andtheir theircounsel counselto to criminal criminal aand/or nd/ordisciplinary disciplinary aactions ctionsas as accessoriesor conspirators accessoriesor conspiratorsin intheir their complicity complicitywithfederal with federaland state felonies. andstate felonies.
c. Rule3.02Minimizing c. the Burdensof Rule 3.02 Minimizingthe ofLitigation Litigation
a. In a. the courseof In the course of litigation,aa lawyershall nottake shallnot takeaaposition position that unreasonablyincreasesthe costsor that unreasonably increases thecosts orotherburdensof other burdens ofthe the case... case...
b. ...0ne exampleof such impermissible b. ...One example of such conductis lawyer who impermissible conduct isaalawyerwho counsels r assists counselsoor clientin seeking multiplicationf assistsaa client in seeking aa multiplicationoof costs thsi costs or otherburdensof litigation the primary or other burdens of litigation as as the primary purpose, becausethe clientperceiveshimself more readily purpose, because the client perceives himselfas as more readily abletobear able to bear thoseburdensthan its opponent,and so hopes to gain those burdens than its opponent, and so hopes to gain
50.DAVIS,PACHECO merits... an advantagein resolvingthe matter unrelatedto the an advantage in resolving the matter unrelated to the
merits... ANDJONESviolateRule3.02by multiplying the costs 50. DAVIS, PACHECO AND JONES violate Rule 3.02 by multiplying the costs of litigationandseekingforthevictimsto putup securitywhilethey"milk"their of litigation and seeking for the victims to put up security while they "milk" their mother'sestateand/orthe familytrustto pay theirlawyer'sfees.PLAINTIFFS mother's estate and/or the family trust to pay their lawyer's fees. PLAINTIFFS requested an accounting fromPACHECO in Januaryandgraciously providedan requested an accounting from PACHECO in January and graciously provided an
Silverado Appx. 0555 No. 1-15-567-CV 1644 yet to produce yetto remotely rresembling produce anything remotely esembling an accounting - havinglittledoubt an accounting - having little doubtoof f her her client'sduty client's duty to do so to do sounder theTexas underthe TexasProperty Codeand Property Code TrustCode. and Trust Code.
Outrageously,sheattempted Outrageously, charge -$30,000 to charge she attemptedto o $50,000 -$30,000 tto $50,000 tto PLAINTIFFSsimply o PLAINTIFFS simply
be given theaccounting to begiven to to which the accounting to whichthey theyare entitledbby are entitled y lawandDEFENDANTS law and DEFENDANTSare are
statutorily required statutorily to keep. required to keep.
51. 51.P tried ACHECO PACHECO toburden triedto burdenP LAINTIFFS PLAINTIFFS withastronomical with astronomicalcosts toachieve coststo achieveresults results
would fail she would she to obtain fail to if shepursued obtain ifshe pursuedthe thea libel ctuallibelclaimassertedherein. claimasserted N actual herein. nl
52. OSHDAVIS 52.JJOSH iolatesRRule DAVISvviolates ule3.02byhisoverly broad,undulyburdensome harassing 3.02 by his overly broad, unduly burdensome harassing subpoenaduces tecum, designed subpoena duces tecum, designedto burdenPLAINTIFFS with exorbitantcoststo to burden PLAINTIFFS with exorbitant costs to depose examinedduring thoroughlyexamined with Dr. Tennisonso thoroughly the depose experts, experts, with Dr. Tennison so during the Injunctionhearing,it is to imaginehe couldhave anythingmore Injunction hearing, it is difficult to imagine he could have anything more substantialto say thanhasalready substantial to say been in opencourt. than has already been testified in opencourt.
Rule3.03 Candor toward thetribunal Rule 3.03 Candor toward the tribunal
a. Alawyershallnot knowingly: a. A lawyer shall not knowingly: i. Make afalse i. ofmaterial statement fact toatribunal orlaw Make a false statement of material fact or law to a tribunal ii. Fail to disclosea fact to a tribunal whendisclosureis necessary ii. Fail