HOUSTON (KTRK) -- A former Harris County reserve deputy accused in a road rage shooting had a history of anger issues that raise serious questions about why he was even allowed to be in law enforcement in the first place.Eyewitness News obtained records from Kenneth Caplan's Harris County personnel files. Caplan will stand trial next month for the road rage shooting on the South Loop that left Lori Annab with a head injury. It happened in November 2014. Annab survived but still suffers seizures, says her attorney Steve Couch."What sticks out is this was not an accident, this was an incident waiting to happen," said Couch with pages and pages of documents laid out in front of him. "First, when I read it, it was chilling."Couch is suing Harris County and Caplan on behalf of Annab. At the time, Caplan was a Harris County Precinct 6 reserve deputy with a questionable personnel file."It's a huge question mark, in my opinion," Couch said.On his application for deputy constable, Caplan listed 21 jobs in 5 years, 12 of which, he disclosed, he was fired from.In the more than two years he worked for Precinct 6, Caplan logged five anger-related incidents or complaints in his file including two similar road rage ones. One involved a mother and her three children. The other involved an HPD officer in full uniform.But go back to 2010, Caplan was kicked out of his first law enforcement academy at College of the Mainland. Four months later, psychologist Carole Busick, who's accused of rubber-stamping officers' required psych exams and is now charged with tampering with evidence, signed off on Caplan attending another academy.Couch plans to add Busick to his lawsuit:"I engaged a psychologist that said she (Busick) fell short of the standard in testing and evaluating Caplan, if she tested him at all."To all of this, Caplan says it was the victim's fault."She was trying to run us into a wall. She got shot. The gun went off but it was an accident. It was self-defense," said Caplan, when reached by phone.He couldn't recall the complaints filed against him and says the long job history means nothing."When you have a job you don't care about, you really don't care if you get fired or not," Caplan said.In response to our request for comment, Robert Soard with the Harris County Attorney's Office sent this email:"We expect the county will be dismissed from the lawsuit. The county is not responsible for actions taken by an off-duty officer using his personal weapon."Busick's criminal attorney did not respond. Her civil attorney told Eyewitness News it would be premature for him to comment since she has not yet been added to the lawsuit.