Jimmy Diaz v. Robert T. Rice and Savannah Robinson
14-14-00622-CV
| Tex. App. | Jul 27, 2015
Case Information

*1 The Fourteenth Court of Appellant, Texas SOl Fannin Suite 245 Houston, Texas 77002 JUL 272015 CHRISTOPHER A. PRINE CLERK

Jimmy biraz, Plaintiff Appellant VS. Savanagh Linda Robinson Hall Robert Thomas Rice,AND Addendum third Party Kennenth, Erazia Little Ken, Inc.wholey No.14-14-00511-CV cunekd Corporation Seaford Inc. Erazia enkepties.Inc. No.14-14-00622-CV. Befendants-Appellees

Amended notice of Appell and interlocutory Appell, Authorized by Statue,

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Amended Notice of Appell and Interlectuory Appell authorized by the Statue, is hereby given that SANnnah Linda Robinson; ROBERT thomns Rice; and addendum third PARty Kenneth EARZLA Little Ken. Inc. Wholey ounered Depration EARZLA Enterpries, Inc. Seated Company boat Vesse Inc. through and by his ATONNEY, etal; PARthes taking the Amended Notice of Appell interlocutory Appell authorized by Statue; Plaintiff mK, Dinz. in the above named Case, is hereby Appeded to the fourteenth Louxs of Appell at 301 Fannin Sile 245, HOUSTON, JEXAS 11002.

From: Base BAis prejudicesnot provided Impartid heating or adequate due process of the law and equal protection of law or opportunity to be heared and access to Court proceedings from denial. I. Defendant Robert thomns Rice he Sued Plaintiff on Febuxey 31, 2012. 2.

*3 Dellendant rice filled Petition declaratory Judgment seek relief within 14 days and Panel level 3 discovey and disclosuwe in the District Guet of Brazoria County, teens 23 rd Judicial District Hon.Judge Peesinding EDWIN DENMAN over the Petition for declaratory Judgment Judge thillies to Comply with law or teX. Liv. Proc. state doeketing, sehedule orders, (to months stillcunning) No. 61021: 2. Plaintiff me, disz he did not received Petition for declaratory Judgment on aee about march 4,202 he filed his response to Plaintiff Petition for declaratory Judgment cause No. 61021 dePendant rice Committed Pexjury he stated that he does not keep records of case expense, then, he stated he just received invocice of case expenses (s) Hon.Judge Peesinding EDWIN DENMAN, failure to Comply with law state teX. Liv. Proc. doeketing, sehedule ordises. ruling abused of its discretion.

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  1. A Budieid Dist. Budge as How. Edwin DENmAN has duties to comply with the law of state of teens state teE Rules of Liv. Proc. Competent and Diligent Responsibility Pursuant teE. VeRwons Ann. ANNOTATED Livi Practice and Remedies Code Canon 3 (2)cas a Budge who received information Clearly establishing that a lawyer has committed a Violation of teens Disclinacy rules of Professional misconduct Should take Appropriate Action Livi Action an Attorney has engaged in Conduct involving disnosesty, tPauL or medicAld Fraud, deoit, or mispresentation engaged in Conduct Constitutioning obstruction of Justice Consumer Protection Act teens Deactive Trade. Practice Act,
  2. on are about July 2013 Plaintiff me, Ditz. he filled his suite under teens Deactive Trade Practice Act Atheton was sevved upon Defendants they filled gespose, Cause No. 735431 Plaintiff me, Ditz filled motion for Change of venue, motion to set trial date, motion for Bench wrerant.

*5 and motion for appointment of Counsel beferdant Savannah Robinson filled Countiee Chins, Crosschains Pleading Affirmative defense. 5. The Fleck Rhound BArchak, Brazokia County, Dusit. Courts, docketing, in the District Cover 412th, Judicial Disדי, of Brazokia County, Texas cause No. 135431 Pending before...The How, Edwin deAmm, Judge Presiading over Suite Chins. 6. on July 1, 2013 the defendants filed motion to Consoloidate Cause No. 61021, was Pending 23 rd Judicial DisTricr Cover, of Brazokia County, Texas, Cause No. 135431 was moved from 412th Judicial DisTricr Cover into 23 rd Judicial DisTricr Cover Brazokia County DisTricr Fleck, Rhounda BArchak Refuse to Provide Judge Presiading over these suit of Civil Actions. 7. Plaintiff he was teanslared Jester 3 for physical therapy

*6 due to serious medical needs meet the imminent danagement exception Physical bodily injuries danages to his shoulder notary cup damages due to his livil rights being deprived in this livil Acton need second Stoso SEEEREY. 8. on July 10, 2013 Maintiff filed his response to defendants motion To Consolidate Maintiff Re filed misjoinder and wortoinder separate Consoliate Pleading's; 4. on seplember 25, 2013, defendants move for motion for summary Judgment, they Solve off discovery disclosures in Violation Clegely established Pursuant some terms Rules of Livif Procedure Under Rule 166 (2016), they did not comply with rule or Procedure Principles, in west Chester tike, ins. Co. U, Alvares 576 SiW, 2d at 971,972 (TEE, App 1892)

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  1. On November 4, 2013 Plaintiff mr Dira he filled his response to Defendants motion for Summary Judgment me Dira filled objection ofPorsing memorandum Attachies his Alludavits in support as Sufficient evidence proof great weight of pro peedance of evip guinde issue of dispule Judge Pesinding Edwin Denman failed, to comply with law sinte teens Rules of Civil Procedure VIC. A Court Code 81,001 Canon 3 Preforming the duties of Judicial office impertially and diligentay Abused of its disceetion; II. On are about 700ft 30 mnech 8,201 Plaintiff he filed motion to motifly se hedule order How. Judge Presinding failed to comply with law sinte teens Rules of Civil Procedure failure to motifly sedequle order, this Abused of disceetion TEX Const Aft V 81 pre United sirtes Const. Amend, 14th and 3th Amendment Righls:

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  1. On April 13, 2015 Plaintiff MR. Dine he filed his motion to leave the cluer to allow him addendum third Parily defendant Kenneth Garcia Little Ken, Ine. Wholen owned Deproidion Geraia enter pries InE, seabod, Inc, Felt of vessel A. Al, Cause No. 135431
  2. Plaintiff's mR. Dirz Complaint Sued addendum third Part Kenneth Geraia ALU throug by his Attorney Volition Breach written Reptlement Contract Consumex Protection Act Deeetive Trade Practice Act Tens Rule of Civil Procedure form 41 and Rule 3810039, and 40 was lwce, Seved upon Bercokinfunty, District Chek, RIOUNDA DAKCHAK, JereyDette 23ddIudicial DistrictCenK1 Cause No. 735431, and, 14.

*9 on April 13, 2015 Plaintiff me. Dinz he filled addendum third party Summons to be sevved upon defendant Kenneth Beaza Little Ken Jne. etal, to answer to Complaint s summons within 30 days After service sevved to Brazoria Cunity, District Clerks Jerey Deere, and Rhounda Barch ak. Certificate of service each Readings.

H, on april 13,2015 Plaintiff me.Dinz, he also filled to Brazoria Cunity, District Rhounda Barchak Process Request formainstrument Citation to be sevved by sheriff upon the addendum third party defendant Kenneth Beaza sak Little Ken Jne. etal, duly sevved upon the Brazoria Cunity, District Clerks Rhounda Barchak, Jerey Deere and upon the defendants Attorney in Charge, Savannah Robinson Linda.

  1. Plaintiff me. Dinz, he filled his self authenticating Prcduction of document as Proof that defendants engage in obstruction of Justice.

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  1. The Brgeoria Country District Cours deep Judicial Seating and District Heeks of Brgeoria Country Years, Abused it Discheckon failures to comply with the Imw of United States Constitutiona! or state teXas rules of civil PreceJure deligence. Hing docking each and every Heading and Issue the Atation upon Defendant Kenneth Erazia, Hal by Shertf Rulle 34 duty of Heeks.
  2. The Hon. EdwinDONMAN Jydoe 23 rd Judicial District Cours of Brgeoria Country, TeAs and 412th Judiciat District Cours of Brgeoria Country, 71 Resinding over these Cains has Abused his DisCRe in DIOIation teIns VEAKUS,ANn, TeIns Civil Practice and Remedies Code V.T.C.A, Govt Code 81,001 507,3
  3. Plaintiff mR, Diaz, on march 23, 2015, he filed motion for discourery and discolyge After 90 days Prioe to Aling motion motlity Schedule order 10.

*11 The motion for discovery discloswe and Production of Breath written Repreement Contact, and an Ampel of original Alleged case. er pense was duly serevered upon the detentor us. Postel service teettied mail retumed receipt * SAUANDh LIND, Robinson No. 9009-2820-2002-955-3786; duty serued upon CIERK BREOORIA Cunny, DIST, CIEek RhoungA BAKethk, she NEVER did answer not stamp tile i ′ ′ of service 14. on April 27. 2us Plaintiff MR. Diez, he tiled motion for sanction and compelling discovery, disclosure BREOORIA Cunty DISTRICT CUNRIS, NOR CIERK, RIOUNDA BAKCHAK NEVER ANSWERED or send a stamp file of service." ENTFRED IN THIS ACrION ON THE 82 day of July 2015 DATED: July 82,2015 A.mon. Dices A.mon. Dices Ramsery 4199 ASSMON 1711383 (A1).

*12 UNSuORN Declaration By inmate

IJimmy Dinz, declare and depose PIRSuornt to the title 38 U.S.C. 1746, suoree undie the Penally of Per- sury that the statement made Amended Notice of Appell interbearleay Appell Authorized by Stntue Pase MS. 14-14-00517-LU / 14-14-00622-LU, dee teue and Corkect the best of my Knowledge Eclures; onthis day signed on 23 May of July 3015

Respectfully submitted (1) Jimmy Dinz

Hemadulart 1100, F. m. Rd. Rosthen, Tt. 11583

LENTIFICATE OFFERVICE

IJimmy Dinz Hereby Eectity that a copy of the foregoing was sevived insteument Amended Notice of Appell into bccuture Appell to: Christopher A. Peine forteenth Cours of Appell 301 Fannin Suite 345 Hous ten, Tt. 17002 on this day of 23 May of July 3015, U.S. Install sevive. From Prism mail box, address Bllous Parkes Sevved) RhoppoA BAKCHAK BAKOCAIA Family Distilled 111 E. Locust Suite 300 112.