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Carolyn Barnes v. Richard Coons
03-15-00700-CV
| Tex. App. | Dec 28, 2015
|
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Case Information

*1 Carolyn Barnes, J.D., Ph.D.

Leander,TX 78641 Barnes.legalguidance@gmail.com (281)467-8681 Ms. Liz Talerico, Deputy Clerk

Third Court of Appeals

PO Box 12547

Austin, Texas 78711

RE: Cause No. D-1-GN-15-000877 on Appeal from Travis County

Carolyn Barnes, et al v. Texas Attorney General, et al Numerous appeals arising out of various orders entered over past six months, including the following that are already pending in this court: Appellate Case No. 03-15-00593-CV; Appellate Case No. 03-15-00605-CV; Appellate Case No. 03-15-00630-CV; Appellate Case No. 03-15-00700-CV; Appellate Case No. 03-15-00719-CV; Appellate Case No. 03-15-00720-CV; All other Notices of Appeals filed in CAUSE NO. D-l-GN-15-00877 REJECTED AND RETURNED, even those filed prior to November 4,2015.

Dear Ms. Talerico:

I am in receipt of your letter dated December 11,2015. As per your request, I am enclosing the letters sent to the Clerk and the Court Reporter requesting the submission of one MASTER CLERK'S RECORD and one MASTER COURT REPORTER'S RECORD.

These MASTER records will be filed for purposes of the above captioned pending appeals and for use in all these appeals and the future appeals arising out ofthis case. {'REiCElVFn

OK Z8 2Q1S *2 If you require anything further from me, please advise.

Thank you for your time and attention in this matter.

Enclosures

Leander,TX 78641 Trish Winkler

Civil Appeals Clerk II

Travis County District Clerk's Office

P.O. Box 679003

Austin, Texas 78767-9003

RE: ONE MASTER CLERK'S RECORD FOR APPEAL

Cause No. D-l-GN-15-000877

Carolyn Barnes, et al v. Texas Attorney General, et al COA NO. 03-15-00719-CV CarolynBarnesv. Dusty Humes; COA NO. 03-15-00700-CV Carolyn Barnes v. Richard Coons; COA NO. 03-15-00720-CV Carolyn Barnes v. Burt Carnes; COA NO. 03-15-00593-CV Carolyn Barnesv. Guilford Jones, John Delaney, Elizabeth Cunningham, and Marty Griffith;
COA NO. 03-15-00605 Carolyn Barnesv. Texas Departmentof State Health Services and Texas Attorney General;
COA NO. 03-15-00630 Carolyn Barnes v. Third Court of Appeals andTexas Supreme Court;

ETC. and all other appeals to follow

DearTrisha:

The Third Court of Appeals senta letter dated December 11,2015 in whichthey granted my alternative requested relief to allow the filing of one MASTER CLERK'S RECORD on appeal for all of the various appealsthat have evolved and continue to flow out ofthe above entitled cause.

I have not ever done a MASTER CLERK'S RECORD, but hopefully mis will you're yourjob much easierand save everyonea great dealoftime andexpense.

I am not quite surehow to designate it because the vase majority ofthe appeals have not beenassigned casenumbersby the Third Court ofAppealsas ofyet

I have listed the appeals that are currently pending in the Third Court of Appeals that have been docketed and given case numbers.

RECEIVED DEC 2 8 2015 .NKOCOWOFAPPEAIS *4 Please make up a MASTER CLERK'S RECORD for filing in the Third Court of Appeals. I would like to include everything that has been filed as of the time you compilethe MASTER CLERK'S RECORD. I havejust filed two more nonces ofappeal and would appreciate your including mem as well. I tried to get everything filed so that you only have to do mis once. However, mere are still other hearings set for next year, but we will just have to file a supplementlaterto pick up the new pleadings, orders,etc.

Please let me know if there is anything I need to file or do to assist you in this matter or make your job any easier. I really appreciate all mat you have done to assist me in this arduous task.

This record is needed for appeal in the above entitled cause and request is made that you file it in the Third Court of Appeals at your earliest convenience.

We previously filed the Affidavit ofInability to Pay Costs on Appeal. Thank you for your time and attention in mis matter. If you have any problems, concerns, or questions, please contact me.

BarnesJegakjuidance@gmail.com

Leander,TX 78641 Dora Canizales

419th District Court

P.O.Box 1748

Austin, TX 78767

RE: ONE MASTER RECORDER'S RECORD for appeal in

Cause No. D-l-GN-15-000877

Carolyn Barnes, et al v. Texas Attorney General, et al Dear Dora:

Please note that on December 11, 2015, the Third Court of Appeals granted my alternative motion to file a MASTER RECORDER'S RECORD for purposes ofappeal in allofthe appellate casesarising out ofthe abovecaptioned cause.

This record is needed for appeal in all the cases on appeal that arose out of or that will ariseout ofthe above captioned cause. Currently,the pending appellatecases are:

COA NO. 03-15-00719-CV Carolyn Barnes v. Dusty Humes; COA NO. 03-15-00700-CV Carolyn Barnes v. Richard Coons; COA NO. 03-15-00720-CV Carolyn Barnes v. Burt Carnes; COA NO. 03-15-00593-CV CarolynBarnes v. Guilford Jones, John Delaney, Elizabeth Cunningham, and Marty Griffith; COA NO. 03-15-00605 Carolyn Barnes v. Texas Department of State Health Services and Texas Attorney General;
COA NO. 03-15-00630 Carolyn Barnes v. Third Court of Appeals and Texas Supreme Court;

This is a formal request that you prepare the Court Reporter's Record for filing in the above cases on appeal. Request is made that you file it in the Third Court of Appeals as soon as possible.

This MASTER CLERK'S RECORD wfll serve as the record in all cases appeal in this cause.

You were previously served with the Affidavit of Inability to Pay Costs on Appeal.

Thank you for your time and attention in this matter. If you have any problems, concerns, or questions, please contact me.

Leander.TX 78641 Dora Canizales

419th District Court

P.O. Box 1748

Austin, TX 78767

RE: ONE MASTER RECORDER'S RECORD for appeal in

Cause No. D-l-GN-15-000877

Carolyn Barnes, et al v. Texas Attorney General,et al COA NO. 03-15-00719-CV Carolyn Barnes v. Dusty Humes; COA NO. 03-15-00700-CV Carolyn Barnes v. Richard Coons; COA NO. 03-15-00720-CV Carolyn Barnes v. Burt Carnes; COA NO. 03-15-00593-CV Carolyn Barnesv. Guilford Jones, John DeJaney, Elizabeth Cunningham, and Marty Griffith;
COA NO. 03-15-00605 Carolyn Barnesv. Texas Department ofState Health Services and Texas Attorney General;
COA NO. 03-15-00630 Carolyn Barnes v. Third Court of Appeals and Texas Supreme Court;

And all subsequently docketed appeals arising out of D-l-GN-15-00877 Dear Dora:

As an addendum for clarification to my letter dated December 18, 2015,1 am not real sure of all the dates ofthe hearings, but here are the dates that I am fairly certain we had hearings in mis case:

July 2,2015

July 16,2015

July 28,2015

August 5,2015

August 18,2015

September 9,2015

September 21,2015

September 22,2015

October 6,2015

October 20,2015

November 10,2015

This was a rapid fire blitzkrieg summary dismissal of all claims by ambush—without any discovery or other substantive due process—in order to deprive me of my forever inviolate right to a jury trial or any reasonable or meaningful avenue to vindicate the violation ofconstitutionally protected rights.

This is a formal request that you prepare the Master Court Reporter's Record for filing in the Third Court of Appeals as soon as possible.

This MASTER CLERK'S RECORD will serve as the record in aU cases appealed in this cause.

You were previously served with the Affidavit ofInability to Pay Costs on Appeal.

Thank you for your time and attention in this matter. If you have any problems, concerns, or questions, please contact me.

£&Mvt[y

Carolyn Barnes

Leander.TX 78641 Trish Winkler

Civil Appeals Clerk n

Travis County District Clerk's Office

P.O. Box 679003

Austin, Texas 78767-9003

RE: COA No. 03-15-642-CV Dennis Tumlinson v. Carolyn Barnes

Cause No. D-l-GN-15-000877

Carolyn Barnes v. Texas Attorney General, et al Dear Trish:

I am in receipt of the record you prepared for the defendant and filed with the Third Court of Appeals in the above cause. There were several matters left out of the record designation that arenecessary for this appeal. Would you please prepare a supplemental Clerk's Record as soon as possible and file it with the Third Court of Appeals. Please include the following documents in the supplemental record:

First Amended Answer filed July 8,2015;

Plaintiffs Motion to Enter a Default Judgment against DENNIS TUMLINSON filed on July 9,2015. (There were severalmotions to enter default judgment filed on that date, but I only need the one concerning DENNIS TUMLINSON);

Noticed ofUnequal TreatmentUnder the Law filed on July 9,2015;

Motion to Remove Complex Case from Central Docket filed July 9,2015; Plaintiff's Motion for Continuance filed on July 10,2015.

Plaintiff's Supplemental Objections, Motion to Strike, and Motion to Quash Travis County filed July 15,2015;

Plaintiffs Supplemental Notice ofUnequalTreatment filed on July 20,2015; Sworn Statement Under Declarationof Penalty of Perjury filed on July 27,2015; *10 Statement Under Declaration ofPenalty ofPerjury filed on August 12,2015; Plaintiffs Briefin Support ofResponse to Motion to Dismiss filed August 14/18,2015; Defendant's Motion to Stay Discovery filed August 19,2015;

ContinuingObjections filed on August 20,2015;

Plaintiffs Third Supplemental and (Continuing Notice of Unequal Treatment filed on August 24,2015;

Plaintiffs Objections, Motion to Strike, Motionto Quashand Responseto TravisCounty Late-filedSupplement to Third Motion to Dismiss filed September 8,2015; Briefon Constitutional Rights filed on September 8,2015;

All of these documents are needed for appeal in the above entitled cause and request is made that you file the Clerk's Record in the Third Court of Appeals at your earliest convenience.

We previously filed the Affidavit ofInabilityto PayCosts on Appeal

If you require anytiiing further from me, ifthere are any deficiencies or defects in tiiese documents or this filing procedure, pleaseadvise immediately.

Thank you for your time and attention in this matter. If you have any problems, concerns, or questions, please contact me.

Ofifl/W-

Carolyn Barnes

Barnes.legalguidance@gmail.com

*11 M m [1]

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Case Details

Case Name: Carolyn Barnes v. Richard Coons
Court Name: Court of Appeals of Texas
Date Published: Dec 28, 2015
Docket Number: 03-15-00700-CV
Court Abbreviation: Tex. App.
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