took until 2:30 a.m., over an hour later, to  begin evacuations of their campers.

44. Camp leaders eventually ordered an evacuation, but only after the floodwaters rose to such  an extreme level, that it was already too late. Even after finally acknowledging the perilousness of  the situation, the directors of Camp Mystic failed to request assistance from nearby emergency  responders for help. The rising floodwaters quickly outpaced the poorly planned evacuation  attempt.
45. When the river rose rapidly, the floodwater swept through the cabins. The Bubble Inn and  Twins cabins that housed the youngest children were hit the hardest. Lulu and the other children  inside experienced extreme fear and confusion as the floodwaters entered their sleeping areas. The  power failed, plunging the Camp into complete darkness as the sound of rushing water and thunder  filled the air.

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46. Chaos ensued as the dark water rose with alarming speed, forcing campers onto furniture  and into corners in a desperate attempt to escape the cold, rising flood. As the water continued to  rise, the children struggled to find safety. Several campers began piling their belongings on top of  their mattresses inside a staff cabin, before their door cracked in half and flood water poured in.  Some clung to one another as debris and currents tore through the cabins while others crawled  onto window ledges to get to cabin rooftops. In the Bubble Inn, the children’s attempts to escape  were thwarted by the overpowering force of the current. Nearby survivors described hearing  terrified screams and cries for help as the water overtook the cabins.
47. Some victims survived for a period of time, while trapped within the cabins, enduring  prolonged physical suffering, panic, and terror as the water level rose beyond their reach. Others  were pulled into the current and swept away into the darkness. These children faced the  unimaginable; a slow and terrifying awareness that they were being overcome by the flood, alone  in darkness, unable to reach safety. The conditions surrounding their deaths were marked by

absolute horror, physical pain, and emotional distress, all of which were foreseeable and  preventable had Defendants acted with even minimal care for their safety. 48. Shortly before her June 2025 Camp Mystic start date, Lulu began to fear thunderstorms,  darkness, and floods. In May of 2025, she sketched those fears in her notebook, a quiet reflection  of the worries that lingered in her gentle heart. That she left this world in the very way she feared  most is a truth too heavy to bear.

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Figure 5 Shown Above: Excerpt from Lulu’s Journal. May 2025.

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1. The Aftermath 
2. In the aftermath of the flood, the scene at Camp Mystic was one of devastation and chaos.  Parents who had entrusted their children to Camp Mystic’s care were forced to wait in anguish as  emergency crews underwent search and rescue efforts. The campgrounds became a disaster zone filled with debris, shattered buildings, and unbearable grief. Families, first responders, and the  surrounding community were left to grapple with the horror of a tragedy that was both predictable  and preventable.
3. In the days and weeks following the tragedy, the Defendants failed to take responsibility  for their actions and instead sought to protect their reputation and financial interests. Even now,  Defendants have refused to accept responsibility for the deaths of the young campers. Only a few  months after the horrific deaths of the young girls, Camp Mystic announced that it intends to  reopen for Summer 2026. The Defendants’ conduct after the flood further demonstrates their  conscious indifference to the safety of the children and the suffering of the families left behind.
4. Act of God 
5. Some may claim that the flood was an unpredictable act of God, but who could rightfully  claim that God willed the deaths of innocent Lulu and the other children? The flood that occurred  was in no way a rare godly phenomenon. Prior flooding had occurred in the Guadalupe River basin  for hundreds of years and Camp Mystic itself had experienced flooding repeatedly since its  formation. The Camp’s structures were in an area designated as a flood zone, because it was  predicted by experts that the area would in fact flood.
6. Camp Mo-Ranch had the foresight and emergency planning to preemptively evacuate  cabins prior to the July 4th flood. Even Camp Mystic’s own teenage counselors recognized the  imminent danger and disregarded staff directives, instead taking it upon themselves to lead

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campers to higher ground, actions that undoubtedly saved their lives. In previous years under  different leadership Camp Mystic experienced similar flood events and successfully evacuated  campers to safety. The death of Lulu and the other campers could have been prevented if those  responsible had taken even basic precautions to protect them. What happened at Camp Mystic was  not divine will at all—it was human failure.

53. At the time of the Incident, Defendants Mystic Camps Family Partnership, Ltd., Mystic  Camps Management, LLC, and Natural Fountains Properties, Inc. were entered into agreements and/or contracts with Defendant Camp Mystic, LLC and/or each other. Under the terms of the  agreements Defendant Camp Mystic, LLC was given authority and responsibility to manage,  supervise, and conduct all daily Camp activities.
54. Defendants Mystic Camps Family Partnership, Ltd., Mystic Camps Management, LLC,  and Natural Fountains Properties, Inc., in whole or part or jointly, as owners and/or controllers of  the land and facilities where the Camp was operated, owed a duty to ensure that the premises were  maintained in a reasonably safe condition, and that the property, including its location within a  flood-prone area, was adequately assessed, monitored, and equipped with protective infrastructure  and emergency warning systems.
55. By delegating day-to-day operations to Camp Mystic, LLC., but retaining ownership and  control over the premises, Defendants Mystic Camps Family Partnership, Ltd., Mystic Camps  Management, LLC, and Natural Fountains Properties, Inc. shared responsibility for providing a  safe environment, including ensuring that all agreements and operating procedures adequately  addressed known flood risks associated with the Guadalupe River and surrounding low-lying  areas.

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56. At the time of the Incident, Eloise “Lulu” Peck, Deceased Minor, was on the premises by  Defendants’ invitation for their mutual benefit. At no time were Timothy Peck, Melissa Peck, or  Lulu warned by Defendants of the dangerous condition posed by the location of the Camp facilities in/near a hazardous flood zone. Plaintiffs did not know of the condition and could not have  reasonably been expected to discover it prior to the Incident. Defendants, however, did know, or  reasonably should have known, of the unsafe condition in the exercise of ordinary care. Defendants’ failure to disclose the known flood danger was a silent misrepresentation and material  omission that induced the Pecks to entrust their child to Camp Mystic.
57. At the relevant periods of time, Defendants were negligent and/or had control of the  campgrounds and/or the Camp facilities and knew or should have known of the unsafe condition.  Nonetheless, Defendants failed to adequately warn Timothy Peck, Melissa Peck, or Eloise “Lulu”  Peck, Deceased Minor, of the dangerous condition and failed to make the campsite reasonably  safe. Instead, Defendants put profits over safety, and Plaintiffs along with Lulu, paid the ultimate  price.
58. As a result of the Incident, Plaintiffs suffered injuries and damages set forth in greater detail  below.
59. All claims in this lawsuit arise out of the same transaction, occurrence, or series of  transactions or occurrences.

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CAUSES OF ACTION 

60. Plaintiffs re-allege and incorporate by reference the preceding paragraphs for all purposes,  the same as if set forth herein verbatim.
61. NEGLIGENCE 
62. Defendants and their employees/agents were negligent in many ways, including failing to  act as persons/entities exercising ordinarily prudent care would under the same or similar  circumstances by choosing to violate rules, requirements, regulations, standards, and laws,  including but not limited to the following, set out in the alternative where necessary:

(a) Failing to assess and monitor flood risks;

(b) Failing to ensure Camp facilities were constructed in safe locations;

(c) Failing to provide timely warnings and initiate evacuations when hazardous  flooding was foreseeable or imminent;

(d) Failing to maintain escape routes and emergency infrastructure;

(e) Failing to implement a coordinated response plan to protect campers and staff;

(f) Failing to warn Plaintiffs and/or Eloise “Lulu” Peck, Deceased Minor, of the  dangerous condition of the Camp facilities being located in a flood zone;

(g) Failing to take proper preventive measures to mitigate known risks and dangers as  a reasonable person or entity would do under the same or similar circumstances;

(h) Taking improper safety measures;

(i) Negligently designing, constructing, installing, inspecting, maintaining, and/or  repairing Camp facilities;

(j) Negligently managing programs, setting policies, maintaining cabins, and/or  handling emergency plans;

(k) Failing to hire competent employees, agents, and/or contractors with proper  qualifications, expertise, and/or training to maintain a safe environment; and

(l) Negligently hiring, training, supervising, and/or retaining employees, agents,  and/or contractors; and

(m) Negligently implementing protective and evacuation procedures.

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62. Vicarious liability can be imposed on Defendants under the doctrine and/or theory of  nondelegable duty. When a duty is imposed by law on the basis of a concern for public safety,  such as that shown and outlined herein, the party bearing the duty cannot escape it by delegating  it to another, be it an employee, agent, and/or independent contractor.
63. The above acts and/or omissions were singularly and cumulatively the proximate cause of  the Incident and Plaintiffs’ injuries and damages therefrom.
64. GROSS NEGLIGENCE 
65. Defendants’ negligent conduct was more than momentary thoughtlessness or inadvertence.  Rather, the acts and/or omissions by Defendants constitute gross negligence as that term is defined  in TEX. CIV. PRAC. & REM. CODE § 41.001(11). Defendants’ conduct involved an extreme degree  of risk, considering the probability and magnitude of the potential harm to others, including  Plaintiffs and/or Eloise “Lulu” Peck, Deceased Minor. Defendants had actual, subjective  awareness of the risk involved but, nevertheless, proceeded with conscious indifference to the  rights, safety, and welfare of Plaintiffs and/or Eloise “Lulu” Peck., Deceased Minor, and others  similarly situated.
66. The above acts and/or omissions were singularly and cumulatively the proximate cause of  the Incident and Plaintiffs’ injuries and damages therefrom. Thus, Plaintiffs sue for exemplary  damages.

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1. PREMISES LIABILITY 
2. Plaintiffs including Eloise “Lulu” Peck, Deceased Minor, were invitees of Defendants to  the premises at issue.
3. Defendants were owners, occupiers, possessors, and/or managers of the premises at issue. 68. A condition or conditions of the premises posed an unreasonable risk of harm to Eloise  “Lulu” Peck, Deceased Minor, and others.
4. Defendants knew or reasonably should have known of the danger that existed at the time  of the Incident.
5. Defendants breached their duty of ordinary care by failing to warn Plaintiffs and/or and  Eloise “Lulu” Peck, Deceased Minor, of the dangerous condition(s) and by failing to make the  condition(s) reasonably safe.
6. Defendants’ failure to exercise reasonable care to eliminate or reduce the risks was a  proximate cause of the Incident and Plaintiffs’ injuries and damages therefrom. D. JOINT ENTERPRISE 
7. Defendants operated in a joint enterprise. Defendants had an agreement to operate, express  or implied; a common purpose to operate and be carried out by the enterprise; a community of  pecuniary interest in that common purpose; and an equal right to a voice in the direction of the  enterprise, which gave them equal right to control. Defendants shared control of safety measures  and shared profits from the operation. Thus, Defendants are jointly and severally liable for the  Incident and Plaintiffs’ injuries and damages therefrom.

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1. ASSISTING & ENCOURAGING 
2. Pleading further in the alternative if necessary, Defendants assisted and encouraged each  other in committing one or more tortious acts and/or omissions as outlined above, and the  assistance and encouragement was a substantial factor in causing the harm suffered by Plaintiffs.  Defendants had a duty to Plaintiffs and breached that duty in the ways outlined above.  Furthermore, Defendants assisted each other in the breach of the duties. Defendants knew what  they were doing was a violation of the law and the standard of care. Defendants had knowledge  that their actions and conduct constituted a tort, and they intended to assist each other and gave  each other assistance and encouragement that was a substantial factor in bringing about the tort.  Thus, Defendants are considered tortfeasors and are jointly and severally liable for their tortious  conduct resulting in the Incident and Plaintiffs’ injuries and damages therefrom.
3. ASSISTING & PARTICIPATING 
4. Pleading further in the alternative if necessary, Defendants assisted and participated with  each other in causing a particular result, making Defendants responsible for the result of the united  effort because the acts and/or omissions were a breach of duty and substantial factor in causing the  result. Defendants’ activity accomplished a tortious result. Defendants provided each other  substantial assistance in accomplishing that result. Each Defendant breached a duty to Plaintiffs

and/or Eloise “Lulu” Peck, Deceased Minor, as outlined above. Each Defendant’s participation  was a substantial factor in causing the tort resulting in the injuries and damages suffered by  Plaintiffs. Thus, Defendants are considered tortfeasors and are jointly and severally liable for their  tortious conduct resulting in the Incident and Plaintiffs’ injuries and damages therefrom.

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1. CONCERT OF ACTION 
2. Pleading further in the alternative if necessary, Defendants participated in an action that  was planned, arranged, and agreed upon by each of them to further some scheme or cause, making  all involved liable for the actions of one another. Defendants were negligent. Thus, Defendants  are considered tortfeasors and are jointly and severally liable for their tortious conduct resulting in  the Incident and Plaintiffs’ injuries and damages therefrom.
3. RATIFICATION 
4. Pleading further in the alternative if necessary, Defendants are liable for the negligent acts  and/or omissions of other Defendants and their agents under the doctrine of ratification.  Defendants approved and accepted the location of the Camp facilities, and ratified each of their  negligent conduct by accepting, approving, and validating such Camp facility locations with full  knowledge of its defects; by accepting its benefits and refusing and failing to repudiate such  negligent conduct; and by failing to correct and make safe such facilities even after they acquired  actual, subjective awareness of the risks of severe injury or death arising out of the facilities  locations. Thus, Defendants are considered tortfeasors and are jointly and severally liable for their  tortious conduct resulting in the Incident and Plaintiffs’ injuries and damages therefrom.
5. RESPONDEAT SUPERIOR 
6. At all times material hereto, all agents, servants and/or employees of Defendants were  acting within the course and scope of employment and/or official duties. Furthermore, at all times  material hereto, all agents, servants, and/or employees of Defendants were acting in furtherance of  their office and/or employment and/or were the agents and/or servants of the Defendants.  Defendants are therefore liable for the acts and/or omissions of their agents, servants, and/or  employees under the doctrine of respondeat superior.

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DAMAGES 

78. As a direct and proximate result of the Incident and Defendants’ negligence, recklessness, and grossly negligent conduct, Plaintiffs suffered from the death of Lulu Peck, and have sustained  resulting damages.
79. Lulu was one of the most spirited and loving children one could ever meet. She was a bright  light in this world, radiating warmth, curiosity, and joy. Lulu approached life with a sense of  wonder that compelled her to meet, pet, and name every animal that crossed her path. To Lulu,  every creature deserved a name, a story, and a place in her world. Lulu possessed a precociously  sweet and joyful demeanor. She delighted in every relationship and connection, embracing each  person and animal for who they were. Her boundless affection and genuine kindness drew others  to her, leaving an indelible mark on everyone fortunate enough to know her. Lulu loved wholly,  purely, and without hesitation; a rare and beautiful soul whose absence has left an immeasurable  void in the lives of those who loved her most.

Figure 6 Shown Above: Photograph of Lulu taken prior to the incident

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80. Plaintiffs hereby make claims for all past and future damages recoverable under Texas law  and pursuant to the WRONGFUL DEATH ACT and Survival Statute, Chapter 71 of the TEXAS CIVIL  PRACTICE & REMEDIES CODE, in an amount within the jurisdictional limits of the Court and which  the jury deems just and fair, to include, but not limited to, the damages set forth in greater detail  below.
81. Plaintiffs Timothy and Melissa Peck, Individually and on Behalf of the Estate of Eloise  “Lulu” Peck, Deceased Minor, seek wrongful death damages, including but not limited to: a. mental anguish sustained in the past;
82. mental anguish that, in reasonable probability, will be sustained in the future; c. pecuniary loss sustained in the past;
83. pecuniary loss that, in reasonable probability, will be sustained in the future; e. loss of companionship and society sustained in the past;
84. loss of companionship and society that, in reasonable probability, will be sustained  in the future;
85. loss of household services sustained in the past;
86. loss of household services that, in reasonable probability, will be sustained in the  future; and
87. exemplary damages.
88. Plaintiffs Timothy and Melissa Peck, Individually and on Behalf of the Estate of Eloise  “Lulu” Peck, Deceased Minor, seek survival damages, including but not limited to: a. physical pain sustained by Eloise “Lulu” Peck, in the past;
89. mental anguish sustained by Eloise “Lulu” Peck, in the past;
90. funeral and burial expenses;
91. loss of household services sustained in the past;
92. loss of household services that, in reasonable probability, will be sustained in the  future; and
93. exemplary damages.

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83. As described above, Defendants have proximately caused the Incident and Plaintiffs’ damages well in excess of the minimum jurisdictional limits of this Court, and Plaintiffs request the following damages:
84. mental anguish sustained in the past;
85. mental anguish that, in reasonable probability, will be sustained in the future; iii. pecuniary loss sustained in the past;
86. pecuniary loss that, in reasonable probability, will be sustained in the future; v. loss of companionship and society sustained in the past;
87. loss of companionship and society that, in reasonable probability, will be sustained  in the future;

vii. loss of household services sustained in the past;

viii. loss of household services that, in reasonable probability, will be sustained in the  future;

1. physical pain sustained by Eloise “Lulu” Peck, Deceased Minor, in the past; x. mental anguish sustained by Eloise “Lulu” Peck, Deceased Minor, in the past; xi. funeral and burial expenses;

xii. punitive and exemplary damages;

xiii. pre-judgment interest;

xiv. post-judgment interest; and

1. all other damages available to Plaintiffs under Texas law.

VII. 

RULE 47 NOTICE 

84. The Court through Rule 47 of the TEXAS RULES OF CIVIL PROCEDURE requires those  seeking affirmative relief to plead the amount of damages sought, despite the fact that Plaintiffs want the jury to decide the amount of the verdict. Therefore, only because the Court requires this  statement, Plaintiffs at this time seek monetary relief in excess of ONE MILLION DOLLARS  ($1,000,000.00), but Plaintiffs intend to leave the determination of the verdict amount to the jury.

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VIII. 

PRESERVATION OF EVIDENCE 

85. Plaintiffs hereby demand that Defendants preserve and maintain all evidence pertaining to  any claim or defense related to the Incident made the basis of this lawsuit, or the damages resulting  therefrom. These requests and demands include but are not limited to preserving and maintaining  all parts of the site of the Incident, the campsite, signs, statements, photographs, video footage,  audio, surveillance, security footage, information, business records, incident reports, equipment  (e.g., safety equipment, including weather monitoring equipment, etc.), invoices, checks,  correspondence, facsimile, email, voice-mail, text messages and any evidence whatsoever  involving or relating to the Incident in question. These requests and demands also include  preservation of the scene of the Incident. Failure to preserve and maintain such evidence will  constitute spoliation of evidence, and Plaintiffs will seek appropriate relief from the Court for any  such spoliation.

NOTICE OF SELF-AUTHENTICATION 

86. Pursuant to Rule 193.7 of the TEXAS RULES OF CIVIL PROCEDURE, Plaintiffs give notice of  intent to use documents produced by any party hereto in any pretrial proceeding and at trial against  the producing party.

DEMAND FOR JURY TRIAL 

87. Plaintiffs hereby demand a jury trial in this matter. Plaintiffs acknowledge payment on this  date of the required jury fee.

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PRAYER 

WHEREFORE, PREMISES CONSIDERED, Plaintiffs request that Defendants be cited to  appear and answer, and on final trial hereafter, the Plaintiffs have judgment against Defendants in  an amount within the jurisdictional limits of this Court, together with all pre-judgment and post judgment interest as allowed by law, costs of Court, and for such other and further relief to which  Plaintiffs may be justly entitled by law and equity, including, but not limited to: a. Actual damages within the jurisdictional limits of this Court;

1. Exemplary damages;
2. Pre-judgment and post-judgment interest at the maximum rates allowed by law; d. Costs of court; and
3. Such other and further relief of any kind to which Plaintiff may show themselves justly entitled.

Dated: November 10, 2025 Respectfully submitted,

HOWRY BREEN & HERMAN, L.L.P.

Randy R. Howry / SBN: 10121690

rhowry@howrybreen.com

Sean E. Breen / SBN: 00783715

sbreen@howrybreen.com

1900 Pearl Street

Austin, Texas 78705

512.474.7300 / 512.474.8557 (f)

TEFTELLER LAW, PLLC

/s/ Jarom Tefteller, with permission 

Jarom Tefteller / SBN: 24060705

jt@tlaw-pllc.com

403 W. Tyler Street

Gilmer, Texas 75644

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903.843.5678 / 903.680.2310 (f)

– and –

THE ARMSTRONG FIRM, PLLC

/s/ Ron Armstrong, II, with permission 

Ron Armstrong, II / SBN: 24059394

rwaii@tafpllc.com

109 Yoalana St., Suite 210

Boerne, Texas 78006

210.277.0542 / 210.277.0548 (f)

Attorneys for Plaintiffs Timothy and Melissa Peck,  Individually and on Behalf of the Estate of Eloise  “Lulu” Peck, Deceased Minor

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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.

Caitlin Baker on behalf of Randy Howry

Bar No. 10121690

cbaker@howrybreen.com

Envelope ID: 107864057

Filing Code Description: Petition

Filing Description: PLAINTIFF’S ORIGINAL PETITION Status as of 11/12/2025 12:42 PM CST

Case Contacts

Name 

Caitlin Baker

Randy Howry

Sean EBreen

Roni Wilson

Jarom Tefteller Ronald Armstrong

BarNumber 

24060705 24059394

Email 

cbaker@howrybreen.com rhowry@howrybreen.com sbreen@howrybreen.com rwilson@howrybreen.com jt@tlaw-pllc.com

rwaii@tafpllc.com

TimestampSubmitted 11/10/2025 1:08:58 PM 11/10/2025 1:08:58 PM 11/10/2025 1:08:58 PM 11/10/2025 1:08:58 PM 11/10/2025 1:08:58 PM 11/10/2025 1:08:58 PM

Status SENT SENT SENT SENT SENT SENT