Mary Ann Castro v. Manuel Castro

In the Fourth Court Of Appeals Fourth Court Of Appeals District "\t ~- \\ San Antonio Texas Bexar County .-.,.„ -.""'■ Maryann Castro _ ■ ■ '. ^ •■ ' ■-. S -"' Manuel Castro Re: Court Of Appeals Number: 04-14-00785-CV Trial Court Case 2011 -CI-15957 To Honorable Court Of Appeals Judge LittleJohn MOTION OF DECLA1R A MISTRIAL Appellant Maryann Castro is praying the Appeals Court will accept her motion of mistrial in the Trial Court case 2011- CI- 15957. In the Agreement for Final Divorce there is a significant amount of procedural error. And Misconduct that prevents a fair trial. a. Counsel Joseph Appeit misconduct that prevents a fair trial Counsel was not honest in the Agreement for final divorce signed on Oct 30, 2013. b. Counsel Joseph Appeit hid the Active Bankruptcy of his Clientfrom Appellant MaryAnn Castro and the Court Appellee Manuel Castro on 10/30/13 motion for automatic stay lift was not filed and still proceeded knowing under the bankruptcy trustee it was needed in order to proceed in the divorce and abused the law by not filling the motion. c. Counsel Joseph Appelt hid that his client Appellee Manuel Castro was not paying the mortgage and had the Community that was awarded to Appellant Maryann Castro protected under the bankruptcy Court and Appellant Maryann Castro could not contact the bank or Communicate with the bank Appellee Manuel Castro removed her as contact person from the mortgage with the help of the mistress and until AppellafHTManuel Castro paid the debt he hid^from the trial court that he was not making any mortgage payments. d. Counsel Joseph Appelt hid a martial asset Keogh plan pension and 99 subaru from Appellant Maryann Castro and filed in a motion for Appellee Manuel Castro to keep when Appellant Maryann Castro never gave up her rights to the martial asset he did not mention in the Agreement for Final divorce and is abusing Appellant Maryann Castro of her rights to her martial asset. e. Counsel Joseph Appelt accepted from Appellee Manuel Castro his client Mistress the non-spouse Christina Pacheco who had a Comparative Market Analysis-realtors opinion prepared for Appellee Manuel Castro overvalue the community at 351,000 and it says not to be used as an appraisal to Commit fraud on the Community at 125000 f. Appellant Maryann Castro has the certified Appraisal the community is not worth 351,000 and there is no 40,000 in equity Counsel Joseph Appelt has continued to Abuse the law with his filings that are fraud and continues to abuse Appellant Maryann Castro by communicating with the judges instead of Communicating with Counsel and Appellant Maryann Castro prays for Justice. Appellant Maryann Castro also Petition for Writ of Mandate To return back to Trial Court due to Counsel Misconduct that prevents a fair trial and the significant amount of procedural error that has fraud on the Agreement for final divorce. Appellant Maryann Castro prays for Appeals Court to approve the motion of mistrial and filing petition writ of mandate to return back to trial Court case before Judge Canales where Justice can be served in the Agreement for final divorce and Appellant Maryann Castro can get the Justice she is entitled to by law clue to misconduct of Counsel Joseph Appelt and his client Appellee Manuel Castro and the Non Spouse mistress Christina Pacheco who all conspired to Commit fraud in the Agreement for final divorce. In the Agreement it states Appellee Manuel Castro to prevent foreclosure Appellee Manuel Castro did nothing to prevent foreclosure Appellee Manuel Castro Continued to pay Counsel Joseph Appelt to abuse the judicial system with his fraud filings in getting the copy of a agreement for final divorce filed knowing Appellant Maryann Castro and her Counsel were challenging due to fraud and abuse that prevented Appellant Maryann Castro from getting a fair trial. Appellant Maryann Castro in the agreement for final divorce it says terms and extension regarding refinancing there was an active bankruptcy and Appellee Manuel Castro and Counsel Joseph Appelt hid that from Appellant Maryann Castro and the significant error of this misconduct that prevents a fair trial hiding the bankruptcy from Appellant Maryann Castro is a significant procedural error called fraud Appellee Manuel Castro and Counsel Joseph Appelt conspired to commit fraud by hiding the Active Bankruptcy and Counsel Joseph Appelt committed a legal malpractice against Appellant Maryann Castro in the Amount of 40,000 that is a civil rico act in a divorce proceeding. Appellant Maryann Castro prays the Court of Appeals accepts her motion of mistrial so Appellant Maryann Castro can get a fair trial. Respectfully Maryann Castro pro s 1501 Olive Jourdanton Texas 78026 Pacattitude2Q14{5)gmail.com Date 3/6/2014 ■• ■ ■ ''--.\,:':. :'■ . - - ■ ■ ■ 3 I HE DEZPJCI CC >■=■-.■;■■ E^ COUNTY, TEXAS — ■ — - _j csme on is be Lssid the si EEdsmsiiarKi.cause cf£cu;i_. PeiffiaoercadKupaadeBt^pesredin p^scffi sad s^nrmrad read)'. After caafefeocei the parties leadieiiaiLEgieQiieit culhi; terms od ccn^rdons sit foitb bdew. By the s-gnatoes below fee parrlss adacwledge that "d£r agresmeai expressJ ths sntire- laQes^sdingaDdaccomafitiepEitiesticoaEsstitsiths Conning, wdiotsfiEjiernotiDEk snsr binding orders in accordance with ihis ag L£^v^^: o^tTOi Dn^g. sfe-i- ,^/feig-^^ I^xcs ^^z^ 5uif\=c7- P3- ^- jp ■~j Page ) of2 A/ a% . - J- ;■ ,1 - . 1 I - I I " i " * ' ' ' '• ■ <-'UJ '-•■'-< L- '■ . ■■ NWu fWi O^m shdi tte 4 rCW&VJC Mrt^fi, Q\ jo qi^ eci fo ftfi w / fV \ ^^' ks/ja£, "15 pa/re?- 4fye/ l^ ii so id cjxI- ^Ap ?il fo&, ^/s/dai 4- b r /l \i-y.Pm\fvh u j to to, K /id ! ■-■■■"~;f:5 :"■;■. 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