IN THE COURT OF APPEALS OF TEXAS
No. 04-14-0791 CV - ?. S ZCA.
JC-T-I
;1 " -1 -T3
MICHAEL THOMAS PAUL ?^— ^
GREG ABBOTT ATTORNEY GENERAL FOR THE
STATK OF TEXAS
MOTION TO APPELLA'l'K COURT TO QUASH DEFECTIVE ORDER TSSUED IN
TRIAL COURTS DFXF.MBER 30'" 2014 ORDER DENYING MOTION TO SET
ASIDE ORDER GRANTING CONTEST TO AFFIDAVIT OF INABILITY TO
PAY ON APPEAL AND ORDERING MICHAEL T. PAUL TO PAY ALL
COSTS OF APPEAL
DUE TO APPELLANT NOT BEING PROPERLY SERVED NOTICE, TRCP 21 AND
THE SUBSEQUENT RE-PETITION THAT WAS DEFECTIVE BEING FILED AFTER
THE 10 DAYS TO FILE MOTION CONTESTING THIS APPEAL
TO TI IE HONORABLE COURT OF APPEALS:
COMHS NOW, Michael Thomas Paul, Appellant in the above
styled and numbered Appeal, and files this Motion for this court to
slay their order of dismissal and QLJASH detective December 30th
ORD1-R DENYING MOT ION TO SET ASIDE ORDKK GRANTING CONTEST
TO AI-FIDAVITOF INABILITY TO PAY ON APPEAL AND ORDERING
MICHAELT. PAUL TO PAY ALL COSTS OF APPEAL . Appellant is not
one lo mince words with non facts and events occurring that have
been ;t.) Obstruction of Justice ; b.) Criminal acts by court personnel
that should be investigated by a grand Jury for collusion and
conspiracy, that Appellant demands Judicial Notice be taken of.
Appellant again asserts as in prior petitions that the District Clerks
1
office and the Office of the Courts Attorney will stop at no ends to
prevent this appeal from being Justly Adjudicated by the merits
under which have been filed in the trial courts record which sought
an injunction and summary judgment. Appellant assumed this court
to be privy too the filing since there is an entry on the docket in this
appeal which states that the Clerks Record has been filed as of
December 04th, 2014 and checked out the very next day. Strange
that it should be filed and then removed from the court so as to allow
for appellant's appeal being dismissed for no record having been
filed. But the record was filed, see exhibit Al. Appellant not
having legal background has been diligently searching for Pro-
Bono legal representation and requests this court to immediately
assign court appointed counsel to Appellant so as to assure there
are no more constitutional violations to his rights. As Appellant
is presumed indigent in this appeal as stated by the Texas Supreme
Court and that supersedes and nullifies any order to pay costs by any
lower court including this court. Monies having to be paid to date
will be sought as damages from the above stated Criminal complaint
as Pain and Suffering for having to try and juggle what bill appellant
can't pay this month because of the blatant extortion of money from
his below average fixed income of only $805per month just so he can
progress his just claim.
WHEREFORE, PREMISES CONSIDERED, Appellant
respectfully request this Court to immediately, without delay, grant
appellant's motion slay order of dismissal and enter an order to quash lower courts
defective carder and grant request for appointed counsel as to allow appellan! to proceed
in this appeal for want of adjudication under both the Texas and United States
Constitution's.
If motion is denied. Appellant will proceed with En Bane filing Due March 16, 2015 and
an; other remedies that may be provided under both Texas and United Suites
Constitution's.
Respectfully submitted,
Michael Thomas Paul
9123Easy Street
San Antonio, Texas 78266
Telephoned 10-294-4533
mtp7389@holmail.com
/s/Michael Thomas Paul
Michael Thomas Paul
Pro-Se Appellant-
litigant
CERTIFICATE OF SERVICE
I certify that a true and correct copy of the above
instrument was served on the following via E-Mail and
delivered on the 16Ih of February, 2015.
Scott M Graydon,
Asst. Attorney General
E-MAIL
P.O Box 12548
Austin,TX 78711 -2548
Donna Kay McKinney
Bexar County District Clerk E-MAIL to Court Attorney
101 W Nueva, Suite 217 Hand delivered
Sa n A n ton i o, TX 78205-3411
(210) 335-2113
Michael Thomas Paul
9123Easy Street
San Antonio, Texas 78266
Telephone: 210-294-4533
mtp7389@hotmail.com I
mtp8389@ginail.com
/s/ Michael Thomas Paul
Michael Thomas Paul
Pro-Se Appellant
Litigant