In The 

COURT OF APPEALS

FOR THE FIRST DISTRICT OF TEXAS

01-15-00208-CV- CV

JOE PAYTN LEE, Appeallant

V. 

RITA LEMNS, Appellee

________________________________________________________________________

On Appeal from the 151st District Court

Harris County, Texas

Trial Court Case 2000-34109

Trial Court Case 2013-55684

________________________________________________________________________

ANSWER TO APPEAL 

Appellee assert that the Defendant Joe Payton Lee and wife filed the Bill of Review and 

Injunction Motion as anothr one of their tactics to delay and deny Appellee legal debt 

they owe to Appellee Appellee will show the Appellants are not entitle to an an Appeal 

regarding the validity of the Default Judgment debt tried in the 127th District Court and 

ordered by Official Officer of the 127th court, Honorable Sharonlynn Woods. 

Apellee will further show that the filing of frivolous claims and motions is not the only 

vice the Defendants Joe Payton Lee and co partners and conspiractories have performed 

in an effort to deny the Appellee what she earned over 14 years ago. The Appellants have 

also zealously evaded service, discovery, have intentionally contempt court, have 

intentionally disobeyed court orders, have intentionally disobeyed verbal orders, have 

committed fraud, have conspired and executed malicious schemes to tangle unaware Rita 

Lemons , business, and her children and to coerce financial defenselessness on a 

protected class citizen, while they exrcise and abuse their authority under various dba's as 

well as government code dba's. 

ACCEPTED

01-15-00208-CV

FIRST COURT OF APPEALS

HOUSTON, TEXAS

4/15/2015 2:22:46 AM

CHRISTOPHER PRINE

CLERK

 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 4/15/2015 2:22:46 AM CHRISTOPHER A. PRINE Clerk ------------------------ VOID K ------------------------ FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 4/15/2015 2:22:46 AM CHRISTOPHER A. PRINE Clerk
Appellants have demonstrated their authority over Precinct 7 as this Precinct's employees

and staff have not performed the public Service duties Appellees have paid the Precinct

eight timesto perform, specifically Writs of Excution paid for in December 2001,

February 2002, September 2009, December 2010, March 2011, January 2012, September

2013 and October 2013. Attorney William Conrad's office paid for one(1) in June 2002.

The Writ of execution mandate for all non exempt property to be executed on until the

Judgment debt is paid in full, but the Precinct failed to carry out the Execution to

completion as prescribed by the Writ.

Appellants have demonstrated their authority over Federal Judge Lynn Hughes as Judge

Hughes have ordered me to court for Sanctions and coercion and the threat of

confinement for zealously attempting to collect legal abd binding debt of his buddy, and

co investor. SBS Global Inc. and The Houston Ballet, their influence over state Judge R.

K. Sandhill who after against my objections granted Mr. Lee and new attorney John

Boudreaux a continuance hearing and when they did not appear for the continuance

hearing, the judge recused himself and transferred disposed civil case. The following

week the Lees were transferring property that is protected under the Abstract of Judgment

filed with the Harris County District Courts Real Property division. Mr. and Mrs Joe

Payton Lee owners of 3606 Dubois St, and 3629 Dubois St., 3620 Dubois St. Houston,

Texas 77051, since 1988 on August 13, 2013 transferred this property to their daughter,

Sharon Lee. Sharon Lee sold or transferred rights to John Boudreaux in September 18,

2013. John Boudreaux transferred or sold the property back to the Lees via Sharon Lee

on March 2013.

Appellees aasert that all of the Appellants actions have been performed knowingly,

willingly with malicious intent to injure the Appellees, her children and her company,

Dental Assistant by the Phone. 

PRAYER

Appellees request the Court of Appeals to grant all reliefs the Appellees are entitled to as

a matter of law.

Appellees request the Court of Appeals to award relief if not granted by the lower courts

the Summary Judgment for $12,254,000.01.

Appellees request the Court of Appeals to grant the reliefs requested, if not granted by the

lower coourts, in the Bill of Review Counter claim for the sum total of Five hundred four

million dollars, three hundred ten thousand, two hundred seventy-four dollars and forty

cents ($504,310,274.40).

Appellees request the Court of Appeals to issue an Order for complete FOIA release.
Appellee request the Court of Appeals to Order the Appellants to answer the

interrogatories completely, because the Appellant have relevant reasons for the complete

and truthful disclosures because Appeellees have meritous motives for making such

request and good cause reasons for requesting assistance.from the 127th. July 19, 2013

and the 151st Distrist Court, November 2013 and etal dates.

The Lees also disobeyed Orders from the beginning, 2001 to current. In 2002 they did not

answer at all. The Lee's have been evading the interrogatories becuase they are apart of a

maliscuios conspiracy against Appellees grandparents, and biological parents and their

clan and were apart of teh malicsious executed schemes to destitute and imprison Rita

Lemons and her interests.

Appellees request the court to issue an ORDER in favor of Appelees against Precinct 7,

for $24,000,000.00, and against Attorney Andrew Payne for $24,000,000.00 for their part

in knowingly, willinglying with malicious intent to injure Appellees and Rita Lemons

children, conspired and executed schemes, refusing to perform their sworn oath public

services to Rita Lemons, in accordance with governing laws.

Appellees rest the Court of Appeals to issue an ORDER restricting Defendants, their

family and associates from harrassing, targerting and attacking Rita Lemons and her

family.

CERTIFICATE OF CONFERENCE

APPELLEES SWEAR UNDER PENALY OF PERJURY, that she has never received

from the Defendants any of the pleadings that the Appeallants have submitted to the First

Cirtcuit Court of Appeals. Further Appeallee assert that she her children and our

associates have been ORDERED by Judge Lynn hughes not to contact the Lees, via

facsimile, email, or come to his residence to serve him. Therefore Appellee have only

made contact with the Lees certified returned receipt. The one and only time I contacted

Mr. Lee, on my own accord, was in an attempt to discuss this matter and settle it without

the added expense of attorneys. I then was lied on as evidenced by the pleadings of Joe

Payton Lee to the federal Judge Lynn Hughes. I have been threatened with incarceration

for my zealous attempt to legally collect the debt owed to me, initiated by services my

company rendered 14 years ago, for a fee. . 

CERTIFICATE OF SERVICE

I swear under penalty of perjury that a true and correct copy has been forwarded to Mr.

and Mrs. Joe Payton Lee, Precinct 7, Brian Quinterro, Andrew Payne and Jyce Hickman

Lee aka Joe V. Curtis, aka Howard J. Curtis and other alias.
Respectfully Submitted,

Rita Lemons

16215 Diamond Ridge Dr.

Houston, Texas 77053

jireh_consult@yahoo.com

(832) 207- 3407 or (832) 679-6387