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 NO. 2012-PR02459-1-2 and

NO. 2012-PR02459-1-2- A

THE “PURPORTED” GLORIA LOPEZ § IN THE PROBATE COURT

ESTRADA FAMILY TRUST, ALEXANDER § 

ESTRADA, “PURPORTED” TRUSTEE §

 §

 Plaintiff, § 

 § NUMBER 2

 V. § 

 §

IRMA LEAH ESTRADA-DAVIS §

A/K/A LEAH ESTRADA-DAVIS §

 §

Defendant § TARANT COUNTY, TEXAS

REQUEST FOR SUPPLEMENTAL CLERK’S RECORD

Now comes Irma Leah Estrada Davis, formerly Defendant/CounterPlaintiff in the above Cause within the Probate Court; and who now is an 

Appellant in the 2nd Court of Appeals’ Case No. # 02-14-00295-CV and 

No. # 02-14-00296-CV; and she now respectfully requests for this Probate 

Court Clerk and the Probate Court Reporters to kindly prepare and file the 

following items in a Supplemental Record and promptly forward them to the 

Court of Appeals. 

 This request is made in addition to previous requests made for such 

record and pursuant to an Order from the 2nd Court of Appeals on October 

ACCEPTED

02-14-00295-cv

SECOND COURT OF APPEALS

FORT WORTH, TEXAS

7/17/2015 5:51:29 PM

DEBRA SPISAK

CLERK

 RECEIVED IN 2nd COURT OF APPEALS FORT WORTH, TEXAS 07/17/2015 5:51:29 PM DEBRA SPISAK Clerk
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16, 2014 stating: “we order the trial court clerk and court reporter to prepare 

and file the record of the contest (to the Affidavit of Indigency) and the 

hearing on the (Indigence) contest...” 

Pursuant to Rules 34.5(a), (b), (c) and 35.3; and 35.5(a), the clerk and Court 

Reporter is requested to prepare a supplemental record of the following proceedings in 

this case for inclusion in the appellate record and please forward these to the Second 

Court of Appeals for filing in the case numbers as indicated above. 

The following information is important and critical to this case and is not 

requested for delay but is purposeful and necessary for true justice and fairness to be 

accomplished; and should be included in the Clerk’s Record and the Court Reporter’s 

Record for the 2nd Court of Appeals: 

1. The Authenticated Digital Video Disc – Video Depo which is Included inside 

the Envelope attached to Irma Leah Estrada Davis’ Affidavit dated January 3, 

2013 – which directly corresponds with the Transcribed pages of same, located 

in (Clerk’s Record Vol. 1 page 182 - 206)

2. November 2, 2012 – Defendant’s First Request for Production

3. December 7, 2012 – Plaintiff’s Certificate of Written Discovery

4. December 12, 2012 – (1st) Motion for Summary Judgment

5. December 12, 2012 - Correspondence from Staff Attorney 

6. December 17, 2012 - Waiver of Citation (2) Estela Monteleone & Joe D. 

Estrada
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7. December 21, 2012 – Notice of Death

8. January 4, 2013 - Summary Judgment Hearing

9. Feb. 1, 2013 - I.L.E. Davis’ Motion to Set Aside and for New Trial

10. February 28, 2013 – Motion to Mediate

11. April 9, 2013 – Response to Plaintiff’s Motion for Contempt; Defendant’s

Motion to Set Aside Contempt Order and for Rehearing and/or New Trial; 

and Defendant’s Motion for Sanctions

12. April 12, 2013 - Inability to complete service to Leah E. Davis

13. April 12, 2013 - Inability to complete service to Leah E. Davis through 

Attny of Record, David Courtade

14. April 12, 2013 - Notice of Trespass, Inability to complete service to Leah 

E. Davis, 

15.April 16, 2013 – Hearing setting Letter – Set for May 1, 2013 @ 9:30 am

16.April 16, 2013 – Motion Hearing (2:00 pm) (COURTADE) Motion for 

New Trial

17. April 17, 2013 - Trial Jury Request; and Order Setting Aside Summary 

Judgment and granting New Trial

18. May 1, 2013 – CANCELLED – Motion Hearing (COURTADE) 

Response to Motion for Contempt/ Motion to Set Aside Order for 

Contempt; Request for De Novo Hearing. RESET BY COURT
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19. May 2, 2013 - Notice of Appeal

20. May 6, 2013 - Defendant Irma Leah Estrada-Davis’ Counter- Motion

21. May 8, 2013 – Correspondence to Judge Morrisett From David Courtade: 

Objection to Proposed Order; and Agreed Order Granting Motion for 

Temporary Injunction

22. May 8, 2013 - Motion for Summary Judgment

23. May 9, 2013 – Correspondence - Doc. ID# 75

24. May 10, 2013 – Request for De Novo Hearing Doc. ID# 76

25. May 16, 2013 - Defendant’s Response to Motion for Contempt 

26. May 24, 2013 - Notice of Appeal; Request for De Novo Hearing Doc. ID# 77

27. MAY 29, 2013 - Amended Answer - Doc. ID# 79

28. June 18, 2013 – Rule 11 Agreement

29. July 5, 2013 - Defendant I.L.E. Davis’ Response to Plaintiff’s 2nd Motion 

for Contempt; 

30. July 5, 2013 - Defendant I. L. E. Davis’ Supplemental Cumulative

Motion for Sanctions

31. July 5, 2013 - Defendant’s Response to Plaintiff’s Motion for Sanctions 

for failure to appear for deposition

32. July 9, 2013 - Defendant’s Response to Plaintiff’s Motion for Sanctions 

for Failure to Attend Deposition
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33. July 9, 2013 - G. L. Estrada’s Trust Response to Defendant’s Response 

to Summary Motion for Summary Judgment

34. August 7, 2013 – Defendant’s Motion to Compel Accounting, for 

Contempt and for Sanctions

35. August 14, 2013 - Order to Compel Accounting of the Trustee of G. L. 

Estrada Family Trust

36. August (21 and 22) 2013 - Notice of Filing; Alexander Estrada Notice of 

Filing ?

37. August 26, 2013 – Correspondence to Ct. from Attorney

38. September 12, 2013 - Status Conference Hearing

39. October 21, 2013 - Motion for Continuance

40. October 22, 2013 - Objection to Motion for Continuance

41. October 28, 2013 - Motion for New Trial

42. November 18, 2013 - Notice of Eviction

43. November 27, 2013 - Counter Claim of Defendant Irma Leah Estrada 

Davis Severed into “A” case

44. January 17, 2014 - Correspondence to Counsel from Court Administrator 

Re: Judge’s decision on postponing hearing

45. January 21, 2014 – Plaintiff’s Reply to Defendant’s Response to Motion 

for Turn Over and/or Petition for Eviction
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46. January 23, 2014 - Defendant / Counter-Plaintiff’s Reply to 

Contingent Response of Plaintiff

47. February 2, 2014 - Motion to Quash Notice of Intent to take Oral 

Deposition of Leah Estrada

48. February 3, 2014 – Motion to Enforce Court Order

49. February 20, 2014 - Defendant I. L. E. Davis’ Motion for Dismissal; 

50. February 20, 2014 - Defendant’s Photos of Gloria L. Estrada 

signing Holographic Will

51. February 20, 2014 - Order to Enforce Court Order

52. February 26, 2014 - Correspondence from Irma Leah Estrada

53. March 24, 2014 - Defendant’s Motion to Set Aside Order Granting 

Motion for Sanctions ...contempt...contact info

54. May 5, 2014 – Plaintiff’s Response to Motion to Set Aside

55. June 10, 2014 - Response of A. David Courtade to Plaintiff’s 

 Supplemental Motion for Sanctions and/or Contempt

56. ]une 10, 2014 – Order

57. June 10, 2014 – Final Judgment

58. June 11, 2014 – Correspondence of Opposing Party and Counsel

59. June 14, 2014 – Correspondence of Defendant Estrada-Davis to 

Court Coordinator
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60. Filed in “A” Case = September 23, 2014 - Contest Affidavit of 

Indigence

61. Correspondence of Irma Leah Estrada Davis’s e-mail to Tina Clay (

The Final Supportive Evidence – The PDF Document which included 

the reference to the below Audio Recordings that were asked to be 

delivered to Judge Ferchill before the morning Hearing on November 

17, 2014 )

62. Please forward separately, the two Audio Recordings made in the 

presence of Gloria L. Estrada and Leah Estrada of: (... one is 

Attorney Bakuts, and the other is his paralegal, Cindy Adler stating 

their own unique interpretations of what G.L.Estrada’s Will is...)

those Audio recordings were e-mailed to Tina Clay – (to forward to 

Judge Ferchill) on November 17, 2014 - at 

TAClay@tarrantcounty.com) & again emailed to Jim Politz (via email to : jrpolitz@tarrantcounty.com) for inclusion to the Probate 

Record and now, to be forwarded to 2nd Appeals Court. 

63. November 17, 2014 - Miscellaneous Probate Hearing (on 

Defendant/Counter-Plaintiff’s Indegency status)
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Additionally, any and all proceedings or hearing information about

family related Cause No. 2013 PRO 0404-2 

1. February 25, 2013 – (3:15 p.m.) Probate of Will Hearing

PRAYER

WHEREFORE, Appellant respectfully prays that this Request be granted 

and that the Clerk of this Probate Court and the Court Reporter of these 

Hearings please properly prepare the above described documents and file 

such Supplemental Record to be included in this case for the Second 

Appeals Court, and for all such other and further relief to which Appellant 

would be justly entitled. Thank you in advance. 

Respectfully submitted,

/S/ Irma Leah Estrada-Davis 

Irma Leah Estrada Davis a/k/a 

Leah Estrada Davis

Executrix of Gloria Lopez 

Estrada’s Estate Appointed by 

Grantor, Gloria Estrada herself

LeahnowLaw@gmail.com

(936) 899-0313

PRO SE
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CERTIFICATE OF SERVICE

I hereby certify that on this 16th day of July 2015, a true and correct copy of 

the foregoing instrument was served on attorney David Bakutis, for Plaintiff and on 

Defendant’s previous attorney, A. David Courtade (via e-file) in accordance with 

the Texas Rules of Court. 

/S/ Irma Leah Estrada Davis

Irma Leah Estrada-Davis