Filed: 12/2/2015 2:33:24 PM
JOHN D. KINARD - District Clerk
Galveston County, Texas
Envelope No. 8055212
By: Pamela Stines
12/2/2015 2:40:26 PM
UNITED STATES DISCTRICT COURT
SOUTHERN DISTRICT OF TEXAS FILED IN
GALVESTON DIVISION 14th COURT OF APPEALS
HOUSTON, TEXAS
12/4/2015 12:09:18 PM
JAMES KEITH WINGATE
CHRISTOPHER A. PRINE
PRO-SE PLAINTIFF. Clerk
CASE NO.
VS.
GALVESTON COUNTY COURT
AT LAW NO. 2
GALVESTON TEXAS
DEFENDANTS
RE: CASE NUMBER 15-FD-1440
EMERGENCY AND EXPIDITED HEARING ON MOTION OF VIOLATION
OF SIXTH AND FOURTEENTH AMENDEMENT RIGHTS AND DUE
PROCESS AS DEFINED BY FEDERAL AND STATE STATUES
PARTIES
1 JAMES KEITH WINGATE 1612 COUNTRY MEADOWS LANE SANTA FE TEXAS 77517
DEFENDANT AND PLANTIFF IN CAUSE NUMBER 15-FD-1440
2.COUNTY COURT AT LAW NUMBER 2 GALVESTON TEXAS
3.JANA LANDRY ATTORNEY SERVICE THROUGH E -MAIL JANA LANDRY@PRODIGY.NET
4.KAREN S. WINGATE THROUGH ATTORNEY JANA LANDRY
JURISDICTION
THE JURISDICTION IS CORRECT
VENUE
THE VENUE IS CORRECT
PLEADING
James Keith Wingate Pro-Se seeks immediate Relief from the assigned
Court Because he has been Denied Equal access and Due Process
His 6th and 14th ammendment rights have been violated Because:
1. In a divorce filed on or about June 16th 2015
2. Mr. wingate saw the first violation of Due process when a County Court Judge
violated a Bankruptcy stay filed July 1 2015 Dominat Jurisdiction
recognized by Presiding Judge and Order issued July 1
Asst. Judge in fact violated that stay on July 2nd by allowing parties
to take steal procur and hide personal and family items subject to
protection under section
3. To Date Mr. Wingate has had to file an advesary two recusals of judges
one motion for Mandamus with a notice to court of second to follow
one motion on contempt one motion for emergency consideration
one expidited motion because a malicious charge was filed against him
while he was at his house by agreement by the efforts of Jana Landry
And Karen S. Winagte and had to post bond and suffer embarassment
this expidited motion is still yet to be heard
4. Mr. Wingate fears for his safety and liberty and the Judges and process
as Defined has not only failed but appears to be broken
DUE PROCESS
As defined by Law guarantees me Equal access with no fear of bias or discrimination
no fear of loss of liberty or life no fear of false imprisonemnt or harassment
Not only should I be able to question these actions as My rights guarantee
But should not fear retalitory actions because I do there have been Paperwork
Issues addressed Mz. Landry filed a Petition with the court and civil Process
documents showing the wrong address for service the pleadings as to discovery level
Are incorrect she has denied me any information related To Karen S. wingate
Im wondering what the next shoe will be dropped
SUMMARY OF FACTS
Plantiff in this action for emergency relief Requests an immediate hearing
And offers to the court Oral argument for federal intervention because
His civil rights have been ignored pro-se is not a legitimate term in this court
He is afraid for his life and liberty the assistant judge has answered a recusal
Motion that I didnt even file I have had to ask the Regional Judges son
To Recuse himself to avoid Judge Bias being shown I have been arrested for
Trespassing on the property I own Oral argument Requested
PRAYER
James Keith Wingate seeks immediate relief in an action thats in abatement
A presiding Judge facing recusal the assistant Judge denying recusal on unflied
Motions after a Violation of a federal stay a motion for summary judgment
two motions of contempt one motion for harassment one motion for expidited
Reconsideration two recusal motions on presiding Judge one Advesary
and one Motion for Mandamus all ive gotten is a Realization of what the
True definition of a want of Prosecution is Im Requesting an immediate
Order estopping any further action Pending investigation of this cause
and parties to this cause
Respectfully Submitted
James Keith Wingate
Notice of Service: This motion for Expidited hearing will be forwarded to the
district clerk Of Galveston County with notice of this Leave to file in Federal court in
accordance with Rules and has been E filed with said court
on December 2nd 2015 a true and correct copy will be sent to Jana Landry
through her e mail service at janalandry@prodigy.net and Karen Wingate through counsel
Afadavit of Fact Now appears James Keith Wingate and swears all content in this
motion and all statements made are based on his best recollection of facts experienced
and any and all documents that may be requested or offered have been obtained from my
Personal Records or are the true and correct filings from my hand
Sworn December 2nd 2015
\s\ James Keith Wingate
James K Wingate
Pro – Se
1612 country meadows ln
Santa Fe Texas 77517
409-457-5147
Kwing94030@aol.com
ORDER
ON DECEMBER 2ND 2015 JAMES KEITH WINGATE APPEARED
SEEKING HEARING ON MOTION FOR VIOLATION OF 6TH
AND 14TH AMENDEMENT RIGHTS VIOLATIONS ON AN EXPIDITED
EMERGENCY AND DENIAL OF DUE PROCESS AS GUARANTEED
PRESIDING JUDGE
GRANTS ORDER
DENYS ORDER
\s\ James Keith Wingate
James K Wingate
Pro – Se
1612 country meadows ln
Santa Fe Texas 77517
409-457-5147
Kwing94030@aol.com