Linda C. Tate Reddic v. Larry D Reddic Sr. ( 2015 )


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  • RE: 14-00203-CV                                                 TWELFTH COURT OF APPEALS
    TRIAL COURT CASE: 12-1808-D                                      SMITH COUNTY TEXAS
    IN THE MATTER OF
    FILED IN COUP! OF APPEALS
    THE MARRIAGE OF
    12thCouri rAoi      strict
    LINDA C. TATE                                                             I             •   i
    Mil fj5 2015 III
    AND                                                                     /ill]          / \L-—••
    LARRY DONELL REDDIC SR.                                              CATHY S. LL'k ' CLEfK \
    MOTION FOR LEAVE TO FILE ANSWER
    TO THE HONORABLE TWELFTH COURT OF APPEALS
    NOW COMES Appellant Linda C. Tate (pro se, with a head injury, limited disabilities askthe
    Courts to forgive if not in proper form) brings this Motion for Leave to File Answer in support to
    show the Courts the following reason to be Granted:
    On 6/27/2012
    a. The suit for this trial court case 12-1808-D was filed on June 27, 2012 by Appellant Linda
    C. Tate in pursuit of the required dissolution inthe 13 of 19 year Marriage (Now) of
    Linda C. Tate and Appellee Larry Donell Reddic Sr. at the advice of the Social Security
    Administration. IRS Code 6013 Section Publication 501. TFC 2.401
    Linda C. Tate states that husband abandoned their 11 year marriage of 17 (then).
    Husband left and disappeared after leaving the residence in Winona, Texas. TFC 6.005
    Weeks later Linda C. Tate heard that husband Larry Donell Reddic Sr. stood in a church
    house with a woman he met off the internet saying "he do", he do what? Without
    divorcing through the judicial system like the IRS and the Social Security Administration
    and Law says must do. TFC 6.202,Tex. R. Civ. P. 504a(4)(c) Section 25.01 Penal Code
    On 7/11/2012
    (1) Linda C. Tate hired counsel Fletcher
    a. Counsel was given on 1st day of hire over 100+ documents retrieved from home in
    Winona, Texas, mostly High Seals of Authority documentations due to her being a US
    Veteran and husband being an employee of the State of Texas.
    b. The 100+ documents given day of hire were expected to be filed with the courts in
    case of fire, lost, or destroyed. Today technology of e-file filing can be done from an
    office.
    c. Linda C. Tate hired counsel to dissolve marriage and protect her interest in her
    community assets.
    d. Counsels of Linda C. Tate after 18 months recently found and unaware of three (3)
    Scheduled Orders. Linda C. Tate was only informed by counsel of the missed
    4/16/2013 and 1/14/14 Scheduling Orders. She wasn't or had no knowledge of the
    Scheduling Order 8/20/2013. See Scheduling Orders of trial court case 12-1808-D
    e. $18,800 paid by Linda C. Tate to her counsel from 7/2012-12/2013, although
    counsel wanted/demanded an additional $15,000 (requested by lead counsel) by
    12/16/2013, and (co-counsel requested) an additional $25,000 ifthere was a need
    to go to trial which was weeks away on 1/14/14.
    f.   Counsels stated to Linda C. Tate if they didn't get the requested excessive amount
    they would have to walk off the case. $40,000 in weeks of trial. Linda C. Tate did give
    co-counsel the $500 that her son had sent her from overseas at war for Christmas in
    hope that he would stay on the case.
    g. Linda C. Tate could not meet neither request she being disabled and on a fixed
    income.
    h. Linda C. Tate has Borrowed Out from a lot of people regarding this case and to find
    out key evidence (Texas State 2002 employee tax statement with Winona, Texas
    75792 on it) was being held from client,
    i.   Once the return of the 100+ given evidence on 12/23/2013 from Fletcher, she later
    found goingthrough everything Ifound the Texas State W-2 awayfrom its original
    presentation on the next to the last page in Linda C. Tate's Deposition that was held
    7/16/2013 as if hidden,
    j. Knowing that Larry Donell Reddic Sr. had to produce the Texas State 2002 employee
    tax statement with its original presentation during request of production, what Linda
    C. Tate wants to know is how long her counsel Fletcher had that information that
    had been hid from client,
    k. The Internal Revenue Service Code 6013 Publication 501, Orders of the Court and
    their Authority has been disregarded, laws and Rules by counsels, TFC 2.401, Social
    Security Administration and the Law.
    On 7/16-17/2013
    a. Oral Depositions through the Orders of the Court was taken Under Oath of Linda C. Tate
    and Larry Donell Reddic Sr.
    On 12/18/2013
    (3). The Discovery Completion Order was to be complied by 12/18/2013. Linda C. Tate still had
    legal counsels on 12/18/2013. The Final Mediation Order was also on 12/18/2013. See
    Scheduling Order for 3rd Setting of 1/14/2014.
    a.   Husband counsel Tina Brumbelow knew Linda C. Tate still had counsel
    b. Lead counsel of Linda C. Tate withdrew on 1/6/2014
    c.   Co-counsel of Linda C. Tate withdrew on 1/8/2014
    d. No Notice or Motion to the Courts for the noncompliance of Scheduling Order in
    the Discovery Completion on 12/18/2013 was ever entered byTina Brumbelow.
    The Motion for NO Evidence Summary Judgment should have went to hired
    counsels of Linda C. Tate based on time frame, still had hired counsels.
    1. The Final Mediation Order was also on 12/18/13 to be held at (Appointed
    Mediator) Beau Sinclaire Law Office, located at 400 Broadway Ave., Tyler,
    Texas 75702
    2. Neither counsel, Tina Brumbelow, Fletcher, Healy or Larry Donell Reddic Sr.
    complied to the Courts Order on 12/18/2014
    3. Tina Brumbelow, did not tell Judge Carole Clark about her noncompliance of
    the Scheduling Order for the Final Mediation also on 12/18/2013 held at
    (Appointed Mediator) Beau Sinclaire Law Office, 400 Broadway Ave., Tyler,
    Texas 75702. Neither counsel nor Larry Donell Reddic Sr. Complied with any
    of the Scheduling Orders on 12/18/2013.
    4. Linda C. Tate was the only one showed appearance for the Scheduling Order
    for the Final Mediation on 12/18/13. She had no knowledge of the Discovery
    Completion compliance at all.
    5. Mr. Sinclaire stated to Linda C. Tate that he had been waiting on counsels
    Brumbelow and Fletcher and Healy to contact him to confirm their
    appearance of Order but no contact was made by either counsel on the
    Order of the Courts.
    On 12/23/2013
    a. Linda C. Tate received in the return of most of the 100+ documents given to counsel Is
    day of hire to be filed and presented to court, the proof to the existence of 13 year
    Marriage of 19 in order to achieve the dissolution in such matter.
    b. Upon the review of returned items witnesses statements and photos were not returned
    and Leslie lead counsel of Linda C. Tate's assistance said she would call once found but
    to this day no call or notice
    c. Linda C. Tate found the Texas State 2002 W-2 employee tax statement of Larry Donell
    Reddic Sr. that he produced in discovery (key document) that had Linda C. Tate's
    residence address of 16397 CR 363, Winona, Texas 75792 on it.
    d. Husband Larry Donell Reddic Sr. stated under oath inthe Court Ordered Deposition held
    on 7/17/2013 that he never lived at 16397 CR 363 Winona, Texas 75792, stated that he
    never received mail there. That 2002 is the attachment to their signed return filed with
    The Internal Revenue Service under the status "Married Filing Joint". Copy of the
    original filed with attachments. Linda C. Tate had a copy of 2002tax return but no
    attachments.
    On 1/6/2014
    a.   Linda C. Tate lead counsel withdrew from trial court case 12-1808-D.
    On 1/8/2014
    a. Pre-trial... six (6) days of Scheduled trial on 1/14/14.
    b.   Co-counsel withdrew from trial court case 12-1808-D.
    c.   Linda C. Tate officially became Pro Se.
    d. Linda C. Tate filed the 100+ documents of High Seals of Authority from State of Texas,
    US Department of Treasury Internal Revenue Service, Veterans Affairs, Social Security
    Administration,TexasState Office of Attorney General, Texas Department of Public
    Safety,Texas Rehabilitation Commission, Texas State Troopers Association, Pre-filed
    sealed documents, Notarized witness statements, copies of pages of deposition under
    oath with responses to perjury of husband were among the filings on 1/8/2014. Tex. R.
    Civ. P. 902
    e. Linda C. Tate prepared three (3) black bindersfor the Courts (which she filed), three (3)
    for husband's counsel Tina Brumbelow and three (3) for herself.
    f. Linda C. Tate tried to give Brumbelow her three (3) binders but her office refused Linda
    C. Tate from bringing her the copies to her office which is a block from Smith County
    Court House.
    g. Linda C. Tate waited for Tina Brumbelow's approval outside Smith County Court House
    for hours to take her the binders but she never did and the sleet was beginning to fall is
    why she went back and file the 3 for the Courts
    On 1/14/2014
    a. Trial date of Third (3rd ) Setting of trial court case 12-1808-D
    On 2/14/2014
    a. TWO MONTHS LATER, Husband's counsel Tina Brumbelow filed a Motion for No
    Evidence Summary Judgment against Linda C. Tate according to Motion for the
    noncompliance to the Scheduling Orders ofthe 321st Dist. Court on 12/18/2013.
    b. The Discovery Completion Order was to be complied by 12/18/13 when Linda C. Tate
    had legal counsel Fletcher and Healy.
    c. This Motion is days from beingtwo months after the noncompliance of the order on
    12/18/2013 and should have been place on Fletcher and Healy counsels of
    noncompliance to the order before their withdrawal dates of 1/6/2014 and 1/8/2014.
    d. "Judicial Bullying" attack on pro se litigant, with comprehension limitations (now),
    disabled spouse seeking for her rightful entitlements according to Law
    On 2/19/2014
    a. Linda C. Tate sent certified via return receipt from the USPS to husband counsel Tina
    Brumbelowon 2/19/2014. The three (3) black binders that Linda C. Tate had been trying
    to get to her after she avoided every attempt from Linda C. Tate. Receipt Return shows
    Tina Brumbelow received the three(3) black binders and a letter stating to Brumblow
    about the filing of Linda C. Tate on 1/8/2014 on 2/20/2014 USPS recording.
    On 3/10/2014
    a. The No Evidence Summary Judgment Hearing held at the 321st District Court. This
    Motion should have not been allowed before the Courts on the grounds of Entrapment
    b. There were filing of 100+documents mostly of High Seals of Authority filed by Linda C.
    Tate on 1/8/2014 but was denied during NESJ because Judge Carole Clark stated that all
    three (3) binders of High Seals of Authority given to Court, taken into 321st Dist. Court
    possession, returned back to her at a later date of 1/14/2014 by 321st Dist. Court clerk
    Sara clerk were not accepted into the Courts because of an affidavit. Tex. R. Civ. P.
    901a(7), Rule 902(1)(2)(4)(5)(8)(10)(11)
    c. In the trial court case: 12-1808-D Index Discovery Document No. 236 posted-ins by
    Court clerk Sara stated that "Mrs. Reddic filed a lot of exhibits along with her divorce
    decree but not on docket)-Sara-(was on this morning docket on 1/8/2014.
    d. Judge Carole Clark asked Linda C. Tate did she "respond", to the Motion for No Evidence
    Summary Judgment, she stated "No". Linda C. Tate wasn't aware of which one the
    responsewas addressed to, The Courts or Tina Brumbelow counsel for her husband
    Larry Donell Reddic Sr. Linda C. Tate having a head injury her processing ability is
    somewhat limited. Tex. R. Civ. P. 902(1)(2)(4)(5)(8)(11), Rule 705(a), Rule 801e(3), Rule
    503
    e. Linda C. Tate did send the filing by her on 1/8/2014 to Tina Brumbelow on 2/19/2014 by
    USPS certified return receipt on 2/20/2014.
    f.   Linda C. Tate mistake was thinking the filing of 1/8/2014 had been recorded after given
    back and the filing was okay to be presented before the Courts.
    g. She didn't understand what the Judge wastalking about or who she was referring to.
    She do know that she filed on 1/8/2014 and sent Tina Brumbelow her copies (3) black
    binders on 2/19/2014 by certified return receipt.
    h. Final Judgment Entry for the Motion for No Evidence Summary Judgment was entered in
    husband Larry Donell Reddic Sr.'s favor but violates TFC 2.401. Tex. R. Civ. P. 166a(i), IRS
    Code 6013 Section 501 Publication
    On April 2014
    a. Linda C. Tate's son of 18 months of war overseas hired Allen Law Firm of Dallas Texas for
    his mother to assist in the needed dissolution in her 13 year marriage of 19 to Larry
    Donell Reddic Sr.
    On 5/30/2014
    b. Allen to ask the Courts to grant Linda C. Tate a New Trial, Motion to Reconsider No
    Evidence Summary Judgment, Motion to Leave to File Answer, Motion for Expedite
    Hearing before June 3, 2013
    c. Upon Allen's request to the courts she sent all the filing of requested Motionsto Larry
    Reddic Sr. served by authorized server as required by law.
    d. Because of the request of Linda C. Tate, Tina Brumbelow at Larry Donell Reddic Sr.'s
    request to file a Sanction against Cynthia Allen and Linda C. Tate for requesting the
    Motions to the Courts that was presented only in the pursuit of Justice and Law, not to
    harass or cause increase in cost of husband.
    On 6/3/2014
    The Final Judgment on Motions for New Trial, Motion to Reconsider No Evidence Summary
    Judgment, Motion to Leave to File Answer, Motion for Expedite Hearing before June 3, 2014
    and the Sanction against Linda C. Tate and Cynthia Allen counsel for Linda C. Tate filed by Larry
    Donell Reddic Sr.'s counsel, T. Brumbelow at his request in trial case number: 12-1808-D was
    entered on 6/3/2014.
    a. Tina Brumbelow stated to Judge Carole Clark that Linda C. Tate and Allen request was
    frivolous in seeking Justice
    b. Tina Brumbelow stated to Judge Carole Clark that Linda C. Tate and her counsel had
    husband Larry Donell Reddic Sr. properly served by an authorized server was in
    violation because they knew she was Larry Donell Reddic Sr's counsel
    c. Judgment Entry for trial court case: 12-1808-D was entered on 3/10/2014
    d. There was No Notice of Appearance of Tina Brumbelow to the Courts after Judgment
    Entry of 3/10/2014 according to 321st Dist. Court Coordinator Vicki Dunn
    e. According to the Discovery Document Filed on 11/21/2012 of Larry Reddic Sr.'s
    Response to Linda Tate's Rule 194 Request for Disclosure on page 12, question #4
    states " attorney fees with cease to accrue when the final judgment entry is entered in
    this matter" which was on 3/10/2014
    f. Linda C. Tate and counsel had every right to serve Larry Donell Reddic Sr. as required by
    Law.
    On 7/3/2014
    Linda C. Tate went to the 321st District Court, Smith County, Texas on 7/3/2014 to file appeal
    with the courts at 4:32p.m.
    a. Two Smith County Deputies denied Linda C. Tate entry into the Smith County Court
    House because everyone had gone home they stated to her due to the observance of
    Independence Day on Friday 7/4/2014 they said.
    b. Closure hours of Smith County Courts were on normal Business Hours 8-5pm for
    7/3/2014. Most employees left early.
    c.   Linda C. Tate did not know the Courts would be closing early before 5:00 pm. on
    7/3/2014. Some employees were still there, only a few cars around the Court house It
    wasn't 5:00 p.m. Linda C. Tate had over twenty-five minutes to file her appeal according
    to the scheduled closing time of the Smith County Court House at 5:00p.m.
    d. She sat outside of the Court House with Smith County's newest hired clerk of the 321s
    as she waits for her ride.
    On 7/72014
    Linda C. Tate had to wait to file her Appeal to the 321st District Court on Monday 7/7/2014.
    7
    The Smith County library clerk stated to Linda C. Tate "that she stayed until
    5:00p.m.Thursday 7/3/2014 nor was she aware of everyone above her had left early
    for the day on 7/3/2014, they never tell her anything" when asked about closing
    hours on 7/3/14.
    Linda C. Tate, have tried within her due diligence to do her best being pro se with
    learning disability due to head injury and lack of knowledge in the civil procedure.
    Never has she intentionally neglected any process in this proceeding in pursuit of
    justice which has consumed her daily life since 2012 along with health issues.
    FACTS
    1. Linda C. Tate filed the petition for the divorce on 6/27/2012 at the advice of the Social
    Security Administration Regional Manager of the Texas Northeastern Div. on 6/26/2012.
    2. Linda C. Tate could have taken the same document the 2002 joint tax return of Larry
    Donell Reddic Sr. and Linda C. Tate given to her from the Internal Revenue Service
    Office and presented it into the courts herself.
    3. Federal and State laws requires the lawful termination of the marriage it should be
    finalized.
    4. Linda C. Tate hired counsel to protect and stop the abuse against her interest in their
    community property in the dissolution of marriage but received neither.
    5. The request of more extreme excessive amounts of monies is what Linda C. Tate has
    received from hired counsel Fletcher.
    6. Linda C. Tate paid $28,800 total in pursuit of Justice and Law regardingthe required by
    law dissolution of Marriage in this Matter which shows that Fraud with the intent to
    delay justice has consumed this case.
    7.   The Texas Family Code 2.401, The internal Revenue Service Code 6013 Section 501
    Publication status filing "Married Filing Joint", the Social SecurityAdministration also
    states a divorce from the legal judicial system is needed.
    8.   Linda C. Tate had to become an attorney,
    a.   go through all filings of 18 months,
    b. prepare a case with no information for former counsels on what they didn't do,
    c.   know the Rules of Civil Procedure in two months,
    d. know everything licensed attorneys with years of schooling don't know about the
    procedures required
    e. Iam onlya disabled wife with a head injury tryingto seek justice and the reliefinthe
    dissolution of the marriage between Linda C. Tate and Larry Donell Reddic Sr.
    According to the TFC 2.401,
    a.   Agreed to be married
    b.   Co-habitation
    c.   Holding out
    Internal Revenue Service Code 6013 Publication 501 on status "Married Filing Joint" states that
    when couples file under the status of "Married Filing Joint" they are agreeing that they are
    legally married and all information is accurate and both must sign. As husband and wife they
    did so for years. Social Security Administration warns that Linda C. Tate and Larry Donell Reddic
    Sr. must divorce and if Linda C. Tate choose to commit bigamy like husband she too would be
    guilty of the same, also they would have to have a copy of the top page of the divorce decree in
    order to terminate the marriage between Linda C. Tate and Larry Donell Reddic Sr. out their
    system.
    APPELLANT, LINDA C. TATE, prays that this Honorable Court will grant this Motion as a Matter
    of Law and Justice.
    Respectfully submitted,
    Or
    )A C. TATE-PRO-SE
    16397 CR 363
    WINONA, TEXAS 75792
    (903) 312-7446
    Email: Iindatate82@gmail.com
    Certificate of Service
    I certify that a true copy of the above was served on each attorney of record or party in
    accordance with the Texas Rules of Civil Procedure on January 15, 2015.
    .inda C. Tate, Pro Se
    10
    Payment Receipt
    Healy Law Offices, P.C.
    113 E. Houston St
    Tyler, TX 75702-8130
    Received From:
    Tate-Reddick, Linda
    Tate, Linda
    4ft Date Received        12/16/13                        Payment Amount   $500.00
    Payment Method       Check
    Check/Ref. No.       1301
    Invoices Paid
    Date               Number         Amount Applied
    07/18/13                2013-303                       -$500.00
    e+v,-\M
    <\5f
    Page 1
    CAUSE NO.               7 dUS'" 0-
    C ^&kzMi,dMj(L--                                     IN THE DISTRICT COURT
    32,"57 JUDICIAL DISTRICT
    sy\
    7    -0 /J';rJ--f'
    %             SMITH COUNTY. TEXAS
    SCH EPIJUNG ORDER
    Based on !he information available to the Court, the following schediilinsi
    order shall apply to this case unless modified by the Court. If no date is given below.
    the Item is goverv/t'ifyy ,bit'^'vxi^vkthv")'!rZ''^'}, 9,i\vew!/uK..
    THIS CASE IS DESIGNATED LEVEL
    jf -&0~ i3_DISCOVERY COMPLETED BYTHIS DATE - Attorneys may
    by agreement extend discovery; however, the trial dale shall remain firm.
    ?
    i. B-mo-                  . MEDIATION AND SETTLEMENT CONFERENCE
    COMPILED BY THIS DATE - If the case involved a Parent-Child Relationship.
    "PUTTING 'KIDS FIRST' MUST BE COMPLETED BY THIS DATE. Also, ifcustody
    "is an issue a full day of mediation is required.
    $i in®      /'?                                                      (r
    STATUS CONFERENCE will be held af/                             O'clock
    .M.
    P'fcETWi *xLC»HIr'EWL'>VC1E -mVi 'r..e YreAs!. a't C^o
    ^ •" -O          ClOCI
    7T            .M. Trial counsel are ORDERED to attend and be prepared lo discuss
    all contested aspects of the suit and trial
    5. f lb~l£                 FI.NALTRIAL will be held ;u       ty'.#>          O'clock ^
    /t
    ,M.
    6. Absent agreement. fc.m&t% , M'"^Ms appoinje d                         mediator in this case. You
    hYiysi' cvwrtVixY said mediator by
    SIGHED rVMD E.CTLWLQ,'««,'l?Hvf?ft,                 W               ./iiuy^iCI      <&•
    M \
    JUDGE PRESIDING
    IE SO. /&*/<&*-&
    §              IN THE DISTRICT COURT
    §           52fSr/uTJfCLA£ DfSTRfCr
    tddtls^A. I                               SMITH COUNTY. TEXAS.
    SCHEDULING ORDFk
    Based on he information available to the Court. the following scheduling
    order shall apply to this case unless modified bv [he Coun [f no dare Is given below
    &ejtes&&groaned ty fte'fejitt States*gCivil ProecdaR:
    THIS CASE IS DESIGNATED LEVEL
    •               DISCOVERY
    —'---'-''-•-- • -w"-1 COMP1     FTRJIRYT^ifc
    t_*-Mviri_.cji_i,»         riATc
    3i uiio OAJ    >-
    E —Attorneys may
    cv agpsoneafi tsand^imay.tamc"traA fere s'naV; remain firm.
    fr
    fl • ED BY THIS DATE -- [f me case involved aParent-Child Relationship
    "PUTTING 
    is an sssue a ti ll Jay of mediation is required.
    j.
    __ STATUS CONFERENCE will be held at                                r>-'ciock
    KJ
    ,J
    4$m€j frJetS PRETRIAL CONFERENCE will be held at 7'*^ O'clock                          C-: '3 '
    ^Z            /f   ..M. Trial counsel are ORDERED tn attend £mJ fee swani .v> v*^- • -
    ai! contesied aspects of die suit and trial.
    ;-e He
    '•"    .         O   CtOCK    ~          .Jvi.
    4W &,iLa/3
    o. Adsent agreement.,.
    — is appoirted mediator in this case. You
    must contaci s.aid mediator"hy
    SIGNED AND ENTERED on (his the                   j^_                   _ day of
    JUDGE PRESIDING
    CAUSE SO. P~ IU^-<-
    §             IN THE DISTRICT C*fcVf Itfl
    §
    y
    SCHEDULING ORDER
    order shall apply to this case unless modified by the Court. Ifno date is given below.
    Jt^VTHIS CASE IS DESSGS'ATEOLEVEL                                  .
    0J^   S       &\ a^jee ment extend di scovexv:. bow'e.ver...tha trial, dare shall tssBmmJmxL..
    ^                 JM&. {±£^0J3 MEDIATION AND SETTLEMENT CQKEESEM^
    COMPILED' BY THIS DATE -- It the case involved a Parent-Child Relationship.
    •FC Ji T\\u 'tODS FIRST WC51 BE COMPLETED BY THIS DATE. Also, ifcustody
    "is an is si is a lull day of mediation'is required.
    S, H^'i'3,9-0B STATUS OXVFEREIVCE wrtT 6e lieitfat "/' >SO O'clock
    C          .M.
    4- U* $£. :3 PRETRIAL CONFERENCE will be held at # '-^ 0 O'clock
    U            T~     -M- Trial counsel are ORDERED to attend and beprepared to discus.*
    all contested aspects of the suit and trial.
    /?'
    5lJfrvJf£dJ3 FINAL TRIA]_ w5j] be held at Y,\3D O'clock                               A   .M.
    6. Absent agreement,<&±t ^ ; ''^H appointed mediator in this case. You
    SIGNED AND ENTERED £» Ms the                      (jj             &r gf ^iflf
    2.       06/27/2012        Civil Case Information (do not haveX - Ltndtu
    3-       06/27/2012        Citation Issued (do not have) - JU/t«*-*>
    4-       07/05/2012        Respondent's Original Answer
    5-        07/06/2012        Citation Returned Served (do not have)
    6.           09/^8/2012     Appearance (do not have)
    :.': ^.7---C ii/i'5/2012        Rule ii Agreement (do not Have)
    8.        12/07/2012     Motion (do not have)
    : 9....-"":: 12/14/2012      Scheduling Order
    10.        02/13/2013    Letter (do not have)
    11. '•'.:  63/15/(20x5   •rvevnrest AV/ory- Trial (da not haw}
    12.       04/03/2013      Motion for Continuance (do not have) KpZfafofof
    13.       04/08/2013     Motionfor Continuance (do not have) / (E>rb,n\bel6&
    H-        04/10/2013     Scheduling Order (do not have)
    15-       05/10/2013       Mediation Letter (do nothaye)
    16.      06/28/2013        Petitioner's 1stAmended Petition for Divorce
    •"• ;i7-^'-: 08/06/2013        Joint Motion for Continuance             -- ft&fah**
    18.     09/17/2013        Scheduling Order
    19-     09/18/2013        Letter (do not have)
    20.      12/23/2013       Motion to Withdraw (do not have)   — "f(x^h^
    2X-      jV.27/2013        Motion for Continuance (do not have)
    22.      01/03/2014        Docket (do not have)
    23.      01/06/2014        Order to Withdraw (do not have) - ^(/thlf^tr
    24.     01/0B/2014        Docket Sheet (do not have)
    25-     01/08/2014        Motionto Withdraw (do not have) —' tfa&aA* G****f4,
    26.     01/08./2Q14       Order to Withdraw (do nothave) - MvAjq - &* ; ivo /nswawa Coverage froviaea)
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    ~*Sofi2-18Q9-D                                                                 Linda CTatc-Reddic
    16397 cr 363
    Winona, TX 75792
    (903)312-7446
    Dear Ms Brambele**.
    Iam responding toyour Motion for Ho Evidence Summary Judgment; and Order Settling Hearing on
    Motion for fuf^:##
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    BILLING DATE (MM/DD/YY): 03/08/03
    SEQUENCE NUMBER: 0095021624
    CASE NUMBER: 4568814451
    CAUSE NUMBER: 972731D
    MEMBER ID: 02855158
    #ttut tft tijc Storm? Enteral
    Utate of Qfexatf
    Chilb Support ©itriBion
    Greg Abbott
    Attorney General
    NCP 0095021624 030803 0000570 00194608
    ll...i.l.l.l...ll.l....l.l.l.l.l,..l...lll,„ll,l„l,„l,l„ll
    LARRY REDDIC
    16397 COUNTY RD 363
    WINONA, TX 75792-5717
    | IThe following are your child support obligations:
    CHILD SUPPORT PAYMENT PLAN 1                                                   MONTHLY
    Pay this amount for April: S420.00
    MESSAGES
    TOTAL PRINCIPAL            TOTAL INTEREST               TOTALARREARS            FUTUREPAY AMOUNT
    5801.25                    50.00                       S801.25                    S0.00
    YOU ARE RESPONSIBLE FOR REMITTING YOUR CHILD SUPPORT
    PAYMENT UNTIL YOUR EMPLOYER BEGINS WITHHOLDING.
    BULLING STATEMENTS WILL NOW REFLECT INTEREST OWED IFYOU
    £\€8H4DA PAST DUE SMjWCE
    ISTATE LAW PROVIDES THAT INTEREST ISOWED WHENEVER ANY CHILD
    ; SUPPORT PAYMENT IS OVER 30 DAYS LATE.
    | ALLPAYMENTS DUE AFTER SEPTEMBER 1.1991 WILL ACCRUE
    ! INTEREST IF NOT PAID ON TIME.
    VF"fWttK^ttWT3CCSTiar^Touha«aP.abatseeiis«ng8ons.                                              Apt no.
    Important!
    PO BOX 130040
    You must enter
    sse print               Can iwn or postafltoe.state, and ZIPcode. 8 youtew a foreign address, see instructions.                                           yourSSN(s)
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    TYLER                                                 TX      75713
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    rm(s)1099-R         11           Aimany resented                                                                                                             11
    «W3S               12            Business income or (toss). Attach Schedule C or C-EZ . . .                                                                  12
    hhetd.
    13            Capital gain or(toss). AttachScheo^DtTmturre& Ifnot require^                                   *• Q                         13
    14           Othergainsor(tosses). AttachForm4797                                                                                         1*
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    a W-2.
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    16a           Pensions andanmiities                   116a j                    0| b Taxable anwunt (see instructions)                   16b
    17           Recrtal real estate,re^atties, partnerships. Scwpor"                                                                        17
    dose, but do       18           Farm income or(loss).AtiachStiieduleF                                                                                        18
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    19           Unemployment compensation                                                                                                   19
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    20a          Social security benefits,                |20a|                       | b Tawbtearnount (see instructions)
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    22           AodtrwarttourttsintherarrigMccninuifbrfi^
    23           Educate expenses (see irrstnictmns)
    Ijusted            24           lr^otocHK^(fjee instructions)
    some
    25           Student loan interestdeduction (see instructions)
    26           TutUon and fees deduction (see tnstructioris)
    27           Archer MSA deduction. Attach Form 8853
    28           Movingexpenses. Attach Form 3903
    29           On&te» of sa&enrjjJoyment tax AttachSchedule SE
    30           Setf-employedhealthinsurancededuction(see instrac&tms)
    31           Serf-emptayedSEP. SIMPLE, andaaHfed plans
    32           Penalty on eanyvdhdnawai of savings
    33a          Alimonypaid b Recipients SSN »-
    34           Add Eries 23 through 33a
    35 Subtract Ene 34 from fine 22.Thisis your adjustedgross income
    ForDisclosure, Privacy Act and PaperaorkRtMtuc^
    CWA0094
    DGlfSS^                            ^CP]
    NO. 12-1808-D
    2013 km -6 PH «: 02
    IN THE MATTER OF                                 §      IN THE DISTRICT COURT
    THE MARRIAGE OF             SM1TH c;0' IMTY TEX3S
    BY_                  §
    LINDA C. TATE-REDDIC                        TpOtT       321ST JUDICIAL DISTRICT
    AND                                             §
    LARRY REDDIC, SR.                               §       SMITH COUNTY, TEXAS
    JOINT MOTION FOR CONTINUANCE
    This Motion for Continuance is brought by Linda C. Tate-Reddic, Petitioner, and Larry
    Reddic, Sr., Respondent, who show in support:
    1.      This case is set for trial on August 20, 2013.
    2.      The parties and attorneys attended a mediation on May 09, 2013 with Beau
    Sinclair as mediator.   The mediation was halted to allow the parties time to gather more
    information and to schedule depositions.
    3.      The depositions have been completed and the parties are ready to resume the
    mediation.
    4.      This continuance is not sought solely for delay but that justice may be done.
    Linda C. Tate-Reddic and Larry Reddic, Sr. pray that the Court grant the Motion for
    Continuance.
    NATALIE FLETCHER
    731 S. Vine Avenue
    Tyler, TX 75701
    Tel: (903) 592-0055
    Fax: (903) 592-6677
    s"1                                                N&eftie' Fletcher         <2*z-
    State Bar No. 24058362
    Attorney for Petitioner
    Signed on.   ?U/i3
    TINA HIGH BRUMBELOW
    P.O. Box 7677
    Tyler, TX 75711
    Tel: (903) 533-1339
    Fax: (903) 592-6684
    r.^h^J^nM"
    By:
    Tina High Brumbelow
    State Bar No. 24031890
    Attorney for Respondent,
    Signed on.      f^y/3
    I, the undersigned attorney of record, swear under oath that the above Motion for
    Continuance is true and correct.
    Attorney for Linda CITate^R
    R eddic
    SIGNED under oath before me on $J(& /*)
    VmIl£oLZ^
    Notary Public, State of Texas
    I, the undersigned attorney of record, swear under oath that the above Motion for
    Continuance is true and correct.
    ^
    Tina High Brumbelow
    Attorney for Larry Reddic, Sr.
    SIGNED under oath before me on   W/3
    s   .
    Notary Public, State of Texas
    

Document Info

Docket Number: 12-14-00203-CV

Filed Date: 1/15/2015

Precedential Status: Precedential

Modified Date: 9/28/2016