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

RE: CASE NUMBER: 12-14-00203-CV
FILED IN COI : QFAPPEALS
TRIAL COURT CASE: 12-1808-D 12th Coij
p—— . _—
IN THE MATTER OF IN THE
THE MARRIAGE OF
LINDA C. TATE TWELFTH COURT OF APPEALS
Vs SMITH COUNTY, TEXAS
LARRY DONELL REDDIC SR.
MOTION TO RECONSIDER NO EVIDENCE SUMMARY JUDGMENT
AND
THE RELIEF OF MARRIAGE AND GRANT DIVORCE ACCORDING TO LAW
TO THE HONORABLE TWELFTH COURT OF APPEALS
Linda C. Tate, (pro se, with head injury, memory and comprehension is limited) so if not in
properformat please excuse trying my best to comply. Here comes Linda C. Tate before the
Honorable Twelfth Court of Appeals, Smith County, Texas is bringing this Motion in pursuit of
Justice and Law. Upon the review of truth and facts I am asking the Courts to Reconsider No
EvidenceSummary Judgment and the Relief in the Matter of Marriage of Linda C. Tate and Larry
Donell Reddic Sr. according to Law.
The Motion for No Evidence Summary Judgment rendered in husband's favor on 3/10/2014
should be dismissed
Order for Discovery Completion was to be complied by 12/18/2013 Linda C. Tate had legal
counsel on 12/18/2014. Tex. R. Civ. P. 193.6(a)
Days from being two (2) months after the Discovery Completion order not being complied by,
is when the motion for No Evidence Summary Judgment 2/14/14.
Linda C. Tate (being pro se and limited disabilities due to head injury) husband's counsel
Brumbelow chose to attack a defenseless litigant with her motion instead of legal counsels of
Linda C. Tate who did not comply to the Orders of the Court.
The Orders from the 321st Dist. Court on 12/18/2013 ordered that the Discovery Completion
and the Final Mediation to be complied by that date. Neither counsel complied to either order
on 12/18/2013.
Brumbelow, husband's counsel never gave the Courts a Notice nor filed a Motion regarding the
noncompliance of the Orders of 12/18/2013 because she too was in noncompliance to Judge
Carole Clark's Orders.
Final Mediation was to be held at (Appointed Mediator) Beau Sinclaire Law Office, 400 S.
Broadway Ave. Ste. 102, Tyler, Texas 75702, tele: (903) 533-1005, fax: (903) 533-1379. Neither
Brumbelow, Fletcher, Healy (counsels of Linda C. Tate), or Larry Donell ReddicSr. appeared for
the Order of the Court.
Beau Sinclaire stated to Linda C. Tate that he had been waiting on counsels of trial court case:
12-1808-D to contact him to affirm the order but neither one had contacted him. Linda C. Tate
asked if she could get that in writing and he stated with disgust Brumbelow made no contact
either. No respect for the Orders of the Courts, Judges or Laws. See Scheduling Orders for third
(3rd) Setting of 1/14/2014.
Linda C. Tate was the only party to trial court case: 12-1808-D to comply by the Courts Order
for the Final Mediation on 12/18/2013 at Beau Sinclaire's Office.
Linda C. Tate has been denied all of her liberties of freedom because of perjury, entrapment
and fraud. Tex. R. Civ. P. 38.1(e), Rule 503.(d)(l)
On 6/27/2012
1. Linda C. Tate filed the petition for a Divorce at the advice of the Social Security
Administration to dissolve the 11 year marriage of 17 years (then), now 13 married of 19
years to Larry Donell Reddic Sr. TFC 2.401, IRS CODE 6013, PUBLICATION 501
2. The Internal Revenue Service (IRS) stated that a legal divorce is required through the
judicial system and they do not acknowledge common law marriages but honor each
state that do so but when couples file under the Federal status "Married Filing Joint"
they are agreeing that they are legally married and the information provided is accurate
and both spouses must sign. They filed several times and both Larry Donell Reddic Sr.
and Linda C. Tate did sign each year they filed. Internal Revenue Service Code 6013,
Publication 501
3. Husband Larry Donell Reddic Sr. left their residence, disappeared without a trace,
changed his cell phone number of 13 years, and stopped all communication with Wife
suddenly without notice, two days after leaving their residence at 16397 CR 363,
Winona Texas 75792. TFC 6.005
4. Weeks later after husband left his wife and residence, Linda C. Tate had learned and
heard her husband Larry Donell Reddic Sr. stood in a church with a woman he met off
the internet saying "HE DO", he do what? Without a Divorce from Linda C. Tate:
Intentionally Committing a felony, bigamy, abandonment, fraud. TFC 2.002, TFC 2.22,
TFC 2.401, TFC 2.501, TFC 3.002, TFC 3.003(b), TFC 6.002, TFC 6.003, TFC 6.005, TFC
6.202, TFC 7.001, TFC 7.001, TFC 7.002, TFC7.003, TFC 7.004, TFC 7.005, TFC 7.007, TFC
7.009, TFC 8.001, TFC 8.051(2)(A)(B), TFC 8.052(3)(4)(6)(7)(9)(10), TFC 8.054(2)(A)(B),
TFC 8.055(1)(A-G), TFC 9.013, TFC 9014, TFC 9.101
6/27/2012 -1/8/2014
1. Linda C. Tate filed petition for divorce herself on 6/27/2012
2. Linda C. Tate had hired legal counsel Fletcher
3. Over 100+ items mostly documentation of High Seal of Authority Authorized by Law that
was given to Fletcher to befiled and presented to Courts by Linda C. Tate 1st day ofhire.
Tex. R. Civ. P. 902(l-2)(4-5)(8)(10-ll), Rule705(a), Rule 901a(7)(10), Rule 1004, Rule
1005, Rule 1006
(a). Afterl8 months of hire, Fletcher and co-counsel Healy demanded by12/16/2013
$15,000 +$25,000 ifthere was a need to goto trial which wasweeks away $40,000 or
they was going to get offthe case 12-1808-D, Linda C. Tate was out of $18,800.
(b). Fletcher failure (3 Scheduling Orders). Linda C. Tate was unaware ofthe 2n
SchedulingOrder of August 20, 2013. Counsels never informed client of such setting.
Tex. R. Civ. P. 504a(3)
(c). Failure to disclose the (Key) 2002 Texas State Department of Public Safety issued by
the State of Texas W-2 employee tax statement to client with Linda C. Tate's residence
of he and his Wife located at 16397 CR 363, Winona Texas 75792 on it. Tex. R. civ. P.
503d(3)(4)
(d). In the Court Ordered Deposition of Larry Donell Reddic Sr. on 7/17/2013 Under Oath
he stated "he never lived there", "didn't have or received mail there", the 'Texas State
patrol car never resided there" but the (Key) 2002 W-2 says different also (the
community witness statements says different). Tex. R. Civ. P. 801e(3), Rule 705(a)
(e). How would the DPS know Linda C. Tate address if he didn't live there and he did
until he disappeared and weeks later stood in a church with a woman he met off the
internet. Tex. R. Civ. P. 504a(4)(c), TFC 7.009
(f). That one (Key) document that was given to Linda C. Tate by Fletcher with the
returned items from Fletcher Law Office was hid in the next to the last page of Linda C.
Tate's Deposition away from its original presentation. Fletcher knew of its importance
(KEY) to case 12-1808-D. Tex. R. Civ. P. 404(b)
(1). A copy of (Larry Donell Reddic Sr. and Linda C. Tate) 2002 original tax returns W-2
issued by the State of Texas and the missing piece needed to end all intentional disputes
in the delay of justice and prohibited liberties of Linda C. Tate. Tex. R. Civ. P. 404(b)
(2). That document proves Marriage also husband's counsel intentional assistance to
aide in crime and fraud against Linda C. Tate, the Wife of Larry Donell Reddic Sr. Tex. R.
Civ. P. 503.(d)(l), Rule 404(b)
(g). Tina Brumbelow helped in the discovery of that Texas State W-2 document by
requesting, gathering, reviewing, sharing, sending and the filing of, but stood before the
courts and stated NO EVIDENCE In trial court case: 12-1808-D. Brumbelow knew of the
over 100+ and of the Court Ordered Depositions.Tex. R. Civ. P. 504a(4)(A)
(h). How long has Fletcher had that one (KEY) document? Production was done in 2012.
It's undisputed both counsels had the (KEY) determining document it in their possession
even her husband he produced it. Rule
(i). Brumbelow, Fletcher and Husband knew of the existence of the Texas State W-2 of
Larry Donell Reddic Sr. for the year 2002 that shows place of residence through the
State of Texas, perjury, intentional fraud against Linda C. Tate and has been for years.
Masey v. Masey, 807 S.W. 2d 391 (Tex. CT. App. 1991)
4. Linda C. Tate handed her new hired counsel Fletcher 100+ documents; photos, High Seal
of Authority documents, pre filed seals of Authority that she retrieved from her
residence that she and husband Larry Donell Reddic Sr. resided along with Linda C. Tate
children. Tex. R. Civ. P. 1006
5. Linda C. Tate expected all document to be filed with the courts no later than the second
(2nd) day of her possession whether she used them or not. Nowadays technology has
advanced to e-file in the courts where you can file a document from your office in case
of fire, lost, stolen or destroyed. Linda C. Tate could have filed all the 100+ herself they
were in her possession within her storage building at home.
6. A prime example why received documents from clients should be filed immediately is
when Linda C. Tate's withdrawing counsel returned most of the 100+ documents and
items some items was not listed that was given to her like: (a). Now deceased neighbor's
witness statement of Mrs. Jewel Choice,
(b). Apartment's assistant maintenance personnel, Bryan Kirkling 2006-2009 of
Bellwood Rd Apts. sworn witness statement.
(c). Clifton Bradford Jr., original hand written statement
(d). Cutiest Bell, neighbor's witness statement, sister photo's missing.
(e). Client called several times for the return of unreturned items but Fletcher assistant
Leslie said she would call once she found them she still await that call.
7. (f). It's very important to file a client document if something happens (organized and
structure). Tex. R. Civ. P. 803(24)
8. No paying client should have to make a call like that, if so they should be told everything
was e-filed to the courts. In 18 months not one document filed, or e-filed to the courts
by Natalie Fletcheror Healy from 1st day of hire. There is no excuse, paid $18,800 and
both were requesting $40,000 more, weeks before scheduled trial on 1/14/14/ to
complete trial court case number: 12-1808-D not the $1,200 most pays for divorce.
9. Linda C. Tate had a copy of their 2002 tax return status "Married Filing Joint", but I
didn't have any attachments. Larry Donell Reddic Sr. produced it in the discovery. Tex. R.
Civ. P. 401
10. Three (3) Scheduled Hearings. See Scheduling Order of trial court case number: 12-
1808-D should have been finalized 4/16/2013. Linda C. Tate had proof of marriage, hired
Fletcher to protect her interest in the community property which was never received.
11. Upon review of Index Pleadings a lot of continuances in 12-1808-D and request of
monies from counsel Fletcher.
12. No Evidence was filed on Linda C. Tate's behalf even when Discovery Completion orders
of court deadline of 12/18/2013 was intentional disregarded by Fletcher and Healy,
although husband's counsel Tina Brumbelow never filed a Notice or Motion to the
Courts about the order not being complied. Linda C. Tate still had hired counsels Natalie
Fletcher and Healy on 12/18/2013. They withdrew on 1/6/14 and 1/8/14.
13. Linda C. Tate believes that if she would have handled her own divorce it would be over
and $28,800 richer also not in now financial ruins.
14. After 2.5 years almost three, setbacks, she is where she started pro se with all the
documents retrieved from home at 16397 CR 363, Winona, Texas 75792
15. High Seal documents of Authority that shows truth and Law. Intentional Fraud, perjury,
and abuse is the only reason why this marriage has not been dissolved according to Law
On II16-17/2013
a. Depositions Order by the Court Under Oath of Larry Donell Reddic Sr. and Linda C. Tate
On 1/6/2014
a. Linda C. Tate lead counsel Fletcher withdrew date
On 1/8/2014
a. Linda C. Tate co- counsel withdrew date
b. Linda C. Tate officially became pro se date
c. Pre-trial date
d. Linda C. Tate requested to take husband Larry Donell Reddic Sr.'s counsel Tina
Brumbelow the three(3) black binders of evidence prepared for her to her office which
was only a block from Smith County Court House at 210 S. Broadway, Tyler, Texas
e. Linda C. Tate waited for hours outside the court house waiting on the approval of
husband's counsel Tina Brumbelow but never received it so I went back into the court
house once it began to sleet and filed the three (3) black binders before the ice storm
came.
f. This is when Linda C. Tate realized that Tina Brumbelow husband's counsel was avoiding
receiving the binders of facts and documents of High Seals of Authority, the 100+
documents filed at the 321st Dist. Court.
On 1/14/2014
a. Date of Scheduled Trial. See Scheduling Order
On 2/14/2014
1. Tina Brumbelow, counsel for Larry Donell Reddic Sr. filed a Motion for No Evidence
Summary Judgment in the trial court case number 12-1808-D in the Matter of Marriage
between Linda C. Tate and Larry Donell Reddic Sr. Knapp v. Eppright, 783 S.W. 2d
293,295 (Tex. App.-Houston [14th Dist.]1989, No Writ.
2. The Court Order for the Discovery Completion date was 12/18/2013. Linda C. Tate had
legal counsels on 12/18/2013 who did not comply to the Orders of the Court. Not Linda
C. Tate otherwise if known she would have complied as she done on the 1/8/14 filing.
3. Days from being two (2) months after the noncompliance of Discovery Completion
Order that Linda C. Tate hired counsels did not comply to the Order, Tina Brumbelow
entered a No Evidence Summary Judgment Motion on 2/14/14.
4. The No Evidence Summary Judgment Motion Brumbelow filed should have been issued
to Fletcher and Healy. On 12/19/2013. Two months later she filed the Motion on Pro Se
Linda C. Tate (with head injury) she knew of her limited disabilities.
5. No Notice or Motions to the Courts that the Discovery Completion Order or the Final
Mediation Order of 12/18/2013, neither had not been complied by Fletcher or Healy
counsels of Linda C. Tate in trial court case 12-1808-D.
6. The Order of Discovery Completion and the Final Mediation was never intentionally
complied by either counsel in case: 12-1808-D that was scheduled on 12/18/2013.
7. Final Mediation at Beau Sinclaire Law Office was intentionally disregarded by all
counsels in case: 12-1808-D. Linda C. Tate was the only person of appearance for the
mediation on 12/18/2013.
8. Mr. Beau Sinclaire of Sinclaire Law Office stated on 12/18/2013 to Linda C. Tate that he
had been waiting on Fletcher and Brumbelow to call to confirm their appearance to the
Mediation Order of the Courts but neither one, Brumbelow, Fletcher, Healy or Larry
Donell Reddic Sr. had contacted him or appeared for the order to be held at Sinclaire
Law Office, Tyler, Texas.
9. This total disregard of the Law and the ones we hold accountable to protect it, honor,
uphold, serve, defend, Pledge to an Oath, citizens trust, are the ones who on a daily
constantly violate it.
a. Since the proceeding of trial court case 12-1808-D, Linda C. Tate has had the
opportunity to observe firsthand the injustice and attack against her by counsels
that has been intentional and personal.
b. Excessive amounts of monies paid and requested or they'll walk off case weeks of
trial. It appears that the noncompliance of the 12/18/2013 was because of disregard
or planned for an extension for more monies to be rendered from Linda C. Tate by
hired counsels
c. Hiding and failure to disclose sensitive (key) evidence from client assisting in the
delay of liberties of Linda C. Tate.
d. Perjury to Judge Carole Clark with no regards of Authority or consequences
e. Counsels appears to judicial settings of choice but not by the Orders of the Court
f. Sharing confidential information Linda C. Tate shared with Fletcher on 1/8/2014
about finding the Texas State employee W-2 tax statement of Larry D. Reddic Sr.with
their Winona address on it to Husband's counsel Tina Brumbelow about me finding
it away from its original presentation as if it was being hid in the next to the last
page of Linda C. Tate Deposition of 07/16-17/2013. Linda C. Tate was standing
behind Fletcher and Brumbelow stated "he will be jumping through hoops". Tex. R.
Civ. P. 504a(l)
On 3/10/2014
Linda C. Tate (pro se) with a head injury, processing things and comprehension are not
100% but not 0%, especially spoken words are now sometimes challenging when normal
conversations loses her if spoken at a fast pace. Brumbelow and Husband knew of Linda
C. Tate's limited disabilities throughout the years.
1. Linda C. Tate really didn't know why her husband's Larry Donell Reddic Sr. counsel Tina
Brumbelow would file such a judgment on 2/14/2014, days from being two (2) months
after the noncompliance of her hired then counsels, when the Discovery Completion
and Final Mediation was to be complied by 12/18/2013 when Linda C. Tate had legal
counsels. See3rd Scheduling Order oftrial case number 12-1808-D
2. Linda C. Tate's filing was done the very day of their pre-trial 1/8/2014, the same day she
tried to give Tina Brumbelow three (3) binders of evidence that she was denied in taking
in to Brumbelow's office to give her.
3. Linda C. Tate was asked about "responding" to the Courts regarding the No Evidence
Summary Judgment she stated "NO", she had already filed the 100+ documents (3 black
binders)with the 321st Dist. Court on 1/8/2014, those binders [were stamped, taken
into 321st Dist. Court possession, given back at a later date of 1/14/141. Tex. R. Civ. P.
902(1)(2)(4)(5)(8)(10-11)
4. Anyone would assume filing in that order was proper. Ifthe filing wasn't correct why
would clerks stamp for acceptance to the courts, take it and give back at a later date.
5. No one said otherwise, the 321st Court clerk Sara who returned the 3 black binderson
1/14/2014 to Linda C. Tate., nor did the accepting clerk say there was an error in the
filing of mostly High Seal of Authority Documents within the binders. No affidavit
needed. Tex. R. Civ. P. 902(1)(2)(4)(5)(8)(10)(11)
6. Linda C. Tate being an US Veteran and Larry Donell Reddic Sr. being a Texas State
employee, most of filed document by her were of Federal or State.
7. Linda C. Tate mistakenly assumed that there was no need to respond to the courts
because she mistakenly thought everything in the filing was okay and ready to be
presented to the Courts. Cf. Stanley V. Citifinancial Mortg. Co., 121 S.W. 3d 811, 815-16
(Tex. App.-Beaumont 2003)
8. That is when Linda C. Tate realized that Tina Brumbelow was avoiding receiving the
three (3) black binders that Linda C. Tate had prepared for her, three (3) for the courts
and three (3) for self.
9. Linda C. Tate did respond to Tina Brumbelow on 2/19/2014 via certified return receipt
of the three (3) black binders that she had been trying to give her but refused by
avoiding to accept, along with a letter stating that she had filed the contents of the
three (3) black binders with the Courts on 1/8/2014, the same day her office denied
Linda C. Tate from taking them to her which is only a block from the Smith County Court
House before the sleet began to fall. Linda C. Tate stays 20 miles away, the rural of
Winona, Texas.
10. Not at any time did the clerk state to Linda C. Tate that the filing on 1/8/14 were not in
proper order to be filed once she accepted the three (3) black binders otherwise she
would have given them back to for the correction. Smith County has a Notary in the
Library basement if she had known of any corrections needed. She had been waiting for
Tina Brumbelow outside of Smith County Court House for hours to get her approval
which she never received or was given.
11. The Courts gave back the (3 black binders) to Linda C. Tate on 1/14/2014 from the 321st
Dist. Court Clerk Sara.
a. Sara never stated that the three (3) binders had not been entered into the recording
of the Court to Linda C. Tate nor did she state there was a need for an affidavit. See
the Discovery Document Index, No. 236, SARA the 321st Dist. Court Clerk posted
"Mrs. Reddic filed a bunch of exhibits in with her "Judgment Entry Decree of
Divorce)-Sara (was on this morning's docket 01/08/2014). Tex. R. Civ. P. 901, Rule
902
b. Clerks of the judicial system can't tell a citizen seeking justice "you need an
affidavit"?
c. According to Tex. R. Civ. P. 901, Rule 902(1)(2)(4)(5)(8)(11), Documents of High Seals
of Authority do not need an affidavit. No need to question its truth because it's
based upon law.
d. High Seals of Authority Documents from the State of Texas, US Treasury Dept.
Internal Revenue Service, Social Security Administration, Texas Department of Public
Safety, Veterans Affairs, Texas State Office of Attorney General, Notarized Witness
Statements, Texas State Troopers Association, Department of Public Safety Officers
Association, United States Postal Services, Pre filed documents, State of Texas
Security Officer license (non-commissioned), Texas State calendar, Sealed
documents, Smith County Tax Records, Texas Rehabilitation Commission, under oath
copied pages of Larry Donell Reddic Sr.'s deposition with responses from
documents, cell phone records, medical records, bank accts. of Larry to show
intentional perjury, bigamy, fraud, abuse were among the 100+ documents filed on
1/8/2014 by Linda C. Tate. Tex. R. Civ. P. 1006
Tina Brumbelow, counsel for Larry Donell Reddic Sr. committed perjury to the judge
a. She stated that there was "No Evidence", she received via certified return receipt
from USPS dated 2/19/2014 to her from Linda C. Tate on 2/20/14, the $18.35 (3
black binders) and the $6.98 (letter). Daughter of Linda C. Tate took pictures of Tina
Brumbelow with the three (3) black binders in her possession the very date of the
No Evidence Summary Judgment on 3/10/2014. Tex. R. Civ. P. 503(d)(1)
b. She being Husband's counsel since 7/2012, she assisted in the gathering, producing,
the requesting, sharing, filing of all evidence of both counsels from start, she
committed perjury. Tex. R. Civ. P. 504a(4)(A)
c. If the response asked in the Courts about "responding" was addressed to Tina
Brumbelow in the receiving of a response from Linda C. Tate? Certified via return
receipt from USPS sent on 2/19/2014 from Linda C. Tate and Tina Brumbelow
received on 2/ 20/ 2014. She stated to the courts and Judge Carole Clark there was
no response, she committed perjury.
d. She stated to the Judge Carole Clark that Linda C. Tate was married to someone else,
she committed perjury
12. She stated to the Judge Carole Clark that discovery was to be complied 12/18/2013.
a. She didn't inform the judge that a scheduled Final Mediation was to be compiled by
12/18/2013 also and that she, Fletcher, Healy or Larry Donell Reddic Sr. attended, no
contact or communication with Mediator Beau Sinclaire as he waited on their call to
satisfy order from the Courts but no response to he stated to Linda C. Tate that
attended the Order of the Courts on 12/18/2014.
13. "With No Regards of the Court's Authority is the highest form of Disrespect" Tina
Brumbelow, Natalie Fletcher, Healy or Larry Donell Reddic Sr. never contacted Mr. Beau
Sinclaire (Mediator) in regards to the Court's order of the Final Mediation in the matter
of trial court case 12-1808-D on 12/18/2013 nor the compliance of the court's order".
See (3rd Scheduling Order)
14. Linda C. Tate was the only one appeared for the mediation and this is what Mr. Beau
Sinclaire of Sinclaire Law Office stated to Linda C. Tate on 12/18/2013 at his office
located 400 S. Broadway Ave. Ste. 102, Tyler, Texas 75702, telephone (903) 533-1005,
Fax: (903) 533-1379. See Scheduling Order in trial court case number: 12-1808-D on
12/18/2013.
15. Mr. Sinclaire (Mediator) appeared at the Pre-trial Hearing on 1/8/2014.
a. Mr. Sinclaire knowing that Tina Brumbelow, Fletcher, Healy or Larry Donell
Reddic Sr. did not comply with the Court Orders for 12/18/2013.
b. He asked for Tina Brumbelow, Larry Donell Reddic Sr. and Linda C. Tate to meet
at his office on the 1/11/2014, after the scheduled pre-trial that was on 1/8/14
and days from scheduled trial hearing date of 1/14/14.
10
c. The violation for not complying wasn't a mistake by either legal counsel involved
in trial court case number: 12-1808-D. It was a matter of disrespect, a disregard
of the Authority not only the Court but to the Judge Carole Clark and disgust of
Mr. Sinclaire, for his time wasted.
d. No Motion to extend time for Final Mediation to the Courts showing failure to
comply with the orders of Final Mediation from Tina Brumbelow in the INDEX
PLEADINGS as of this day.
16. Neither did Tina Brumbelow inform Judge Carole Clark that Linda C. Tate still had legal
counsels on 12/18/2013 since discovery should have been complied [3/10/14 -Court
Record- pg.6 (13-21)].
a. The completion order of discovery wasn't an issue on 12/18/2013,12/19/2013,
to Husband's counsel Tina Brumbelow since the order of the Court had not been
complied by Fletcher or Healy.
b. There's was not a "Motion" presented to the Courts in the INDEX PLEADINGS for
a No Evidence Summary Judgment to Linda C. Tate's lead counsel Fletcher that
was filed by Tina Brumbelow that withdrew on 1/6/14, or to co-counsel Healy
that withdrew 1/8/14.
c. Discovery completion issues should have been addressed to Fletcher and Healy
like any other professional counsel would do defending their client in pursuit of
justice, instead of waiting until 2/14/14 (a month after scheduled trial date of
1/14/14, also days of being two (2) months after the non-compliance with the
Court order for the completion of discovery on 12/18/2013) in the trial court
case number: 12-1808-D.
d. The 321st Dist. Court was opened she never filed a Motion for No Evidence
Summary Judgment not even on the day Linda C. Tate's lead counsel Fletcher
withdrew 1/6/14 or on 1/8/14 co- counsel Healy withdrew in the Index
Pleadings. No Notice or Motion to Courts not even to Judge Carole Clark.
e. The completion of discovery on 12/18/2013 wasn't an issue to Husband's
counsel Tina Brumbelow, and she being a professional counsel with a paying
client? What counsel wouldn't notify the Courts of a non-compliance of a Court
Order, maybe one who has intentions to commit fraud to file when Linda C. Tate
become pro se for only a month, defenseless, to stop all avenues of her rightful
liberties of Law, attack, fraud to assist in the continued mental anguish that has
been placed on Linda C. Tate in pursuit of Justice.
f. Brumbelow, waited until 2/14/14, also being days of two (2) months later after
discovery compliance of 12/18/2013 and attack Linda C. Tate being pro se for
only a month, defenseless towards her fraud, intentional entrapment,
11
intentional infliction of emotional distress, intentional delay of faced denials in
her pursuit of Law and Justice,
g. Linda C. Tate feels this attack is Personal and Cruel to intentionally strip a person
of their entitlements, freedoms and liberties, with no regards of the law or
penalties thereof. Tex. R. Civ. P. 503(d)(1), TFC6.002.
17. Tina Brumbelow counsel of Larry Donell Reddic Sr. sent the Motion for No Evidence
Summary days of being two (2) months, after Court's order on discovery completion
compliance had not been met to Linda C. Tate on 2/14/14. Actually the No Evidence
Summary Judgment should have went to the legal counsels that Linda C. Tate paid
$18,800 and were still legally still under contract until withdrawal through the Courts.
a. The Motion for No Evidence Summary Judgment shouldn't been permitted on
3/10/2014 due to intentional entrapment, intentional delay of justice, intentional
emotional distress with the intent to sabotage case 12-1808-D. Two months later
and no notification to Courts about the order of Discovery completion day of
12/18/2013.
b. If the Court's response was meant for Linda C. Tate in regards to the response of
getting the 3 black binders to Tina Brumbelow.
c. According to Tex. R. Civ. P. 9.2(b)(1), the "Mailbox Rule" if the filing was on
2/14/2014.
(1). It actually allows an additional 3 days which allows 24 days under Rule 9.2.
(2).The count starts on 2/15/2014
(3).The 15th + (13) = February 28' 2014 + March 10, 2014. (13 + 10)=23 (didn'tmeet
24 days) Earliest NESJ Judgment should have been issued on March 11, 2014.
(4). Smith County Court House was closed due to ice storm on March 3rd2014 and
March 4th2014 due to ice storm, that's two(2) makeup days
(5).The 23 days + 2 makeup days + 1 (from 23) = (26 total days) Earliest NESJ
Judgment should have been issued is on March 13, 2014
(6) NO EVIDENCE SUMMARY JUDGMENT WAS ISSUED ON WRONG DATE. Tex. R. Civ.
P. 9.2(b)(1)
18. Tina Brumbelow didn't inform Judge Carole Clark about the Court Ordered Deposition
held Under Oath on 7/16/2013 and 7/17/2014 of Linda C. Tate and Larry Donell Reddic
Sr.
19. NO EVIDENCE SUMMARY JUDGMENT was entered 3/10/2013 because the Judge Carole
Clark stated that filed stamped evidence given to the courts was not a response. Any
orders from the Courts should be notified immediately upon noncompliance unless
there's malicious intent of the party or disregards of that order.
12
a. Linda C. Tate made the mistake thinking that if the courts accepts a document,
stamp it, hold in their possession for a week, then later return the document
without stating "you need an affidavit" or "we didn't record the documents given"
for whatever reason she would have prevented the Motion for No Evidence
Summary Judgment because she knew Husband's counsel Tina Brumbelow was
avoiding in the receiving of what she had prepared for her (3 black binders of
evidence).Tex. R. Civ. P. 198.3.
b. Evidence of High Seals of Authority, Notarized witness statements, pre filed sealed
documents, copies from Depositions sworn under oath documents should have been
accepted into any level of the judicial system according to the Rules. No affidavit
needed. Otherwise the Motion for No Evidence Summary Judgment wouldn't have
been permitted. Tex. R. Civ. P. 401., 404(b), 902(1)(2)(4)(5)(8)(11)
c. Linda C. Tate was not aware of her filings of High Seal of Authority Documents on
1/8/2014 were not accepted by the courts until the No Evidence Summary Judgment
Hearing when Judge Carole Clark stated so on 3/10/2014. Tex. R. Civ. P.
902(1)(2)(4)(5)(8)(11)
20. No review from the Judge Carole Clark regarding trial case number 12-1808-D, no
review of the Scheduling Orders on three (3) Trial Dates in 18 months; Depositions
Ordered by the Courts, Index Pleading; Discovery Index Mediation Ordered by the
Courts; Events and Orders of the Court; Interrogations; Production; Discovery Index;
Request for Disclosure Rule 194; Admissions; Objections and Answers to see whether if
Tina Brumbelow was aiding client in crime or fraud, delaying Justice or denying ones
Rightful Entitlements according to law was never asked from the judge. Tex. R. Civ. P.
166 a (b). McLendon v. Detoto, No. 14-06000658-CV, 2007 Tex. App. LEXIS 5173 (Tex.
App.-Houston [14th Dist.] July 3, 2007, Pet. Denied).
a. Since the proceeding started on 6/27/2012 and it's now 3/10/2014, no review or
questions asked as to what was done within the trial court case 12-1808-D. "No
Evidence" husband's counsel Brumbelow stated, never asked by the judge was there
any court ordered Depositions under oath?, were there orders of mediations?, what
were the orders of the court? were there any filing of 12-1808-D?, No notice that
Linda C. Tate had only two months to know everything about a trial case of twenty
(20) months with three legal counsels from the start.
b. No notice or review of Linda C. Tate's counsel withdrawal dates of 1/6/2014,
1/8/2014 and the Motion for No Evidence Summary Judgment dates Tina
c. Brumbelow entered to the Courts 2/14/2014 which was only Intentional Entrapment
and also being days of two (2) months overdue noncompliance order of the Courts
for the discovery compliance of 12/18/2013.
13
d. No question about the discovery completion date of 12/18/2013; never asked why
did it take her days from being two (2) months to file the motion against pro se
Linda C. Tate when it should have been filed 12/19/2013 against counsels of Linda C.
Tate, Fletcher and Healy when they are counsels of the noncompliance to the
discovery order on 12/18/2014 also still counsels of record.
e. Did trial court case number 12-1808-D of 321st Dist. Court, Smith County, Texas stop
for 12/2013-2/14/2014, stop being counsels until they withdrew because Linda C.
Tate refused to give an additional $40,000, $15,000 for December 2013 and the
$25,000 for trial if we had to go.
(1) A missed Christmas Cruise planned for the Caribbean by Fletcher and Healy.
Healy took his family but Fletcher didn't. Healy told Linda C. Tate when she took
him the last $500 in December 2013 before Texas Legal Aide of Tyler, Texas told
Linda C. Tate not to give up another dime.
f. It is undisputed Brumebelow didn't file a Motion or give Notice to the Courts for the
Discovery Completion on 12/19/2013 for not complying to orders of Discovery
Completion against her new found BFF and Facebook buddy Natalie Fletcher and
Healy, counsels of Linda C Tate.
g. This attack on Linda C. Tate is very Personal and Cruel, beyond the standard judicial
conduct and the oath sworn to.
(1) When a counsel stands before the judge commits perjury and aide in fraud
(2) to disregard the orders of the Court: Final Mediation-no show, No Notice or
Motion of noncompliance of order 12/18/13, two months later file a Motion
against a pro se client instead of hired counsels of order when rendered
(3) then presented a dead man, frivolous groundless Sanction to the Courts to
stop Justice for properly being served on June 3, 2013 also.
(4) To intentional prohibit a pro se litigant or anyone from seeking justice that's
within the law and in pursuit of justice from their liberties with the intent to
cause inflictions of emotional distress, infliction of mental anguish, infliction
to cause financial ruins, infliction of medical setbacks, infliction of harm, yes
it's a personal attack with NO REGARDS OF THE LAW which one is entitled to.
21. Discovery completion was not a factor to Tina Brumbelow as of 12/18/2013-2/13/14
a. No Motion or Notice were ever filed by Tina Brumbelow to the courts informing the
Courts of the order of discovery completion on 12/18/2013 had not been complied
before Linda C. Tate's withdrawing counsels withdrew on 1/6/2014 and 1/8/2014.
b. No Motion or Notice to the Courts was filed about the discovery completion
deadline of 12/18/2013 before or on the scheduled pre-trial of 1/8/2014 and (Linda
C. Tate became pro se).
14
c. No Motion or Notice to the Courts of order for discovery was not met nor was
anything filed seven (7) days prior to trial date of 1/14/2014. "Judicial Bullying".
d. Discovery completion required on 12/18/2013 according to her statement regarding
to Tex. R. Civ. P. 166(a)(c) on 3/10/2014, that discovery is required seven (7) days
before the hearing, which was to be tried on 1/14/2014 which was less than seven
days before the scheduled trial before counsels withdrew, No Motion or Notice to
the Courts. See Index Pleadings of trial court case 12-1808-D. [page 6 (13-21) ] of
Court Record on 3/10/2014. Malooly Bros., Inc. v. Napier, 461 S.W. 2d 119,121 (Tex.
1970)
e. Brumbelow knew there were over 100+ documents, Court ordered Depositions,
Court ordered Mediation, Notarized witness statements, many filings affirming the
marriage of Linda C. Tate and Larry Donell Reddic Sr. also why the divorce was
brought forth through the advice of the Social Security Administration, US
Department of Treasury: The Internal Revenue Service (IRS) and Texas Family Code
2.401. Tex. R. Civ. P. 603. TFC 2.401, Speck v. Lutheran Church of Houston, 235 S.W.
3d 811 (Tex. App.-Houston [1st Dist.] 2007, No Pet.
f. Tina Brumbelow counsel of Larry Donell Reddic Sr. has violated every Rule under
intent damages in Tex. R. Civ. P. 503(d)(1), Rule 41.001
FACTS REVIEW
On 6/27/2012
a. Linda C. Tate filed the petition for divorce at 321st District Court, Smith County, Texas
b. At this time Linda C. Tate had been Married for 11 years of 17 to Larry Donell Reddic Sr.
Tex. R. Civ. P. 504a(4)(c) Section 25.01 Penal Code
c. She had Husband Larry Donell Reddic Sr. served by authorized server of Smith County
Sheriff Department notification of divorce proceedings.
On 7/11/2012
a. Linda C. Tate hired Natalie Fletcher and co- counsel to dissolve Marriage and stop the
abuse against her and her interest in their community assets. Texas Family Code 2.501
b. 100+ documents given to counsel Natalie Fletcher from Linda C. Tate to file as evidence
to be presented in the proof of Marriage and Divorce. Tex. R. Civ. P. 401, Rule 404(b)
15
c. High Seals of Authority Documents from the State of Texas, US Department of Treasury:
Internal Revenue Service, Social Security Administration, Texas Department of Public
Safety, Veterans Affairs, Texas State Office of Attorney General, Notarized Witness
Statements, Texas State Troopers Association, Department of Public Safety Officers
Association, United States Postal Services, Pre filed Seal documents, State of Texas
Security Officer license (non-commissioned), Texas State calendar, Sealed documents,
Smith County Tax Records, Texas Rehabilitation Commission, Photos of Linda C. Tate and
Larry Donell Reddic Sr., cell phone records, medical records, bank accts. of Larry were
among the 100+ given to be filed immediately in case of lost, fire or destroyed. Tex. R.
Civ. P. 705(a), Rule 902(1)(2)(4)(5)(6)(8)(11), Rule 1005, Rule 1006
4/16/2013
a. (1st)Trial date wasn't met by three (3) legal counsels
8/06/2013
a. Joint Motion for Continuance-Linda C. Tate had no knowledge of a continuance or the
hearing that was set for 8/6/2013. Counsels of Linda C. Tate never informed her of the
Hearing only the Deposition was told about and was done on 7/16-17/2013, evidence is
in deposition, over 100+ documents in Natalie Fletcher's possession. Natalie Fletcher
had the determining Texas State 2002 W-2 employee statement of Larry Donell Reddic
Sr. REDDIC SR. with Linda C. Tate's address on it. 16397 CR 363, Winona, Texas 75792. IT
WAS HID ON THE SECOND TO LAST PAGE IN LINDA C. TATE'S DEPOSITION AWAY FROM
ITS ORIGINAL THAT WAS ENTERED INTO DISCOVERY BY LARRY DONELL REDDIC SR.
8/20/2013
a. (2nd) Trial Court Hearing date
b. Linda C. Tate wasn't ever given this information about this trial date from counsels
Fletcher or Healy. I had been requesting to get this case finalized to prevent farther
delay when we had from the start all the evidence needed to prove case. Counsels
Fletcher and Healy were continuing the demand of excessive amounts of money in the
sum of $40,000 more if we went to court. The agreement had already been broken to
handle the dissolution in the trial court case 12-1808-D for $10,000, but Linda C. Tate is
already over $17,000 by this time. She found this court date of 8/20/2013 when she
started going through papers being pro se.
c. If Linda C. Tate would have had the original attachments to her husband's 2002
employee tax statement(Linda and Larry) filing "Married Filing Joint" 2002 tax W-2,1
16
would have completed my divorce myself, that was hid from me. She had everything
from the beginning except the Texas State issued tax W-2 of Larry Donell Reddic Sr.,
delaying for more money.
12/3/13
a. Counsel Fletcher started demanding that Linda C. Tate needed to borrow from family,
uncle or anyone to get the $15,000 she requested or they would have to get off the
case.
b. Healy co-counsel wanted $25,000 up front and wouldn't agree to getting it at the end of
the finalization of case 12-1808-D. There was no way Linda C. Tate could come up with
that amount when they already had concrete evidence of perjury, the Texas State 2002
employee tax statement W-2, the 2002 IRS tax statement of Larry Donell Reddic Sr. and
Linda C. Tate status "Married Filing Joint"
c. Linda C. Tate gave lead counsel Fletcher $0 of her requested excessive amount and
Healy $500 because Fletcher stated she owed him.
(l)Linda C. Tate didn't find out that Healy was a hired attorney from a different location
until 12/ 2013 and at her expense, and Christmas was near.
(2)Linda C. Tate had always thought Healy was one of Fletcher's legal assistants from her
office until she told Linda C. Tate she owed him?
(3)Linda C. Tate hired Fletcher LawOffice, walked into Fletcher's office and signed a
contract with her.
(4)Each time Fletcher put Healy name on a paper, Healy signature isn't on anything, nor
is his Bar No., nor the contract she put his name on.
(5)Linda C. Tate overheard Healy discussing something with Fletcher talking and Healy
told Fletcher he wasn't going to lose his license over whatever they were discussing.
12/11/2014
a. Fletcher stated that she had to have the $15,000 now and Healy stated $25,000 more if
we had to go to trial. First, Linda C. Tate didn't hire Healy she did.
b. When Linda C. Tate hired Fletcher she swore to her that she could and would handle my
case as soon as possible from the start upon review of the 100+ evidence given 1 day.
c. At this time after excessive money request from Fletcher and Healy Linda C. Tate started
seeking help from sources of the State of Texas.
d. Texas Legal Aide, Branch of Tyler, Texas stated to Linda C. Tate not to give her counsels
another dime.
e. Linda C. Tate did take Healy the $500 that her son overseas at war sent to her for
Christmas hoping that he wouldn't walk off her case weeks before scheduled trial of
1/14/14.
17
f. Linda C. Tate responded to Fletcher's demand of $15,000 right now or else she stated to
her client.
g. Linda C. Tate explained to Fletcher that she has paid her well over the amount she first
stated at the signing of the contract.
h. Linda C. Tate explained the need to dissolve this case of 18 months and that she had
exhausted all means of borrowing to get the excessive request of $15,000.
i. She had nothing else to give unless Fletcher agrees to get the rest at the end of trial
which was only weeks away. Fletcher wouldn't agree to the suggested solution of Linda
C. Tate, she needed it right then although Linda C. Tate couldn't afford it nor had it to
give,
j. Fletcher solution to Linda C. Tate on the requested $15,000 right then was to go to her
family, uncle, brother, cousin, whom ever she needed it now then, she couldn't work for
free,
k. Linda C. Tate regret the decision of not handling her case from the start because she is
in the same position 2.5 almost 3 years ago, she is still in the same place as 2012, now
2015.
12/18/2013
a. Final court ordered Mediation was to be at Beau Sinclaire Law Office. Linda C. Tate was
the only one that complied to the order of the Court. Larry Donell Reddic Sr., Tina
Brumbelow, Natlie Fletcher or Healy appeared for the final mediation scheduled to be at
Mr. Beau Sinclair's Law Office. Tex. R. Civ. P. 193.6(a)
b. The order of Discovery Completion was on 12/18/2013 also, Linda C. Tate had legal
counsel on 12/18/2013 that did not comply to the Discovery Completion Order. Tex. R.
Civ. P. 193.6(a)
c. Counsels of Linda C. Tate didn't withdraw until 1/6/2014 and 1/8/2014
d. No Notice or Motion of No Evidence Summary Judgment issued to the Courts until days
of being two (2) months later of 12/18/2013 filed on 2/14/14 by Tina Brumbelow
counsel for Larry Donell ReddicSr. See Index Pleadings and Scheduling Order of trial
court case 12-1808-D.
12/23/13
a. Linda C. Tate retrieved all of the 100+ documents, court ordered depositions of Linda C.
Tate and Larry Reddic Sr. and all the filing regarding trial court case 12-1808-D from
Natalie Fletcher's secretary Leslie. After review I asked Leslie for the return of photos
that wasn't returned (belonged to sister), witness statement of now deceased neighbor
Jewel Choice, Bryan Kirkling (maintenance personnel at Bellwood Apts.), witness
18
statement of next door neighbor Cutiest Bell and Clifton Bradford Jr.'s original hand
written statement.
On 1/6/2014
a. The Courts returned from the Christmas Holidays
b. Linda C. Tate lead counsel Natlie Fletcher withdrew from case 12-1808-D of 18 months
and three (3) scheduled court trial dates
On 1/8/2014
a. Linda C. Tate became officially pro se
b. Date of scheduled pre- trial
c. Co-counsel of Linda C. Tate withdrew
d. Linda C. Tate asked the office of Tina Brumbelow to accept the three (3) black binders
prepared for her but was denied
e. Linda C. Tate waited outside of Smith County Court House for hours to get a response
from Husband's counsel Tina Brumbelow for the approval of taking the binders to her
which was only a block away from Smith County Court House located 210 S. Broadway,
Tyler, Texas. ^
f. After waiting for hours and the sleet began to fall is when Linda C. Tate decided to filed
the three (3) binders she also prepared for the courts.
g. High Seals of Authority Documents from the State of Texas, US Department of Treasury
Internal Revenue Service, Social Security Administration, Texas Department of Public
Safety, Veterans Affairs, Texas State Office of Attorney General, Notarized Witness
Statements, Texas State Troopers Association, Department of Public Safety Officers
Association, United States Postal Services, Pre filed documents, State of Texas Security
Officer license (non-commissioned), Photos of Linda C. Tate and Larry Donell Reddic
Sr.,Texas State calendar, Sealed documents, Smith County Tax Records, Texas
Rehabilitation Commission, cell phone records, medical records were among the 100+
given to be filed immediately in case of lost, fire or destroyed. Texas Rule of Civil
Procedure 902(1)(2)(4)(5)(8)(11), Rule 1005, Rule 705(a), Rule 801e(3), Rule 503
On 2/14/2014
a. Tina Brumbelow counsel for Larry Donell Reddic Sr. filed a Motion for NO EVIDENCE
SUMMARY JUDGMENT due to the Noncompliance Order from 12/18/2013 as stated on
the Motion. Linda C. Tate had legal counsel until 1/6/2014 and 1/8/2014. Tex. R. Civ. P.
b. No Notice to the Courts or Motion for No Evidence Summary Judgment against Fletcher
and Healy for the noncompliance Discovery completion order 12/18/2013.
19
c. Brumbelow filed the Motion days of being two (2) months after the Discovery
Completion Order she waits to attack Linda C. Tate, Pro-Se of one (1) month, Head
Injury, Defenseless towards her intentional Entrapment and Fraud. See Scheduling
Order ofthird (3rd )Setting in trial courtcase 12-1808-D.
On April 6. 2014
a. Linda C. Tate's son is home from 18 months of war overseas and he hires Cynthia Allen
of the Allen Law Firm of Dallas, Texas to assist his mother in seeking the Relief and
Justice in the dissolution of the 13 years marriage of 19 between Linda C. Tate and Larry
Donell Reddic Sr.
b. Finally help to get this stressful matter behind her and receive the justice, freedom and
liberties entitled by law that has been denied to her.
c. The Motion for No Evidence Summary Judgment was entered 3/10/14 because of "No
Response" and No Evidence Judge Carole Clark stated to Linda C. Tate pro se for only 2
months of 20 months case.
d. Allen law firm asked Linda C. Tate why haven't the divorce been finalized from review of
case and evidence that should have been presented in the 1st trial case of 4/16/2013?
On June 3, 2014
a. Allen tried to ask the courts for a New Trial, to Reconsider the No Evidence Summary
Judgment, for a Leave to File Answer, and a Motion to Set Aside Final Judgment and
an Expedited trial prior to June 3, 2013. Deadline of this Rule fell on a Saturday.
Requestfor trial priorto deadline was unavailable according to 321st Court
Coordinator Vicki Dunn. Tex. R. Civ. P. 329(b)(c)
b. Tina Brumbelow in return filed a Sanction against Linda C. Tate and Cynthia Allen for
having the Motions properly served to Larry Donell Reddic Sr. according to Law.
c. Brumbelow stated that Linda C. Tate and Allen Law Firm violated Texas Disciplinary
Rules of Professional Conduct 4.02, Rule 21 and 21a because Linda C. Tate and
Cynthia Allen was harassing and knew she was Larry Donell Reddic Sr.'s Counsel of
Record.
d. The No Evidence Summary Judgment was entered 3/10/14, according to the
11/21/2012 filing by Tina Brumbelow in the Discovery Document Filed in Larry
Reddic Sr.'s Responses to Linda Tate's Rule 194 Request for Disclosure on page 12,
question #4, shows that attorney fees will cease to accrue until the final judgment
entry in entered in this such matter. Tex. R. Civ. P. 198.3(b)
(1). The No Evidence Summary Judgment in the trial court case 12-1808-D was entered
on 3/10/2014.
20
(2). Linda C. Tate didn't receive any notice of the Judge signing the judgment on
3/10/2014 regarding 12-1808-D to this day after 321st Court's Clerk Sara told her she
would receive a copy of the signing in the mail.
(3). Linda C. Tate and Cynthia Allen were within the law by having Larry Donell Reddic Sr.
properly served as law requires to notify of filing.
(4). Once Judgment entered on 3/10/2014, there was no notice to the Courts, Allen or
Linda C. Tate of Tina Brumbelow's appearance of legal counsel for Larry Donell Reddic
Sr. after entry of judgment on 3/10/2014.
(5). All requests to the Courts entered by Cynthia Allen on Linda C. Tate's behalf to
dissolve the 13 year marriage of 19yrs. to Larry Donell Reddic Sr.
(6). A New Trial, To Set Aside No Evidence Summary Judgment, To Reconsider No
Evidence Summary Judgment, for Leave to File Answer and Expedited Hearing prior to
June 3, 2014 Motions were denied because Brumbelow stated to Judge Carole Clark that
she was still Larry Donell Reddic Sr.'s counsel but still no record of her appearance
according to the 321st Dist. Court coordinator Vicki Dunn.
(7).The frivolous Sanction filed by Brumbelow is another intentional attack against Linda
C. Tate to assist in the delay of justice according to law. Brumbelow was not counsel for
Larry Donell Reddic Sr.'s after judgment on 3/10/2014, entry of judgment according to
thr eeenterentered, also attorney fees ceased when entered according to the
11/21/2012 filing in the Discovery Document Filed in Larry Donell Reddic Sr.'s Response
to Linda C. Tate's Rule 194 Request for Disclosure, page 12, question #4.See d. above.
(8). No review of trial court case 12-1808-D from Judge Carole Clark, confusion of judge
on the Tex. R. Civ. P. 166a(i) on the Motions filed on Linda C. Tate's behalf, no evidence
to frivolous Sanction filed by Brumbelow or Brumbelow's truth to the Courts based on
mere spoken words.
(9). Linda C. Tate's pursuit of justice as required by law had been denied once again along
with her liberties denied and excessive delays in justice being served to her.
Respectfully submitted,
Respectfully submitted,
Linda C. Tate (Pro Se)
16397 CR 363
Winona, Texas 75792
21
Tel: (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, 2014
*_^
C. Tate (Pro Se2 __.
Linda C. Tate (Pro Se)
16397 CR 363
Winona, Texas 75792
Tel: (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, 2014.
istc^Lv^ (_ .
C. Tate (Pro Se)
22
AFFIDAVIT FOR MOTION TO RECONSIDER NO EVIDENCE SUMMARY JUDGMENT
AND
THE RELIEF OF MARRIAGE AND GRANT DIVORCE ACCORDING TO LAW
Affiant
SWORN TO AND SUBSCRIBED before me on the iJ
P day
day of_J^U£AI
of H||S\
Notary Public, State of Texas
MX*hi. KARA BARRETT
Notary's printed name <^VXXCQk |jCuTejr 1 'ft Notary Public, State of Texas
i&rS&i MY Commission Expires
'*'£ijfcy February 10, 2018
*
{^TyXACX^ Vc%VkHJb£X My commission expires: 3-lCHg
Payment Receipt
Healy Law Offices, P.C.
113 E. Houston St
Tyler, TX 75702-8130
Received From:
Tate-Reddick, Linda
Tate, Linda
~f% 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
.<£f
Pagel
NO. 12-1808-D
IN THE MATTER OF § IN THE DISTRICT COURT
THE MARRIAGE OF §
% ^5 PJQLCIAJLQIS.T5XCT
LINDA C. TATE §
AND §
LARRY REDDIC, SR. § SMITH COUNTY, TEXAS
INDEX-PLEADINGS
NO. Date Document
1. 06/27/2012 Petitioner's Original Petition for Divorce —L(t*eU/
2. 06/27/2012 Civil Case Information (do not haveX — Ltndeu
3- 06/27/2012 Citation Issued (do not have) - JLi/»<^*>
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- 11/15/2012 Rule u 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. 03/15,(20x5 ifecroest forfary Trial (do not ftave/
12. 04/03/2013 Motion for Continuance (do not have) \JpGt4eJW
13- 04/08/2013 Motion for Continuance (do not have) / (Eirbmbeleu}
H- 04/10/2013 Scheduling Order (do not have)
15- 05/10/2013 Mediation Letter (do not have)
16. 06/28/2013 Petitioner's 1stAmended Petition for Divorce
17. 08/06/2013 Joint Motion for Continuance — fie"f
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(x4^hw
2X. J2/.27/2013 Motion for Continuance (do not have)
22. 01/0 3/2014 Docket (do not have)
' 23- 01/06/2014 Order to Withdraw (do not have) - ^Wc/ver
24. 01/08/2014 Docket Sheet (do not have)
01/08/2014 Motion toWithdraw (do not have) *"/W«i <****&•<{
Hf<****^ '- 25-
26. 01/08./2014 , Order to Withdraw |dr>xwthome) —Me*M -&* Qw*&J \
3»^ 1
Index Pleadings - Page 1of 2
In the Matter ofthe Marriage of LindaC. Tate and Larry Reddic, Sr. - No. 12-1808-D
Petitioner Respondent Joint Docs Court Unidenfied
Party
llA,
27. 01/08/2014 Petitioner's Judgment Entry Decree of Divorce (not on docket)
28. 01/14/2014 Notice ofSetting-Jury Trial (3/11/2014)
29. 02/14/2014 Respondent's Motion for No Evidence Summary Judgment
30. 02/ld1/2DJLd, Respondent's.fCkder- Sjerti^Hearino^oD-MntinnLfiM: Na Evidence.
Summary Judgment)
31- O3/U/2OI4 Court's Events and Orders ofthe Court
32. O4/09/2OI4 1Petitioner's-Motion for New Thai
33- O4/09/2OI4 Petitioner's Motion for Leave to File Answer and to Reconsider
Motion for No Evidence Summary Judgment
34- O4/10/2OI4 Petitioner's Correspondence to Court requesting Hearing Date
35- O4/14/0214 Petitioner's Notice of Hearing (Motion for Leaveto File Answer
and to Reconsider Motion for No Evidence SummaryJudgment)
36. O4/15/2OI4 Petitioner's (Attorney Cynthia Woolen Allen's Notice ofVacation
or Unavailable Dates)
37- O5/12/2OI4 Petitioner's (AttorneyDarlene Darensburg Noticeof Vacationor
Unavailable Dates)
3&. O^Jj"OAf Petitioner's Motion to Set&ide Final fitdgmenton No Evidence
Motion Summary Judgment Pursuant to TX Rules of Civil
Procedure 3o6(a)(3)(4) and Request for Expedited Hearing Prior
tojune3, 2014
39- 05/114/2014 Citation Return - Service on Larry Reddic
40. 05/30/2014 Larry Reddic's Motion for Sanctions
41. 06/02/2014 Petitioner's Response to Motion for Sanctions
Index Pleadings - Page 2 of 2
In the Matter of the Marriage of Linda C.Tateand Larry Reddic, Sr. No. 12-1808-D
Petitioner Respondent Joint Docs Court Unidenfied
Party
,'• / drs / \
CAUSE NO. ^>*' '' &y& M
/, -•-/
'tyyiccfa... C•"(iz-m^SA^% IN THE DISTRICT COURT
321ST JUDICIAL DISTRICT
T\ <£y ••'••/ ' 0 ?^fcTOi ALC^WfcWEMCEwV,'r.e'ne'.o ai t - C^ O'c'ioc'k
lL M. Trial counsel are ORDERED to aitend and be prepared lo discuss
all contested ;aspeels of the suit and trial.
a-*
5. / l&~~ 4> FINAL
FINAL TRIAI.
TRIAL will
will he
be held at '•' O'clock M.
bsent agreement. fc$Ajs& A/frkgft^fc appointed mediator in this case. You
?i\vsi' cvOYiVutV said mediator by
SIGNED :\HD &Wi£&J2,-ui,hic W
JUDGE PRESIDING
CAl'SE:'C. . ^ ~ /<£o8~ &
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IN THE DISTRICT COURT
§
vs.
52f Sr/OUfCTAL DfSTRfCT
& SA
~''^i LJ tdcLt^ . SMITH COUNTYJTJEXAS
SCHEDULING ORDF.R
Based on tie information available to the Court, the following scheduling
otder shall apply to this case unless modified bv the Coun. Ef no date is given belo ••
THIS CASE !S DESIGNATED LEVEL
DISCOVERS COt^ETED BY TH IS DATE - Attorneys may
fey agsefcraeaS t*"vmy,Y»wra,ltetri!ft fete jj^fl remain fina
__________ MBDfA77QNAN&SETTtmfENTCONFERENCE
COMPILED !JV THIS DATE -- Ythe case involved aParent-Child Relationship
'TUTTING <-US FIRST" fvfUSTBE COMPLETED BY THIS DATE Also! foustadv
is an issue a f» is day of mediation is recouped.
3. STATUS CONFERENCE will be held at O'clock
M.
ijfa&jfaeM PRETRIAL CONFERENCE will be held at "/ '^ " O'clock
A . . M.Trial counsel are QJ3BERJ5D •-•> often*) ar>d *v» :m~vw~wS «„ J:...., ,,
all contesied aspects of the suit End trial.
p.O,&>C/<3v\K&\
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5. Absent Sgnse^rienC is appointed mediator in this case. You
must contact said mediator bv
SIGNED AND ENTERED on this the /^ , day of ". .^J
/j&£$uj&~ .
//-HA. £3f~ JUDGE PRESIDING
CAUSE SO o^ iMt £
Q(. •'•' r' ^L' j^j^± § L\ THE DISTRICTC»rft>^
SCHEDULING PR1PEH
Base*1 os Ate infonvMiiossavxtiabfe aw f^e Coca*?. $ae fcdkni'mg se&e&idfflg
order shall apply to this case unless modified by the Court. If no date is given below.
0j THIS CASE IS DESIGNATED LEVEL
0^W1 / !' {^}t0— uU^M^SCDVERYCOMPLETEDBY THIS DATE - *4&arraejx may
^ | 0" ./ bv a«ree ment extend discovery;,however..the. trial.date shall remamitim,.
U X. 2. cj)^' t(1,9-0 IS MEDIATION AND SETTLEMENT CaNEEUJEMOE
COMPILED> BYTHIS DATE -- If the case involved a Parent-Child Relationship,
-YCY1 i\\G "Sirs FIRST 3IC5I BE COMPLETED UY THIS DATE. Also, if custody
""" is an "is si le a "lull day or mediation "is required.
3. tt^'16,9.0/3 STATUSCONFERENCEwiiT6e held"at L^ /SO 0-clock
El .M.
4. '^Jr- ^~"--:;- PRETRIAL CONFERENCE will be held at 4 -O)0 O'clock
U •— -M. Trial counsel are ORDERED to attend and h£ prepared to ifisosss
^1J contested aspects of the suit and trial.
5X ^v- 'yfr A>/v3 FINAL TRIAL will be held at ^ *3$ O'clock J* _.M.
T7 "7
6. Absent agreement,^- ^T^'T^* 'd?^'me6 mediator in ihi*c^- *"
SIGNED AND EN'TEREDck» skis sk? /? ^v^f ^ifjuibou &Q[£
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j?/0V/20M iyU3lb/9-862i 09:29:2s AM 908 DALLAS ST
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Sale Unit Final 757929998
01/06/2015 (800)275-8777 1:22 PM
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Expected Delivery: Tue 07/08/14 (Domestic)
Return Rcpt (Green (TYLER, TX 75706)
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NO. 12-1808-D
IN THE MATTER OF § IN THE DISTRICT COURT
THE MARRIAGE OF
§
LINDA C TATE § 321ST JUDICIAL DISTRICT
AND §
LARRY REDDIC, SR. § SMITH COUNTY, TEXAS
LARRY DONNELL REDDIC SR.'S RESPONSES TO LINDA C TATE'S
RULE 194 REQUESTS FOR DISCLOSURE
To: Linda C. Tate, by and through her attorney ofrecord, Natalie Fletcher.
In accordance with the Texas Rules of Civil Procedure, Larry Donnell Reddic Sr. serves
the written Responses to Rule 194 Requests for Disclosure pursuant to Rule 194 of the Texas
Rules ofCivil Procedure on the parry named above.
Tina High Brumbelow
P.O. Box 7677
Tyler, TX 75711-7677
Tel: (903) 533-1339
Fax: (903) 592-6684
tina@bryfibelowlmv.com
Tina High Brumbelow; State Bar No. 24031890
Attorney for Larry Donnell Reddic Sr.
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 ofCivil Procedure on November 21,2012.
Tina High Brumbelow
Lany Donnell Reddic Sr.'s Role 194 Request for Disclosure Pagel
Cause No. 12-1808-D: 1TMOTMO Reddic
•3?"
•;r?
6. the nature and length of the professional relationship with the client;
•iyp .i?K& and
W/ 7- the experience, reputation, and ability of the lawyer or lawyers
performing the services.
Further, Larry DonneU Reddic Sr. may rely upon any and aD legal theories and, in
general, the factual bases ofthe claims ordefenses ofLinda C. Tate that may benefit
hL,
Furthermore, Larry Donnell Reddic Sr. reserves the right to supplement and/or
amend this discovery response, in accordance with the Texas Rules of Civil
Procedure, with additional information and/or documentation, if any, as it becomes
available.
4. State the amount and any method ofcalculating economic damages.
Larry Donnell Reddic Sr. has incurred legal fees reasonable and necessary to
prosecute and/or defend this suit Attorney's fees will continue to accrue until the
entry of final judgment in this matter. Copies of redacted statement will be made
available for copying and inspection upon reasonable notice to Tina High
Brumbelow at210 S. Broadway, Suite #200, Tyler, TX 75702.
w Larry DonneU Reddic Sr. said attorney's fees, court costs, and all other damages are
within the jurisdictional limits of the court. The method of calculating these
damages is based on the set fee for of the attorney, paralegal, or support staff
multiplied by the house ofwork performed by the attorney, paralegal or support
staff. Said fees continue to increase over time.
Further, Larry DonneU Reddic Sr. reserves the right to supplement and/or amend
this discovery response, in accordance with the Texas Rules ofCivil Procedure, with
additional information and/or documentation, ifany, as it becomes available.
5. State the names, addresses, and telephone numbers of persons having knowledge of
relevant fects, and give abrief statement of each identified person's connection with the
case.
1. Larry DonneU Reddic Sr.
c/o: Tina Brumbelow
P.O. Box 7677
Tyler, TX 75711
(903)533-1339
Larry DonneU Reddic Sr.'s Rufe 194 Request for Disclosure
Cause tin 12-1808-D;
I7.IJM3L.n- ITMOTMO
mirrrun Reddic
d-jj.--
fepttt
* "6* **
CauseNo.
CAUSE NO. 12-1808-D
IN THE MATTER OF § IN THE DISTRICT COURT
THE MARRIAGE OF §
§
321st JUDICIAL DISTRICT
LINDA C.TATE §
AND §
LARRY REDDIC, SR. § TYLER COUNTY, TEXAS
DISCOVERY INDEX
MEDIATION
No. Pleading Served Response
1. MEDIATION NOTICE - FROM SINCLAR LAW OFFICES 04/10/2013
TO NATALIE FLETCHER AND TINA BRUMBELOW
(5/9/2013 @ 8:00 AM)
2. DISPUTED ISSUES CHECKLIST 05/2013
3- CONFIDENTIAL INFORMATION SHEET 05/2013
RESPONDENTS 1" AMENDED MOTION TO COMPEL DISCOVERY RESPONSES - PAGE 1
DF-13-04147-S-255* ITMOTMO: Mark Cooks v. Cynthia Cooks
U.S. Postal Se^/'M-.<
CERTIFIED MAi-U.
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m For delivery information visit our website at www.usps.com
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(Endorsement Required) $0.00
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p- orPOBatNo. 4J6 $. 3ft>£-cLuJ&M Jj&\ jZ Linda C Tatc-Rcddic
16397 cr 363
Winona, TX 75792
(903)312-7446
Dear Ms. Brumbeicvv.
I am responding to your Motion for No Evidence Summary Judgment: and Order Settling Hearing on
Motion for No Evidence Summary Judgment set for March 10. 2014 at 9;30a.m.
Very Truly Yours,
P.S. I nave made several attempts to give you my evidence butyou didn't show up for the
second attempt mediation. You nor Ms. Fletcher showed nor had you everscheduled for the mediation
wim Mr. Sinclaire according to him for December 18,2013 at his office. The finalization ofthe
mediation came after me filing with thecourts. I attempted to give you my evidence the day of the pre
trial January 8J203 4. Your secretary stated that I couldn't justbring it, but she would have to get your
approval first. After waiting on your call, I wentahead and filed my evidence with the court.
.-.-.-
- -•'•- -• T
". •*—*'- •-*—** *W«i
0. //Lr / j U $ ~ f_
Ltnd*.. C /^£-?6^crV
/k - this card to the back of the ma.lp.ece. 2/? ' -
oronthefront if spacepermits. D. Isdeliveryaddressdifferentfromiternl? DYes
1 ArticleAddressed to: * .
tf YES. enter delivery address below: >-> NO
I 3. ServiceType
5EfCertified MalP D Priority Mail Express
w QRegistered DReturn Receiptfor Merchandise
„. • insured Mail DCollecton Delivery _
i)Mtfttte,©*A?f*flul *) MC. 6*»* "4 Restncted Demy? k°
later become an issue.
236. Binder (black) - Linda C. Tate-Reddic (Plaintiff) - •Mrs. Reddic filed a bunch of exhibits
Continuous of Exhibits in with her "Judgment Entry Decree of
Divorce)—Sara (was on this morning's
docket 01/08/2014)
237. Oral Deposition of Linda Tate • Lotsa post-it notes
July 16, 2013
Volume I of II
238. Oral Deposition of Linda Tate •
#!%!]#,2HHg
239. Oral Deposition of Larry Reddic • Deposition summary
July 17, 2013
Volume I of I
(J) i&CW^L (\j)6-ZMWUsvct Uilcc^LjL
P^ptAtA b^ ^ GJ^b"M^
BILLINGDATE (MM/DO/YY): 03/08/03
SEQUENCE NUMBER: 0095021624
CASE NUMBER: 4568814451
CAUSE NUMBER: 972731D
MEMBER ID: 02855158
gXatt of Gfcxatf
Chilb Support Bitrision
Greg Abbott
Attorney General
NCP 0095021624 030803 0000570 00194606
ii...i.i.i.i...ii.i....i.i.i.i.i...i...m...ii.i,.i...i.i..n
LARRY REDDIC
16397 COUNTY RD 363
WINONA. TX 75792-5717
[TThe following are your child support obligations:
CIHILD SUPPORT PAYMENT PLAN 1 MONTHLY
Pay this amount for April: S420.00
MESSAGES
TOTAL PRINCIPAL TOTAL INTEREST TOTALARREARS FUTUREPAY AMOUNT
5801.Z5 * $0.00 S801.25 $0.00
YOU ARE RESPONSIBLE FOR REMITTING YOUR CHILD SUPPORT
PAYMENT UNTIL YOUR EMPLOYER BEGINS WITHHOLDING.
BULLING STATEMENTS WILL NOW REFLECT INTEREST OWED IF YOU
&.€.? H4&A PASJIXAEBMAMCE.
STATE LAW PROVIDES THAT INTEREST IS OWED WHENEVER ANY CHILD
SUPPORT PAYMENT IS OVER 30 DAYS LATE.
ALL PAYMENTS DUE AFTER SEPTEMBER 1,1991 WILL ACCRUE
INTEREST IF NOT PAID ON TIME.
^•ftft>ViK\fcKmT3\ffi5TTCn^TCGKR©rr" DFFKINOPAL,
INTEREST OR ARREARS OWED. PLEASE CONTACT THE OFFICE OF THE
ATTORNEY GENERAL AT 1-800-252-8014 OR YOUR LOCAL CHILD
SUPPORT UNIT.
Internal Revenue Service
United StatesDepartment of the Treasury
This Product Contains Sensitive Taxpayer Data
Account Transcript
Request Date: 11-02-2012
Response Date: 11-02-2012
Tracking Number: 100147669809
FORM NUMBER: 1040
TAX PERIOD: Dec. 31, 2002
TAXPAYER IDENTIFICATION NUMBER: XXX-XX-XXXX
SPOUSE TAXPAYER IDENTIFICATION NUMBER: XXX-XX-XXXX
LARRY D REDDIC 6 LINDA C TATE
ANY MINDS SIGN SHOWN BELOW SIGNIFIES A CREDIT AMOUNT
ACCOUNT BALANCE:
0.00
ACCRUED INTEREST:
0.00 AS OF: Sep. 03, 2007
ACCRUED PENALTY: 0.00 AS OF: Sep. 03, 2007
ACCOUNT BALANCE PLUS ACCRUALS
(this is not a payoff amount): 0.00
INFORMATION FROM THE RETURN OR AS ADJUSTED
EXEMPTIONS:
05
FILING STATUS: Married Filing Joint
ADJUSTED GROSS INCOME: 49,538.00
TAXABLE INCOME: 32,688.00
TAX PER RETURN:
3,212.00
SE TAXABLE INCOME TAXPAYER: 0.00
SE TAXABLE INCOME SPOUSE: 0.00
TOTAL SELF EMPLOYMENT TAX: 0.00
RETURN DUE DATE OR RETURN RECEIVED DATE (WHICHEVER IS LATER) ADZ.
PROCESSING DATE
TRANSACTIONS
COOS EXPLANATION OF TRANSACTION CYCLE BA21 gsznzm
/ »
150 Tax return filed 20032008 05-26-2003 $4,112.00
n/a 18221-082-81104-3
806 W-2 or 1099 withholding 04-15-2003 -37,673.00
846 Refund issued 05-26-2003 $3,561.00
This Product Contains Sensitive Taxpayer Data
CWA0093
- I 35H« gs
/£'
c ^ y
iU4U U.S. Individual Income Tax Return ZUUZ (99) IRS USe Orty—Pond writtor staptetattinspaca.
tot»ygirJan.W)«c31.20tg.orolhyla»vflypaqbintno .20Qg.«nrtiBQ .20 OUBNO.154&0074
r Your fist Qsmo and «&&•! Last name i Your socud security number
abel
LARRY REDDIC I XXX-XX-XXXX
Ifajoint return, spousefe first names L35tA3fM Spouso'a social security number
racoons.)
LINDA C TATE .XXX-XX-XXXX
5 trie IRS
Homead*eM{mimberardstreefl.»vciuhawaP.atx«.seelnstnttttora. Apt no.
eL Important!
PO BOX 130040 You must enter
3se print City, townor pastaOee.state, anilZIPcode. Ifyouhavea foreign address,see instructions. your SSN(s) above.
ypa
V TYLER TX 75713
sMantiai ' You Spouse
ctloa Campaign Kota.Checttng~r>s~ariB notchangevourtaxorreduceyourrefund.
«instructions.) • Doypu.OfyourspcKoegfflingaM^'eturn.viantOtoaototMsfUna'? •» UYes®No DresSl
lj~JSntgte 4|~~] Head ofh«JsehokJ(vrithQU8fifring person). (See mstr.)
ling Status 2 OH Married fffinrj Jointly (even ifonly onehad income)
t Qusfityina ponoii n • chnd but not your OEpondnnCwttr
ttvachilifsAaRiohara. •>•
eckordy 3 f~|Married fifing separatery. Enterspouse's SSNabove
ibox
L_l and fufl name here. •» 5 n ^S5afymgvwo^iB¥(er)vr-
imsW-2and
b Tax-exempt interest Ob not include on Ere 8a . | 8b j 0
26 here. 9 OrtfnaiydflMeno^ Attach SctuxtuleB if requ^ 9
:o attach 10 Taxabte refunds, credits, or offsets of state and localincome taxes (see instruclions) . . 10
rm(s) 10994* 11 11
«was 0
12 Business income or (toss). Attach Schedule C or C-EZ . . . 12
hheid.
13 Capitalg^orGoBsXAttachScheduleDifrexRj^ '*- \~\ 13 0
14 Other gams or (losses). Attach Form 4797 14
outfidrwt 15a KM distributions |15a| 1b Taxable amount (see instructions) 15b 0
aW-2. 16a 16b 0
(instructions.
17 Rental realestate, reyaSes, partners*^ S corporations.tnjsts,e^ ....... 17
dose, but do 18 Farm income or (Joss). Attach Schedule F 0
18
attach, any
19 19
me
26 TuBion and fees deduction (see instructions) 26 0
27 Archer MSA deduction. Attach Form 8853 27 0
28 Moving expenses. Attach Form 3903 . . 28 0
29 One^iarfof setf-employmera tax Attach SctieduleSE 29 0
30 Seti-etrpkiyedheaim insurance o^airtm(s^ 30 0
'31 Self-emptoyed SEP. SIMPLE, andquaBAed plans 31 0
32 Pertttyoneafyvnftdrawalef savings 32 0
33a ASmonypaid b ReepienfeSSN e- .. ,«ft
34 Add fines 23 through 33a
35 Subtract fine 34 from fine 22.Thisis your adjustedgross income . . . . 49,538
\ ferOiscfc>s]ire.Prhracy Act and PapervtufcReduce
J^k£M 1040(2002)
EXHIBIT NO.
CWA0094
^ffa§|< "P|
NO. 12-1808-D
2013 m -6 PN I?.- 02
IN THE MATTER OF § IN THE DISTRICT COURT
THE MARRIAGE OF bMiTH Oui my TEX§S
ey_ §
LINDA C. TATE-REDDIC TPijtT 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 soughtsolely 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
*%*&? Ndteftie Fletcher
State Bar No. 24058362
Attorney for Petitioner
Signed on. ?/*>//3
TINA HIGH BRUMBELOW
P.O. Box 7677
Tyler, TX 75711
Tel: (903) 533-1339
Fax: (903) 592-6684
By: &
Tina High Brumbelow
State Bar No. 24031890
Attorney for Respondent
Signed on. ^7/3
I, the undersigned attorney of record, swear under oath that the above Motion for
Continuance is true and correct.
Natalie Metcher /(pf/^J .
VmIl£oLE^~
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
w
Attorney for Larry Reddic, Sr.
SIGNED under oath before me on 1M2L
* Notary Public, State of Texas
^5^'
TYLER AZALEA STATION
TYLER, Texas
757019998
4822710711-0094 5UTS 'PostalgSeKvice
01/15/2015 (903)597-4242 03:12:32 PM
in 'Domestic Mail Only"\
=—. Sales Receipt
Product Sale Unit Final iffl!rFBlfflHi'"H"J''|,il-via Sr _
HI
O
$8.45
Issue Postage:
w~si&;zp&'~Z^j~~"'-j£ _75-7^ £,
PS^F6rrni386d^u|y!2i)14|
Total; $8.45
Paid by:
Debit Card $8.45
Account #: XXXXXXXXXXXX3517
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