CAUSE: 2001-CI-16843 <\

MICHAEL THOMAS PAUL (PLAINTIFF) IN THE DISTRICT COURr.

VS 225 U. "-

GREG AB30T ATTORNEY GENERAL "~

FOR THE STATE OF TEXAS (DEFENDANT) BEXAR COUNTY, TEXAS

PLAINTIFF'S ANSWER TO DISTRICT COURT'S

ATTORNIES

CLAIM OF NON INDIGENCY OR IN THE

ALTERNATIVE FRIVILOUS APPEAL

pLAINTIFF is pro se. The hearing set and heard in presiding court Bexar County on _.

December 5th, 2014 was requested by DINAH GAINES, Chief Staff Attorney, Bexar^ ~<7£

County Civil District Courts as malicious filing in an attempt to silence this cait^oiice :~o

and for all. Let it be known that respondents first attorney RANDOLPH V. GONfZ^LEZ =■';

SBN:08131200 appeared October 17 and filed motion for continuance statingjjiat no s» '■€: -inotice had been given per Tex. R. Civ. P. 21 and that he needed more time to pre£&re im ^p _■'_

answer .since he was unfamiliar with the particulars of the filed suit. Plaintiff will show ca : ■

E-file and E-serve confirmation on October 06. 2014 to Attorney General who sent Mr.

GONZALEZ because he had represented the defendant in Justice Court, Comal County.

Texas on September 20th, 2014 regarding this exact issue. Plaintiff never having had to

plea civil case and who had not been in civil courtr since 2002 was unfamiliar with

the TexasRules of Civil Procedure when he filed in small claims court for S10.000 plus

damages and other relief as the court would see fit. Because there was lack of

concurrent inherent jurisdiction the Justice slated she was not eligible to make any

rulings and had to grant the defendants motion to dismiss for lack of jurisdiction. Again

being novice Propia Persona litigant Plaintiff was unaware regarding the legalese

language when the judge granted the motion with prejudice vs. no prejudice, or he would

ha\e objected to the motion. Plaintiff stopped at the clerks office before leaving the

facility as to enquire of the Judge if he needed to file in Bexar County which was the

correct court having jurisdiction or was an appeal necessary first. The clerk returned and

stated that the judge said if he wanted to file an appeal it must be done within 10 days

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and he was freeto make his own decision since they could not give legal advice. Plaintiff

believing that he just needed to file in the proper court that retains jurisdiction in family

court cases as dedicated by the Judicial Court System in TEXAS and the states

constatulion designating the 225th of Bexar county as family court and was the

originating court being the court of inherant and concurrent jurisdiction making it the

only court allowed to hear pleadings regarding this cause. Plaintiff attempted to efilc the

ncessarydocumentation to reopen the initial cause which is the subject of this suit but

was deniedby the clerks office on more than one occasion. The First time was told that

this cause isclosed and that new affidavit of Indigency had to be submitted to file in

original cause. Plaintiff filed in person and submitted new affidavits of inability to pay

court costs stamped September 22. 2014 with two stamped copies sent for service of

notice by the Sheriff and set the matter for hearing October 5th. The next afternoon the

Plaintiff receives an email from the district clerks office stating that the petition

submitted had nothing to do with the original divorce and it was being issued new

cause number. Plaintiff replied to the email stating that the petition was everything to do

regarding thedivorce proceeding and if the clerks office attempted to bypass the record

then plaintiff would be forced to report the issue for judicial review. October 05th.

2014 healing in presiding was scheduled when initial filing was done September, 22.

2014. Plaintiff wasnot on the docket for the case he filed into but instead had received

new case number from the clerks office and was asked if he could show service to the

opposing party. Plaintiff didn't receive the return of service from the sheriff as required

so he asked for the courts leave to return to the District Clerk who was to effect service

where he was told that since the cause number was new one he would need to refile

requests for service under the new number as the notices were not served. Plintiff

enquired to the clerk he sent the reply email to on September 23 and was told by the clerk

that he was told to do it. Plaintiff demanded the filing be placed into the original cause

and had to complete another setof request for service which was duplicate to what was

filed on September 22, 2014. Plaintiff returned to presiding court and made formal

complaint to the court clerk regarding the intentional misfiling of his petition and

requests for service and asked if the judge would sec him. Because the presiding judge

was still on the bench and hadoverheard the conversation she agreed to hear from the

plaintiff but stated she could make no ruleings regarding the petition for temporary

injunction and declaratory relief without showing proof of service.

page of
After reading the petition and seeing the attached exhibits as evidence regarding the

petition for declaratory relief and temporary injunction the presiding judge stated that

theplaintiff should go out front and file selling for new dale. Plaintiff did as

insiructedand was giving the earliest date October 17. that the court was hearing newly

docketed pleas then proceeded to give notice tothe defense regarding the new date.

There has been multiple attempts to keep this case from being justly adjudicated and

plaintiff contends that the district clerks office including the staff attorney are corrupt and

have violated procedures and even laws regarding the theft of Federal Benefits in excess

of $11.600 from plaintiffs Social Security Disability. Plaintiff learned through the staff

attorney before she knew whom he was. that there had been no filings in the original case

since the divorce decree of May 2002. Upon learning this information plaintiff began to

suspect that there was more than just the intentional filing of civil judgment claiming he

owed $5,140.00 to the state and it appeared on his credit reports causing emotional

distress, pain and suffering and his public image was so defamed to make him appear as

DEAD BEAT DAD for not paying his child support as ordered by the court. The only

problem with that is Termination Order relinquishing the parent child relalionshipwith

his daughter that ordered ex partc in December of 2004 ending with "no other relief so

ordered." Had the plaintiff been so behind in his support to the child it would have been

pleaded heavily by the state and request for an order for contempt to compel payment

issued. Yet the state made no claims and the Oblige also made no claims as to not

receiving support payments. Then months after the termination the US Social Security

Administration receives second writ for withholding for garnishment of wages that

continue through 2008 when plaintiff finally learns that the withholding was being paid

to the state of Texas and not his son in California, accumulating to $11,600 as reported

by an audit he initiated after providing the order to the administration from the December

2004 termination which slopped the garnishments administratively from further

payment. Plaintiff then received court stamped judgment for an additional $5140.00

lien and was issued against REAL property had the plaintiff had any. Plaintiff

telephoned the District clerk and stated that he owed nothing and that he was victim of

theft by deception and that the lien was not dully owed. The clerkstated that he needed to

contact the attorney generals office directly which is what he didand was immediately

told that they wouldconducl an internal investigation and would get back with him. But

more than likely the money had been paid to the oblige, plaintiffs ex wife and that if that

were the case then he would need to take her to court to recover his money.

page of
Every time plaintiff would call Austin to the office of the attorney general to inquire of

the investigation he was placed on hold lor 15 io twenty minutes before anyone would

reply and their answer was always we slill are doing an investigation but rest assured as

soon as we determine what has happened you will be the first to know. Then in 2013

Plaintiff learns that the civiljudgment had been reported to all three major credit bureaus

and when he would inquire they would always state that they had verified the claim and

he owed it. Plaintiff requested investigations to the factual legitimacy of the lien but was

never given any reply. Then in 2014 when il was still appearing on his credit reports,

plaintiff gave written notice to cure the defect or face civil penalty upon which the

investigations concluded that there was an error and the civil judgments were deleted.

Plaintiff states Judgments as plurai since there was also fraudulent claim from Salano

County California showing as receiving payments for child support and even had

claimed some as 30-60-90 late but the account was showing paid and current. That is

why Plaintiff thought the payments were lor his son in California. The reporting bureau

has sent letter showingcomplcte deletion of these false claims.

It is at this point in time that plaintiff filed formally with the Attorney Generals Chief

Ombudsman requesting relief to have what was removed from him returned. No

statements of suit seeking extra damages just return what was wrongfully taken. Since

the Office of the attorney general Chief Ombudsman is to initiate the report and contact

the reporting party every quarter until final resolution and no administrative claim can be

made that the investigation is completed and close the complaint which is required by the

Texas Government code. Plaintiff learned through the district clerks new online eservice

thai the court record showed entries between 2003 and 2008 and plaintiff stated that no

notice had been given per Tex. R. Civ. P. 21 not once but twice regarding the entries in

the clerks database as to appear that orders were entered by judge. Plaintiff has since

learned in the filing of this petition that the entries are just that. Entries with no

supporting documentation or actual orders issued by district judge and the first was

change in place of payment and payee from 2003 which led plaintiff to believe the entire

time that the money was redirected to someone other than the original oblige and here he

was being told up until September that he needed to try and get it from the oblige.

page of
The OAG's office of child support enforcmcm and Mary Morton and her representing

lawyer Mr. Randolph V. Gon/.alcs SBN 08131200 filed their answer in Justice court

stating that his only recourse is to sue the oblige as he has non other, because they didn't

have his money.

Between the intentional deceptive tricks and tactics to keep plaintiff from recovering his

money that was illegally seized and entries in the clerks database that have no basis in

fact other than they just appeared years ago when they weren't' there the year before.

And payment record given lo plaintiff by the assistant attorney general Randolph

Gonzalez which states that only $7,462.89 was ever owed and collected by the OAG

child support enforcement division is just another of the non truthes entered by the office

ofthe attorney general in this cause especially since there was an official audit by the

Social Security Administration and subsequent stamped copy of payments from local

officeclearly showing $1 L600.00 makes the entry of fraudulent court document filed

which constitutes acommission of crime since the supposed judgment with lien was

aginst real property in the state.

It is at this point in time where plaintiff demands judicial review of the district clerks

office of Bexar County Texas and there conspiracy to hide the truth and to continuously

harass the plaintiff and file against known physically disabled and indigent citizen

claiming he is not indigent toprotect those that knowingly forged the electronic

database.

Plaintiff further request sanctions against the District Court Attorney as well as sanctions

against the office of the attorney generals which has and continues to file mis

statements of fact and will even have an assistant attorney general commit perjury in

open court to delay the hearing so new motion can be filed and heard before retired

comptroler ofthe State who ignores facts, has no record before him and doesn't

recognize case law such as the stripping doctrine. Pending filed motions that needed to

be addressed were summerily over ruled before the defendants ineligible claim to

sovereign immunity which was pleaded claiming there was never authorization nor

agreement by the state lo waive thier immunity and thus granted the dismissal of

plaintifs claims with perjudice and stating that this case has been fully adjudicated and

can not be heard again even though the state legislature has deemed the only reason for

suit against the individual in his capacity as an employee ofthe state.

The only real motion for dismissal is the one not attempted for limitations. But

Plaintiff has been sent demand for payment from an automobile accident he had last

June where the guard rail and cable was damaged when his automible struck the

page of
center devider on loop 1604 and lh 35 interchange totaling his 2012 K.IA and leaving him no

transportation. The Department of Motor Vehicles demanded payment for said obligation and

sent him demand for payment letter. Fortunatly the plaintiff had comprehensive and

collission insurance which not only replaced his totaled vehicle but also paid the

demand from the state which stated that there is no limitations to an obligation owed

under Texas Civil Practice and Remedies Code chapter 16 16.061 'Rights not

Barred1.

Wherefore the Sovereign state assumes position when an obligation is due: Plaintiff now

assumes that same position as afforded the sovereign since the plaintiff is

sovereign himself least document can be produced by the State which clearly

denies the plaintiff the right to soverignity.

Under this premis of the same position as the state regarding an obligation to return

said obligation owed for claim of damage to the sovereign. Plaintiff seeks return of

sovereign's obligation to the plaintiff since there is nothing in the laws of texas that

clearly states that the sovereign can keep property which clearly belongs to another.

The plaintiff would pray this court to make all orders sought for the futherance of

justice. And to notify all those that would use the power of this court to take advantage of

others through trickery and deception presented to this honerable court, that if coughl they

will pay heavy price.

Pleader attests that the statements made in this affadavit are truthful and accurate to

the best of his knowledge and attests to the same here on.

Sworn this day 20th December 2014 in the county of Comal.

Michael Thomas Pau

Propia Persona

9123 Easy Street

San Antonio, Tex 78266

(210)294-4533

page of
NOTICE. THIS FORM CONTAINS SENSITIVE DATA.

Cause Number: 2001-CI-16843

... In Ihe ••■■•-■ ■' Pelilioner/

Plaintiff MICHAEL THOMAS PAUL J25TH District Court

•,..--::. County Court at Law

Justice of the Peace Doleodant GREG ABBOTT ATTORNEY GENERAL

Respondent/ FOR THE STATE OF TEXAS ....BJ1XAR. County. Twos

Plaintiffs Amended Affidavit of Indigency for APPEAL

(Request to Not Pay Court Fees)

:>** :ims w: !o ask trie cuur1 'lot to Y«u nw.si eimei stye, this 'orm in You can be prosecuted if you lie on

■■'wge *cu ('■•• cou'i fees 'iis 'crm is front of no'ary puul.r or 2; si:i:i 'His this form.

aisu calieii <ti 'Vfidavit o' Inability to form am sign and attach completed M0 court may or may no! approve this

Pay Co-..r; Cusis" or 'Paupers Oatf "Unsvto:r. Declaration' form. By req'uss! 10 not ooy court 'ees rh«A.'.;urr You can only i>se Shis fonri if. (1) you signing in fron! of ;j inj'.ary. you suvar :t,nv Jr.-e, y0,, |O arrive' (|iiOS'.!0'^

.iiv ;;.::;;« fe-i-'-s becai;sc yo.i art «'i'J#« o.if.': :na: !i«: inlormaiion ^t3OL-1 your financos a; hearmc. A:

:ii«M ,.:-j yoi en-', pay nourt foes jtrovirifin 'f. Ii.o .in;! i-ursn By !Ms, deaniHj you will hove lo present

-id !'ifiv-r-ai-..a you g;vii on llvs forf .'-.itji'iii!! .iii<! attnr.r.m-.j ;«i Uriswoci ovidvnoi1 ■,•:> the itidqp of your inco^i'?

•;■'.;•:» bi" ■:''•> "o:rt!l«li! true anri Osci.-ir.vio'i 'onr> vim ..'er.'.-./c- j'io'c .-jsir expenses !t. [jrr.vp'-iar v.i. *iflvf--X11

.^•:J';va'SL»;t;.-/i1.a!tr.t.r:{;imJitio'» .oiHy :■;. ^sy "ourt fees

ri'O.'IOK! >S ;.';(C- ?ilx.(i (if'SCl

The person who signed this affidavit appeared, in porson, before me, the undersigned notary, and stated

under oath:

"My name is MICHAEL THOMAS PAUL My phone number is ro 294 -4533

-My mailing address is 9123_EASY STREEJ_ SAN ANTONIO, TEXAS 78266

"My email address is MTP73H9@HOTMAIL.COM

am above me age of eighteen (18) years, and am fully competent to make this affidavit. am unable to pay court

costs The nature and amount cf rny income, resources, debls. and expenses are described in this form.

'.. .'■..• "I. i.y-., .,t.!f.i ;■■:*;■ .;■:><-& j.V.-..••.-••»;.•.• Cf. ■.■..'.-. ;.■ .-i-;-;.-: ;••' .-,».' «.r.w

recsive these public benefits/government entitlements that are based on indigency:

SSI WIC Pood Slamps/SNAP TANF Medicaid CHIP AABO

Needs-based VA Pension County Assistance. County Health Care, or General Assistance (GA)

US in Medicare ('Extra Help") Community Care via DADS Low-Income Energy Assistance

Emergency Assistance ;""• Child Care Assistance under Child Care and Development Block Grant

Public Housing Olher: ,;*••.. ••.;.

'My income sources are staled below ..:.■•■. .i« ■,■■ -:l•;..-,

Unemployed since: ■uw 20Q2 -orWages: work as for

Child/spousal support .J My spouse's income or income from another member of my household •</*«»/»»■•,

Tips, bonuses Military Housing Workers Ccmp '.*'■ Disability Unemployment X. Social Security Disability

Relirement/Pension Dividends, interest, royalties 2"" job or other income:

(5 "My income amounts are stated below. (■r.-.s.ij;,..

(a) My monthly net income after (axes are taken out is: 'w.-c ■><>*;.•*::..;;!•., ■> $795.00

(b) The amount receive each month in public benefits is. •■.•mi ,.iUi..- mei*-.

(c) The amount of income from olher people in rny household is:' j.-ja'-H»\j:«.' -..cr .■■ i« -.

(d) The anount receive each month from other sources is: .-,,•.«.»••.■ »■>v.-,-..-..•-• 100 00

(e) My TOTAL monthly income is Md 311 sources cf income acovo- K95.00

■!.-;"•■ .•■•:•<:.• c'-A- ,•( .M.'.t'r i»:f."'.V(.-•■ •:••-•;./• :. ...• ■..... a-"i.:j :<:':•:■:>.'.:

TeiasLawHe.o.org Affidavit ol Indigency. February 2014
About my dependants: 'The people who depend on me financially are listed below:

■Vvf'O Ay:-

I.J" _1_ '____"'" _[

'"""

.Mr

'•My property includes: Value*

Cash L__-r_M.

Bank accounts other financial assets ■; -;

RBFCU CHECKING ACCT 98.00

©'My monthly expenses are.

Rent/house payments/ma inlena nee

Food and household supplies

Utilities and telephone

.Ml^.SAYJNGA... 5.00 Clothing and laundry

Vehicles (cars, boats) ■.•.•xmuwaii.iya&i

1QJ 4.KIA.R!O_FJ, LJ

Real estate (house or land) (Donot«si me house younvo m.)

Other property (like jewelry, stocks, etc.) ■■oeicmo;

2002 PROWLER 32' RV S_2J)00

Medical and dental expenses

Insurance (life, health, auto, etc)

School and child care

Vehicle payments

Gas. b.is fare, auto repair

Child spousal support

Wages withheld by court order

Debt payments

Other expenses lOoscnbe)

L_

Amount

45.00

200.00

127.00

30..00

88.48

FINGERHJJT

FUEL FOR CAR AND HOME

25.00

200.00

Total value of property 16,105

"My debts include;

Total monthly Expenses 750.48

jliQDjSTJ.TONE QAIULQSPITAL 5850.00,

NIJ^

***due totjle size limit online documentation will be provided at hearing 12 22; 14 as required

any aintrr iscts you ivacif the court to >".>i>iv ■.•lye'! a-. n;ii'Si/;i' motl'S!)- kV'u.'.'M.'S. family vaii'Hjupruw o'- .i!;m-, h-i:'!"—

<;e ;o this fe-in .-ifirf'aos; <! 'Exhibit AilM:or>& Supvoiitaq Facts Check nore if you attach another page..

"1 am unable to pay court costs. vorify that the statomonts mado in this affidavit are true and correct."

Your Signature. •■

Sworn to and subscribed before me today. ..by \Y\iCX\C\C ~rTvJ>"vvL> -9<r.

MICHAEL

PAUL

Affidavit tnctigoncy rebmary 201^
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Details

BenefitsChecktp Bexar County County... [] CashNetUSA (2) CashNetUSA ['"_ CIVIl PRACTICE AND _. coa.tx Oefamation da...

Precept Without Hearing

Precept Without Hearing

Abstract of Judgment

Notice of Hearing Served

Temporary Injunction S«rv

Abstract of Judgment

Notice of Hearing Served

Precept Without Hearing

Temporary Injunction Scrv

Rejection Information

$0.00

S0.00

so.oo

so.oo

$0.00

so.oo

$0.00

$0.00

$0.00

Rejection Reason Date Time

Incorrect/Incomplete 10/6/2014 8:58 AM

Rejection Comment

THE LEAD DOCUMENT IS CCIS FORM, NOT A REQUEST. SELECT THE

CORRECT RUNG CODE. ALSO THE CASE IS CLOSED, SO NEW

AFFIDAVIT OF INABILITY IS NEEDED. MARC

Documents

Lead Document

Attachments

Attachments

eService Details

Civ1ICase_lrrfomwtfonSheetSIGNED.pdf [Original]

Requeet_At>stract_Judgment_WritOfExeeution for presidfng.pdf [original]

Status

Sent

Sent

Nome/Email Firm

office of attorney general

esd-filer-303@texasattorney

DRO Legal Enforcement Tarrant County Domestic

DRO-LegaK&tarrantcounty.o Relations Office

Served Date/Time Opened Log

Yes Not Opened View

Yes 10/6/2014 10:15:04 View

Request

SERVICE ATTNY GENERAL

j" sjjjJSiS 5^ ^ ;'" ^^
NOTICE: THIS DOCUMENT COM AINS SENSITIVE DATA

N(.l'N«:nc MICHAEL I'M I.

CP Nairn.-. URASDYL il'OOUFRTO.X

OAO Number: 0»>lW2IW

(AlSK NUMBER S2I4025

M1CIIM.I IHOMASi'AII s- INTIIEJI'STICECOl.RI

;\ I'KLCINC NUMUI-.K WO

OriKI O!: [HF AilOKNhYC.LMRALCIlll.l) .*

SUPPORT DIVISION AND MARY MORION ." C0MA1. COUNTY. II..VAN

OKOF.R DENYING PLAINTIFF'S REVISED PETITION: SMALL CLAIMS COURT AND GRANTING THE

OFFICE OFTHF. ATTORNEY GENERAL AND MARY MORTON'S MOTION TO DISMISS AND MOTION

TO DISMISS ON PLF.A TO THF. .11 RISDIt T1ON

On the 18" da\ of September. 20N ir.e Conn held hcatinu in -Ins cau->c

The ATTOKNI-Y OKNLRAl and MARY MORTON. Defendants, appeared hv an Assi^ianl Altoric> Genera!.

VUC HALL THOMAS PAl.'l I'lnimill. uppcaivii Pro So

The Cour: heard and coiiMdcrcd the ;ilc.ii)im!s. the ariiiimciUi of Counsel, and the e\iocncc pronerl>

and finds ihiinlK-Plaimilfs Rev ised I'ciiiion Small Clir.ms Counts DFNIF.l). he Conn further GRANTS ilxOlllC

OP Tilt ATTORNEY (iF.NKRAI :md MARY Ml»RTON's Motion to Dismiss and Molion lo Oiimiss on ?lc» In ihe

IT ISTIIfcRI.IORH OROF.RED :hat MICHAEL HOMAS PALI.'s Hclition at-d 1'lcHilir.gsarcnll hereb>

nil pfv-iudicc IT IS Ft IK 11IER ORDDRCU that all any nnd all relic: requeued but nol granted hereby UliNIFD.

inal Signed by:

JIDGU PRESIDING

APPROVED AS 10 FORM ONLY

RANUOLPII V. CiON/ALE/ SUN

\rtorney of Record

Child Support Divisior.

lOSS.St Marv'sSt.. Stc -4S

San Anionio. n20f<

Telephone No. (2l<h 804-640(1

ax No. (210) V30-3625

EXHIBIT: ASSISTANT ATTORNY GENERAL GONZALEZ PURJURY CLAIM TO JUDGE

MERY.NO SERVICE, DONT KNOW ANYTHING ABOUT THIS CASE TO DELAY THE

COURTON NOVEMBER 17, 2014.
NOTICE: THIS DOCUMENT CONTAINS SENSITIVE DATA

NCP Name: .KUCHA El. PA VL

CV Name: BRANDY L. WOOL VERTON

OAG Number: 0010017209

CADSF. NUMBER S214025

MICHAEL THOMAS PAUL IN THE JUSTICE COURT

VS. PRECINCT NUMBER TWO

OFFICE OF TlIE ATTORNEY GENERAL CHILD

SUPPORT DIVISION AND MARY MORTON >' COMAI. C:OUNTY. TEXAS

THE OFFICE OF THE ATTORNEY GENERAL CHILD SUPPORT DIVISION AND MARY MORTON'S

TRIAL BRIEF IN SUPPORT OF THE OFFICE OF THE ATTORNEY GENERAL AND MARY MORTON'S

MOTION TO DISMISS ON PLEA TO THE JURISDICTION

TO THE HONORABLE JUDGE OF SAID COURT:

The OFFICn OF THK ATI ORNEY GENERAL CHILD SUPPORT DIVISION and it's employee, MARY

MORTON, (hereinafter Movanls) filed plea to the jurisdiction objecting ro the court's excrciso of subject mutter

jurisdiction over the cause of action as alleged by Plaintiffs, MICHAEL THOMAS PAUI.'s. (hereinafter Non-Movam)

Revised Petition and requests the Court to dismiss Plaintiffs cau.se of action on the Plea to the Jurisdiction, and in

support thereof, shows the Court the following:

I.

FACTS/PROCEDURAL HISTORY

A. On August 11, 2014, Non-Movant. \\ICHAP.I. THOMAS PALI., filed his lawsuit alleging over

payments on court ordered child support payments to the custodial parent for over three year period. Non-Movant

seeks monetary relief from the Movanls. in the amount of $10,000 plus damages for 'REAL PHYSICAL HARM" and

statutory interest and court costs.

H. Non-Movanl alleges thai Movjiiiw provided child support services to the custodial parent and continued u,

withhold support after the support obligation legally :minnted.

C. Non-Movant further alleges that MovanLs Hied false claim in State District Court to "gamer Civil

Judgment that appears/appeared on personal Credit Bureau".

D. Non-Movant does not plead facts indicating constitutional provision or statute that clearly and

unambiguously waives sovereign immunity in these various claims.

E. Non-Movanl does not plead facts indicating the Legislature's consent to pursue this suit against the stale

or public official.

F. In heir individuul capacities, the Movants, and all persons acting on behalf of the State of Texas

participating in ihi.s cause have sovereign und official or quasi-judicial immunity from .suits or liability for attorney's fees.

EXHIBIT: ASSISTANT ATTORNY GENERAL GONZALEZ PURJURY CLAIM TO JUDGE

MERY.NO SERVICE, DONT KNOW ANYTHING ABOUT THIS CASE TO DELAY THE COURT

-NOVEMBER-17^044=—
monetarv judgments, damages or other monetary relief, except as provided by law, when aeting within the discretion,

course, and scope of their official duties at all times relevant to Non-Movanl's claims.

II.

ARGUMENTS ON PI PA TO THE .nmiSDICTlON

A. Movants can demonstrate that ihis Court does not have suhjeel mailer jurisdiction over this cause of

action and thai Non-Movant*s cause of action should be dismissed on the plea lo the jurisdiction on the contentions and

affirmative defenses set forth herein based on the doctrine of sovereign immunity.

B. Movants pled both plea to the jurisdiction on the doctrine of sovereign immunity and raised the

affirmative defense of sovereign immunity to Non-Movanl's claims. The doctrine of sovereign immunity appliesto

lawsuits seeking lo award monetary relief against governmental entities and their employees or public officials unless

constitutional provision or statute clearly and unambiguously waives sovereign immunity from suit. This is true

regardless of whether Movant has asserted valid claim or ultra vires conduct; violation of due process rights; or ihe

intentional tort of fraud. No matter how Non-Movant couches his pleading, what is sought is money judgment for the

alleged overpayment of child support in an amounl in excess of SI 0,000 plus damages tor 'REAL PHYSICAL HARM'"

and statutory interest and court costs from Movants, undisputedly governmental emily and its employee. Non-Movant.

however, has failed to identify any constitutional provision or statute that clearly and unambiguously waives sovereign

immunity from suit. ITie Non-Movant is precluded from seeking monetary relief from the Movant or any of its

employees on any of his alleged claims.

C. Non-Movant's exclusive remedy for support paid in excess of the support order is found in Texas Family

Code Provision 154.012. This provision provides thai if an Obligor is not in arrears and the Obligor's child support

obligation has ended, the Obligee shall return excess proceeds to the obligor. An Obligor can file suit to recover child

support payment in excess of Ihe support obligation against the Obligee. Movants had closed its case in April 2009,

shortly after being informed lhal Non-Movanfs parental rights had been terminated in 2005. Neither the Non-Movant or

the Obligee had previously informed the Movants of said termination order prior lo 2008. There is no legal basis for

payment by Non-Movant of the excess proceeds. Non-Movanl's sole remedy is suit against the Obligee pursuant to

Section 154.012.

III.

AUTHORITIES ON PLEA TO THE JURISDICTION

SOVEREIGN IMMUNITY GENERALL

A. Governmental immunity from suit defeats trial court's subject matter jurisdiction and is properly

asserted by plea to the jurisdiction. Texas Dcpl. of Transportation v. Jones, S.W. 3d 636. 637 (Tex. 1999). Whether

court has subject matter jurisdiction is question of law. Texas Natural Resources Conservation Comm'u v. IT-Davy, 74

S.W. 3d 849. 855 (Tex. 2002). Sovereign immunity deprives trial court of subject matter jurisdiction in suits against

EXHIBIT: ASSISTANT ATTORNY GENERAL GONZALEZ PURJURY CLAIM TO JUDGE

MERY.NO SERVICE, DONT KNOW ANYTHING ABOUT THIS CASE TO DELAY THE COURT

NOVEMBER 17.2014.
the State and its agencies and officials, unless the State has clearly and unambiguously consented to be sued..See Tex.

Dep't of Parks and Wildlife v. Miranda. 133 S.W.ld 217,224 (Tex. 2004). Moreover, because sovereign immunity from

suit deprives trial court of subject-matter jurisdiction, it cannot he waived and may be raised at any time.,SV<? Miranda.

\tt SW3&a\ 22*; Texas Ass'n ofBus. v. Texas Air Control Bd.. 852 S.W.2d at 445 (Tex. 1993).

B. Sovereign immunity encompasses two principles: immunity from suit and immunity from liability.

Travis Cowuy vs. Petztsl and Aiawiaies, 77 SW3d 216 (Tex. 2001). Rven if the legislature consents to suit, the

government is srill protected from liability. Putzel, supra.

C. Sovereign immunity also bars suits that seek to control state action. See Fouler v. Teacher Ret. Sys.. 273

S.W.3d 883.886 (Tex. App.-Austin 2008, no pet.). Absent an express waiver of its sovereign immunity, the State is

immune from suit. See Stale v. Holland, 221 S.W.3d 639, 643 (Tex. 2007).

D. It is the plaintiff's burden to establish the State's consent to suit. IT-Davy, 74 S.W.3d at 855. First, only

the Legislature may waive sovereign immunity..See IT-Oavy. 857 (reaffirming thai it is the Legislature's sole province

to waive or abrogate sovereign immunity). Second, any waiver of sovereign immunity must be in clear and unambiguous

language. See Tonka v. City ofMexiu. 197 S.\V.3d 325. 332-33 (lex. 2006).

E. Non-Movant does not plead waiver of sovereign immunity for any of his claims (overpaid child support

payments: "Real Physical Harm" and court costs), nor does he request prospective injunctive relief or declaratory relief.

See City of El Paw v. Heinrich. 284 S.\V.3d 366, 369 (Ten. 2009). This Court should dismiss Non-Movant's cause of

action because his suit for damages is not recognized by any textual exception to Movanfs sovereign immunity. See Fed.

Sign v. Tex. .*>'. t/niv., 951 5>.W.2ci 401. 405 (Tex. 1997) (.state agencies are immune from liability in Texas unless the

Legislature waives that immunity): \ee ahu TF.X. GOV'T CODE 311.034 (codifying common-law standard for

immunity waiver: "[A] statute shall not he construed as waiver of sovereign immunity unless the waiver is affected by

clear and unambiguous language.").

CLAIM AGAINSTMARYMORTOX

A. Absent waiver by the legislature, sovereign immunity generally deprives courts of subject-matter

jurisdiction over suits against the State., its agencies, or officer* or employees acting within heir official capacity. See

Citv of F.I Paw v. Heinrich, 284 S.W.3d 366, 369-76 (Tex. 2009). In its attempt to invoke this court's subject-matter

jurisdiction. Ntm-Movant, sues MARY MOR ION, an employee of the OFFICE OK THK ATTORNEY GENERAL

CHILD SI.IM'ORTDI VISION. See id. at 372-73, 377. Sovereign immunity does not bar suits for prospective injunctive

or decluraton relief to restrain the official from violating statutory or constitutional provisions because, in concept, acts

of stale official* ihat are not lawfully .iiithoi \/tn\ nru nui considered to be acts of" the State, and ihe remedy of compelling

EXHIBIT: ASSISTANT ATTORNY GENERAL GONZALEZ PURJURY CLAIM TO JUDGE

MERY,NO SERVICE, DONT KNOW ANYTHING ABOUT THISjCASE TQ DELAYTHE COURT

NOVEMBER 17,2014.
such officials to comply with (he law, while binding on the Slate, does not attempt to exert control over the State, Id. at

372-73 (emphasis added).

B. To assert such a valid ultra vires claim, the claimant "must not complain of government officer's

exercise of discretion, but rather must allege, and ultimately prove, that the officer acted without legal authority or failed

lo perform purely ministerial act." Id. at 372. Otherwise, the suit, even if seeking only prospective declaratory or

injunctive relief, implicates sovereign immunily because it seeks to control state action.."ke id. However, even if the suit

complains of ultra vires actions, the remedy .sought cannot have the effect of awarding retrospective monetary relief

against the State or oilier relief that would independently implicate sovereign immunity. S^ id. at 369-76; CreedmoorMaha Water Supply Corp. v. Texas Coimn'ii on Envtl Quality, 307 S.W.3d 505, 515 (lex. App.-Austin 2010. no pet.).

C. Thus, sovereign or governmental immunity deprives trial courts of subject-matter jurisdiction over suits

for monetary damages or other retrospective monetary relief against government entities and their officers and

employees, acting in their official capacity, unless the State expressly consents. See Heinrich. 284 S.\V.3d at 368, 380

(Tex. 2009); Texus Dep't of Trump, v. Jones. S.\V.3d 636, 638 (lex. 1099) (per curiam). This is true regardless whether

the claimant has otherwise asserted valid claim of ultra vires conduct. See Heinrich, 284 S. VV.3d at 369-76; Cn-i'dtnoorMaha Water Supply Corp. Texas Comm'n on Envtl. Quality. 307 S.WJd 505, 515 (Tex. App.«Austin 2010, no pet.).

Kastnvr vs. Texas Board of Law Examiners, 2010 Tux. App. Lexis 6076 (Tex. App.—Austin 2010, no pet.).

FRAUDULENT CIVIL JUDGMENT CLAIM

A. The Texas Tort Claims Act provides for limited waiver of sovereign immunity for non-intentional torts.

Miranda. 133 3dat 224: TEX. CIV. PR,IC. REM. CODE# 10J.0OI 109. However, under TEX. CIV. PRAC. ti

REM CODE 10l.057(2j. claims arising from intentional torts arc excluded from the waiver of immunity. TEA". CIV.

PRAC. REM. CODE 101.057(2). In Non-Movanl's Revised Petition Non-Muvanl pled cause of action for "filing

false claim" and filing "fraudulent civil judgment". Fraud is an intentional tort See Texas River Rargex v. City ofSan

Amonio.Ti S.W.3d 347. 356 (lex. App. San Antonio 2000, pet. denied). Additionally, Non-Movant"s intentional tort

claim of fraud or "raise claims'are barred by sovereign immunity because the Texas Tut Claim Act docs not provide

waiver of sovereign immunity to these types of claims. Under the Texas Tort Claims Act. there are only three areas in

which the State and its agencies waive immunity for torts..we TF.X. CIV. PRAC. REM. CODE 101.021. (1) the

operation or use of motor vehicle, (2) premises tlelect, or (3) the use or misuse of property owned or controlled by the

State. Sec Old South Amusements. Inc. 2010 Tex. App. Lexis 5450.

EXHIBIT: ASSISTANT ATTORNY GENERAL GONZALEZ PURJURY CLAIM TO JUDGE

MERY.NO SERVICE, DONT KNOW ANYTHING ABOUT THIS CASE TO DELAY THE COURT

NOVEMBER 17, 2014.
ss

PRAYER

WHEREFORE, PREMISES CONSIDERED, Movonts pray that the Court grant Movants' Motion to Distni

on Pica 10 the Jurisdiction, and that this Honorable Court will dismiss Non-Movant's cause <>r action with prejudice as to

the Movants and any funher relief, special or general, at law or in equity, as may be shown that Movants are justly

entitled lo receive.

Respectfully submitted,

Greg Abboit

Allomey General of Texas

Daniel T. Hodge

First Assistant Attorney General

Randolph V. Gonzalez SUN: 08131200

Melissa Ramos Munoz SBN: 00786186

Attorney of Record

Child Support Division

CHILD SUPPORT UN!T 02Q1E

fO6S. ST. MARY'SST.. STE. 445

SANAKTOMO TX 78205-3614

Telephone No. 210-804-6416

Fax No. 210-930-3625

EXHIBIT: ASSISTANT ATTORNY GENERAL GONZALEZ PURJURY CLAIM TO JUDGE

MERY.NO SERVICE, DONT KNOW ANYTHING ABOUT THIS CASE TO DELAY THE COURT

NOVEMBER 17,2014.
CERTIFICATE OF SERVICE

certify that true and correct copy of the foregoing has been served on the below listed parties or

representatives pursuant Rule 21 a, Texas Rules of Civil Procedure, on the. 5* day of September. 2014.

RANDOLPH GONZALEZ

Attorney ofRecord

Early:

MlCHAliL TPAUI.

BRANDY WOOLVERTON

Attorney for Party:

EXHIBIT: ASSISTANT ATTORNY GENERAL GONZALEZ PURJURY CLAIM TO JUDGE

MERY.NO SERVICE, DONT KNOW ANYTHING ABOUT THIS CASE TO DELAY THE COURT

NOVEMBER 17, 2014.
LIABILITY

A:. ':„-■.; ■..-:.,-

1410010194

Sta:e:n»n: Da-.i12/05/14 1,188.80

A-i. Paymyms and Charges after th« .td

c'ate Aiil appear on rext statement

To Pay Online Visit www bpservice.com; Control #14279013123

City of San Antonio

Emergency Medical Service

621 N. Alamo

San Antonio, TX 78215

We Accept Most Major Credit Cards

For Assistance:

Telephone (210) 227-7252

10/01/14

1410010194

Patient

MICHAEL

PAUL

Unless pa

It will be transferr

lisU

Current

EMS SERVICE

*** FINAL NOTICE ***

yment is received on this past-due accoun

FIFTEEN (15) DAYS

ed to our collection agency. Delinquent ace

>d with the credit bureaus serving this area

1.188.80

within

ounts may be

.....

_—

1.188J30

1,188.80

b.uir;e Due

City of San Antonio

Emergency Medical Service

621 N. Alamo

San Antonio, TX 78215

EDP# 142790131

MICHAEL PAUL

9123 EASY ST

SAN ANTONIO TX 78266-2647

To Pay Online Visit www bpservice.com; Control 14279013123

SPn S^iaHB

City of San Antonio

P.O Box 158

San Antonio. TX 78291-0158

AMujNT PAID
LIABILITY

NPAS, Inc. PO, BOX 99400

LOUISVILLE. KY 40269

031322-430510686-A1

Services

Provided by:

METHODIST STONE OAK HOSPITAL

Patient Name:

Account Number:

Service Date(s):

Statement Date:

Placement Date:

Michael Paul

502157591

10/01/2014 -10/02/2014

12/01/2014

11/01/2014

MICHAEL PAUL

9123 EASY ST

SAN ANTONIO, TX 78266-2647

Contact Us

NPAS, Inc

Toll Free 1-800-223-9899 Espanol 1-80C-681-9692

MON-FRI 8AM-9PM SAT 9AM-1PM ET

Please bo prepared to provide the patient/responsible party lull name, date

of birth and mailing address. All calls may be recorded.

PAYMENT REQUEST

Total Charges

43,773.79

Total Pymt Adi

42.SS3.34

Current Balanco

820.45

Payment Duo By

12/16/14

Amount You Owo

$820.45

Our records reflect that you were previously contacted regarding the unpaid balance of the account. We urge you to send

payment in full today. In the event you are unable to pay the balance in full, please contact us to discuss options for

resolving your account.

METHODIST STONE OAK HOSPITAL; METHODIST HOSPITAL FACILITY

Insurance Information

If the insurance information on file is incorrect, please contact us at the

toll-free number above.

Primary: TRAILBLAZER

Payment Options

®PAY ONLINE at your provider's weosite.

www.saheallrt.com/billinginqasp

OPAY BY PHONE at no additional cost through our automated system

during or after normal business hours.

©MAIL PAYMENT lo the provider win the attached coupon at tno

payment address specified Please do net send cash

PLEASE SEE REVERSE SIDE FOR IMPORTANT INFORMATION

I' your Main*.* cftanqec ciuick >.hii box urtd

complete torn at DJCli

MICHAEL PAUL

9123 EASY ST

SAN ANTONIO. TX 78266-2647

PLEASE DETACH THIS COUPON AND RETURN WITH

PAYMENT TO ADDRESS BELOW:

METHODIST STONE OAK HOSPITAL

P.O. BOX 740794

CINCINNATI, OH 45274

I'Xhil'H

Thr. imi '.Viltl Your P/iyimnl

Statement Date 12/01/2014

Account Number

Payment Due Date

Balance Due

Payment Amount Enclosed

502157591

12/16/14

820.45

Ploaso do not send cash, if paying by chock or monoy order, please

indicate account number and mako payable to tho provider.

C.tuon Cart Numtwr

CcfCirernbur'A Signature

am Au'JKwi/dJon (ptoase 2hccK one)

Amount

PAUL MICHAEL
LIABILITY

STATE FARM INSURANCE COMPANIES

RECEIPT OF PAYMENT

PAYMENT DATE/TIME: 12-03-2014 11:54AM

POLICYHOLDER(S)

MICHAEL PAUL

9123 EASY ST

SAN ANTONIO, TX 78266-2647

POLICY DESCRIPTION/POLICY NUMBER

SFPP PAC SUSP-SEE

1115-5352-25

CHECK/ REF

000003T3257N2

AMOUNT

$88.48

TOTAL AMOUNT PAID: $88.48

AUTHORIZED SIGNATURE:

NICOLE GONZALES

AGENT

Rick Cantara Agent

14791 IH 35 N, STE 105

Selma, TX78154

(210)656-3276

THANK YOU FOR YOUR PAYMENT ON THE ABOVE POLICY(IES). PAYMENTS ARE RECEIVED

SUBJECT TO COLLECTION AND POLICY PROVISIONS WE APPRECIATE YOUR BUSINESS.

1004258 2002 142682 201 0502-2012
LIABILITY

PO BOX 200143

San Antonio, TX 78220

(210) 333-4287

Fax: (210) 333-6287

11/14/2014

i'i

5774 T15 AUTO"3-DIGIT 782

Michael Paul

9123 Easy St

Garden Ridge TX 78266-2647

RE: MICHAEL PAUL, 059174, $74.58

Dear Valued Customer

Our records indicate that your account is currently past due. Please remit your payment by the 15th of this month to

avoid any interruption in service. If payment in full cannot be made at this time, please contact our office at (210)

333-4287 to make payment arrangements. Failure to do so will result in suspension of your services.

DATE INVOICE AMOUNT

10/1/2014 0000685260 74.58

Total Balance

if you have already remitted your pay, please disregard this notice.

We appreciate your business and thank you for your cooperation with this matter.

Sincerely,

The Staff at

Tiger Sanitation Inc.

$74.58
BENEFIT

Blue Cross MedicareRx (pdp)" 23999

P.O. Box 3897

Scranton, PA 18505

Effective Date: January 01,2015

Evidence of Coverage Rider

for People Who Get Extra Help Paying for Prescription Drugs

(also called Low Income Subsidy Rider or LIS Rider)

011552/PDPTX

Please keep this notice it is part of Blue Cross MedicareRx Basic (PPP)SM's Evidence of Coveraiie.

Our records show that you qualify for extra help paying for your prescription drug coverage. This means that

.you will get help paying your monthly premium and prescription drug co-payments.

As member of our Plan, you will receive the same coverage as someone who is not getting extra help. Your

membership in our Plan will not be affected by the extra help. This also means that you must follow all the rules

and procedures in the Evidence of Coverage.

Please see the chart below for description of your prescription drug coverage:

Your monthly plan

premium is

S0.00*

Your yearly

deductible is

S0.00

Your co-payment amount for

generic/preferred multi-source

drugs is no more than

S2.65 (each prescription)

Your co-payment amount for

all other drugs is no more

than

S6.60 (each prescription)

The monthly plan premium does not include any Medicare Part premium that you may still need to pay.

The plan premium you pay has been calculated based on the Plan's premium and the amount of extra help you

get.

Please refer to your Evidence of Coverage for more information on paying your plan premium.

You must continue to pay your Medicare Part premium.

The benefit information provided is brief summary, not complete description of benefits. For more

information contact the plan. Limitations, copayments, and restrictions may apply. Benefits, formulary,

pharmacy network, provider network, premium and/or copayment/co-insurance may change on January of

each year.

Blue Cross MedicareRx is prescription drug plan provided by HCSC Insurance Services Company (HISC),

an Independent Licensee of the Blue Cross and Blue Shield Association. Medicare-approved Part

sponsor. Enrollment in IllSC's plan depends on contract renewal.

;Y0096_liNR_TMP_LIS Rider PDP 15 Accepted 100120!4
BENEFIT

Regarding Mr. Michael Paul with telephone number 210-294-4533, this is to confirm his application and

certification form have been approved by the Texas Low Income Discount Administrator. Mr. Paul is

eligible for both the Lifeline (telephone) and electric discounts. Note the electric discount runs from

May through August of each year.

His certification is valid to May of 2015. Upon recertification, more months' benefit will be extended

per program rules.

Note his telephone carrier (Cricket) has not send the LIDA is customer record. Therefore, he is not

receiving the Lifeline discount. And his energy company (CPS Energy) does not participate in the

program. In order to receive the energy discount, he would need to sign up with participating energy

company.

Dan Marion, PMP

Account Manager-Texas LIDA

Solix, Inc. 30 Lanidex Plaza West Parsippany, NJ 07054

T: 973.581.5052 M: 973.769.7587

www.sollxlnc.com Solix on Facebook Solix on Twitter

Transparent Solutions. Visible Results
11/30/2014

Period

through

Statement

11/01/2014

rbfcu.org

(RBFCUt78148-2097 TX City. ,>ersal

REQUESTED SERVICE ADDRESS

PAUL MICHAEL

ST EASY 9123

78266-2647 TX ANTONIO SAN

Services: Member to Inquiries Direct

78148-2097 TX City, Universal 2097, Box P.O.

rbfcu.org 1-800-580-33001

314089681 #; Routing

membership! your for you Thank

you like members helping to dedicated We're

money. earn and money save time, save

9656057 SUMMARY CHECKING

Balance Statement Previous

0.00 'APYE 0.05 Rate Checking

S3.99

Credits Total

$1,385.00

Debits Total

-$1,383.89

Balance Statement Current

S5.10

Deposits Account Checking

Amount Description Date

CK 379907 from Transfer Internet Deposit /02 11

SEC XXSOC 310 TREAS SSA Deposit ACH 11/03

CashNetUSA9!411131PAYDAYADV Deposit 11/12

$100.00

S79S.00

S450.00

Description Date

SAV 184402803 from Transfer Internet Deposit 11/24

SAV 184402803 from Transfer Internet Deposit 11/24

SAV 184402803 from Transfer Internet Deposit 11/29

Transactions Other Card Check Freedom

Amount Description Date

-510.00 SAV 184402803 to Transfer Internet Withdrawal 11/02

00 -$260 2505 TOOL NORTHERN Withdrawal Sale Of Point 11/03

ANTONIO SAN 410 Loop NW

95 $29 855-306-9430 855-306-9430 PB Withdrawal ACH 11/03

WEBPAYMENT

$40.00 NACOGDOCHESSAN 12307 RBFCU Withdrav/al ATM 11/04

ANTONIOTXUS

-$151.24 WMSUPERCENTER6102FM Withdrawal Sale Of Point 11/06

USA SCHERTZTX 3009

-$145.88 1565 WARNER TWOTIME Withdrawal Sale PointOf 11/06 flflW.TWrtBI <t fhpnaiilt

STATE INSU FARM STATE Withdrawal Sale Of Point 1/uo

800-956-63 PLAZA FARM

■$88.48

vviinorawai /u/

UNIVERSAL #555 HEB Withdrawal Sale Of Point 11/09

CITTXUS

IH 17599 20 STORE CORNER Withdrawal Sale Of Point 11/10

USA SCHERTZTX 35

8631 F140 MCDONALD'S Withdrawal Sale Of Point 11/10

TX ANTONIO SAN BROADWAY

Withdrawal 11/10

NE 2235 BOX THE IN JACK Withdrawal Sale Of Point 11/11

ANTONIO SAN 410 LOOP

•i40.00

•$46.13

$17.84

$8.12

-$12.00

•$4.20

Description Date

FM 5580 WIREL RING RING Withdrawal Sale Of Point Ill/ll

SCHFKT7 114 STF

IH 2017599 STORE CORNER wntiarawal bale ui point

-CONS CREDIT PAYPAL Withdrawal 11-iu/U.n tn. (i/iz

BS

LONb CntUI rHYrML wiinurawai t\\.n -1

(Rejected) DRS

CONVERSE OLD 12415 RBFCU Withdrawal ATM 11/12

rrryTvii<:

914111317P4340980- CashNetUSA Withdrawal ACH 1/14

PAYDAYADV

3009SCHERTZTXUS FM 4980 RBFCU Withdrawal ATM 11/16

SAV 184402803 to Transfer Internet Withdrawal 11/17

PERRIN 10703 Nova Super Withdrawal Sale Of Point 11/19

Antonio San RD BEITEL

IH 2017599 STORE CORNER Withdrawal Sale Of Point 11/19

N SCHERTZTX USA 35

92 Super Wal-Mart WAL Withdrawal Sale Of Point 11/20

SCHERTZTXUS

WIH 11745 OFFICE FEDEX Withdrawal Sale Of Point 11/22

TX ANTONIO SAN 10

Cleared Checks

period. statement activity this No

Amount

$1.00

$1.00

$3.00

Amount

$45.00

-$1.07

-$35.00

535700

-$160.00

-$88.27

-S40.00

-$100.00

$5.00

-$13.00

99 $2

72 -$38

$100

OF PAGE
Description

Courtesy Pay Fees

Insufficient Funds Fees

Dividends

Previous Statement Balance

S6.00

Other Information

This Period Checking

$0.00

$0.00

$0.00

PRIMARY SAVINGS SUMMARY 184402803

Savings Rate 0.20 *APYE 0.00

Total Credits Total Debits

SI 5.60 -$20.60

YTD-Checking

$0.00

-$24.00

$0.01

Current Statement Balance

$1.00

Primary Savings Account Deposits Other Transactions

Date Description Amount

11/02 Deposit Internet Transfer from 9656057 CK

11/10 Withdrawal

11/17 Deposit Internet Transfer from 9656057 CK

11/18 ACH Deposit LENDING CLUB -8885963157

Description

$10.00

■$15.00

55.00

$0.60

Date Description Amount

11/16 ACH Withdrawal LENDING CLUB -8885963157

11 /24 Withdrawal Internet Transfer to 96560S7 CK

11 /24 Withdrawal Internet Transfer to 9656057 CK

11179 Withdrawal Internet Transfer to 9656057 CK

-50.60

$1.00

-$1.00

$3.00

Other Information

This Period Savings YTD Savings

Courtesy Pay Fees

Insufficient Funds Fees

Dividends

$0.00

$0.00

$0.00

$0.00

S72.00

S0.03

'APYE: Annual Percentage Yield Earned. APYE is calculated based upon account activity and average monthly balance.

Please examine your statement upon receipt and report any differences, irregularities, or discrepancies as specified in the RBFCU Membership Agreement

PAGE OF

BENEFIT

Michael T. Paul Sign Out Need Larger Text? Accessibility Help

vfe^; my Social Security

My Home

Overview Benelit Payment Details Earnings Record My Profile

Note: If your benefit has changed in recent months, your Payment Details may not show the

most current amounts. You can view your current amounts by using the link below to "Get

Benefit Verification Letter."

Benefit Details

Monthly Benefit Amount

Payment Schedule

Next Pay~eni Date

$835 00 (before any deductions)

3rd of the month

January 3.2015

The following information should not be used as proof of coverage It Is provlaed by the

Center for Medicare Medlcaid Services (CMS) and may not reflect recont updates.

Active

Enrolled

Part (Hospital Insurance)

Coverage Started:

Monthly Premium'

Part (Medical Insurance)

Coverage Started.

Monthly Premium.

January 2005

SO 00 (as of January 2005)

November 2011

$0.00 (as of November 2011)

Part (Medicare Advantage)

Please contact Medicare for the status of your enrollment.

Part (Medicare Prescription Drug Coverage)

Please contact Medicare for the status of your enrollment

team aDout replacing your Medicare card.

Medicare Questions?

Please calLmnQ.fi33*l?27 or visltvA'.w.mediraiaiifiyfor assistance Ifvou are deaf

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print this page.

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deposited to your account

automatically.

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Envelope Details' https://efile. txcourts.gov/EnvelopeDetails.aspx?envelopeguid= 14ce74cfPrint this page

Case#2001CI16843

Case Information

Location

Date Filed

Case Number

Case Description

Assigned to Judge

Attorney

Firm Name

Filed By

Filer Type

Fees

Convenience Fee

Total Court Case Fees

Total Court Filing Fees

Total Court Service Fees

Total Filing Service Fees

Total Service Tax Fees

Total Provider Service Fees

Total Provider Tax Fees

Grand Total

Payment

Account Name

Transaction Amount

Transaction Response

Transaction ID

Order

Bexar County District Clerk

12/20/2014 03:59:59 PM

2001CI16843

Individual

michael paul

Not Applicable

$0.06

$0.00

$0.00

$2.00

$0.00

$0.00

$0.00

$0.00

$2.06

bexar county cash account for appeal

$2.06

5866037

003553213-0

Affidavit of Inability To Pay Indigency

Filing Type

Filing Code

Filing Description

Reference Number

Comments

Courtesy Copies

Status

Fees

EFilcAndServc

Affidavit of Inability To Pay Indigency

AMMENDED AFFIDAVIT OF INABILITY TO PAY COURT COSTS FOR

APPEAL

2001-CI-16843/14-14-0791

APPEAL AFFIDAVIT AMMENDED WITH CONTRIBUTING

DOCUMENTS

James.Abanaka@bexar.org

Submitting

of 12/20/2014 4.02 PM
Envek-v Details' lutps://cfile.txcourts.gov/EnvclopeDetails.aspx? cnvelopcguid= 14ce74cl'-..

Name/Email Firm

SCOT GRAYDON

SCOT.GRAYDON@TEXASATTORNEYGENERAL.GOV

GREG ABBOTT

greg.abbott@texasattorneygeneral.gov

Service

Type

EServe

TEXAS

ATTORNEY EServe

GENERAL

Status Served

No

No

Sent

Not

Sent

Date/Time

Opened

Not

Opened

Not

Opened

of 12/20/2014 4:02 PM
CERTIFICATE OF SERVICE

hereby certify that on the 20th day of December, 2014, copy of the foregoing

was served on the following pursuant to the Texas Rules of Civil Procedure:

*** COPIES WILL BE GIVEN IN COURT MONDAY MORNING AT 9:00 AM

SINCE THESE EMAIL DELIVERY NOTICES WILL STILL BE IN TRANSIT.

Scott M. Graydon

Assistant Attorney General

P.O.Box 12584

Austin, Texas 78711,2548

Donna Kay McKinney

Bexar County District Clerk

101 WNueva, Suite 217

San Antonio, TX 78205-3411

(210)335-2113

Isl Michael Thomas Paul

Michael Thomas Paul

9123 Easy Street

San Antonio, Texas 78266

210-294-4533

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COURT OF APPEALS FOURTH COURT Of" APPEALS DISTRICT

CADENA-REEVES JUSTICE CENTER

300 DOLOROSA, SUITE 3200

SAN ANTONIO, TEXAS 78205-3037

WWWTXCOURTS.GOVMTIICOA.ASPX

KEITH E. MOTTLE

CLERK OF COURT

TELEPHONE

(210)335-2635

FACSIMILE NO.

(210)335-2762

December 15, 2014

Scot Macdonald Graydon

Office of the Attorney General

PGBox 12548

Austin, TX 78711-2548

DELIVERED VIA E-MAIL

Michael Thomas Paul

9123 Easy Street

San Antonio, TX 78266

04-14-00791-CV

2001-CI-16843

RE: Court of Appeals Number:

Trial Court Case Number:

Style: Michael Thomas Paul

v.

Greg Abbot Attoreny General for the State of Texas

The copy of appellant notice of appeal in the above styled and numbered cause has this

date been filed or conditionally filed.

The fee for filing appeals in this court from the district or county is $195.00. The fee

must be paid at the time the notice of appeal is filed. In addition, this court charges an additional

fee of $10.00 for the filing of any motion. Any delay in remitting filing fee will delay the

processing of your appeal and the court's ruling on pending motions. See Tex. R. Apr P. 5.

Our records do not reflect payment of the $195.00 fee. Please remit the filing fee no later

than December 29, 2014. If the fee is not paid within the time allotted, the matter will be

referred to the court, and the appeal is subject to being stricken by the court. See Tex. R. App. P.

5. In accordance with Tkx. R. App. P. 32 and 4th Tex. App. (San Antonio) Loc. R. 5.2.,

docketing statement must be filed with the notice of appeal. Our records do not contain

docketing statement for this appeal. Please ensure that docketing statement is immediately

filed to ensure prompt processing of the appeal. The Appellant's docketing statement is due

from Michael Thomas Paul. The docketing statement is to be filed with this court by December 29,2014.

The appellate record generally must be filed in this court within 60 days after the date of

judgment is signed. See Tex. R. App. P. 35.1.

Very truly yours,

KEITH E. HOTTLE, CLERK

cc:

Deputy Clerk. Ext. 3219

Donna Kay McKinney (DELIVERED VIA E-MAIL)

Dinah L. Gaines (DELIVERED VIA E-MAIL)
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