CAUSE No. 06-15-00047-CV
RECEIVED IN
1718 si^DisfrSt6 Court of Appeals
AUG 1 9 2015 Sixth Appellate District
State Of Texas
Texarkana, Texas
Debra Autrey, CierK
Bl-State Justice Building
100 North State Line Avenue #20
Texarkana, Texas 75501
Lowell Merritt / Appellant
v.
James Andrews and Robert Davis Appellee(s)
Both Parties Recorded an Invalid Document in Deed Records to Cloud
Title To Mr. Merritt's Real Property Located in Waco, McLennan County.
Cause No. 2015-2602-4
Filed in the 170th District Court-Transferred to 19th District Court
Final Orders were based on an Order made void by Texas Case Law
Appeal From Final Order Issued By
Honorable Judge Ralph Stother in the 19th DISTRICT COURT
McLennan County Courthouse 501 Washington Ave., Suite 303
Waco, Texas 76701 Phone: (254) 757-5081Fax: (254) 759-5683
All Attempts to obtain Court Reporters Transcript have Failed
(i)
Identity of the Parties Involved
Lowell Merritt / Appellant /pro se Contact Info for Mr. Lowell Merritt
2470 E. Stone Rd. Wylie, TX. 75098
Ph: 214-779-5430
E-Mail: knightl55@excite.com
vs.
James Andrews / Appelle / pro se Contact Info for Mr. James Andrews
122 Touchstone Road Wylie, TX. 75098
and Phone Number and E-Mail are Unknown
Robert Davis / Appellee / pro se Contact Info for Mr. Robert Davis
(he is Representing Himself 8131LBJFrwy. Suite 700
Pro se is not allowed to collect Dallas, TX. 75215
attorney Fees) Ph. 972-234-3400 FAX 972-234-1750
E-Mail: BDavis@mssattorneys.com
Court Issuing Final Order Dismissing Litigation
Honorable Judge Ralph Stother 19th DISTRICT COURT McLennan
County Courthouse 501 Washington Ave., Suite 303 Waco, Texas 76701
Phone: (254) 757-5081 Fax: (254) 759-5683
(ii)
TABLE OF CONTENTS
Content Page
Cover Page (i)
Identity Of Parties (ii)
Table of Contents (iii)
Index of Authorities (iii), (iv), (v)
Oral Argument... none requested 1
Statement of Jurisdiction 1
Statement of Case 1
Statement of Facts 1
Argument 2 -12
Summary Of Argument 12
Prayer 13
Certificate Of Service 14
Appendix 15.16
Final Order 17
EXHIBITS after Final Order
(iii)
INDEX OF AUTHORITIES
Statutes & Codes Page
Tex.R.App.P Rule 17.2 1
Civ.Prac.&Rem.Code Ch. 12 Sec. 12.002 1,4,8
Civ.Prac.&Rem.Code Ch. 12 Sec. 12.003 13
Civ.Prac.&Rem.Code Ch. 15. Sec. 15.011 2,11
Penal Code Sec. 32.49 1,4
Rule 18a Recusal 10
Gov.CodeChapter 27 Justice Courts Sec. 27.055(b) (recusal defined) 5
Gov. Code Chapter 82 Sec. 82.061 and Sec. 82.062 12
Tex.R.Civ.P. Rule 523 5
TEXAS CASE LAW Page
Brosseau v. Ranzau, 911 S.W.2d 890 (Tex. 1995) 6.10
CitizensIns.Co.Of Am. v. Daccach, 217 S.W.3d 430, 452-53(Tex. 2007)...3
Cramer v. State Farm Mutual Auto Ins. Co. (Tex.-2007) 7
Cunningham v. Parkdale Bank, 660 S.W.2d 813 (Tex 1983) 3
El-Karchv.TexasAlcoholicBev.Comm'ns874S.W.2d 192,194-1994) 12
Granado v. Madsen, 729 S.W.2d 866, 870 (Tex. 1987) 2
Hallv. McKee, 179S.W.2d(Tex. 1944) 7
(iv)
Texas CaseLaw continued Page
In Re Marriage of Grossnickle, 115 S.W.3d238, 252 (Tex. 2003) 10
Mapcolnc. v. Forrest, 795 S.W.2d 700,703 (Tex. 1990) 3
Mausv. Truman & Mitchell. 456 S.W.2d 181 (Tex. 1970) 11
Mullen v. Coussons, 745 S.W.2d 50 (Tex. 1987) 7
Nabejas v. Tex. Dep'tPub. Safety 972 S.W.2d 875, 876 (Tex. 1998) 3
Poolev. Goode,442S.W.2d810. 812 (Tex. 1969) 7
State v. Riewe, 13 S.W.3d 408, 413-14 (Tex.Cr.-App.2000) 3
Seberv. Glass, 258 S.W.2d. 122, 124 (Tex, 1958) 2
Tex.Ass'n offius. v. Tex.AirControl Bd. 852 S.W.2d 440,445(Tex.l993)...3
Tex. S. Ct. in Bridgmen vs. Moore, 143, Tex. 250, 183 S.W.2d Page 707..12
Youngblood v. Wilson & Cureton, 321 S.W.2d (Tex 1959) 11
(v)
ORAL ARGUMENT NOT REQUESTED
POINTS OF ERROR (1) Texas Courts are simply not at liberty to ignore
Texas Case Law that voids Orders issued and res judicata does not apply to
Adjudication by Courts that lack subject matter jurisdiction.
Statement of jurisdiction
Texas Rules Of Appellant of Procedure... Rule 17.2 gives the 6th District
C.O.A. the same Subject Matter Jurisdiction as the 10th District C.O.A.
STA TEMENT OF THE CASE
Merritt v. Andrews filed 06/26/15 in 170th Dist. Ct. in McLennan County
For Recording Invalid Document dated (March 2008) in Deed Records to
Cloud Title to Mr. Merritt's real property located in McLennan County
violated Tex.Civ.Prac.&Rem.Code Chapter 12 Sec. 12.002 combination
Civil and Criminal violation of State Law...Civil Violation for Recording it
and Criminal Penal Code Sec. 32.49 Class A Misdemeanor for not removing
it Mr. Davis was added to this suit...since he was never tried in a Proper
Court... for violating Tex.Civ.Prac.&Rem.Code Chapter 12 Sec. 12.002.
STA TEMENT OF FACTS
Judge Strother in the 19th Dist. Ct. in Waco, TX. "Dismissed My Litigation"
based on an Order he received without a Motion urging action... included
Vexatious Litigant papers issued by 380th Dist. Ct. in Collin Co... .assumed
Collin County was a "proper court"...he dismissed my statutes & case laws.
ARGUMENT
Merritt v. Davis Lawsuit was originally instituted in McLennan County
04/07/ 2009 assigned this to 74th District Juvenile Court Judge Coley
..Bench Trial Set with FIAT Signed Exhibit (AA page 3 of 3) Subject
Matter Topic "Mr. Merritt's real property located in McLennan County
Clouded by Invalid Document Recorded in Deed Records by Mr. Davis"
Texas District Courts
Texas district courts are courts of general jurisdiction and are presumed to
have subject matter jurisdiction over all matters unless the Texas
Constitution or Statute confers Exclusive Jurisdiction elsewhere.
Civ.Prac.&Rem.Code Chapter 15 MANDATORY VENUE
Sec. 15.011. LAND. Actions for recovery of real property shall be broughtin the
county in which all or a part of the real property is located... (and the only real property
owned by Mr. Merritt was real property located in Waco, McLennan County Texas.)
19th Dist. Ct. Judge Strother in Waco signed an Order that did not have a
Motion urging action to be taken... caused his order to be defective per
Granado v.Madsen, 729 S.W.2d 866, 870 (Tex. App.-Houston [14th] 1987,
writ refd. n.r.e.) (judgment order in case where there were no live pleadings
and thus no cause of action against whichjudgment could be granted was a
nullity and of no effect); Seber v. Glass, 258_S.W.2d_122, 124 (Tex.Civ.
App.-Fort Worth 1958, no writ) (No Pending pleading causes the trial
court to be without jurisdiction and purported order was void). Where
there is no pleading, there can be no judgment. Cunningham v. Parkdale
Bank,660 S.W.2d 813(Tex.l983)
Unlike Personal and Territorial Jurisdiction Subject Matter can not
be waived even if parties agreed ... and Judgments from a court that lacked
subject matter jurisdiction is forever a nullity per State v. Riewe, 13 S. W.3d
408, 413-14 (Tex.Cr.App .2000)... A Court must have subject matter
jurisdiction to adjudicate a case per Tex. Ass 'n ofBus. V. Tex. Air Control
Bd, 852S.W.2d440, 445 (Tex. 1993)...mdMapcoIna v. Forrest, 795
S. W.2d 700, 703 (Tex.1990) A judgment is void when court rendering the
judgment had no jurisdiction... and Res Judicata DOES NOT Apply per
Citizens Ins. Co. ofAm. v. Daccach, 217' S.W.3d430, 452-53 (Tex. 2007)
AND....The $h Dist Court OfAppeals could only dismiss and remand Case
back to McLennan County...because Texas Case Law states... Appeals court
has no jurisdiction over a void judgment or order per Nabejas v. Tex. Dep't
ofPub. Safety, 972 S. W.2d 875, 876 (Tex.App.-Corpus Christi 1998).
MOTION TO TRANSFER VENUE
Mr. Davis files Motion to Transfer Venue right after he sees a Bench Trial
has been signed off on to hear this Case in McLennan County...so to keep
from being held accountable in a PROPER COURT...Mr. Davis inserts
FALSE Statements in his Brief stating Sec. 15.013 Prevails..Exhibit (A )
(this is an Injunction Statute)... and Merritt v. Davis was for a Civ.Prac.&
Rem.Code Chapter 12 Sec. 12.002 Violation...Civil for Recording it &
Criminal Penal Code Sec 32.49 violation... for not removing it.
PAST TO PRESENT HISTORY OF EVENTS
Back in 2007.. I was told my neighbor Mr. James Andrews was being cited
for Health and Safety Code Violations by Collin County Authorities ... and
for some reason he thought I was the one reporting this... so... out of spite
and retaliation... and Files A False Report To Collin Coimty Sherriff Office
saying me and my dog had been causing him trouble for at least 15 months
... LONG STORY SHORT... I lost this in JP Court because Judge Douglas
ALLOWED Mr. Andrews, Mr. Slayton and Sgt Vance TO NOT
ANSWER MY QUESTIONS ... .to remedy this... I did the following:
FIRST...I Appealed this Verdict to a "Criminal Court" in Collin County.
SECOND...I Filed THREE Separate Lawsuits For The Following
Violations: CV-09-47 Mr. Andrews Filing a False Report, CV-08-48 Mr.
Slayton, Perjury and CV-08-49 Sgt. Vance, Failing To Provide Equal
Protection Of The Law... All Lawsuits said the same verbiage of.. "Answer
My Questions in Wylie JP Court and I will drop my lawsuit"
THIRD...I DID NOT WANT JP Ct. Judge Douglas to preside over this
Because in the Criminal Case he ALLOWED PEOPLE TO NOTANSWER
MY QUESTIONS... and Caused me to lose and have to Appeal this to
County Court... and I wanted ANOTHER JUDGE... after calling three
different Administrative Judicial Courts... all stated they had come out and
replaced Justice of Peace Judges... and Government Code Chapter 27 that
was specifically written for Justice of Peace Courts had Section 27.055(b)
and used the word recusal and defined this as Inability to Perform Official
duties... and the first Rule under Tex.R.Civ,P was Rule 523 District Rules
Govern... and there was no Recusal there... so I read the verbiage the
verbiage in Rule 18a and it stated may be used in "any" court and did not
exclude JP Courts... so I file a Rule 18a Recusal Motion with the JP Court
Office and was File Stamped Jan 7th 2008...
On Jan 30th 2008. .Judge Douglas walks into the Courtroom and says
"No one is going to be able to Speak or Object To Anything Today and the
Recusal Motion does not apply to me"... then had the Bailiff pass out
Sanctions without listing a "specific conduct" being violated.
GOVERNMENT CODE CHAPTER 27 JUSTICE COURTS
Sec.27.055(b) If a justice is temporarily unable to perform official
duties because of absence, recusal, illness, injury, or other
disability, the county judge may appoint a qualified person to serve as
temporary justice for the duration of the disability.
JP Ct. Judge Douglas did not contact Commissioners Court and refused
to follow Guidelines in the Gov. Code and or Rule 18a... Continued to
Preside & Issued Orders...See Brosseauv. Ranzau, 911 S.W.2d890
(Tex.App.-Beaumont 1995, no writ), if a trial court fails to comply with the
strictures in Rule 18a, all actions taken thereafter are void.
JP Ct. Sanction Orders Were Appealed to County Court
I have to back up a bit... When I let Judge Douglas know he did not have
authority to Issue Orders...he set ANOTHER Hearing for (March 19th 2008)
where... he bumped up the Dollar Amount of Sanctions then I appealed mis.
Appeal This To County Court In McKinnev Texas
I hand carried my Appeal Brief over to County intake desk in McKinney
Texas where the Clerks wanted a few thing done ... which was to put the
name of each person under the CV Numbers... Appeal being Made Due To
What Court's Actions... so I hand wrote with Arrow pointing to "Due To JP
Ct. Judge Douglas Precinct 2 Collin County" and Gave them the MY
Affidavit and two Page initial Brief that was File Stamped March 27the
2008 being 9 Days after JP Court Verdict was Issued..and the Clerks gave
My Appeal Cause No. 1-798-2008 which I found out was later signed by
Judge Corinne A Mason ... then I filed THREE Separate Briefs that ALL
stated the same thing EXCEPT had a Different Name on it., were all file
stamped April 11th 2008 Motion To Appeal Rulings where I listed Names
and Council along with Contact Information of the Front Page and let Judge
Mason know JP Court Judge Douglas refused to abide by his Recusal.
HERE'S WHAT HAPPENED
The Defense Council did not file anything in County Court... and the Court
Coordinator said there were no Names or Address to send out Notice... SEE
Exhibits (B) 1st & 2nd Pages; "Motion to Appeal Rulings" Exhibit (C ) with
Notification of Appeal by FAX Exhibit (D ) ...Everyone's Name and
Address & Council Name was in "My Motion To Appeal"...yet County
Judge DWOP the case Exhibit (E)... was not such a bad thing because
Case Texas Case Law says the following... "It is well-settled that
[Perfection of an appeal to county court from a justice court nullifies the
judgment of the justice of peace court" per Mullins v. Coussons, 745 S.W.2d
50, 51 (Tex.App.-Houston [Nth Dist] 1987, no writ); Poole v. Goode, 442
S. W.2d810, 812 (Tex.Civ.App.-Houston [Nth Dist] 1969, writ refd, Once
a county court acquires jurisdiction by perfection of an n.r.e.). appeal from
justice court, the rules of procedure permit only that the county court to try it
or dismiss it per Hall v. McKee, 179 S. W. 2d 590, 593 (Tex.App. -Fort Worth
1944). And Cramer v. State Farm Mutual Auto Ins. Co. (Tex.App.- Houston
[1st Dist] Nov 6, 2007) the justice court's judgment to the county court is de
novo and a justice court's determination of fact or law "is not res judicata
and does not constitute the basis for estoppel by judgment in a county court.
Mr. Davis Records The JP Court Order Anyway
I find this out by total accident that Mr. Davis recorded this in Collin and
McLennan County... yet... the only real property I owned was located in
McLennan County... I FAXED Mr. Davis a Letter demanding him to remove
it and he saidthe JP Court Judgments Traveled Underlying with the Appeal..
County Court DWOP... reinstates Justice Courts Orders... yet I knew he
waswrong.so I filed My Lawsuit known as Merritt v. Davis for Violation
of Civ.Prac.&RemCode Chapter 12 Section 12.002...Recording an Invalid
Document to Cloud Title to my real property in McLennan County ... and
filed this in "County Court" in both Collin & McLennan ... and Quickly
Withdrew and Re-Filed this in District Courts in Collin & McLennan
County the same day...but after carefully reading Statutory Laws...
.. -Action for this must be taken in a PROPER COURT... defined as one that
had Mandatory Venue and is why I initiated ACTION in the 74th District
Court in McLennan County asking for a BENCH TRIAL and got the FIAT
signed to hear this 06/10/2009 EXHIBIT (AA Page 3 of 3)...Mr. Davis filed
a MOTION To Transfer Venue listed reasons for Transfer of case on Page 4
of his BriefEXHIBIT (A)... and case of Merritt v. Davis was erroneously
transferred to 380th District Court in Collin County... where Judge Wooten
DENIED My Motion to remand the Case back to where Mandatory Venue
lies in McLennan County... sua sponte a Vexatious Litigant Order... and
after bouncing this around in Collin County for years... was a total waste of
time because NO COURT IN COLLIN COUNTY had Mandatory
Venue and Lacked Subject Matter Jurisdiction...
Then recently I found my neighbor James Andrews Recorded JP Ct.
Order issued in (March 2008) in (2013) after he found out... I had a Heart
Attack... So I sent him a Letter demanding him to remove this or I will file a
Lawsuit in a Proper Court for his Violation ofLaw... and on June 26th 2015
filed my Lawsuit in the 170th District Court in Waco given Cause No. 2015-
2602-4 then this got transferred to 19th District Court due to an ORDER
being sent to Collin County WITHOUT A MOTION urging Action To be
taken and No Notice or Service to anyone... after this... I added Mr. Davis
to this Lawsuit since he has never been held accountable in a proper court.
HISTORICAL EVENTS IN CIVIL AND CRIMINAL COURTS
(1) I WON in CIVIL COURT on May 5th 2008 DUE TO [Perfection of
Appeal nullified Judge Douglas' Orders AND the DWOP was the Final
Verdict settling all claims...SEE Court's Register of Actions Exhibit (E)
(2) I WON in CRIMINAL COURT.. on June 11th 2008 because the Judge
Stated "You Will Answer All Questions"... Verdict Not Guilty by stating
There was not one scintilla of evidence to support Mr. Andrews claims
MR. DAVIS RECORDS JP Ct. Orders KNOWING
(1) Judge Douglas did not act on his Recusal...Orders were void by Texas
Case Law Brosseau v. Ranzau, 911S. W.2d890 (Tex.App.-Beaumont 1995,
no writ), if a trial court fails to comply with the strictures in Rule 18a, all
actions taken thereafter are void...(Statute of limitations to review this has
expired) and is moot since [Perfection of Appeal nullifies JP Ct. orders.
(2) JP Ct Orders were Appealed to County Court via Cause #1-789-2008
[Perfection of Appeal Nullified JP Court Orders and DWOP was the Final
Verdict dismissing disputes of both sides.
(3) "Error of a filing clerk" is what caused Judge Douglas to be listed as a
Defendant in "Court Register of Actions"... not me.
Merritt v. Davis was transferred to Collin County in 2009
Judge Wooten of the 380th District Court in Collin County sua sponte
Vexatious Litigant Order... yet was prohibited by Texas Case Law... (In re
Marriage ofGrossnickle, 115 S.W. 3d238,252 (Tex.App.-Texarkana 2003)
(stating the vexatious litigant statute only applies when a section 11.051 is
filed within ninety day after the date on which the defendant files his or her
original answer)... and Mr. Davis admits he did not... see Exhibit (F)
10
The Art of Deception...Blatant lies...and Half Truths
In Court to On April 2014... Mr. Davis Knowingly and Intentionally
LIES to the Court to HIDE his Larceny ... saying (1) Both McLennan &
Collin County had Mandatory Venue... (2) The suit was against him but
relief sought is against Collin County for issuing the Vexatious Litigant...
(3) Mr. Davis also changed his Story by saying he Transferred Venue up to
Collin County based on Mandatory Venue ofwhere Defendant Lives....
(4) Said he was representing a Client for Collin County... (ALL FALSE as
Follows: (l)..McLennan County only one to have Mandatory Venue via
CPRC Ch. 15 Sec 15.011..(2)..ReJief is "Removal of invalid Document"...
Vexatious Litigant Order is already void per TEXAS CASE... (3)..In 2009
Mandatory Venue Sec. 15.013 prevails in 2014 Exhibit (G) it's "where the
defendant lives" ...SEE Case I^xw...Youngbloodv. Wilson & Cureton, 321
S.W.2d (Tex.App-Ft.Worth 1959) Maus v. Turman & Mitchell, 456 S.W.2d
181 (Tex.App.-Austin 1970) employment of "another attorney" was
necessary to recover attorneys' fees.... (The Reason Mr. Davis has No
Letter of Authority from Collin Co. Commissioners Court it's a case-by-
case Contract at Collin County sole discretion & they DlD NOT ask a
Order void by Case Law and nullified by Appeal be Recorded... nor ask
11
for Mr. Davis' services)...Mr. Davis' Half Truths and Blatant Lies in
Court is Perjury... in his Brief is called Tampering with Government
Records and Deceiving an Official into paying his pro se fees is Larceny.
... Any Court can fine & jail Mr. Davis for "Attorney Misconduct" per
Government Code Ch. 82 Sec. 82.061...and Sec. 82.062 a District Court.
SUMMARY OF ARGUMENT
When an Appeal is taken from a void judgment, the appellant court must
declare the judgment void...Because the appellate court may not address the
merits, it must set aside the trial courts judgments and dismiss and remand.
SEE Case Laws..El-Karch v. Texas Alcoholic Beverage Comnt'n, 874
S. W.2d 192, 194 (Tex.App.-Houston[lJhDist] 1994, no writ) AND The
Texas Supreme Court speaking through Folley, Commissioner, in
Bridgmen vs Moore, 143 Tex 250,183 S. W.2d at page 707, stated... "A
violation of law tried by a court void of Subject Matter Jurisdiction
causes all of it's orders to become void having no force of law... orders are
good nowhere and bad everywhere" and "There is Ilo time limitation
regarding a violation of law was adjudicated by a court that did not
have power to act as a court"...."a Void Judgment is mere waste paper,
an absolute nullity, and all acts performed under it are also nullities".
(Acts performed it ...means 5th Dist. COA Orders are also nullities)
12
PRAYER
(1) Reverse Vexatious Litigant Order recorded in Austin, Texas due to all
Collin County Court Orders were void by Texas Case Law due to lack of
subject matterover Merritt v. Davis Case... and the 5th Dist COA in
Dallas had no jurisdiction over void orders or McLennan County Texas.
(2) Strike 19th District Court Order to Dismiss Litigation in Waco McLennan
County since it was based on Collin County Vexatious Litigant Order that
was void by Texas Case Law for lack of subject matter jurisdiction.
(3) Remand this Case back to 19th Dist Court... with instructions to have
170 District Court hear Case known as Merritt v. Andrews & Davis with
a statement stating Mr. Merritt should enjoined by local official per Tex.Civ.
Prac.&Rem.Code Chapter 12 Section 12.003.
Respectfully Submitted
^^ ^J
Lowell Merritt / Appellant / 2470 E. Stone Rd. Wylie, TX. 75098
E-Mail: knightl55@excite.com /Ph. 214-778-5430
13
CERTFICATE OF SERVICE
A copy of this Document was sent Certified Mail 7015 0640 0004 4532
7178 to Defendant (pro se) Mr. James Andrews address at 122 Touchstone
Wylie, TX. 75098 and sent to Defendant (pro se) Mr. Robert J. Davis Fax
Number 972-234-1750 on Ht/&tl/S7'/7** %£>/£ .
Respectfully Submitted
Lowell Merritt / Appellant / 2470 E. Stone Road Wylie, TX. 75098
E-Mail: knightl55@excite.com / Ph: 214-778-5430
14
- •' ' i.
APPENDIX
Event Page
Appeals Court Cause 06-15-00047-CV (i)
Final Order Appealed from 19th Dist. Ct. McLennan County (i)
Identity Of Parties (ii)
Table Of Contents (iii)
Index Of Authorities (iv) (v)
Oral Argument Not Requested 1
Statement of the Case 1
Statement of Facts 1
Argument „,2-ll
Summary of Argument 12
Prayer 12-13
Certificate of Service 14
FINAL VERDICT from 19th Dist Ct. in Waco 15
Document of Evidence...
Exhibit (AA) initial filing of Merritt v. Davis, Motion for Bench Trial with
FIAT signed & Notice by Fax
Exhibit (A) page 4 of Mr. Davis Brief to Change Venue
Exhibit (B) Appeal of JP Court Orders to County Court... 2 pages
Exhibit (C) shows Motion To Appeal Ruling filed in County Court
15
Exhibit (D) is Notice By FAX regarding Affidavit to Appeal using strict
proof per Rule 572 to all Council and to JP Court Judge Douglas
Exhibit (E) Page 1 and 2 of County Courts Register of Actions showing
Council for Defense filed nothing, and DWOP was Final Verdict.
Exhibit (F) is where Mr. Davis admits he did not declare Mr. Merritt to be a
Vexatious Litigant...(yet is Mandated by this Statute and is why Case Law
prohibits sua sponte)
Exhibit (G) is where Mr. Davis CHANGES HIS STORY on how he
Transferred Venue of Merritt v. Davis case to Collin County BECAUSE he
no Evidence 15.013 Injunction EXISTED...he swore was true in 2009 so he
claims it was The "Mandatory Venue of where Defendant Lives" in 2014.
16
CAUSE NO. 2015-2602-4 \ * <*
LOWELL MERRITT § IN THE DISTRICT COtef^^ -* &
vs § MCLENNAN COUNTY, TCX/ftw ^9
§ ^