FXLED XN
court of Appeals
No. 05-18-00868-CV MAR 4 2019
Lisa Matz
- - - - - - - - - - - - - - - - - - - - - - - - C - l e - - r k - - - - ,5th District
IN 1'HE COURT OF APPEALS
FOR TH ~ FIFTH DISTRICT OF TEXAS
Brigetta D'Olivio
Defendant-Appellant
v.
Greg Fox and Laura Fox,
Plaintiffs-Appellees
On Appeal from the 191st Judicial District Court
Dallas County, Texas
Tr. Ct. No. DC-16-05606
APPELLANT'S 3r41 AMENDED MOTION TO EXTEND TIME
TO FILE t\PPELLANT'S AMENDED BRIEF
TO THE FIFTH COURT OF APPEALS:
The undersigned, Briget a D'Olivio, Appellant, files this Third Amended
Motion To Extend Time Tc File Appellant's Amended Brief and would show the
Court as follows:
1
1. Appellant has not been erved "Appellees' Objection To Motion For
Extension of Time", dated F b. 27, 2019, nor has she been served "Appellees'
Amended Objection To Moti n For Extension of Time", dated March 1, 2019.
2. In both of his Certifica es of Service for each of said the above-referenced
objections, Appellees'attom y, David M. Kleiman, (Kleiman) states, in part,"/
hereby certify that a true an correct copy of this document has been served upon
Appellant Brigetta D 'Olivio via the Court's eFiling service at
3. Said statement in each of aid certificates of service by Kleiman is false.
4. Appellant has never regis ered, nor has she ever given anyone, nor any entity,
the permission to register he as an e-filer on any EFSP, including
Texasonline.gov. Appellan does not have an e-File account with any EFSP.
5. Appellant has never waiv d her right to be served. Simply filing said above-
referenced "Appellees Obje tion to Motion For Extension of Time", dated Feb. 27,
2019 and "Appellees' Ame ded Objection to Motion For Extension of Time",
dated March 1, 2019 does n t constitute service.
6. Where Appellant has nev r registered as an e-filer and where there is no account
of Appellant with any EFS , there can be no such service to Appellant via "e-
File". Nor has Appellant ha been served Appellees' above referenced filings via
email, certified, first class o regular mail.
2
INTRODUCTION
7. That pursuant to Rule 34. of the Texas Rules of Appellate Procedure, there is
no written stipulation filed w th the trial court ( 191 st District Court) wherein only
certain records would be file with the Court of Appeals in the event of an appeal
for the underlying cause nu ber, (DC-16-05606).
8. That, on the contrary, in ppellant's Request For Clerk's Record, dated and
filed July 30, 2018, it specifi ally states, in part, " ... All additional items required
to be included in the Clerk's record according to Rule 34.5 of the Texas Rules of
Appellate Procedure".
9. There are thirty-eight (38 records that have been previously requested to be sent
up to the Court of Appeals, hich have not yet been sent up.
10. There are at least six (6) records that had been previously filed with the Court
Clerk for the 191 st District ourt, which are now missing and/or removed from the
Court Portal without a Cou Order.
11. There are errors and alt rations in the Reporter's Record and the Clerk's
Record for which Appellan has requested corrections and of which Appellant has
requested relative informati n. Appellant has made numerous and various requests
for corrections, clarificatio s and inquiries, without any substantive response.
12. There are missing invoi es, improper invoices and invoices not sent to
Appellant as it relates to th above-referenced thirty-eight (38) records, which
3
correspond to five (5) supple ental clerk's records requests, dating as far back as
December 31, 2018.
13. One (I) of said five (5) s pplemental clerk's records requests was filed under
an unrelated cause number. is is despite the fact that said supplemental clerk's
records request specifically i entified the correct cause number (DC-16-05606).
Another supplement request as not filed on the portal despite having been filed,
and despite having a file sta p. That said supplemental request was filed only
after Appellant asked why it wasn't filed.
14. Although Appellant has communicated directly with District Court Clerk,
Felicia Pitre, regarding the hove-referenced issues so that Appellant can pay, and
so that the supplemental cle k's records can be sent up to the Court of Appeals,
Ms. Pitre has been unrespo sive to Appellant's requests for clarifications,
corrections and invoices th t relate to each outstanding supplemental clerk records
requests.
15. Since Ms. Pitre failed t cooperate with Appellant's requests for clarification,
corrections and correct inv ices, Appellant filed correspondence with the Court
Clerk of the 191 st District ourt on February 25, 2019. Since filing said
correspondence, reference to Appellant's supplemental requests for clerk's
records on the court portal have changed.
16. Appellant's Amended Brief is due on March 7, 2019.
4
17. For all of the above-refer need facts, which are addressed in detail below,
Appellant is requesting an ex ension to file her Amended Brief so that the complete
and correct requested records relevant to the underlying appeal have been sent up
to the Court of Appeals, and o that Appellant will have the opportunity to review
and cite said records prior to 1ling her Amended Brief.
18. That Appellant files this ithin motion not for purposes of delay, but in the
interest of justice.
19. This is Appellant Pro Se' s 2nd request for extension to file her Amended Brief.
Appellant is requesting an e tension to file her Amended Brief on March 28,
2019, provided said pleadin s/records have been sent to the Court of Appeals.
Appellant's extension conte plates avoidance of substantial and irreparable
prejudice and damage to Ap ellant.
APPELLANT'
JULY 30, 2018
20. On July 30, 2018, Appe lant's then attorney Timothy Hootman, (Hootman),
filed a "Request For Clerk' Record" with District Clerk, wherein fifteen (15)
records were requested, (Ex ibit 1, Request For Clerk's Record, dated July 30,
2018).
5
21. According to the docket heet for cause no: DC-16-05606, dated Feb. 22, 2019,
there is a notation that on Au ust 1, 2018, the records for said July 30, 2018 clerk's
records request were being p epared, (Exhibit 2, Docket Sheet, dated Feb. 22,
2019, p. 11).
22. On August 25, 20181, In ex for Volume 1 of 1, dated August 1, 2018 was filed
with the Court of Appeals. I said Index, F elcia Pitre lists the records requested by
Hootman on July 30, 2018. said listing, there is a pleading entitled, "Plaintiffs'
Proposed Findings ofFact nd Conclusions ofLaw", which was not part of
Appellant's Request For Cl rk's Record, dated July 30, 2018, (See Exhibit 1,
Request For Clerk's Record dated July 30, 2018).
23. On August 8, 2018, a" Zerk's Record Payment Notice" (invoice) of$907.00
was filed for said July 30, 2 18 request. Next to the notation on the Docket Sheet
for said date, it states, "Cler 's Record Payment Notice". It further stated,
"Emailed Atty $907.00", (E hibit 2, Docket Sheet, dated Feb. 22, 2019, p. 11).
24. Approximately five (5) eeks later, on September 11, 2018, The Court of
Appeals (COA) sent a lette to Hootman asking Hootman to verify payment of said
Invoice for said July 30, 20 8 Clerk's Record Request. In his response to the COA,
Hootman stated that he had sent a check in the amount of$907.00 for said invoice
to the Dallas County Distri t Clerk's office on September 10, 2018.
1On the same date, August 25, 20 8, Appellees' Supplemental Request For Clerk's Record, dated
August 24, 2018, was also filed at he Court of Appeals. There is no indication on the record that
Appellees filed any request for Cle k's Record prior to August 24, 2018.
6
25. On September 14, 2018, ootman emailed Appellant, wherein he stated, "The
district clerk accidentally se t the $907. 00 bill for the clerk's record to the wrong
attorney ... ", (Exhibit 3, Lett r, dated September 11, 2018 and Email, dated
September 14, 2018).
26. Prior to said email, date September 14, 2018, Appellant had not been made
aware that the bill for said cl rk' s record request, dated July 30, 2018, was not
received by Hootman or tha it was "accidentally" sent to the wrong attorney.
27. After receiving said ema 1 from Hootman, Appellant deposited an additional
$3,145.00 into Hootman's b account, which she confirmed via text message to
Hootman.
28. In said text message, sh informed Hootman that $907.00 of said $3,145.00
was to be used to pay said i voice, (Exhibit 4, Invoice, dated August 8, 201, Text
Message of deposit and cop Deposit Slip for $3,145.00).
29. At the time that Appella t paid said invoice of$907.00 for said July 30, 2018
"Request For Clerk's Reco ", she had not yet become aware that said unsigned
pleading, entitled, "Plainti s 'Proposed Findings ofFact and Conclusions of
Law", was included in the ost of said invoice2 •
2Appellant had become aware tha said pleading, "Plaintiff's Proposed Findings of Facts and Conclusions
of Law" only after the Clerk for the ourt of Appeals provided her with a CD of the pleadings sent up to
the Court of Appeals.
7
30. Said pleading, however as not part of Appellant's "Request For Clerk's
Record", dated July 30, 2018, (Exhibit 1, Request For Clerk's Record, dated July
30, 2018).
DECEMBER 31, 2018
31. On December 30, 2018, ppellant sent an email to Hootman, wherein she
stated, in part, "Attached is list of documents/records that absolutely must be sent
up to the Appellate Court... /so I still have not received a copy of the remaining
files that went up to the App /late Court that you stated you had received...",
(Exhibit 5, Email, dated De ember 30, 2018@6:JOpm with ListofDocuments3).
32. The list attached to said mail included thirty-four pleadings, records etc,
which were in addition to n erous other pleadings/ records that Appellant had
previously requested Hoot an to have sent to the Court of Appeals.
33. At 12:00am on Decemb r 31, 20184, Hootman filed "Appellant's Request For
Supplemental Clerk's Reco cf', wherein he listed twenty-seven (27) pleadings,
records, etc requested, (Exh'bit 6, "Appellant's Request for Supplemental Clerk's
Records ").
3 Said list of pleadings/records wa reduced to writing and attached to said email to Hootman since he
had failed to request said pleading /records upon Appellant's previous multiple requests (verbal and in
emails) to do so.
4 After having filed Appellant's Su lemental Request For Clerk's Record on Dec. 31, 2018 at 12:00am,
Hootman filed his Motion To With raw as Attorney on Appellant's other appeal, 05-18-01126-CV (Hermus
case) on Jan. 2, 2019.
8
34. On the Feb, 22, 2019 Co rt Portal, for the date for Dec. 31, 2018, under the
comment section, it refers to ppellant's Request For Supplemental Clerk's
Record as "Supplemental Cl rk 's Record Request", (Exhibit 7, Court Portal, dated
February 20, 2019).
35. On the same court portal (Feb. 20, 2019) for the date, Jan. 4, 2019, under the
comment section it states," reparing Supplemental Record 05018-00868",
(Exhibit 7, Court Portal, da d February 20, 2019).
36. After Appellant had file said correspondence to Felicia Pitre with the Court
Clerk in the 191 st District C urt on February 25, 2019, after having not received
responses to her inquiries a d requests for invoice clarification and corrections, the
references to said Dec. 31, 018 "Appellant's Request For Supplemental Clerk's
Record" (within exhibit 6), hanged on the court portal.
37. On the February 28, 20 9 and the March 1, 2019 court portal under the
comment section for the da e, Dec. 31, 2018, it refers to Appellant's Request For
Supplemental Clerk's Rec rd as "#2 Supplemental Clerk's Record Request",
(Exhibit 8, Court Portal, d ted February 28, 2019, p. 28 and Exhibit 9, Court
Portal, dated March 1, 20 9).
9
38. Said Dec. 31, 2018 was ppellant's first Request For Supplemental Clerk's
Record, while Hootman was still her attomey 5• Note that on the Docket Sheet,
dated February 22, 2019, thee is no number attached to Appellant's Request For
Supplemental Clerk's Recor , (See Exhibit 2, Docket Sheet, dated February 22,
2019, p. 13).
39. On the same court portal (Feb. 28, 2019) for the date, Jan. 4, 2019, under the
comment section it does not eference a numbered supplemental request for
Appellant's Dec. 31, 2018 r quest for supplemental clerk's record. Instead, it
states, "Preparing Supplem tal Record 05018-00868", which is the same as
Docket Sheet, dated Februa 22, 2019, and the court portal, dated March 1, 2019,
(Exhibit 9, Court Portal, dat d March, 1, 2019, p. 28; See also Exhibit 8, Court
Portal, dated February 28, 019, p. 28 and Exhibit 2, Docket Sheet, dated Feb. 22,
2019, p. 13).
40. For the date Janua 17 2019, on said court portal (Feb. 28, 2019), under the
heading, "Clerk's Record P yment Invoice", it states, "#2 Supplemental Clerk's
Record', (Exhibit 8, Court ortal, dated February 28, 2019, p. 28).
41. On the court portal, dat d February 20, 2019, for the same date, January 17,
2019, under the heading "C erk's Record Payment Invoice", it does not refer to any
record requests, (Exhibit 7, ourt Portal, dated February 20, 2019).
5 Attorney Timothy Hootman contin ed to be Appellant's attorney until he was discharged by the Court of
Appeals on January 15, 2019. He ad filed a Motion To Withdraw from this underlying appeal on January
7, 2019.
10
42. On the Docket Sheet,
Fw: Submitted new filing(s) fo case#OS-18-00868-CV with submission id#27545149
tim hootman Fri, Sep 14, 2018 at 6:33 PM
Reply-To: tim hootman
To: Brigetta D01ivio
Brigetta
The district clerk accidentally sent the $90 bill for the clerk's record to the wrong lawyer (i.e., not to me) so I went ahead and
paid it because it was late. See the attache letter in this regard that I filed with the court of appeals. Please reimburse me
when you can.
Tim
713.366.6229 (c)
- Forwarded Message -
From: support@filetime.com
To: "thootman2000@yahoo.com"
Sent: Friday, September 14, 2018 06:31:0 PM CDT
Subject: Submitted new filing(s) for cas 18-00868-CV with submission id#27545149
file TEXAS
Fast and Reliable
Proof of Submission
Submission ID: Cause No:
27545149 05-18-00868-CV
Submission Date & Time: Client ID:
09/14/18 06:30 PM COST Document:
Appellant: Letter to court of appeals.pdf
Brigetta D'Olivio
Appellee:
Greg Fox
Case Information Fees Breakdown
Case Title: Client ID:
Jurisdiction: Cause No: Court Fees
5th Court of Appeals 05-18-00868-CV
Case Category: Attorney: Letter
Civil - Other Civil Timothy Andrew
Case Type: Hootman Filing Fee $0.00
Civil Filer:
Payment Account: Timothy Andrew Total Fee For This Filing $0.00
4635720015893108 Hootman
Submission Fees
Case Parties
eFiling Manager
$0.09
Convenience Fee
Appellant livio Yes
https://mail.google.com/mail/u/O?ik=ba80a72ce2&view= search=all&permmsgid=msg-f%3A 1611627791996327736&i::imnt=m"'n-fDt.~A 1 i::11 i::-,nn• n
2/6/2019
Gmail - Fw: Submitted new filinQ(s) for case#OS-18-00868-CV with submission id#27545149
Appellee Greg F x No FileTime Service Fee $2.99
Filings Sales Tax on FileTime Fee $0.25
Filing Type: eFile & eServe
Total Submission Fees $3.33
Document Total Fees for this Filing $3.33
Type Security
Letter Letter to court of appeals.p f Lead Document Public Credit Card Information for
This Filing
Filing Description: Letter Your credit card statement will
show:
Pleading
Jurisdiction $0.00
eFiling Manager $3.33
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EXHIBIT 5
41
012019 Gmail- DC-16-05606 Appeal
Brigetta DOlivio
DC-16-05606 Appeal
3rigetta DOllvio Sun, Dec 30, 2018 at 6:10 PM
ro: Tim Hootman
Attached is a list of documents/records that ab olutely must be sent up to the Appellate Court immediately and most definitely
before oral argument.
When l repeatedly asked you about receiving t e trial transcript, the status of the appeal and what documents were sent up to the
Appellate Court, you repeatedly told me not to orry about it. Now l find out that NONE of the relevant documents, especially as
they relate to my claims and defenses, have be n sent up to the Appellate Court, and moreover, not only has the trial transcript has
been altered but my 2nd Amended Answer & 1 t Amended Counterclaims is not correctty referenced in your answer. My 2nd
Amended Answer & 1st Amended Counterclai s were filed on Nov. 13, 2017, were timely and were unopposed. The plaintiffs'
answer to this was untimely and they never cur d the special exceptions defect as raised in my amended and 2nd amended answer
& 1st amended counterclaims.
Also attached hereto are specific breakdowns o various, yet pertinent aspects of the underlying case that need to be addressed on
appeal since, not only do they go to the heart of e case, but they also prove that my constitutional right to due process and my
right to a full and fair trial on the merits was viol ed. These facts and evidence, which are a part of the trial m@rd. further prove that
plaintiffs' underlying case was frivolous and that t the time that it was filed, atty Kleiman knew that it was frivolous and that his filing
of said underlying case was nothing short of as akedown. (This info may come in 2 emails - depending upon space)
Also, I have still not received a copy of the rernai ing files that went up to the Appellate Court that you stated that you had received.
Nor have l received a copy of the trial evidence t at has been sent up to the Appellate Court. Please forward that to me upon
receipt of this email. This is also important beca e during trial, Greg Fox admitted to splicing and altering audio recording, altering
my bank records, and testimony was given whic showed that the Foxs also altered the GCSA and Exhibit B of Amendment 3.
I agree that this is a contract case and that Ame ment 4 supersedes Amendment 3. HOWEVER, the numbers relevant to the
contract and hence, the numbers relevant to the rial, are derived from what was considered the "formal construction budget", dated
June 26, 2014, which the Foxs agreed to via em ii on June 27, 2014. Said formal construction budget was subsequently reduced to
the written and signed Amendment 3, dated July , 2014. Included in, and attached to, said Amendment 3 was Exhibit B, dated July
7, 2014. Said Exhibit B reiterated the constructio budget breakdown as well as the 23 required items that the Foxs were required to
purchase with the allowance budget, which was a so specifically referenced in both the formal construction budget and said
Amendment 3.
Parenthetically, EVERY amendment to the GCSA and all of which the Foxs signed, contractually obligated the Foxs for any and all
costs for any and all upgrades, modifications and/ r change orders, as well as, for any overages on the allowance budget.
As a contract case, breach of contract is the most ormidable aspect. Where one breaches first, then he/she cannot then enforce the
contract on the party who did not breach. The pa who did not breach is entitled to benefit of the bargain - full contract price plus
whatever interest {in this case 18%) for any unpai balances on the contract, and where fraudulent inducement exists, and in this
case, where the evidence is overwhelming that th Foxs intentionally and repeatedly perpetrated fraudulent inducement, then tort is
allowed, hence damages.
The Court erred, and in fact, further demonstrated ts gross prejudice against me when, during trial, it REFUSED to allow my fraud
claims against the Foxs to be presented. Not only as this overt bias, but it flies in the face of due process. My 2nd Amended
Answer and 1st Amended Counterclaims, filed No . 13, 2017, were not only timely filed, but stood unoQQOSed. Included in my
counterclaims were causes of action for fraudulent inducement, fraud by nondisclosure, common law fraud and fraudulent
concealment.
The fraud committed by the Foxs was inextricably i tertwined with the underlying contract. The underlying contract is the GCSA and
4 Amendments, thereto. You, in fact, even stated t me last week that the judge "hates'; me and would sign any order against me.
For an appellate attorney who was not a part of the trial level to make that statement further shows that Judge Slaughter's bias
against me is so grotesque that a person not intima e with the trial level in this case would be aware of her bias.
10/2019 Gmail- DC-16-05606 Appeal
During trial, Greg admitted that he and Laura reached the contract first and that they were insolvent before they entered into
contract and were already in material breach ( II of this intentionally concealed by the Foxs throughout life of contract).
As l have informed you repeatedly, the trial tra script is altered - in MULTIPLE areas, INCLUDING where Greg Fox admitted that he
and Laura breached the contract first, where G eg Fox admitted that he and Laura ordered more than 380 upgrades, where Greg
Fox admitted that he and Laura were in materi l breaches (insolvency, federal tax lien.and failure to pay when due) and where
Laura admitted that they had received the final ·nvoice, and did not pay it, and that they owed me money but would only pay what
they owe me if they were ordered by the Court o pay me, etc.
Four (4) critical documents prove that during th trial Greg Fox admitted to breaching first, and these four documents further prove
that the transcript was altered.
1. .Q!.Q§ing..ru-gument during trial on Nov. 22, 2017,..QY. m:v. attorney, Jennifer Gjesvold wherein she explicitly stated that plaintiff Greg
admitted during his trial testimony that he and L ura breached the contract first. When asked by the judge if he had any rebuttal to
Gjesvold's closing statement, Foxs' attorney Kl inman said he did not. IF Greg Fox had not admitted to breaching first, then logic
would dictate that Kleiman would have rebutted Clearly they forgot to alter this part of the trial transcript.
2. f.!:!mi.!. dated Nov. 24, 2017 from mY. attorneY. enn~ r jesvold to mY. sister. Said email was sent only two (2) days after trial had
ended. See copy of email below.
l~
1
Fri, Nov 24, 2017, 9:52 AM
Jennifer Gjesvold, Esq. !
To me
Hey Bernie! Thanks so much. Your my leg I eagle. Awesome!! I am still working on the brief. This is helpful. I need
the breakdown briggetta did in fourteen the ·udge told her to slow down. Cause the judge was writing it down. So i
need to be consistent with what she wrote own. Also need the adjusted cost to complete. Ultimately I want her to do
the same analysis as the expert cause she was so on point. And / listed her as an expert a nd he never objected nor
did he take her on vior dire.... so I want and eed her to redo accurately his expert report by Saturday. Just exactly as
he did just fixing what I pointed out when h was on cross. Then I also need her damages breakdown. Finally I need
her to release the lien on Monday so I can how the court that she's done that and so that knocks out his fraudulent
lien, conversion, theft, and what she did to itigate damages,ie paying to hold their property in the container on their
property, ect. Paying subcontractors who th y did not pay, that sort of stuff. I need all that by Saturday. If possible.
Your one smart cookie and if you can help er stay streamlined and focused, meaning three pages or less, plus proof
of payment for what she paid for in the cool tube thing. That would be great. Hope you both had a wonderful
thanksgiving. Let's meet sunday to pull eve hing together. I highly doubt opposing counsel will submit anything
beyond what he submitted as exhibit 80. So i think now is the time for a directed verdict on everything except breach
of contract then use their own testimony to ang them since Greg admitted he breached first. She has to give that
the utmost weight. So i need her breakdow. on breach of contract damages. Regards, jen
3. f!:nsli!, dated Feb. 1, 2018 from Gjesyold to me I am in process of retrieving the email. In said email, Gjesvold reiterated the
FACT that Greg Fox admitted during his trial testi ony that he and Laura breached the contract first.
4. Defendant's Post Trial Brief, filed Nov. 29, 2 , wherein par. 1, lines
1-1 O, it states, "Greg Fox admitted at trial to brea ing the contract for services first, that it was a material breach, and that he and
his wife were insolvent at the time they entered in the contract for services with Ms. D'Olivio.... Greg Fox admitted that there was a
federal tax lien on the subject property which was second material breach to the general service contract ... Laura Fox admitted at
trial to receiving the May 19, 2016 emails, Defend nt's Exhibit 18 and Defendant's Exhibit 19, which shows that both Greg and
Laura Fox admitted to receiving the final invoice o or about May 8, 2016 and that they could not pay the undisputed amount due
and owing to Ms. D'Olivio ..." .
At NO time since the trial, has Foxs' attorney, Klei an, ever stated that the Foxs did not admit during their trial testimony that they
breached the contract first, that they ordered more than 380 upgrades, that they were insolvent before they entered into contract,
that they were in material breaches, including as t federal tax lien since June 2015. In fact, atty Kleiman never filed any
controverting statements rebutting or challenging t e statements made by my attorney regarding these issues, neither during
closing arguments at trial, nor in response to "Defendant's Post Trial Brief', filed on Nov. 29, 2017. Moreover, my former attorney,
Gjesvold never amended the post-trial brief.
To say that the altering of a trial transcript is of no i port is to deny the reality that i) altering a trial transcript is, itself, fraud on and
by the Court; ii} is a crime; iii) belies any claims ma e by plaintiffs; iv) taints the record on appeal; v) is a continuation of violation of
my constitutional right to due process, etc. This iss e will NOT go unattended.
As my retained appellate attorney, I am insisting th t the altered transcript be noted on appeal and all records that I have requested
be immediately sent up to the Appellate Court whe the appellate brief has been filed with verification that this has been done .. I
10/2019 Gmail - DC-16-05606 Appeal
am also insisting that the appellate brief be am nded.
Please call should you have any questions.
Sincerely,
Brigetta D'Olivio
Brigetta D'Olivio
Custom Home Builder
214.733.7204
Beautiful Homes by Brigetta
NAWIC
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5 attachments
:.'.l to ac (1 ).pdf
61K
:J p3.pdf
90K
-;_:j p2.pdf
137K
:J p5.pdf
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:.1 p6 (1).pdf
. 169K
Non-Jury Pre-Trial Order, A gust 10, 2016
Defendant's 2nd Amended swer & I St Amended Counterclaims, filed Nov. 13, 2017
Defendant's Brief on Damag s, filed Nov. 29, 2017
Plaintiff's Amended Designa ion of Expert Witness, filed July 28, 2017
Plaintiff's Original Petition, led May 10, 2016
Plaintiff Amended Petition, fi ed July 28, 2017
Deposition Transcript, filed gust 11, 2017
Defendant's Amended Motio For Continuance, filed August 18, 2017 @4:00pm
Defendant's Answer to Motio To Withdraw, filed August 21, 2017 @12:40PM
Defendant's Amended Answe To Motion To Withdraw, filed August 22, 2017 @3:22PM
Defendant's Amended Motio To Set Aside, filed September 7, 2017 @11 :55AM
Defendant's Motion To Quas , filed September 7, 2017@1 l:45AM
Atty Clark's Motion To With aw, filed August 18, 2017@10:43AM
Defendant's Motion For Conti uance, filed August 16, 2017 @4:48PM
Order, dated August 21, 201 7
Order dated September 22, 20 7 (denying motion to quash)
Docket Sheet, dated Septembe 22, 2017, filed on September 29, 2017@4:07PM
Defendant's Amended Respo e to PJ's Motion For Sanctions, filed Oct. 4, 2017 @4:0IPM
Defendant's Correspondence t the Court, dated 8/24/, 2017, filed August 25, 2017 @3:52PM
Hearing Transcript for Nov. I , 2017
Hearing Transcript for August 3, 2017
Hearing Transcript for Septem er 22, 2017
Defendant's Motion To Comp 1, Sanctions, Continuance, filed Nov. 9, 2017@ 1:28PM
Defendant's Demand For A J Trial filed Nov. 13, 2017
Defendant's Correspondence t the Court, filed October 4, 2017
Defendant's Correspondence t the Court, filed September 26, 2017 @2:34PM
Defendant's Correspondence t the Court, filed Nov. 13, 2017 @12:39PM
Defendant's Motion To Comp 1 Arbitration, filed Nov 2017
Defendant's Combined Motion To Strike Plaintiff's Answer to Counterclaims as Untimely and
TO Strike From the Record Pla ntiff's Motion To Strike Defendant's Amended Answer and
Counterclaims, filed Nov. 20, 017
Defendant's Amended Excepti n To Plaintiff's Petition, filed Nov. 20, 2017
Defendant's Motion To Exclud Expert Testimony & Report, filed Nov. 20, 2017
EXHIBIT 6
42
FILED
DALLAS COUNTY
12/31/2018 12:00 AM
FELICIA PITRE
DISTRICT CLERK
Angela Conejo
No. DC-16-05606
GREG FOX § IN THE DISTRICT COURT
§
V. § DALLAS COUN1Y, TEXAS
§
§ 191ST JUDICIAL DISTRICT
APPE
CLERK'S RECORD
To the Clerk: '
Appellant, B~a D'Olivio, files this request for supplemental
clerk's record in th s appeal and requests the clerk to prepare a
Supplemental Clerk's ecord, including the following items:
• Info Sheet, fi ed on or about 05/11/2016
• Non-jury Pre trial Order, filed on or about 8/10/2016
• Defendant's nd Amended Answer & 1st Amended Counterclaims,
filed on or ab ut 11/13/2017
• Defendant's rief on Damages, filed on or about November 29,
2017 !
• Plaintiffs Ajended Designation of Expert Witness, filed on or
about 07/;si~o17
• Deposition tr*script, filed on or about 08/18/2017
• Defendant's ended Motion for Continuance, filed on or about
8/18/2017 I
• Defendant's tswer to Motion to Withdraw, filed on or about
8/21/2017
• Defendant's ended Answer to Motion to Withdraw, filed on or
about 8/22/2 17
• Defendant's ended Motion to Set Aside, filed on or about
9/7/2017
• Defendant's Jotion to Quash, filed on or about 9/7/2017
• Atty Clark's Mption to Withdraw, filed on or about 8/18/2017
I
1
I
• Defendant' Motion for Continuance, filed on or about 8/16/2017
• Order, date on or about 8/21/2017
• Order, date1 on or about 9/22/2017 (denying motion to quash)
• Docket She~t, dated 9/22/2017, filed on or about 9/29/2017
• Defendant's Amended Response to Pl's Motion for Sanctions,
filed on or a out 10/4/2017
• Defendant's Correspondence to the Court, dated 8/24/2017, filed
on or about o/4/2017
• Defendant's otion to Compel, Sanctions, Continuance, filed on
or about 11/ /2017
• Defendant's emand for a Jury Trial, filed on or about
11/13/2017
• Defendant's ~orrespondence to the Court, filed on or about
10/4/2017 I
• Defendant's ~orrespondence to the Court, filed on or about
9/26/2017 i
• Defendant's ~orrespondence to the Court, filed on or about
11/13/2017 I
• Defendant's ¥otion to Compel Arbitration, filed Nov 2017
• Defendant's ombined Motion to Strike Plaintiffs Answer to
Counterclaim as Untimely and to Strike From the Record
Plaintiffs Mo ·on to Strike Defendant's Amended Answer and
Counterclaim , filed on or about 11/20/2017
• Defendant's ended Exception to Plaintiffs Petition, filed on or
about 11/20/ 017
• Defendant's otion to Exclude Expert Testimony & Report, filed
on or about 11 20/2017
Dated:
2
Respectfully submitted,
/s/TimothyA. Hootman
Timothy A. Hootman
SBN 09965450
2402 Pease St
Houston, TX 77003
713.247.9548 (office)
713.366.6229 (cell)
713.583.9523 (fax)
thootman2ooo@yahoo.com
ATTORNEY FOR APPELLANT
BRIGETTA D'OLIVIO
~ERTIFICATE OF SERVICE
On this day, a opy of the above document was served by electronic
service on the followi g attorneys of record:
David M. Kleiman
VINCENT ERAFINO GEARYWADDELLJENEVEIN, P.C.
1601 Elm treet, Suite 4100
Dallas, 75201-3703
dkleiman vinlaw.com
Dated: December 30, to18
/s/TimothyA Hootman
Timothy A Hootman
3
EXHIBIT 7
43
2/20/2019
Details
Case Information
DC-16-05606 191st Di trict Court SLAUGHTER, GENA
05/10/2016 OTHER CONTRACT CLOSED
Party
..,
FOX, GREG
Lead Attorney •
KLEIMAN, DAVID
MASON ·,·
Retained
214-979-7400
214-979-7402
..,
FOX, LAURA
Lead Attorney
KLEIMAN, DAVID
MASON
Retained
214-979-7400
214-979-7402
https://courtsportal.dallascountv.ora/DALLASPROD/Hnm /Wnrko::n=ir.. Mnn..?n=n
2/20/2019 Det~!!e
...
D'OLIVIO, BRIGETIA
Pro Se
Address
3800 PEBBLECREEK CT.
PLANO TX 75023 Pro Se
Pro Se
Lead Attorney
PATIERSON, GARY
E
Retained
713-223-3095
713-223-2121
••
Disposition Events
Judgment•
JUDGMENT NON-JURY
Judicial Officer
SLAUGHTER.GENA
Judgment Type
JUDGMENT NON-JURY
$281,506.40
$31,100. 4
.
....
$1,126.00
$58,407.00
. of $372.,_140.04
l
httru:!• //,..n11rtc::!,nnrt!:1I rl~ll~e!:,..n11nh1 nrn/n.4.1 I .6.~1-1Qnn/l-ln o/\J\/nrltc::n~r:ol\.Anrlo?n=n
Ii
Details
2/20/2019
FOX, GREG, et
D'OLIVIO, RIGETIA
Events and Hearings
...
.. .:. Plaintiff's Original Petition
' .
...
Civil Case Information Sheet
...
ESERVE
OUT OF COUNTY
07/07/2016
3/36
Details
2/20/2019
...
Order Granting Substituted Se ice
...
ORDER SUBS SERVICE - AD IN QUE
...
BRIDGETTA D'OLIVIO
...
BRIGETTA D'OLIVIO RETUR OF SERVICE
...
..
Defendant's Original Answer
...
Vacation Letter
...
...
SLAUGHTER, GENA
9:00AM
BY COURT ADMINISTRATOR
4/36
Details
2/20/2019
S/S MAILED
Vacation Letter < .•
•
PLAINTIFF'S
UPDATED VACATION LETTE
•
•
•
PLTF'S SUPPLEMENTAL M/ OMPEL
•
SLAUGHTER, GENA
10:00 AM
•
AND; SUPPL MOTION
•
5/36
2/20/2019 Details
•
PLT - AMENDED
•
AMENDED
(NOT AGREED)
•
•
RE: DIM/CONTINUANCE
RE: CONTINUANCE AND W THDRAWAL OF ATTORNEY
•
TO DEFENDANTS MOTION FOR CONTINUANCE
•
ATTORNEY
6/36
Details
2/20/2019
PRIVATE PROCESS SERVER
08/22/2017
ATTY
•
•
•
AMENDED
•
AMENDED MOTION FOR C NTINUANCE
•
ORDER WITHDRAW
•
•
DEFENDANT
7/36
Ii
Deta!!s
2/20/2019
•
ANSWER TO MOTION TO WI HDRAW AS COUNSEL
•
ATTORNEY
PRIVATE PROCESS SERVER
08/22/2017
ATTY/DB
•
TO MOTION TO WITHDRAW AS COUNSEL
....
AMENDED ANSWER TO M TION TO WITHDRAW AS COUNSEL
•
CIT EXEC 8/21/17 PPS
·•
I
8/36
Details
2/20/2019
...
ATTORNEY
ATTORNEY
ATTORNEY
PRIVATE PROCESS SERVER
08/23/2017
ATTY
...
ATTORNEY
PRIVATE PROCESS SERVER
08/23/2017
ATTORNEY
...
SLAUGHTER, GENA
9:30AM
15 MINS - 214-733-7204 -AM /M/CONTINUE SET BY BRIGETTA
D'OLIVIO
...
CIT EXEC 8/22/17 TO DAVI MASON KLEIMAN PPS
... 9/36
h++,",.,,,..,.,,,rt,mnrh:il 1fall""'"m1ntv.ora/DALLASPROD/ ome/WorkspaceMode?p=O
i I
Details
2/20/2019
CIT EXEC 8/22/17 TO DAVID KLEIMAN PPS
•
RE: NOTICE OF WITHDRAW L
•
SLAUGHTER,GENA
9:30AM
CARRIED TO ANOTHER WEE
ATTORNEY
PRIVATE PROCESS SERVER
08/30/2017
ATTORNEY
,,.. . ' ...
httos://courtsoortal.dallascountv.org/OALLASPROD/ ome/WorkspaceMode?p=O
10/36
Details
2/20/2019
ATTORNEY
N/C
...
ATTORNEY
PRIVATE PROCESS SERVER
08/30/2017
N/C
...
ATTORNEY
N/C
...
•
CIT EXEC 8/29/17 TO DAVI KLEIMAN MASON PPS
...
CIT EXEC 8/29/17 TO DAVI MASON KLEIMAN PPS
...
...
LETTER TO JUDGE
11/36
Details
2/20/2019
•
DEFENDANT
•
DEFENDANT - TO M/SET ASI E ORDER
•
DEFENDANT - AMO M/SET A DIE ORDER
•
AMO M/ SET ASIDE ORDER DEFENDANT
•
ORDER ON AMO M/SET ASI E ORDER
•
DIM/QUASH
12/36
h++""'" "~n, ,r+.,r.nr+.. 1,1,:,11,,.,,,n, ,ntv nrn/DALLASPROD/ ome/WorkspaceMode?p=O
2/20/2019 Details
ORDER ON MOTION QUIIAS
•
M/QUASH
•
SUBPOENA: JP MORGAN C ASE BANK NA
•
PLAINTIFF'S RESPONSE TO MOTION TO QUASH
•
SLAUGHTER, GENA
03:45 PM
BRIGETIA D'OLIVIO 214 733-7 04 15 MIN M/QUASH
•
0/DENYING (DF) M/QUASH
•
LETIER TO COURT REPO TER REQUESTING TRANSCRIPT -
COPY GIVEN TO MELBA W IGHT
•
13/36
httos://courtsoortal.dallascountv.org/DALLASPROD/ ome/WorkspaceMode?p=O
I I
2/20/2019 Details
DESIGNATION REQUESTED J TIME OF ACCEPTANCE W/IN 3
DAYS
,cc ...
LETIER TO JUDGE SLAUGH ER
05-17-01119-CV
...
SLAUGHTER, GENA
10:00 AM
REQUESTED BY ATIORNEY/P O SE
15 MINS - SET BY KIM - 214-97 -7443 - CC REQ
...
clerk's record request
...
TO MOTION FOR SANCTIO S
.....
RE: INVOICE #171004-1
14/36
htt1Js://courtsoortal.dallascounty.org/DALLASPROD/ ome/WorkspaceMode?p=O
Deta!!s
2/20/2019
•
RE: REQUEST TO RE-SCHE ULE DEFENDANT'S SCHEDULED
HEARING DATE OF OCTOBE 4TH, 2017-AMENDED MOTION
TO SET ASIDE ORDER
•
AMENDED - MOTION FOR S NCTIONS
•
PREPARING CLERKS REGO D
'.
EMAILED PRO SE FOR $402
SLAUGHTER, GENA
10:00 AM
HEARING RESCHEDULED
D/M/SET ASIDE- BRIGETTA DOLIVIO 214 733-720415 MINS
•
15/36
htt"c:·I/M11rt<:rinrtal rlallascountv.ora/DALLASPROD/ ome/WorkspaceMode?p=O
Details
2/20/2019
ROBERT M. CLARK'S RESP NSE TO BRIGETTA D'OLIVIO'S
MOTION TO SET ASIDE ORD RAND MOTION TO QUASH
I
DE; C;NFERENCE TO_ 1 Si AMO ANS & COUNTERCLAIM
I· •
DEFT'S 1ST AMO ANS & CO NTERCLAIM
....
Reporters Certification for the deposition of Brigetta D'Olivio
...
FIRST AMENDED ANSWER
...
SANCTIONS AND CONTIN ANGE
...
TO MOTION TO COMPEL, ANCTIONS AND CONTINUANCE
...
...
"
CONTINUANCE t
ORDER ON MOTION TO C MPEL, SANCTIONS AND
htt"c,·//r,n11rt.:nnrtal.dallascountv.ora/DALLASPROD ome/WorkspaceMode?p=O
16/36
2/20/2019 Dsta!!s
•
RE: MOTION TO COMPEL, S NCTIONS AND CONTINUANCE
•
RE: DOCKET CALL
I
I •
•
....
2ND-1ST AMENDED COU TERCLAIM
....
PLAINTIFF'S RESPONSE :r MOTION TO COMPEL
PLAINTIFF'S OBJECTION T REQUEST FOR JURY TRIAL
....
...... ____ ,, __ , ... _.,,.. ...~, ~ .. 11 .. ., ... ,.., ,nh, nrn/nAI I A~PR()n/ nme/WorksoaceMode?o=O 17/36
Details
2/20/2019
SLAUGHTER, GENA
10:15 AM
RE-SET W/BRIGETTA D'OLIVIO (214-733-7204) 15MIN (FINAL
HEARING)
....
Plaintiffs' Witness List
....
Notice of Appearance
•
Defendant's Witness List
....
Defendant's First Amended itness List
•
DEFENDANT'S 2ND AMEN ED
....
Plaintiffs' Greg and Laura F x Motion to Strike Counterclaim
....
18/36
htt"o·//rnr ,rtc:nnrt<>I n<>ll<><:.r.n, intv nra/DALLASPROD ome/WorksoaceMode?p=O
Details
2/20/2019
(Plaintiffs Greg and Laura Fox) ' Answer to Counterclaim
..ii.
SLAUGHTER, GENA
9:30AM
BY COURT ADMINISTRATOR
Plaintiffs' Amended Answer to Counterclaim
Combined Motion to Strike P' Answer to CC & Strike MTS-D'Olivio
....
Motion to Compel Arbitration- 'Olivio-0006
....
Defendant's Amended Speci I Exceptions to Plaintiff's Amended
Petition
....
05-17-01119-CV
19/36
httt,.,· //r.n, ,rt.,nnrtal.dallascountv.ora/DALLASPROD/ ome/WorkspaceMode?p=O
Details
2/20/2019
...
PLAINTIFFS' POST TRIAL BR EF EMAILED JUDGE ON BREIF
...
D~FEND~N1'S POST TRl~L tRIEF EMAILED JUDGE ON BRIEF
COURTESY COPY REC'D - LAINTIFF'S POST TRIAL BRIEF -
PLACED IN ADMIN TRAY
...
Plaintiffs' letter to Court re Rel ase of Lien EMAIL JUDGE
COURTESY COPY REC'D 1 /4/17 CORRESPONDENCE LETTER
TO JUDGE SUBMITTED TO DMIN TRAY.
...
05-17-01119-CV SUBMIT ST COA W/CONFIRMATION #26599
...
05-17-01119-CV
Letter to Judge Slaughter WI H PROPOSED JUDGMENT
...
20/36
htti,c:·/lt.._n, ,rt,:mnrt::il d::illascountv.ora/DALLASPROD/ ome/WorkspaceMode?p=O
2/20/2019 Details
Order on Defendant's Special xceptions
FINAL JUDGMENT
:'\: ...
Proposed Order
...
FOR ENTRY OF - ***FINAL J DGMENT ATTACHED TO MOTION
AS AN EXHIBIT**
, ...
PER MS D'OLIVIO HER ADD ESS IS CORRECT
...
...
...
Notice of Hearing RE:Plainti s Greg and Laura Fox's Motion for
Judgment
...
Proposed Order on Motion t Withdrawal-D'Olivio
21/36
hth,c,·//"n,,rt,mnrt::il rl::illascountv.ora/DALLASPROD/ ome/WorkspaceMode?p=O
2/20/2019 Details
UNOPPOSED
RE: RIGHT TO ATTORNEY C IENT PRIVILEGE
SLAUGHTER, GENA
11:00 AM
m/enter jdgmt (david kleiman 2/9 9-7446)
...
...
...
REQUEST FOR FOF CNCL F LAW SUBMITTED TO ADMIN'S
QUEUE
...
ffc submitted to judge
htti,i,· //rr,11rt<>rinrt~I n::ill::iscouritv.·ora/DALLASPROD/ ome/WorkspaceMode?p=O
22/36
2/20/2019 Details
Letter to Court
...
Plaintiffs' Repsonse to Defend nt's Request for Findings of Fact and
• Conclusions of Law
' ...
Plaintiffs' Proposed Findings o Fact and Conclusions of Law
Findings of Fact and Conclusi ns of Law
Plaintiffs' Post Judgment Moti n to Compel
...
RE: MOTION TO COMPEL
...
Request
...
Notice of Appeal
...
23/36
htt11 .. · //r:n1 ,rt..nnrtal rlallascountv.ora/DALLASPROD/ ome/WorkspaceMode?p=O
2/20/2019 Details
Request
...
PREPARING CLERK RECOR
05-18-00868-CV
EMAILED ATIY $907.00
...
SLAUGHTER, GENA
02:30 PM
KIM OLTMAN 214-979-7443 - M TION COMPEL FILED 6/28/2018 - 30-
MINUTES
...
ORDER GRANTING PI_._.A INTFFS POST JUDGMENT MOTION
TO COMPEL. AN_D FOR S NCTIONS
...
Plaintiffs' Supplemental Req est for Clerk's Records
...
AND FOR CONTEMPT
111.1,.i,.,.;ii.,, " " " ' " ' ' ..... ~ V I l,Ul,"'U.IU~,11 ... ....,...,u, 11,y.v1 MJ '"""'-'-'""'-· I,....,...,, I IVI 110, 11' " " " ' ' ' ~ t ' U V O I V I V U Q ; t , ' - v
n.o.+~ilc-
?1?n1?n10
...
PREPARING SUPPLEMENT LERK RECORD 05-18-00868-CV
...
SUPPLEMENT CLERK RECO D
COA 05-18-00868-CV - POST CARD
05-18-00868-CV SUBMIT 5T COA W/CONFIRMATION #30613
...
05-18-00868-CV
...
SUPPLEMENTAL RECORD ENT TO THE 5TH COA WITH
CONFIRMATION # 30834
...
CLERKS RECORD SENT T THE 5TH COA WITH
CONFIRMATION #30831
...
05-18-00868-CV
i I
notaoilc.-
?t?n1?n1a
...
PLAINTIFF
'.,, .
...
, ...
ESERVE
OUT OF COUNTY
12/26/2018
ESERVE/CM (1) 222//399
...
PLAINTIFF AMENDED
...
Notice of Hearing RE:Plainti s Greg and Laura Fox's Amended
Application for Turnover Ord r
...
...
ESERVE
no.t~ilc
?t?nnn10
...
ESERVE
OUT OF COUNTY
01/24/2019
ESERVE/CM (2) 222/465
...
(1) EXECUTION - UNEXECU ED - BRIGETIA D'OLIVIO
...
SUPPLEMENTAL CLERK'S ECORD REQUEST
...
PREPARING SUPPLEMENT L RECORD 05-18-00868-CV
...
APPELLANT'S REQUEST F R SUPPLEMENTAL REPORTER'S
RECORD
...
...
BILL PRO-SE FOR THIS SU PLEMENT. VERIFIED ATIORNEY T.
HOOTMAN WITHDREW FR M APPEAL CASE. ORDER SIGNED
IN THE 5THCOA 1/15/19.
...
?/?n1?n10
First Amended Notice of Heari g
...
(2) WRIT OF EXECUTION N LLA BOLA - BRIGETTTA D'OLIVIO
SUPPLEMENTAL CLERK'S ECORD REQUEST
...
BRIGETTA D'OLIVIO
...
LETTER TO COURT OF AP EALS
...
Gary Patterson's Motion to thdraw as Counsel
...
ORQER GRANTING MOTIO FOR WITHDRAW OF COUNSEL
...
PREPARING SUPPLEMEN L CLERKS RECORD #2 05-18-00868-
CV
...
?t?n1?n10
'•
**CANCELLATION**
•
DEFENDANT'S RESPONSE O PLAINTIFFS' AMENDED
APPLICATION FOR TURNO ER ORDER
•
ORDER DENYING PLAINTIF S' AMENDED APPLICATION FOR
TURNOVER ORDER
•
SUPPLEMENTAL CLERK'S ECORD REQUEST
•
SLAUGHTER, GENA
02:00 PM
REQUESTED BY ATTORNEY/ RO SE
PUAMENDED APPLICATION OR TURNOVER ORDER FILED 12/03/18
30M KAREN 214-979-7410
n.o.toil~
?t?nt?n10
Financial
Total Financial Assessmen $908.00
Total Payments and Credi s $908.00
5/11/2016 Transaction $295.00
Assessment
5/11/2016 CREDIT FOX, GREG ($295.00)
CARD -
TEXFILE
(DC) CLK
8/27/2018 Transaction $75.00
Assessment
8/27/2018 CREDIT FOX, GREG ($75.00)
CARD -
TEXFILE
(DC) CLK
9/6/2018 Transaction $507.00
Assessment
9/20/2018 PAYMENT VINCENT ($507.00)
(CASE SERAFINO
FEES) GEARY
CLK WADDELL
JENEVEIN PC
11/28/2018 Transaction· $15.00
Assessment
11/28/2018 CREDIT eceipt # FOX, GREG ($15.00)
CARD - 8072-
TEXFILE 018-
(DC) CLK
11/29/2018 Transaction $8.00
Assessment
11/29/2018 CREDIT Receipt# FOX, GREG ($8.00)
CARD - 78275-
TEXFILE 2018-
(DC) DCLK
12/18/2018 Transaction $8.00
Assessment
12/18/2018 CREDIT Receipt# FOX, GREG ($8.00)
CARD - 82319-
TEXFILE 2018-
(DC) DCLK
Total Financial Assessm nt $2,543.00
Total Payments and Cre its $1,123.00
noh~ile!-
?/?0/?010
8/17/2017 Transaction $8.00
Assessment
8/17/2017 PAYMENT R ceipt # D'OLIVIO, ($8.00)
(CASE 5 651- BRIGETTA
FEES) 2 17-DCLK
8/18/2017 Transaction $8.00
Assessment
8/18/2017 PAYMENT D'OLIVIO, ($8.00)
(CASE BRIGETTA
FEES)
8/21/2017 Transaction $16.00
Assessment
8/21/2017 PAYMENT D'OLIVIO, ($16.00)
(CASE BRIGETTA
FEES)
8/22/20'17 Transaction $16.00
Assessment
8/22/2017 PAYMENT D'OLIVIO, ($16.00)
(CASE BRIGETTA
FEES)
8/28/2017 Transaction $16.00
Assessment
8/28/2017 PAYMENT D'OLIVIO, ($16.00)
(CASE BRIGETTA
FEES)
10/5/2017 Transaction $402.00
Assessment
10/23/2017 Transaction $80.00
Assessment
10/23/2017 PAYMENT eceipt # D'OLIVIO, ($80.00)
(CASE 9600- BRIGETTA
FEES) 017-DCLK
11/13/2017 Transaction $40.00
Assessment
11/13/2017 PAYMENT eceipt # D'OLIVIO, ($40.00)
(CASE 4033- BRIGETTA
FEES) 017-DCLK
8/8/2018 Transaction $907.00
Assessment
9/20/2018 PAYMENT eceipt # HOOTMAN ($907.00)
{CASE 2851- &
FEES) 018-DCLK COMPANY
1/17/2019 Transaction $1,018.00
Assessment
?/?n1?n1a
2/18/2019 Transaction $32.00
Assessment
2/19/2019 PAYMENT R ceipt # D'OLIVIO, ($32.00)
(CASE 1 247- BRIGETTA
FEES) 2 19-DCLK
Documents
not'.!llil~
?/?nnn1a
?/?n1?n1a notailc.-
?l?n1?n10 not-:ailc.-
?/?n1?n10
I I
EXHIBIT 8
44
L/28/2019 Details
Case Information
DC-16-05606 j GREG FOXet al vs. BRIGETTA D'OLIVIO
Case Number Court Judicial Officer
DC-16-05606 191st istrict Court SLAUGHTER, GENA
File Date Case ype Case Status
05/10/2016 OTHE CONTRACT CLOSED
Party
PLAINTIFF Inactive Attorneys•
FOX, GREG Lead Attorney
KLEIMAN, DAVID
MASON
Retained
Work Phone
214-979-7400
Fax Pl1one
214-979-7402
PLAINTIFF Inactive Attorneys•
FOX, LAURA
Lead Attorney
KLEIMAN, DAVID
MASON
Retained
Work Phone
214-979-7400
Fax Phone
214-979-7402
hff.-.r-•//,..,.,., ........................ 1 ........................ , ... /\Afnrkconl>r,<>Mnrl<>?n:0
2/28/2019 Details
MOTION - QUASH
09/07/2017 CERTIFICATE OF ERVICE ..,.
CERTIFICATE OF SERVICE
09/07/2017 CERTIFICATE OF ONFERENCE..,.
NOTICE OF HEARING
Comment
DIM/QUASH
09/07/2017 NOhl-SIG"JED PR POSED ORDER/JUDGMENT ..,.
ORDER QUASH
Comment
ORDER ON MOTION QUIIA H
0:J107/2017 CERTIF!CATE OF 0!,:1:ERH 1CE ..,.
CERTIFICATE OF CONFERENCE QUASH
Comment
M/QUASH
09/14/2017 RETURN OF SER ICE..,.
SUBPOENA JP MORGAN CH SE BANK NA
Commc11t
SUBPOENA: JP MORGAN HASE BANK NA
09/1 D'2017 MOTION - SANCTI NS ..,.
Motion for S:s11ctions.pdf
09/20/2017 RESPONSE ..,.
Pis' Re:cponse to i\i,Jtion to Qua h
Comment
PLAINTIFF'S RESPONSE T MOTION TO QUASH
(JJ/22/2017 iviouon - Quash ..,.
Jw :iciai Officer
SLAUGHTER, GENA
Hearing Time
03:45 PM
2/28/2019 Details
Comment
BRIGETTA D'OLIVIO 214 733- 204 15 MIN M/QUASH
09/22/2017 ORDER - DENY •
ORDER - DENY
Comment
0/DENYING (OF) M/QUAS
09/25/2017 MISCELLANOUS
MISCELLANOUS EVENT
Comment
LETTER TO COURT REPO TER REQUESTING TRANSCRIPT -
COPY GIVEN TO MELBA RIGHT
09/25/2017 NOTICE OF /\PPE L - CT. OF APPEALS •
NOTICE OF APPEAL - CT OF PPEALS
Comment
DESIGNATION REQUESTE AT TIME OF ACCEPTANCE W/IN 3
DAYS
09/26/2017 CORRESP0!1DEN E - LETTER TO FILE •
CORRESPONDENCE - LETTER TO FILE
Comment
LETTER TO JUDGE SLAU HTER
09/26/2017 COA - POST CAR •
COA - POST CARD
Comment
05-17-01119-CV
09/29/2017 f.l ,lion - s,.nctions
Judicial Officer
SLAUGHTER, GENA
Hc,aring Time
10:00 AM
Cancel Reason
REQUESTED BY ATTORNEY/ RO SE
Comment
15 MINS - SET BY KIM - 214-9 9-7443 - CC REQ
09/29/2017 REQUEST CLERK REPARE RECORD •
2/28/2019 Details
REQUEST CLERK PREPARE ECORD
Comment
clerk's record request
09/29/2017 RESPONSE ....
RESPONSE
Comment
TO MOTION FOR SANCTI
10/04/2017 CORRESPONDEN E - LETTER TO FILE •
CORRESPONDENCE-LETT
Comment
RE: INVOICE #171004-1
10/04/2017 VACATION LETTE
10/0,'./2017 CORF:ESPONDEt~ ..,E - LETTER TO FILE•
CORRESPONDENCE-LETT
Comment
RE: REQUEST TO RE-SCH DULE DEFENDANT'S SCHEDULED
HEARING DATE OF OCTO ER 4TH, 2017 -AMENDED MOTION
TO SET ASIDE ORDER
10/04/2017 RESPONSE •
RESPONSE
Comment
AMENDED - MOTION FOR ANCTIONS
10/05/2017 NOTE - CLERl'.S
Comment
PREPARING CLERKS REC RD
10/05/2017 CLERK'S RECOR PAYMENT INVOICE •
CLERK'S RECORD PAYMENT INVOICE
Comment
10/12/2017 MOTION HEARIN •
CERTIFICATE OF SERVICE
NOTICE OF HEARING
,ar:/'lO
2/28/2019 Details
ORDER QUASH
Judicial Officer
SLAUGHTER.GENA
Hearing Time
10:00 AM
Cancei R(:,c1son
HEARING RESCHEDULED
Commfi11t
0/M/SET ASIDE - BRIGETTA 'OLIVIO 214 733-7204 15 MINS
'10/23/2017 COUi\iTER CLi,IM •
COUNTER CLAIM
10/23/2017 RESPONSE •
RESPONSE dc1605606 Fox.p f
Comment
ROBERT M. CLARK'S RES ONSE TO BRIGETIA D'OLIVIO'S
MOTION TO SET ASIDE O DER AND MOTION TO QUASH
10/23/2017 CERTIFICATE OF ONFERENCE •
CERTIFICATE
Comment
DEFT CONFERENCE TO 1 T AMO ANS & COUNTERCLAIM
10/23/2017 CERTIFICATE OF ERVICE •
CERTIFICATE OF SERVICE
Comment
DEFT'S 1ST AMO ANS & C UNTERCLAIM
10/24/2017 CERTIFICATE OF EPOSITION •
333064EF.pdf
Comment
Reporters Certification for th deposition of Brigetta D'Olivio
10/24/2017 ORIGINAL ANSW R ·· GENERJI..L DEhllAL •
Comment
FIRST AMENDED ANSWE
ii/09/20i7 MOTION - COMPE •
t,lOTION - COMPEL
httn.:·//r,n11rh::nnrl<>I rl:>11:>c:.r,n, ,nh, nrnlnAI I A~i:>Rnn/1-1 mo/11\/nrvc:n,:i,..oUnrlo?n:/1
2/28/2019 Details
Comment
SANCTIONS AND CONTIN ANCE
1110" 12017 CERTIFICATE CF Ot\lFERENCE •
CERTIFICATE OF CONFERE
Comment
TO MOTION TO COMPEL, ANCTIONS AND CONTINUANCE
11/09/2017 CERTIFICATE OF ERVICE •
CERTIFICATE OF 0ERViCE
11/09/2017 NON-SIGNED PR POSED ORDER/JUDGf·.11::NT •
NON-SIGNED PROPOSED O DER/JUDGMENT
Comment
ORDER ON MOTION TO C MPEL, SANCTIONS AND
CONTINUANCE
11/09/2017 NOTICE OF HEARlf~G I Fl!\T •
NOTICE OF HEARING I FIAT
Comment
RE: MOTION TO COMPEL, ANCTIONS AND CONTINUANCE
JURY DEfJAND
11/13/2017 CORRESPONDEN ,E - LETTER TO FILE•
CORRESPONDENCE - LETTE TO FILE
Comment
RE: DOCKET CALL
1111 ~:.'2017 CERTIF!SI\TE OF E:RVICE •
CERTIFICATE OF SERVICE
1i 113/2017 AFFIDAVIT •
AFFIDAVIT
11/13/2017 A!VilND:::.O A!\JSVVl::i< -AIV,d\JOED G!:..NER.AL DENIAL•
AMENDED ANSWER - AHENDED GENERAL DENIAL
Comment
2ND-1ST AMENDED COU TERCLAIM
2/28/2019 Details
11/14/2017 RESPONSE •
Plaintiffs Response to Motion t Compel.pdf
Comment
PLAINTIFF'S RESPONSE T MOTION TO COMPEL
11/14/2017 OBJECTiG:~ •
Plaintiffs Objections to Request for Jury Trial.pdf
Comment
PLAINTIFF'S OBJECTION T REQUEST FOR JURY TRIAL
11/16/2017 MOTION HEARING•
Af'v1D fv1 SET 1\SIDE
CERT OF CONF SET ASIDE
MOTICJr\J - QUASH
ORDER QUASH
RESPONSE dc1605606 Fox.p f
Judicial Officer
SLAUGHTER, GENA
Hearing Time
10:15AM
Comment
RE-SET W/BRIGETIA D'OLIVI (214-733-7204) 15MIN (FINAL
HEARING)
11/17/20'17 W!Tt-,JESS LIST•
Witne:.s Lisl.pdf
Comment
Plaintiffs' Witness List
11/17/2017 NOTICE OF APPE RANCE •
rJotice of Ari), .;,,;1ce.pdf
Comment
Notice of Appearance
i:/17i2017 WITNESS UST •
defendants witness list.pdf
Comment
Defendant's Witness List
1 Q/'lQ
2/28/2019 Details
11/17/2017 WITNESS LIST•
defendants first amended witne s !ist.pdf
Comment
Defendant's First Amended itness List
11/17/2017 WITNESS UST•
defendants second amended w tness list.pdf
Comment
DEFENDANT'S 2ND AMEN ED
11/17/2017 MOTION - STRIKE •
Molion to Strike.pdf
Comment
Plaintiffs' Greg and Laura Fo Motion to Strike Counterclaim
11/17/2017 ORIGINAL ANSWE TO CROSS CLAIM - COUNTER
PETITION•
Answer to Counterclaim.pdf
Comment
(Plaintiffs Greg and Laura F x) ' Answer to Counterclaim
11/20/2017 Non Jury Trial•
Generic Reset Non Jury Trial N tice
Generic Reset Non Jury Trial N tice
Judicial Officer
SLAUGHTER, GENA
t 1,c:2mng Tin H
9:30AM
Cancel Rea;,,)n
BY COURT ADMINISTRATOR
11/20/2017 /,:v1Ei~DED A1~'3V: R-/-11,,Et'.DED GEt,ER/'.L DEf,,!A.L •
Amended Answer to Countercl im.pdf
Comment
Plaintiffs' Amended Answer t Counterclaim
1"1/20/2017 MOTION - STRIKE •
Combined Motion to Strike
httos://courtsoortal.dallascountv.ora/DALLASPROD/H me/WorksoaceMode?o=O 19/38
2/28/2019 Details
Comment
Combined Motion to Strike 's Answer to CC & Strike MTS-D'Olivio
ii/2112017 f\/lOTION - CUJ1PE ""
motion to compel arbitration-0' livio
Comment
Motion to Compel Arbitratio D'Olivio-0006
11/21/2017 SPECIAL EXCEPT ONS •
Defendant's Amended Special xceptions
Comment
Defendant's Amended Speci I Exceptions to Plaintiff's Amended
Petition
11/21/2017 ll~ACTIVATE CA:. - (OCA)
11/27/2017 COA- POST CAR •
COA - POST CARO
Comment
05-17-01119-CV
11/29/2017 BRIEF FILED •
Fox V. 0·01;. .;,) -Pc, t T,;c;I r, i,"f.; ·df
Comment
PLAINTIFFS' POST TRIAL RIEF EMAILED JUDGE ON BREIF
11/29/2017 BRIEF FILED •
D'Olivio Post Trial Brief
Comment
DEFENDANT'S POST TRIA BRIEF EMAILED JUDGE ON BRIEF
11/30/2017 NOTE - CLEFi.?n=O
2/28/2019 Details
Comment
(1) EXECUTION - UNEXE UTED - BRIGETIA D'OLIVIO
'12/31/2018 SUPPLEMEr,lTA CLERK'S RECORD REQUEST •
SUPPLEMENTAL CLERK'S ECORD REQUEST
Comment
#2 SUPPLEMENTAL CLE K'S RECORD REQUEST
01/04/2019 NOTE - CLERKS •
Commeni
PREPARING SUPPLEME TAL RECORD 05-18-00868-CV
01/16/2019 REQUEST REP RTER RECORD •
REQUEST REPORTER REC RD
Comment
APPELLANT'S REQUEST OR SUPPLEMENTAL REPORTER'S
RECORD
01/16/2019 Sl'PPLEf'i1i::':f'JTAL CLEPK'S RECOPD REQUE:ST •
SUPPLH1ENTAL CLERK'S RECORD REQUEST
Comment
#3 SUPPLEMENTAL CLE K'S RECORD REQUEST
01/16/2019 NOTE - CLERKS
Comment
BILL PRO-SE FOR THIS S PPLEMENT. VERIFIED ATIORNEY T.
HOOTMAN WITHDREW F OM APPEAL CASE. ORDER SIGNED
IN THE 5THCOA 1/15/19.
01/17/2019 CLERK'S RECOR PAYl11El·~T INVOICE •
Comment
#2 SUPPLEMENTAL CLER 'S RECORD
01/22/2019 NOTICE OF HEARING! FIAT•
2019-01-22 - 1st Amended
NOH_on_Amended_Applicatio _for_ Turnover_ Order.pdf
Comment
First Amended Notice of He ring
01/25/2019 RETURf~ OF SER !CE •
(2) WRIT OF EXECUTION- BR GETTTA D'OLIVIO
https://courtsportal.dallascounty.org/DALLASPROD/H me/WorksoaceMode?o=O '}0/~0
2/28/2019 Details
Comment
(2) WRIT OF EXECUTION NULLA BOLA - BRIGETITA D'OLIVIO
02/12/2019 SUPPLEf 1ENTA. CLERK'S R.ECORD RE(i:JEST •
SUPPLEMENTA.L CLERK'S ECORD REQUEST
Comment
#4 SUPPLEMENTAL CLE K'S RECORD REQUEST
02/13/2019 CORRESPONDE CE - LETTER TO FILE •
CORRESPONOENCE-LET
Comment
BRIGETIA D'OLIVIO
02/14/2019 CORRESPONDE CE - LETTER TO FILE•
CORRESPONDENCE - LETT R TO FILE
Corr,rnE::nt
LETIER TO COURT OF A PEALS
02/15/2019 MOTION - WITHDF~AW ATTORNEY•
Gar; Pa!l<,r:on's f,fotion to Wi hdra:: a Coun,,r::I for DC-16-05606.pdf
Comment
Gary Patterson's Motion to ithdraw as Counsel
02/15/2019 NOi',l-SIGNED PR POSED ORDER/JUDGMENT•
Order Granting fviotion for Wit draw of Counsel for DC-16-05(i06.pdf
Comment
ORQER GRANTING MOTi N FOR WITHDRAW OF COUNSEL
02/18!2019 t'1DTE - CLEF:,:S
Comment
PREPARING SUPPLEMEN AL CLERKS RECORD #2 05-18-
00868-CV
02J-i8/2019 CLERK'S RECOR PAYMEf.;T INVOICE•
CLERK'S RECORD PAYMENT nNOICE
Comment
#3 SUPPLEMENTAL CLER 'S RECORD
02/18/2019 NOTICE OF HEAR NG/ FIAT •
2019-02-18 - Notice_of_Cancel ation_of_hearing.pdf
httos:1/courtsoortal.dallascountv nrn/nAI I A~PRnn/1-l m<>/\ll/..,r1,~ .... ~ ....au ....,.~.,~-n
2/28/2019 Details
Comment
**CANCELLATION**
02/19/2019 RESPONSE.,.
RESPONSE
Comment
DEFENDANTS RESPON E TO PLAINTIFFS' AMENDED
APPLICATION FOR TURN VER ORDER
02/19/2019 NON-SIGNED P OPOSED ORDER/JUDGMENT•
NON-SIGNED PROPOSED RDER/JUDGMENT
Comment
ORDER DENYING PLAIN IFFS' AMENDED APPLICATION FOR
TURNOVER ORDER
02/20/2019 f,1,'.ition - Turnover .,.
Ami•nded Application for Turn ver.pdf
SLAUGHTER, GENA
Hearing Time
02:00 PM
Cancel Reason
REQUESTED BY ATTORNEY PRO SE
Comment
PUAMENDED APPLICATION OR TURNOVER ORDER FILED
12/03/18 30M KAREN 214-97 -7410
02i2Eii20i 9 CLE1~:.1('S riWnrl<l"-<>Mnrlc?n:11
3/1/2019 Details
Anticipated l\',8thod
08i28/20'17 CITATION•
Anticipated Server
ATTORNEY
Anticipated Method
Comment
N/C
08/28/2017 CITATION•
Anticipated Server
ATTORNEY
Anticipated Method
Actu:11 Server
PRIVATE PROCESS SERVE
t
Returned
08/30/2017
Comment
N/C
08/28/2017 CITATION•
Ariti'.-ipated S ,:·ver
ATTORNEY
Anticip2:tud l\ lrithod
Comment
N/C
08/30/20"17 RETURr~ OF SER /ICE •
DA\11D - CiT
Comment
CIT EXEC 8/29/17 TO DAV D KLEIMAN MASON PPS
08/30/2017 RETURN OF SER ICE •
Ql\VID M4SON KLEIMAN - Cl
Con rnent
CIT EXEC 8/29/17 TO DAVID MASON KLEIMAN PPS
09/01/2017 MOTION - SUBST TUTE SERVICE •
HJTIGi~ - SUBSTITUTE SER'/ICE
09/07/2017 NOTE·· ADi,1!N1ST ATOR •
Comment
LETTER TO JUDGE
https://courtsportal.dallascounty.org/DALLASPROD/ ome/WorksoaceMode?o=O
3/1/2019 Details
09/07/2017 MOTION - SET
AMENDED M/SET ASIDE RDER
09/07/2017 CERTIFICATE O SERVICE"'
CERTIFICATE OF SERVICE
Comment
DEFENDANT
09/07/2017 CERTIFICATE O CONFERENCE "'
CERT OF CONF SET ASIDE
Comment
DEFENDANT - TO M/SET SIDE ORDER
()9/07/2017 CERTIFICATE O co ,1FERENCE
1 "'
CERT OF CONF SET ASIDE
Comment
DEFENDANT - AMO M/SE ASDIE ORDER
09/07/2017 NOTiCE OF HEA ING/ FIAT "'
NOTICE OF HEARING/ I IAT
Comment
AMO M/ SET ASIDE ORD R - DEFENDANT
09/07/2017 NON-SIGNED PR POSED ORDER/JUDGMENT"'
AMO M SET ASIDE
Comment
ORDER ON AMO M/SET A IDE ORDER
09/07/2017 MOTION - OUAS "'
fP)T!C,t,J - QUASH
09/07/2017 CERTIFICATE OF SERVICE"'
CERTIFICATE OF SERVICE
09/07/2017 CERTIFICATE OF ,ONFERENCE"'
!JOT!CE OF HE".=/Wnrlc,o.n"'r-"Mntio?n=fl
3/1/2019 Details
Comment
DIM/QUASH
09/07/2017 NON-SIGNED P OPOSED ORDER/_ 11 JDGr ti ENT •
ORDER QUASH
Comment
ORDER ON MOTION QUII SH
09/07/2017 CERTIFICATE OF CONFERD...JCE •
CEHTWICATE OF COI\JFEfroMnrlo?n~n
3/1/2019 Details
Comment
DEFENDANTS 2ND AME OED
11/17/2017 f•10TION - STRP( •
Motion to Strike.pdf
Comment
Plaintiffs' Greg and Laura ox Motion to Strike Counterclaim
11/17/2017 ORIG!r~AL ANSW R TO CROSS CLAH11- COUNTER
PETITION•
Answer to Counterclaim.pdf
J
I
Comment
(Plaintiffs Greg and Laura j°x) ' Answer to Counterclaim
11/20/2017 Non Jury Trial•
GenHic Reset Non Jury Trial otice
Generic Reset Non Jury Trial otice
Judicial Officer
SLAUGHTER, GENA
Hearing Time
9:30AM
Cancel Reason
BY COURT ADMINISTRATO
11/20/2017 AMENDED Af\JSW R-AIVIL::NDED GENt::RAL D!::NIAL •
Amended Answer to Countercl im.pdf
Comment
Plaintiffs' Amended Answer o Counterclaim
11/20/2017 MOTION - STRIKE •
Combined Motion to Strike
Comment
Combined Motion to Strike 's Answer to CC & Strike MTS-D'Olivio
11/21/2017 f.10TIQi,; - COUPE •
motion to compel arbitration-0' if:vio
Comment
Motion to Compel Arbitration D'Olivio-0006
11/21/2017 SPECIAL EXCEPT! NS•
https://courtsportal.dallascounty.org/DALLASPROD/H me/WorkspaceMode?p=O 19/38
3/1/2019 Details
D, fendant's Amended Specia Exceptions
Comment
Defendant's Amended Spe ial Exceptions to Plaintiff's Amended
Petition
i1/2ii2017 INACTIVATE CAS (OCA)
11127120'17 COP, - POST CA
COA - POST CARD
Comment
05-17-01119-CV
11129/2017 8R!EF F!LED •
Fox v. D'Olivio -Po,;; Triai Bne .pdf
Comment
PLAINTIFFS' POST TRIAL BRIEF EMAILED JUDGE ON BREIF
11/29/2017 BRIEF FILED ...
D'O!;vio f'ost Tria! i.A1ef
Comment
DEFENDANT'S POST TRI L BRIEF EMAILED JUDGE ON BRIEF
11/30/2017 NOTE - CLERf.W ATTCR 'EY
05/02/2018 REACTIVATE CAS (OCA)
05/02/2018 COLLECTIONS - INANCIALS
05/17/2013 f',1'JTlSE OF APPE R/iJ~<:E •
Notice of Appearance. D'Olivio. df
https://courtsportal.dallascounty.org/DALLASPROD/H me/WorkspaceMode?p=O 22/38
3/1/2019 Details
05/17/2018 REQUL:ST F(:;1 :rJD::~s c·:-: FACTiCC::1·:.:Lu~::JNS OF
LAW•
Request for Findings of Fact 'Olivio.pdf
05/17/2018 i\JOTE · CLEF 1 S
Comment
REQUEST FOR FOF CNC OF LAW SUBMITTED TO ADMIN'S
QUEUE
05/18/2018 NOTE - ADMINIS RATOR •
Comment
ffc submitted to judge
05/25/2u18 CGh'.RESPCi ,DE1 CE - LETTER TO Fi LE •
Ur to Court.pdf
Comment
Letter to Court
05/25/2018 RESPONSE •
P's Resp to D's Req FFCL.pdf
Comment
Plaintiffs' Repsonse to Defe dant's Request for Findings of Fact
and Conclusions of Law
05/25/2018 FINDINGS OF FA T/CONCLUSIONS OF LAW •
P's Propc, .ed FFCL.odf
Comment
Plaintiffs' Proposed Finding of Fact and Conclusions of Law
05/25/2018 NON-SIGNED PR POSED ORDER/JUDGMENT •
FFCL.pdf
Findings of Fact and Conclu ions of Law
Fox_Post Judgment r 1TC.pdf
Comment
Plaintiffs' Post Judgment M ion to Compel
07/03/2018 NOTICE OF HEAR NG I FIAT•
https://courtsportal.dallascountv.orq/DALLASPROD/ me/WorkscaceMode?c=O
3/1/2019 Details
NOH_on_Ps_PJ_Mtn_to_C
Comment
RE: MOTION TO COMPE
07/30/2018 REQUEST REPO TER RECORD•
Request for RR.pdf
Comment
Request
07/30/2018 NOTICE OF APP AL - CT OF APPEALS •
Notice of appeal.pdf
Comment
Notice of Appeal
07/30/2018 REQUEST CLER PREPARE RECORD•
Comment
Request
08/01/2018 NOTE - CLERKS
Comment
PREPARING CLERK REC
08/08/2018 COA - POST Cl1R •
COA - POST CARD
Comment
05-18-00868-CV
O?'nf,/2018 CLER!('S RECOR PAY:'::::}:T !f !VO!CE •
CLERK'S RECORD PAYMEN INVOICE
Comment
EMAILED ATIY $907.00
08/17/20'18 Motion - Compel •
Judicial Officer
SLAUGHTER, GENA
Hearing Time
02:30 PM
httos://courtsoortal.dallascountv.ora/DALLASPROD/ me/Worksn::ir.P.MorlP.?n=n ')A/~D
3/1/2019 Details
Comment
KIM OLTMAN 214-979-7443 MOTION COMPEL FILED 6/28/2018 - 30-
MINUTES
08/17/20'!8 ORDER - COMP L •
ORLER - COMPEL
Comment
ORDER GRANTING Pl_._. _INTFFS POST JUDGMENT MOTION
TO COMPEL. AN_D FOR ANCTIONS
02,/24/2018 SUPPLEk1EtHAL CLEF!l('S RECOFm FE:CUTiC:<•
Anticipil;ed Server
ESERVE
Anticipated f.:lr;tilod
Act•.1al Serv,"
OUT OF COUNTY
Returned
01/24/2019
Comment
ESERVE/CM (2) 222/465
12/26/2018 RETURI ~ OF SER ICE .,.
RETURN OF SERVICE
Comment
(1) EXECUTION - UNEXEC TED - BRIGETTA D'OLIVIO
SUPPLEr' 1Ef\lTAL CLERK'S R CORD REQUEST
Comment
#2 SUPPLEMENTAL CLER 'S RECORD REQUEST
https://courtsportal.dallascounty.org/DALLASPROD/H me/WorksoaceMode?o=O
3/1/2019 Details
01/04/2019 NOTE - CLERKS
Comment
PREPARING SUPPLEME TAL RECORD 05-18-00868-CV
01/1 .12019 REOUl::ST REPC ,TER F:c:CORD ....
REQUEST REPORTER REC RD
Comment
APPELLANT'S REQUEST OR SUPPLEMENTAL REPORTER'S
RECORD
01/16/2019 SUPPLEMENTAL LERK'S RECORD REQUEST .,..
SUPPLEMENTAL CLERK'S R CORD REQUEST
Corrnn~:nt
#3 SUPPLEMENTAL CLER 'S RECORD REQUEST
01/16/2019 NOTE - CLERKS
Comment
BILL PRO-SE FOR THIS S PPLEMENT. VERIFIED ATIORNEY T.
HOOTMAN WITHDREW F OM APPEAL CASE. ORDER SIGNED
IN THE 5THCOA 1/15/19.
01/17/2019 CLERl<'S [";ECOR PAYMENT INVOICE •
Comment
#2 SUPPLEMENTAL CLER 'S RECORD
01/22/2019 NOTICE OF HEA ING / FIAT ....
I
2019-01-22 - 1st Amended
NOH_on_Amended_Applicatio 1_tor__Turnover_Order.pdf
Comment
First Amended Notice of He ring
01/25/2019 RETURN OF SER ICE •
(2) V,.FiT OF EXECUTIG:~- BF GETTT.4 D'OU\ ,0
Comment
(2) WRIT OF EXECUTION ULLA BOLA - BRIGETTIA D'OLIVIO
02/12/2019 SUPPLEMENTAL LEF'.i('S RECORD REQUEST .,..
SUPPLEMENTAL CLERK'S R CORD REQUEST
co, ,ment
#4 SUPPLEMENTAL CLER 'S RECORD REQUEST
https://courtsportal.dallascounty.org/DALLASPROD/H me/WorkspaceMode?p=O ?Rf'.'IR
3/1/2019 Details
02/'13/2019 CORRESPONDE CE - LETTER TO FILE.,..
CORRESPONDEr; :::E - LETl ER TO FILE
Comment
BRIGETTA D'OLIVIO
02/i4/2019 CORRESPONDE CE - LETTER TO FILE .,..
CORRESPONDENCE - LETT R TO FILE
Comment
LETTER TO COURT OF A PEALS
02/15/2019 MOTION - WITH RAW ATTORNEY.,..
Gary Patierson's Motion to Wi hdraw as Counsel for DC-i 6-05606.pdf
Comment
Gary Patterson's Motion to ithdraw as Counsel
02/i5/20'19 NON-SIGNED PR POSED ORDER/JUDGMENT.,..
Comment t
ORQER GRANTING MOTi N FOR WITHDRAW OF COUNSEL
02/18/2019 NOTE - CLER!TE OF SEF-, /ICE
NOTICE OF HEARING
ORDER QU,-\fH
CERTIFICATE OF CONFEREl'JCE QU.1\SH
SUF:.POENA: JP f· iORC3AN C ASE F'.Af!f, t<-'.\
Motion for Sanctions.pdf
Pis' Response to Motion to O ash
Generic Reset Non Jury Trial otice
Generic Re,et Non .Jury Trial Jotice
ORDER- DENY
MISCELLANOUS EVENT I
CORRESPONDENCE - LETiER TO FILE
iJOTICE OF APPEAL - CT Cl APPEALS
COA - POST CARD i
REQUEST CLERK PREPARr RECORD
RESPONSE I
C~:RREE~:~N.~~t~'.~~ - L:l~r~RR :Oc·· :'.~EE
Cv1, 1
_ ..:.:,1 V \i!JC 1,j•_..c - LC t: 1 i!L j
RESPONSE
I
D )C' ET
CLERK'S RECORD PAYME, 1T INVOICE
RESPU :SE c'c16056<1·'"l Fox pdf
333064EF.pdf
COUNTER CUdH
CERTIFICATE
CERTIFIC.1\TE OF SERVICE
NON-SIGNED PROPOSED RDER/JUDGMENT
NOTICE OF HEARING / FiA
CERTIFICATE OF CONFER f'JCE
CERTIFICJffE OF SERVIC
MOTION - COMPEL
JURY DEf'.AND
COR1,ES1 '.)NO ENCE - LE I TEt·, TO FILE
P,FFIDAVIT
35/38
h<+n~-11~n, ,rtc,nnrt<>l rfall<>cu•n11ntv nrn/nAI I AS PRO /Home/WorksoaceMode?p=Q
Details
3/1/2019
CERTIFICATE OF SERVICE
AMENDED ANSWER - AMEN ED GENERAL DENIAL
Plaintiffs Response to Motion t Compel.pdf
Plaintiffs Objections to Reque t for Jury Trial.pdf
Witness List.pdf
Notice of Appearance.pdf
defendants witness list.pdf
defendanis first amended wim~ss iist.pdf
defendants second amended t,itness list.pdf
Motion to Strike.pdf
Answer to Counterclaim.pdf
Amended Answer to Counter laim.pdf
Combined Motion to Strike
motion to compel arbitration- 'Olivio
Defendant's fa.mended Specia Exceptions
Fox v. D'Olivio -Post Trial Brie .pdf
D'Olivio Post Trial Brief
Kleiman letter to Court - Fox\ D'Olivio.pdf
GOA - POST CARD
COA - CORRESPONDENCE LETTER
2017-12-18 - ltr to Judge slau hter re JUdgment.pdf
2017-12-18 - Proposed Judg ent.pdf
Proposed Order on Amended Special Exceptions
Proposed Order COMPEL A BITRATION
MANDATE DISMISS
COA - CORRESPONDENC LETTER
Fox_NOH_on_P _s_Mtn_for_ udgrnentpdf
Order on Motion to Withdraw as Counsel-FINAL DRAFT-D'Olivio .pdf
Motion to Withdraw as Coun el-Brigetta D'Oiivio.pdf
CORRESPONDENCE - LET ER TO FILE
ORDER - WITHDRAW ATT RNEY
JUDGMENT NON-JURY
Notice of Appearance, D'Oli\ io.pdf
Request for Findings of Fact D'Olivio.pdf
Ur to Couri.pdf
P's Resp to D's Req FFCL,p 'f
P's Proposed FFCL.pdf
FFCL.pdf
Fox_Post Judgment tvlTC.pc f
NOH_on_Ps_PJ_Mtn_to_ ompe!pdf
36/38
httn,::· //rn11rt<:nnrtal.dallascountv.ora/DALLASPRO /Home/WorkspaceMode?p=O
3/1/2019 Details
Request for RR.pdf
Notice of appeal.pdf
Request for CR.pdf
COA - POST CARD
COVER
CAPTION
DOCKET SHEET
COST 51l_L
CLERK CERTIFICP>TE
CLER!".'S RECORD P:\YiJEN 1r;·.;o:cE
ORDER - COMPEL
Pl,-;_Supp_R.:.,ri11r-1:c.t_for_CIPr _s_ Records pdf
Post Judgment Motion For Sa ctions.pdf
COVER
COA 05-18-00868-CV - POS CARD
CLERK'S RECORD P/\Yf·.'1EN INVOICE
COA - NO PAYMENT LETTE
COA-CORRESPONDENCELETTER
APPELLATE RECORD
APPELLATE RECORD
COA - POST CARD
COA - POST CARD
2018-i 1-28 - Application fort rnover.pdf
REQUEST
ISSUE v"JRIT
Amended Application for Tur over.pdf
REQUEST FOR SERVICE
ISSUE WRIT
RETURN OF SERVICE
SUPPLEMENTAL CLERK'S ECORD REQUEST
REQUEST REPORTER RECORD
SUPPLEMENTAL CLERl<'S ECORD REQUEST
2019-01-22 -1st Amended
NOH_on_i\mended_Applicat on _for_Turnover_ Order.pdf
(2) '.\T'(IT CS EXECUTlm~- :z:GETTTA D'OUVl0
SUPPLEMENTAL CLERK'S ECORD REQUEST
COF.i=<.ESPCl,DEk'::E - LET ER TO FILE
CORRESPONDENCE - LET ER TO FILE
SUPPLEMENTAL COVER
CLERK'S RECORD PAYME T INVOICE
Gary Patter,.on's r._,1otion to :thdr;·;\\ ,,s Counsel for DC-16-05606.pdf
37/38
https://courtsportal.dallascounty.org/DALLASPRO /Home/WorkspaceMode?p=O
3/1/2019 Details
Order Granting Motion for Wit draw of Counsel for DC-16-05606.pdf
2019-02-18 - Notice_of_Canc llation_of_hearing.pdf
RESPONSE
NON-SIGNED PROPOSED O DER/JUDGMENT
CLERK'S RECORD P.tWMEN INVOiCE
CORRESPONDENCE-LETT
CERTIFICATE OF SEFZ JICE
E.;JPPLEi\JiEiHAL CLEF:1< S RE Cu Fm REQUEST
#5 SUPPLEMENT.AL CLERK'. · RECORD REQUEST
38/38
htlps11oo,rtsoortal.dallasoo,,ty.o,g/DALLASPROLome/Wort
05-18-00868-CV I Trial Ct pause No. Dc-16-05606
3 messages
I
Brigetta D01ivlo Thu, Jan 10, 2019 at 11:02 PM
To: Tim Hootman
Tim,
i
The following must be done nllater than January 11, 2019:
1. Corrections to the December 31, 018 Supplemental Requests
2. Appellant's Second Amended Re uest For Reporter's Record - To Be File Stamped and Filed no later than January 11,
2019. I
1. Corrections to the Decembel' 31, 201.8 Supplemental Requests
Please correct the following inform tion contained within the ''APPELlANT'S REQUEST FOR SUPPLEMENTAL CLERK'S
RECORD" that was file stamped on December 31, 2018.
Please make these corrections to sa d document (Corrections are highlighted in yellow):
1. pg.1- "Deposition Transcript, file~ on or about 08/18/2017"- INCORRECT
"Deposition Transcript, dated on August 11, 2017''
I
2. pg. 2- "Defendant's Corresponde!ce to the Court, dated 8/24/2017, filed on or about 10/4/2017" INCORRECT
"Defendant's Corresponde~ce to the Court, dated 8/24/2017, filed on August 25, 2017.
2. Appellant's Second Amende~ Request For Reporter's Record
I
• Hearing Transcript for Nov~ber16, 2017
• Hearing Transcript For Au st 23, 2017
• Hearing Transcript For Sept mber 22, 2017
Brigetta D'Olivio
Custom Horne Builder
214.733.7204
Beautiful Homes by Brigetta
"r l ;i,.r, j /;,', / ;-,,r,.,;1, ·,' ., :." i ,}! ~ / "',)!.'· ,.,., ,, · ( :1 } t ,.: ·,· .' ,,
NAWIC '
****** CONFIDENT/AL/TY NOTICE •••••• I
NOTICE: This e-mail message and all attachmelpts transmitted with it may contain legally privileged and confidential information intended solely for the use of the
addressee. If the reader of this message is not t~e intended recipient, you are hereby notified that any reading, dissemination, distribution, copying, or other use of this
message or its atta~hments is strictly prohibite1. If you have received this message in error, please notify the sender immediately and delete this message from your
system. The recipient should check this email afd any attachments for the presence of viruses. This company accepts no liability for any damage caused by any virus
transmitted by this email Thank you. :
EXHIBIT 11
47
0
',,. .,.
FILED
No. DC-16-05606
ZOl9JANl6 PM /=52
Greg Fox
v.
Brigetta D'Olivio
APPELL~T'S REQUEST FOR SUPPLEMENTAL
I
CLERK'S RECORD
To the Clerk, I
Appellant, Brigetta D'~livio, files this request for supplemental clerk's record in
this appeal and request~ the clerk to prepar~ a Supplemental Clerk's Record,
including the followin~ items:
'
I
• Defendant's Corfespondence to the court, dated: 8/24/2017 and filed:
8/25/2017 i ·
• Deposition Tran~pt, dated August 11, 2017.
Dated: January 16, 201)9
Respectfully Submitted,
Brigetta D'Olivio, Appellant
3800 Pebblecreek Ct
Apt 120
Plano, TX 75023
214.733.7204
CERTIFICATE OF SERVICE
r
On this day, a copy of e above document was served via certified mail 7016 1370
0002 0445 5999 servic on the following attorneys of record,:
David Kleiman
0 GEARY WADDELL JENEVEIN, P.C.
1601 Elm Street, S te 4100
dkle'
':ff:/u-l ~ ({<.o.St=
Brigetta D'Olivio, Appellant
EXHIBIT 12
48
No. DC-16-05606
IN THE DISTRICT COURT
DALLASCOUNTY,TEXAS
191 ST JUDICIAL DISTRICT
APPfLLANT'S REQUEST FOR SUPPLEMENTAL
i CLERK'S RECORD
To the Clerk:
I
Appellant, Brigetta D'LIVIO, BRIGETTA 11247-2019-DCLK
JO PEBBLECREEK CT.
~NO, TX 75023 Transaction Date
02/19/2019
~scri tion Amount Paid
:::>UVIO, BRIGETTA
DC-16-05606
GREG FOXet al vs. BRIGETTA D'Oij\VIO
TRANSCRIPr FEE 32.00
SUBTOTAL I 32.00
Remaining Bf lance Due: $1,420.00
PAYMENT TOTAL l'--____32_.o_o_,j
CASH Tendered 52.00
Total Tendered 52.00
Change 20.00
02/19/2019 Cashier Audit
04:06 PM Station DC145 62877962
OFFICIAL RECEIPT
EXHIBIT 14
50
No. DC-16-05606 FILED
19 FEB rZ Pit 3: It I
GREG FOX IN THE DISTRICi,~JPR\
DALLAS co .• TEXAS .
v. DALLAS GOUNTY, TEXA~PUTY
BRIGETIA D'OLIVIO 191 ST JUDICIAL DISTRICT
APPELLfrs CORRESPONDENCE TO COURT CLERK
191 st District Court February 12, 2019
Court Clerk
600 Commerce St.
~Floor
Dallas, TX
Dear Court Clerk, I
Appellant, D'Olivio, filed "~pellant's Request For Supplemental Clerk's Record" on Janwuy
!
16, 2019@ 1:52 pm. !
!
In said request, Appellant tuested the Clerk to prepare a Supplemental Clerk's Record, to
!
include the following:
ndence to the Court, dated 8/24/2017 and filed 8/25/2017
dated August 11, 2017
Listed on the court portal, o January 16, 2019, states in part, •• ... 01116/2019 NOTE-
CLERKS ... comment ... BILL rRO SE ... " '
Listed on the court portal, ot January 17. 2019, states, "01/1712019 CLE_RKS RECORD
PAYMENT NOTICE" i
, 1of3
1
Plus
AppeHant's Req~ For Supplemental Clerk's Record dated December 30, 2018 (3 pages)
Appellant's Requ st For supplemental Oerk's Record dated January 16, 2019 (2 paces)
opyof Page from Court Portal-OC-16-05606 (1 page)
!
N9T received a ''PAYMENT NOTICE" for the Supplemental Clerk's
i
To date, Appellant has
Record (dated January 16, ~O 19) with the request to include the above-referenced court records.
I
Appellant requests that thelcourt Clerk forward the following:
I
1. Strict Proof of mailF and/or copy of email~date & time sent to Appellant, regarding the
"PAYMENT N01CE" for the Supplemental Request for Clerk's Record as is indicated
I
on the court portal. I
I
2. Copy of the "PA. N T NOTICE" as indicated on the court portal.
I
3. A complete list of tte Clerk's Record that bas been prepared and sent up to the Court of
Appeals.
I
Please find attached the folfowing:
I
I. Appellant's Reques~ For Supplemental Clerk's Record dated December 30, 2018, file
I
stamped on Decem+r 31, 2018 and placed on the court portal on January 8, 2019.
2. Appellant's Reques~ For Supplemental Clerk's Record dated January 16, 2019, file
saunped January 161 2019 and placed on die court portal on JanUIIIY 16, 2019.
3. Copy of the page £r4m Court Portal indicating above-referenced court portal dates
I
I
(January 16, 2019 8fd January 17, 2019) inputs.
Sincerely,
cc: Court of Appeals
~
2of3
Plus
Appellant's Req st For Supplemental Cleric's Record dated December 30, 2018 (3 pages)
Appellant's Re est For supplemental Clert<'s Record dated January 16, 2019 (2 pages)
Copy of Page from Court Portal-DC-16-05606 (1 page)
CERTfflCATE OF SERVICE
On this day, January 12, 2~19, a copy of the above document was served via Certified Mail
(7018 1830 0000 3897 278p) service on the following attorney of record:
!
David M. Kleiman *:
Vincent Serafino Geary W dell Jenevein, P.C.
160 l Elm Street, Suite 41
Dallas, TX 7520 l
THIS SPACE LEFT INTENTIONALLy BLANK
I 3of3
Plus
Appellant's Requ For Supplemental Clerk's Record dated December 30, 2018 (3 pages)
Appellant's Req est for Supplemental aerie's Record dated January 16, 2019 {2 pages)
~
pyof Page from Court Portal-OC-16-05606 (1 page)
!
FILf
DALLAS COUN'
12/31/2018 12:00 /'
FELICIA PITF
DIS1RICT CLEf
Angela Conejo
No. DC-16-05606
GREG FOX § IN THE DISTRICT COURT
§
v. § DALLAS COUN1Y, TEXAS
§
1
I
BIUGE'ITADl'LIVIO § 191ST JUDICIAL DISTRICT
Ae__J,lttWf'S REQUEST FOR SUPPl,BMBNTAL
I CJ.ER.K'S RECORD
To the Clerk: I
Appell4t, Brigetta D'Olivio, files this request for supplemental
clerk's record) in this appeal and requests the clerk to prepare a
f
Supplemental lerk's Record, including the following items:
• Info beet, filed on or about 05/11/2016
• Non- ury Pre-trial Order, filed on or about 8/10/2016
• Defe dant's 2nd Amended Answer & 1st Amended Counterclaims,
filed nor about 11/13/2017
• Defe dant' s Brief on Damages, filed on or about November 29,
• ;~::Jiffs Amended Designation of Expert Witness, filed on or
abouf07/28/2017
• Depo ition transcript, filed on or about 08/18/2017
• Defe dant's Amended Motion for Continuance, filed on or about
8/18 2017
• Defe dant's Answer to Motion to Withdraw, filed on or about
8/21 2017
• Defe dant's Amended Answer to Motion to Withdraw, filed on or
abou 8/22/2017
• Defe dant's Amended Motion to Set Aside, filed on or about
9/7/ 17
• Defe dant's Motion to Quash, filed on or about 9/7/2017
• Atty iark's Motion to Withdraw, filed on or about 8/18/2017
1
nt's Motion for Continuance, filed on or about 8/16/2017
• Order, ated on or about 8/21/2017
• Order, ted on or about 9/22/2017 (denying motion to quash)
• Docket heet, dated 9/22/2017, filed on or about 9/29/2017
• Defend t's Amended Response to Pl's Motion for Sanctions,
filed on or about 10/4/2017
• Defend nt's Correspondence to the Court, dated 8/24/2017, filed
on or a ut 10/4/2017
• Defe.nd nt's Motion to Compel, Sanetions, Continuance, filed on
or abou 11/9/2017
• Defend t's Demand for a Juzy Trial, filed on or about
11/13/2 17
• Defen t's Correspondence to the Court, filed on or about
10/4/2 17
• Defend t's Correspondence to the Court, filed on or about
9/26/2 17
• Defen~t's Correspondence to the Court, filed on or about
11/13/2,17
• Defend nt's Motion to Compel Arbitration, filed Nov 2017
• Defend nt's Combined Motion to Strike Plaintiffs Answer to
Counte laims as Untimely and to Strike From the Record
Plain · s Motion to Strike Defendant's Amended Answer and
Counte aims, filed on or about 11/20/2017
• Defend t's Amended Exception to Plaintiffs Petition, filed on or
about 11 20/2017
• Defend t's Motion to Exclude Expert Testimony & Report, filed
on or a ut 11/20/2017
Dated:
2
Respectfully submitted,
/s/TimothyA. Hootman
Timothy A Hootman
SBN 09965450
2402 Pease St
Houston, TX 77003
713.247.9548 (office)
713.366.6229 (cell)
713.583.9523 (fax)
thootman2ooo@yahoo.~.om
ATIORNEY FOR. APPELLANT
BRIGETIA D'Ouv10
CERTIFICATE OF SERVICE
On this 4y, a copy of the above document was served by electronic
service on the topowing attorneys of record:
I
Da ·d M. Kleiman
VlN ENTSERAFINOGEARYWADDELLJENEVEIN, P.C.
160 Elm Street, Suite 4100
Dal s, TX 75201-3703
dkl iman iiNinlaw.com
Dated: Decembe~ 30, 2018
!
/s/TimothyA. Hootman
Timothy A Hootman
3
0
FILED
No. DC-16-0S606
2DJ9 JAN 16 PM I: 52
Greg Fox
V.
Brigetta D'Olivio
~ REOOJ'.ST fOB81/ffl«JMRNTAL
1 CLERK'S RECOBQ
To the Clerk,
Appellant, Brigetta 'Olivio, files this request for supplemental clerk's record in
this appeal and requ ts the clerk to prepare a Supplemental Clerk's Record,
including the follo items:
!
• Defendant's dmrcspondence to the court, dated: 8/24/2017 and filed:
8/2s12011 I
• Deposition T ~ dated August 11, 2017.
Dated: January 16, ,19 .
!
Respectfully Submitted,
Brigetta D'Olivio, Appellant
3800 Pebblecreek Ct
Apt 120
Plano, TX 75023
214.733.7204
i CERTIFICATE QF SEBYJCI
On this day, a copy Jfthe above document was served via certified mail 7016 1370
0002 044S S999 s~e on the following attorneys of record,:
!
David Kleiman
0 GEARY WADDELL JENEVBIN. P.C.
1601 Elm Street Suite 4100
Dallas, TX 7520 -3703
.
r::::t.,~~~..!L.~~:::.._/f Wed, Feb 13, 2019 at 3:30
To: Felicia.pitre@dalfascounty.org 1
I
!
Ms. Pitre,
1. In reference to the meeting at
i
ytr
office on January 18, 2019 wherein the manipulation of the DC-16-05606 court portal
was discussed, I am inquiring as t whether or not the investigation is complete. We discussed the removing of documents,
changing of previously filed docun ents under same heading, etc.
Please inform me if the subpeona i ready to be served in order to retrieve the results of the investigation performed by your I'.
department. i
Does your IT Department have a s1parate fraud division? .
I
2. I have an invoice dated Februal)j 13, 2019 for the amount due of $1018.00.
·what is this amount for? I
What Appellant Reque. st and/or S*plemental Request for Clerk's Record is this for?
Please provide the file stamp date nd time this request was made and by whom.
I will be in to pay this receipt on Fe ruary 13, 2019;
I look forward to hearing from you
Thank you,
Brigetta
Brigetta D'OJi,·iu
C'u,tom H<,ml l\t;iqk,r
...... • L
"''** CONFIDENTIALITY NOTICE**'*" i
NOTICE: This e-mail message and all attochme]ts transmitted with it may contain legally privileged and confidential information intended solely for the use of the
addressee. If the reader of this message is not th intended recipient. you ore hereby notified that any reading, dissemination, distribution, copying, or other use of this
message or its attachments is strictly prohibited If you have received this message in error, please notify the sender immediately and delete this message from your
system. The recipient should check this email an any attachments for the presence of viruses. This company accepts no liability for any damage caused by any virus
transmitted by this email. Thank you
2/13/2019 Gmail - Request Response
Brigetta OOlivio Wed, Feb 13, 2019 at 1:25
To: Felicia.pitre@dallascounty.org :
Ms. Pitre,
I am waiting for a response regard~ng the following:
I
1. Invoice Dated February 13, 20191
2. Investigation into the manipulatfon of court template-portal
I
The Invoice questions I posed to y9u, must be answered. I am waiting to make a payment should a payment be due.
Thank you
Brigetta
Brigctta D'Oli\io
Cu,:,;tt,n1 l-J.,1:1it.· Hul!dtr
214.733 72:'4
*'**'* CONFIDENTIALITY NOTICE...... I
I
NOTICE: This e-mail message and all attachmi·ts transmitted with it may contain legally privileged ond confidential information Intended solely for the use of the
addressee. If the reader of this message is not t e intended recipient, you are hereby notified that any reading, dissemination, distribution, copying, or,other use of this
message or its attachments is strictly prohibited. If you have received this message in error, please notify the sender immediately and delete this message from your
system. The recipient should check this emoil o any attachments far the presence of viruses. This company accepts no liability for any damage caused by any virus
transmitted by this email. Thank you '
I
EXHIBIT 16
52
FELICIA PITRE
DALLAS COUNTY DISTRICT CLERK
600 Commerce Street, Suite 101
Dallas, Texas 75202-4604
IN ACCOUNT WITH
DATE: 2/13/2019
TIMOTHY A HOOT~N
2405 PEASE ST ,
HOUSTON TX 77003
INTERNAL REVENUE SERVICE
IDENTIFICATION NO.: XX-XXXXXXX
Case No. DC-16-05606
Style of Case
GREG FOX, et al
vs.
BRIGEITA D'OLMO
Pages: 993
Clerk's Record $993.00
Transcript Fee- $ 25,00
Attomey Copy Fee- NIA $_ __
Total Fee- $1018.00
i
The Clerk's Record has be~ prepared,
The Clerk's Record will be ~elivered to the Court of Appeals upon payment.
!
Please return a copy of this ~tatement with remittance.
'1
Thank.you.
GAY LANE
Cc:
Lisa Matz
Clerk of the Court, Court of ppeals
Fifth District of Texas at Da as
George L. Allen Sr. Courts uilding
600 Commerce Street, Suite 200
Dallas, Texas 75202
2/13/2019 Gmail - Invoice and Court Portal lnvestiQation
Brigetta D01ivlo Wed, Feb 13, 2019 at 3:30 P
To: Felicia.pitre@dallascounty.org 1i
Ms. Pitre, ;
In reference to the meeting at you~office on January 18, 2019 wherein the manipulation of the DC-16-05606 court portal
1.
was discussed, I am inquiring as to hether or not the investigation is complete. We discussed the removing of documents,
changing of previously filed docume ts under same heading, etc.
Please inform me if the subpeona is ady to be served in order to retrieve the results of the investigation performed by your IT
department. ·
Does your IT Department have a septrate fraud division?
I
2. I have an invoice dated February 1~, 2019 for the amount due of $1018.00.
What is this amount for? ,
What Appellant Request and/or Sup~emental Request for Clerk's Record is this for?
Please provide the file stamp date an time this request was made and by whom.
I will be in to pay this receipt on Feb ary 13, 2019;
I look forward to hearing from you.
Thankyou,
Brigetta
Brigetta D'Olivio
Custom Home Builder
214.733.7204
Beautiful Homes by Brigetta
'·n r ;·.tr'.•'
I •'t;"'Ii'.·
,:.;. ;il .• 1.'/ /1;,"(,,:.. ,' , Ii,';·
NAWIC
****.. CONFIDENTIALITY NOTICE ******
i
NOTICE: This e-mail message and oil attachments transmitted with it may contain legally privileged and confidential information intended solely for the use of the
addressee. If the reader of this message is not the ilended recipient, you are hereby notified that any reading, dissemination, distribution, copying, or other use of this
message or its attachments is strictly prohibited. If u hove received this message in error, please notify the sender immediately and delete this message from your
system. The recipient should check this email and o attachments for the presence of viruses. This company accepts no liobWty for any damage caused by any virus
transmitted by this email. Thank you. !
2/13/2019 Gmail - Invoice and Court Portal lnvestiQation
.Brigetta DOIMo Wed, Feb 13, 2019 at 3:30 A
To: Felicia.pitre@dallascounty.org !
Ms. Pitre, ~!
1. In reference to the meeting at you office on January 18, 2019 wherein the manipulation of the DC-16-05606 court portal
was discussed, I am inquiring as to hether or not the investigation is complete. We discussed the removing of documents,
changing of previously filed docume ts under same heading, etc.
Please inform me if the subpeona is ady to be served in order to retrieve the results of the investigation performed by your IT
department. .
Does your IT Department have a seprate fraud division?
2. I have an invoice dated February 1~, 2019 for the amount due of $1018.00.
What is this amount for? r
What Appellant Request and/or Suptemental Request for Clerk's Record is this for?
Please provide the file stamp date an time this request was made and by whom.
I will be in to pay this receipt on Feb ary 13, 2019;
I look forward to hearing from you. i
Thank you,
Brigetta
Brigetta D'Olivio
Custom Home Builder
214.733.7204
Beautiful Homes by Brigetta
''f! ..i·J'. ;:,,,·,·,'_,,;·,1:r; r.':·11:1·,.•1:"J i·.,,./(.:1,,,·,.:,>;:''
J-.:A\X1IC
***.. * CONFIDENTIALITY NOTICE **"** ,
NOTICE: This e-mail message and oil ottachmentsironsmitted with it may contain legally privileged and confidential information intended solely for the use of the
addressee. If the reader of this message is not the i tended recipient, you are hereby notified that any reading, dissemination, distribution, copying, or other use of this
message or its attachments is strictly prohibited. If 'OU have received this message in error, please notify the sender immediately and delete this message from your
system. The recipient should check this email and arr attachments for the presence of viruses. This company accepts no liability for any damage caused by any virus
transmitted by this email. Thank you. :
I
2/26/2019 Gmail - ReQuest Response
MGmaH Brigetta DOlivio
i
... ________ --· ·- --·-------·-----·--·"···· -·-·-- -------···-·- ---····-·--------~---·-------·---·-·····-- .. ·----···-·-· -···-····-·---·------·-----·-·--·---··-··-- ·-·--··-
I
-···-···-· ·-- -- ----- ·--·-· ·····-·-- - ....... -- -·---·--··-··--·- -··-- ·-----······· ...... ·- --
Request_ Response----------·-· ~'I _______________________________ -----·--·---·--·-------------·---------·---···--·----·-·-···---------·----------··------·-·-·----------·-··-· _
Felicia Pitre Wed, Feb 13, 2019 at 5:11 PM
To: Brigetta DOlivio
Ii
Ms. D'Olivio:
I
I
Listed is a summary of actions regardi~g monies owed for the Clerk's Record:
i
9/25/17 Notice of Appeal filed by IPro se - assigned 05-17-01119-CV
" I
• 9/29/17 Pro se requested Clerks ~cord
i,
• 10/5/17 Invoiced Prose $402.00 (rot paid)
• 12/5/17 No pay letter 5th COA
4/10/18 Dismissed by 5th COA ,
• f
7/30/18 Notice of Appeal filed by ttorney - Timothy Hootman assigned 05-18-00868-CV
I
• 7/30/18 Attorney requested Clerksl Record
I
• 8/8/18 Invoiced attorney $907.00 1
1
• 8/24/18 Supplemental Clerk Recori request filed by opposing attorney David Kleiman
I,
• 8/31/18 Invoiced attorney $507.ooi
i
• 9/11/2018 No pay letter sent 5th C~A for attorney Hootman $907.00
I
• 9/24/18 Attorney Hootman paid $9p7.00 Clerks record sent
• 9/24/18 Attorney Kleiman paid $SOV.OO Clerks record sent
!
I
• 12/31/18 Supplemental request file~ by attorney Hootman
!
• _1/16/19 Supplement filed by Pro sei
!
• 1/17/19 Invoiced attorney $1018.og
• 2/12/19 Supplement filed by Prose 'I
i
!
',
A.dditionally, our IT Department is reachiig out to our vendor regarding you're allegations. We will notify you once we
receive an official response from our ven~or.
EXHIBIT 17
53
2/26/2019 Gmail - Request Response
t~ Grnail Brigetta DOlivio
iri~; ; ~~;;~;~i~: ¥~"~~~~~~--~----------------~~;,; ;~,
Felicia, !!
35 ~M
Is the Invoice dated Febru.ary 13, 201*the same as the listing stating, "1/17/2019 Invoiced attorney $1018.00?
If so, why was an attorney who was di arged sent any information regarding my ~~ sjnce according to the information on
the portal listed as 01/16/2019states. part, "...BILL PRO SE... "
What else, if anything, has been sent t discharged attorney Hootman since COA Order dated 01/15/2019.
Has discharged attorney Hootman pai for the $1018.00 Invoice? He was paid over $20,000.00 thus lat.
Has Invoice dated February 13, 2019 b en paid?
As far as the investigation into the cou template/portal as it relates to DC-16-05606, what do you need from me?
As far as the investigation into manipul ting/changing the portal, the 68th District Court has 1~0 done the same.
I
Thank you for taking the time to respotjd to my requests.
Sincerely,
Brigetta
[Quoted text hidden]
EXHIBIT 18
54
2/21/2019 Gmail - Dc-16-05606 Tr. Ct. and 05-18-00868-CV
M Gmail Brigetta DOlivio
Dc-16-05606 Tr. Ct. and 05-18-00868-CV
Brigetta DOlivio Thu, Feb 21, 2019 at 12:23 PM
To: Felicia Pitre
Ms. Pitre,
I
Please confirm exactly what Invoices hare been paid for by discharged attorney Hootman in reference to Cause No. DC-16-
05606. 1
I have paid Mr. Hootman over $20,000~00 which also included the cost of preparation of Clerk's Record.
I
Please forward any and all receipts of parnent and to which request each payment was associated with.
Please also include which documents (rdcords) were actually included in the cost associated with each Invoice, and which
documents (records), were in-fact prepared and sent to the Court of Appeals,
Thankyou
Brigetta D'Olivio
Custom Home Builder
214.733.7204
Beautiful Homes by Brigetta
"U7hereyo11r zision ef a drea11J ho,,,e becomes o rea.i!J"
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EXHIBIT 19
55
2/23/2019 mail-Alleged Outstanding lnvoice(s) DC-16-05606 Trial Ct. 05-18-00868-CV
M Gn1ail Brigetta DOlivio
Alleged Outstanding lnvoic (s) DC-16-05606 Trial Ct. 05-18-00868-CV
Brigetta D01ivio Sat, Feb 23, 2019 at 8:55 PM
To: Felicia Pitre
Ms. Pitre, ~',
Your immediate response to the ques ·ons regarding an alleged "outstanding balance" allegedly owed by Appellant D'Olivio,
as indicated via email and corresponde ce filed with the Court of Appeals and the 191st District Court, and, brought to your
attention on multiple occasions and also brought to the attention of District Oerk, Angela Conejo on February 19, 2019, is
required. !
i
Your immediate response to supply A*pellant D'Olivio with a copy of the Invoice(s) associated with the alleged "outstanding
balance" is required. I
Please Note:
There is a typo, highlighted in the color~. in the email sent on February 21, 2019 that is attached to this email as a "forward"
email and partially quoted below. 1.
The correction is highlighted in yellow. I
:,
February 18, 2019 (incorrect date) is be 1eplaced with: February 13, 2019 (correct date)
... "February 19, 2019, I spoke with "Ang~a (Conejo)" regarding an Invoice for $32.00. Angela stated that she did not know
what the Invoice dated February 18. 201, was for. She stated that she believed it was for the Clerk's Record request but not
sure which request... " 1
[Quoted text hidden]
EXHIBIT 20
56
District Clcrk, Pitre Tr. Ct. Cause No. DC-16-05606; 05-18-00868 CV 2019
Brigetta D'Olivio, Appellant
3800 Pebblecreek Ct.
Ff LED
Apt. 120 19 FEB 25 PH 12: r 5
Plano, TX 75023
214.733.7204 f·EL;t.::t-. ?lTnE
D1srn1cT Ci.ERK
[i{_:autjfu lhom1;sbvbrig_etta,0',.grrn1i I.crnn DALLAS CG., IEXAS
·--DEPUTY
APPELLANT'S CORRESPONDENCE
TO DISTRICT CLERK, FELICIA PITRE
February 22, 2019
Filed with District Clerk
Dallas County District qourt &
C/0 District Clerk: Via Certified Mail
Felicia Pitre 70181830 0000 3897 5644
191 st District Court
600 Commerce St.
First Floor
Dallas, TX 75202
I'
Re: 1. Correspondence d!ted February 13, 2019 and filed February 13, 2019
Correction(s) to p;2, Lines 7 and 9
2. Appellant's Requ t for Copy ofinvoice(s) indicating an "outstanding
balance"- No Res onse from Felicia Pitre after multiple requests in writing
Dear Ms. Pitre,
I
Appellant, Brigetta D' Oli io has a pending Appeal, Cause No. 05-18-00868 CV from the 191 st
District Court, Trial Caus No. DC-16-05606, and requests the following:
1. Correction(s) to e noted for the record, from Correspondence that was filed with
the District Cler c/o Felicia Pitre and, at the 5th Court of Appeals, c/o Chief Clerk,
Claudia McCoy. he Correspondence was fl.Jed on February 13, 2019.
For your conveni nee, a copy of the referenced filed Correspondence, is enclosed.
Note for the record, the ab ve referenced Correspondence filed on February 13, 2019 requires a
correction to page 2, para. 12, Lines 3 and 5.
On page 2, para. 2, Line 3,\ it states in part, " ... Rule 1. 06 of the Texas Rules ofCivil Procedure. ".
The verbiage, "Texas Rule~ of Civil procedure" is incorrect.
': .1 of2
l,correspondence Letter Dated February 22, 2019-2 pages
I Plus
Atta~hed Correspondence Letter Dated February 13, 2019- 3 pages
District Clerk, Pitre Tr. Ct. Cause No. DC-16-05606: 05-18-00868 CV 2019
The correct verbiag for citing the specifically mentioned rule in the above-referenced
Correspondence, pg. , para. 2, Line 3, is now considered correctly cited as: " ... Local Rule
1.06. ". i
I
On page 2, para. 2, Lfne 5, it states in part, " ... Rule 1.07 ofthe Texas Rules o._fCivil Procedure.".
The verbiage, "Texa~ Rules ofCivil procedure" is incorrect.
!
The correct verbiagelfor citing the specifically mentioned rule in the above-referenced
Correspondence, pg.~. para. 2, Line 5, is now considered correctly cited as: " ... Local Rule
1. 07. ".
I
2. Copy of Invote(s) indicating an "outstanding balance"- Appellant has made
multiple atte pts, in writing, to receive an Invoice for the alleged "outstanding
balance'' for e Clerk's Record, to no avail.
I
Said Invoice is not lis~ed in your "Summary ofactions regarding monies owed for the Clerk's
Record" to which ym~ emailed Appellant the "summary ofactions", on February 13, 2019.
I
Appellant D'Olivio, hfs sent you multiple emails requesting not only clarification for the
February 13, 2019 Inv ice but also, requests for copies of any and all Invoices that you claim an
amount of $1423 .00 i an "outstanding balance", to no avail.
Should Appellant D'~Iivio have any "outstanding balance", she is prepared to pay what is
owed, if any. !
i
A payment cannot be tade without an invoice.
Appellant D'Olivio ha{ not been supplied with any Invoice referencing an "outstanding
balance" and nor does your list of "summary ofactions" provided to Appellant via email,
indicate that an any In. oice has been supplied to Appellant D'Olivio, that has not been paid for.
Appellant D'Olivio is fgain requesting any such Invoice to be forwarded to her, immediately.
Time is of the essence!I
Please forward any anJ all Invoices that are attributable to the alleged "outstanding balance"
owed by Appellant, D 'Plivio, immediately.
I
Thank you for your tittje and consideration.
,,
Sincerely,
._):' __·;:-,. _,_ . ~ --
·.!.:_... /" .. , .,',; . ~· . . /. ·t .... i::'.,
, I
Brigetta D'Olivio, Ap~llant
!
2 of2
, Correspondence Letter Dated February 22. 2019- 2 pages
i Plus
I
f'-tlached Correspondence Letter Dated February 13, 2019- 3 pages
DC-16-05606
FILED
l9F'f813 PH 3: 3:S
~-·.1 , . . • .
GREG FOX, ET, ALJ IN TME1UWt1Q&f,fOURT
PLAIN1(FF ~LLAS CO., TEXAS
i
V. ~LLASCotiN,IlV,UftxAS
BRIGETTA D'OLIVHD 191 sr WDICIAL DISTRICT
DEFENDA/IT
CORRESPONDENCE
111
5 Court of Appeals
C/0 Chief Clerk
Claudia McCoy i
600 Commerce St. Ste. ~00
Dallas, TX 75202
1
February 13, 2019
Dallas County District tjourt
C/0 District Clerk 1,
Felicia Pitre i
191 51 District Court
600 Commerce St.
First Floor
Dallas, TX 75202
RE: Documents Filed on ebruary 12, 2019 by Appellant, Brigetta D'Olivio- 05-18-00868-CV
1. "Appellant's Cor espondence to Court Reporter for the 19F1 District Court"-
Correspondence etter Filed on February 12, 2019 @3:37 pm
2. "Appellant's Cor 'espondence to Court Clerk"- Correspondence Letter Filed on February
12, 2019@ 3:41 m
!,
Dear Ms. McCoy and Msj Pitre,
Appellant, Brigetta D'Oli+io, filed two (,2) Letters of Correspondence in relation to Trial Cause
No. DC-16-05606, on Fe~ruary 12, 2019 at the 191 st District Court Clerk's Office.
The two Letters of Corres ondence are:
1. "Appellant's Corr spondence to Court Reporter for the 19!31 District Court"-
Correspondence L tter Filed on February 12, 2019 @ 3 :37 pm
1 of 3
2. "Appellant's orrespondence to Court Clerk"- Correspondence Letter Filed on February
12, 2019@3: 1 pm
i
Appellant's letters of rrrespondence have been filed on the 191 st District Court Portal under the
!
improper Cause No. ~C-18-18015.
Said letters of corresp~ndence are in no relation to the Cause No. DC-18-18015 case.
i
The "new Lawsuit" (tjC-18-18015) filed by Greg Fox and Laura Fox does not comport to, nor
I,
meet the requirements pf Rule 1.06 of the Texas Rules of Civil Procedure.
!
The ••new Lawsuit" (D~-18-18015) filed by Greg Fox and Laura Fox does not comport to, nor
I
meet the requirements tr Rule 1.07 of the Texas Rules of Civil Procedure.
'
'
Plaintiff's and their atttjmey, David M. Kleiman's assertion that they are related is wholly
I
inaccurate.
I,
The new case DC-18-1 ~O 15 is frivolous.
I
'1
Appellant's Letters of Cprrespondence referenced above, must be placed on the proper court
portal and under the profer cause number (Cause No. DC-16-05606).
Please correct the record'\ to reflect the proper fiiing.
i
I
Respectfully Submitted, 1!
') /jP,l?/':19
~
2 of 3
CERTIFICATE OF SERVICE
I
Appellant, Brigerta D,Olivio, in the above-caption case, do certify that on the 13th day of
'
!
February, 2019, serve4 Plaintiffs' attorney, David M. Kleiman, the ,vithin Correspondence Letter
I
dated February 13, 20119. Said service was made via certified mail tracking number 7018 1830
I
0000 3897 1936, at the llast known address for David M. Kleiman at Law Office of Vincent
Serafino Geary Waddelt Jenevein, 1601 Elm St., Ste 4100, Dallas TX in accordance with Rule
i
21a of the Texas Rules ~fCivil Procedure.
I
Respectfully Submitted, ,
3 of 3
EXHIBIT 21
57
3/3/2019 Gmail-test
M Gmail Brigetta DOlivio
test
Gay Lane Mon, Feb 25, 2019 at 12:49 PM
To: "Beautifulhomesbybrigetta@gmail.com" Beautifulhomesbybrigetta@gmail.com>
test
Gay Denise Lane
Document Production, Lead Clerk
Office of Felicia Pitre
Dallas County District Clerk
600 Commerce St. Suite 145
Dallas Texas 75202
214-653-6549
gdlane@dallascounty.org
https://mail.google.com/mail/u/O?ik=ba80a72ce2&view pt&search=all&permmsgid=msg-f%3A 1626467775231577332&simol=msa-f0/n3A 1n?Mfl777!';? 111
EXHIBIT 22
58
2/25/2019 Gmail - Supplemental Clerk record payment invoice
Brigetta DOlivio Mon, Feb 25, 2019 at 12:52 P,
To: "Beautifulhomesbybrigetta@gmail. om"
Cc: Shelia Bradley , Gay Lane
Dear Brigetta D'olivio, .
i
Please remit payment for the supple~ental clerk record prepared for the cause no DC-16~05606 styled: Greg Fox, et al vs
Brigetta D'O/ivio. ·
Please see attached invoice
Gay Denise Lane
Document Production, Lead Clerk
Office of Felicia Pitre
Dallas County District Clerk
600 Commerce St. Suite 145
Dallas Texas 75202
214-653-6549
gdlane@dalfascounty.org
. ~ dc-16-05606clersk record paym+nt involce.pdf
429K !
I FELICIA PITRE
'ALLAS COUNTY DISTRICT CLERK
1
600 Commerce Street, Suite 101
' Dallas, Texas 75202-4604
IN ACCOUNT WITH
DATE: February 25, 2019
BRIGETTA D'OLIVIO
3800 PEBBLECREEK CT
PLANO TX 75023
INTERNAL REVENUE SERVICE
IDENTIFICATION No.: XX-XXXXXXX
Cause No. DC-16-05606
Style of Case
GREG FOXet al
vs.
BRIGETTA D'OLIVIO
Pages:993 1
Supplemental Clerk's Recor~ Fee- $993.00
Transcript Fee- '· $ 25.00
Attorney Copy Fee- NIA $ 0.00
Total Fee- $1018.00
Supplemental Clerk's Rec01}'1 will be delivered to the Court of Appeals upon payment.
Please forward payment with rvoice in the next 3 business days. .
Please return a copy of this s,atement with remittance.
Thank you.
GAYLANE
Cc:
Lisa Matz
Clerk of the Court, Court of Ap eals
Fifth District of Texas at Dalla
George L. Allen Sr. Courts Bui ding
600 Commerce Street, Suite 20
Dallas, Texas 75202
EXHIBIT 23
59
2/25/2019 Details
Cancel Reason
REQUESTED BY ATTOR
PUAMENDED APPLICATI N FOR TURNOVER ORDER FILED
12/03/18 30M KAREN 214- 79-7410
i
Q2i2!5/2019 CLERK'S RECq)RD PAYMENT 11\JVOICE ""
!
CLERl<'S RECORD PAYMdNT INVOICE
!
2/25/2019 Details
ISSUE WRIT
Amended Appiication for turnover.pdf
NOH on /\nKI P,pp for Turiover· Orcier.pdf
REQUEST FOR SERV/C
!
1::;suE WRIT .
RETURN OF SERVICE I
SUPPLEMENTAL CLERK'IS RECORD REQUEST
REQUEST REPORTER Rf CORD
SUPPLEMENTAL CLERK'~ RECORD REQUEST
2019-01-22 - ·1st ,D,.111ended ·
NOH_ on_Amended_Appliqation_for_Turnover_ Order.pdf
I
(2) WRIT OF EXECUTIONt BRiGETTTA D'OLIVIO
I
SUPPLEMENTAL CLERK'f RECORD REQUEST
CORRESPONDENCE - L9TTER TO FILE
CORRESPONDENCE - LE~TER TO FILE
SUPPLEMENTAL COVER i
CLERK'S RECORD PAYM~NT INVOICE
Gary Patterson's Motion to ~'Vithdraw as Counsel for DC-16-05606.pdf
I
Order Granting Motion tor V}'ilhdraw of Counsel for DC-16-05606.pdf
I
2019-02-i 8 - Notice__ of_ Carcellation_of_hearing.pdf
RESPONSE
'
NON-SIGNED PROPOSE DI ORDER/ JUDGMENT
CLEF~K'S RECORD PAYM9NT INVOICE
EXHIBIT 24
60
DC-16-05606
GREFOXANDLAURA OX
Plaint ffs
V
.. 191ST JUDICIAL DISTRICT
BRIGETT A D'OLIVIO
..
ENTAL RE UEST FOR CLERK'S RECORD
To The Court Clerk:
Appellant, Brigetta D'O ivio, files this request that the Court Clerk prepare the following
I
supplemental court clerk's cord in this appeal and that the record include the following:
1. David M. Kleiman' Correspondence to the Court, filed December 4, 201 7
2. David M. Kleiman' Correspondence to the Court, filed December 15, 2017
3. David M. Kleiman' Correspondence to the Court, filed May 25, 2018
4. Order, dated April 2 , 2018
5. Atty Gjesvold's Mo ion To Withdraw, filed April 19, 2018
6. DWOP Notice (hear ng was scheduled for August 11, 2016
7. Reporter's Certifica ion of Deposition, filed October 24, 2017
Dated: February 26, 2019
Respectfully Submitted,
,
Brige D'Olivio, Appellan Pro Se
/ 3800 Pebblecreek Ct.,# 12
Plano, TX 75023
214-733-7204
Tr. Ct. Cause No. DC-16-05606: 05 18-00868 CV 2019
DC-16-05606
GRE FOX AND LAURA ox IN THE DISTRICT COURT
.. DALLAS COUNTY, TX
V
.. 191ST JUDICIAL DISTRICT
BRIGETTA D'OLIVIO .
Defen ant ..
CERTIFICATE OF SERVICE
I certify that on February 26, 2019 a true and correct copy of this Appellant's Supplemental
Request For Clerk's R cord was served via Certified Mail 7018 1830 0000 3897 5675, on David M.
Kleiman, Vincent Serafino Geary Wadden Jenevein, 1601 Elm Street, Suite 4100, Dallas, TX 75201,
Plaintiff's attorney of record.
'
"}.
·. :"?u ,./l_f;.tt7',_:z.,
9
Brigetta D'Olivio, Appellant
3800 Pebblecreek Ct.
Apt. 120
Plano, TX 75023
214.733.7204
beautifulhomesbybrJ.Rettn@g_r:r:ail.com
I of 1
Certificate of Service
EXHIBIT 25
61
DC-16-05606
GREFOXANDLAURA OX ..
.
V
: 191ST JUDICIAL DISTRICT
BRIGETTA D'OLIVIO
Defend nt
SUPPLE ENTAL RE UEST FOR CLERK'S RECORD
To The Court Clerk:
Appellant, Brigetta D'Oli io, files this request that the Court Clerk prepare the following
supplemental court clerk's r ord in this appeal and that the record include the following:
1. David M. Kleiman's orrespondence to the Court, filed December 4, 2017
2. David M. Kleiman's orrespondence to the Court, filed December 15, 2017
3. David M. Kleiman's orrespondence to the Court, filed May 25, 2018
4. Order, dated April 25 2018
5. Atty Gjesvold's Moti n To Withdraw, filed April 19, 2018
6. DWOP Notice (heari g was scheduled for August 11, 2016
7. Reporter's Certificati n of Deposition, filed October 24, 2017
Dated: February 26, 2019
Respectfully Submitted,
/Brige D'Olivio, Appellant Pro Se
/ 3800 Pebblecreek Ct.,# 120
Plano, TX 75023
214-733-7204
F Il,.,• f-.... ;,,.,,,.'· .
_..,. '"'
DC-16-05606 2019 F£B 27 Att/0: 5 7
GREG FOX AND LAU FOX
Plain iffs
V
191ST JUDICIAL DISTRICT
BRIGETTA D'OLIVIO I
Defenrant
ENTAL RE UEST FOR CLERK'S RECORD
To The Court Clerk:
Appellant, Brigetta D' livio, files this request that the Court Clerk prepare the following
supplemental court clerk's record in this appeal and that the record include the following:
I. Order Denying D fendant's Motion To Compel Arbitration, filed on or
about Dec. 22, 201 .
2. Order Denying D fendant's Amended Special Exceptions, filed on or about
Dec. 22, 2017.
Dated: February 27, 2019
Respectfully Submitted,
CAUSE NO. DC-16-05606
GREG AND LAURA FOX, § IN THE DISTRICT COURT
§
Plaintiffs, §
§
V. § DISTRICT COURT NO. 191 ST
§
BRIGETTA D'OLIVIO, §
§
Defendant. § DALLAS COUNTY, TEXAS
CERTIFICATE OF SERVICE
I certify that on Febru ry 27, 2019 a true and correct copy of this Appellant's Supplemental
Request/or Clerk's Record as served via Certified Mail 7018 1830 0000 3897 5699 was served
on David M. Kleiman, Vince t Serafino Geary Waddell Jenevein, at 1601 Elm Street, Suite 4100,
Dallas, TX 75201, Plaintiffs attorney of record.
Brige, D'Olivio, Appellant
3800 Pebblecreek Ct.
Apt. 120
Plano, TX 75023
214.733.7204
hcatnifulhonwsb\ hri1.:ct1a a _ginaiLc(im
EXHIBIT 26
62
Q DAL AS COUNTY, TEXAS COl
Welcome,..
ERTi Fi CATE
ERVICE
View Document
2/27/2019
UPPLEMENTAL
LERK'S
ECORD
EXHIBIT 27
63
2/27/2019 Gm ii - February 26 2019 Appellant Supplemental Request for Clerk's Record
M Gmail Brigetta DOlivio
February 26 2019 Appellant S pplemental Request for Clerk's Record
Brigetta DOlivio Wed, Feb 27, 2019 at 2:47 PM
To: Angela Conejo
Ms. Conejo,
On February 26, 2019 @ 2:31 pm, Appella t, Brigetta D'Olivio, filed a "Supplemental Request For Clerk's Record". Said
request was not filed as of February 27, 20 9 @ 10:57 AM this morning.
I asked you where the above-referenced fil ng was since it was not listed on the 191st District Court portal under Cause No.:
DC-16-05606.
You stated that you did not know where it as. I stated that the "filings" should not be "lost" and requested that you "find it"
and properly file it on the portal.
On February 27, 2019 @ 10:57 AM, Appell nt, Brigetta D'Olivio, filed an additional "Supplemental Request For Clerk's
Record" which was listed as being filed, i mediately following the file of February 25, 2019, yet the February 26, 2019
referenced above was still NOT filed (Pleas find attached a picture of the portal (TR. Ct. DC-16-05606) indicating such).
Please have the February 26, 2019 "Suppl mental Request For Clerk's Record" found and properly filed (191st District Court
Portal-Tr. Ct. DC-16-05606).
Thank you
Brigetta
Brigetta D'Olivio
Custom Home Builder
214.733.7204
Beautiful Homes by Brigetta
"Lrhtre_yrmr l'i.rion qfa dretl!JJ home heaJIJJt'S fl reali(y''
NAWIC
****** CONFIDENTIALITY NOTICE ••••••
NOTICE: This e-mail message and all attachments trans itted with it may contain legally privileged and confidential information intended solely for the use of the
addressee. If the reader of this message is not the intend d recipient, you are hereby notified that any reading, dissemination, distribution, copying, or other use of this
message or its attachments is strictly prohibited. If you h ve received this message in error, please notify the sender immediately and delete this message from your
system. The recipient should check this email and any a achments for the presence of viruses. This company accepts no liability for any damage caused by any virus
transmitted by this email Thank you.
Screenshot_20190227 110435_ Chrome.jpg
93K
L . .- · _.'L 1,;
!''.i :pi-_:-,
https://mail.google.com/mail/u/O?ik=ba80a72ce2&vie =pt&search=all&permmsgid=msg-a%3Ar-5283924304694072321 &simpl=msg-a%3Ar-5283924... 1/1
2/27/2019 0 (108Qx1920)
® 11-.\. a._\.~ a~ lrl ·· a 48,' ., 84%111:04AM
( ) DALLAS COUNTY, TEXAS COl
CERTIFICATE
OF
SERVICE~
j View Document
02/27/2019
SUPPLEMENTAL
CLERK'S
RECORD
https://mail-attachment.googleusercontent.com/attach ent/u/O/?ui=2&ik=ba80a 72ce2&view=att&th=16930b3deff2a391 &attid=O .1 &disp=inline&realatti... 1/1
EXHIBIT 28
64
------. --- --
,
• Q ••
r· . •
,.,.,.,.-~... '·
, . __,, .
:'J. we ddth·e
direc ed verdict
. durin~ closing.
!
Message ~etails
. Type
Advanced ~essaging
!
From 1
Jennifer A,torney(+15419745091)
Time sent !
4:41 AM, D~c 6
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OK
/.:
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••
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~_'._,) The ~:mly thing
left do in fox t9
· is sePd the judge
.... . ..... ·--~" .... ..• -~ .. .i '
Message ~etalls
Type
Advanced Messaging
From !
Jennifer A~orney(+15419745091)
~
l'
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left ~o do in fox
is s~md the judge
a pr posed final
jud ment since
klie ans made
ve little sense
and she would
hav to redraft
it e tirely which
stat judges wont
do. hat doc
along with the
two other orders
you equested,
you ,enoticed on..· •u :;·· -..,;,.._'<-'!!'.•_,.,.~.,·
·:-~··~ar:1· ; , · · · ·..,,.•...•.····-···~-~"'..•:·--@.~-
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1
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EXHIBIT 29
65
BRIGETTA D'OLlVIO
3800 PEBBLECREEK CT., # 120
PLA:VO, TX, 75023
214·733-7204
VJA CERTIFIED :\~AIL
1t}Z l[JuOltlX)~'l;11 t2~i'l
FEBRtAR\' 13. 201~
\\'tight Rep(wtex,;; LL(t
% Vlelba Wriuht . :
1818 Holly Spring Dri
Arlington, TX 76018 :
Re·. DC-l6-05606
Trial: °';O\. 21-22,!2017
Dear Ms. Wright:
'
Vpon receipt of this rqqucst, please forward the following to me at the above-rdcrcnccd address:
l. Copy ofNotic~ of Request for the Trial Transcript for the triai of '!\o,·emb~r 21-22, 2017
for the above-1pfcrenccd cause number. and the name of each party an<.Vor a1torncys who
were so notifie~.
2. .'\Jame of pcrso~(s) who ordered the trial transcript for the above-referenced cause number
anJ~'iG ~,
l· ,/~\\~:1~i~.Jl1"J:¥.;'!!'J~~~;~~"'."'i'f'"t;>a'~,7::, ,,
0
EXHIBIT 30
66
Wright Reporters. LLC 2019
Certified Mail dated February 28. 2019
Tracking No: 701818300000 3897 5705
BRIGETTA D'OLIVIO
800 PEBBLECREEK CT., APT. 120
PLANO, TX 75023
214- 733- 7204
VIA CERTIFIED MAIL
7018 1830 0000 3897 5705
February 28, 2019
Wright Reporter's, LLC
C/0 Melba
1818 Holly Spring Dr.
Arlington, TX 76018
Re: Certified Letter dated F ruary 13, 2019
7018 1830 0000 3897 1 51
Tr. Ct. Cause No.: DC-1 -05606
Dear Ms. Wright,
A Certified letter dated Feb ary 13, 2019 with certified mail tracking number: 7018 1830 0000
3897 1851 is confirmed as h ving been delivered in person to the 1818 Holly Spring Dr.,
Arlington, TX referenced ad ress.
To date, there is a complete bsence of any response, for requested information contained within
said certified letter dated Fe ruary 13, 2019.
Your immediate response is equired.
j ,J
/ Brigelta D'Olivio, Appellan
1 of 1
irst Request- Certified Letter dated February 13. 2019
ertified Letter dated Februal)' 13. 2019 Tracking No.:
7018 1830 0000 3897 1851
EXHIBIT 31
67
WRIGHT REPORTERS, LC DATE: August 3, 2018
c/o 191st District ourt
600 commerce Street INVOICE#: 180803-1
7th Floor, suite 72 c
Dallas, Texas 7520
214-653-7146 TAX ID#: XX-XXXXXXX
Mr. Timothy A. Hootman
2402 Pease street
Houston, Texas 77 03
CAUSE NO. DC-16-056 6-J Honorable Gena slaughter presiding
Greg FOX
vs
Brigetta D'Olivio
Date Taken Amount
$2,500.00
subTotal $2,500.00
Paid 0.00
BALANCE DUE
Thank you very much.
Melba D. wright, CSR
official court Reporter
191st Judicial District court
Dallas county, Texas
wrightmelba@msn.com
(214) 653-7146
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CHASE
Terms and Conditions (R mitter and Payee):
* Please keep this copy r your record of the transaction
* The laws of a specific tate will consider these funds to be "abandoned"
if the Cashier's Check ·snot cashed by a certain time
- Please cash/dep sit this Cashier's Check as soon as possible to
prevent this from occurring
- In most cases, th funds will be considered "abandoned"
before the "Void fter'' Date
* Placing a Stop Payme t on a Cashier's Check
- Stop Payment ca only be placed if the Cashier's Check
is lost, stolen, or estroyed
- We may not re-is ue or refund the funds after the stop payment has
been placed until 90 days after the original check was issued
* Please visit a Chase br nch to report a lost, stolen, or destroyed Cashier's Check
or for any other inform tion about this item
I
FOR YOUR PROTECTION SAVE THIS COPY Customer Copy
CASHIER'S CHECK 9458212253
I 08/20/2018
Void after 7 years
Remitter: BRIGETTA A DO~IVIO/DBA PAQUETTE HOLDING
$** 2,500.00 **
Pay To The WRIGHT REPOR ERS, LLC
Order Of:
Drawer. JPMORGAN CHASE BANK, N.A.
Memo:-------------------------------------- ------------------------
Note: For information only. Comment has no e ct on bank's payment.
NON NEGOTIABLE
282111107 NEW 01/08 8810004306
~·'
CASHIER'S CHECK 9458212253 25-3
CHASE
Remitter: BRIGETIA A DOL VIO/DBA PAQUETIE HOLDING
bate 08/20/2018 Void after 7 years 440
Pay To The WRIGHT REPOR ERS, LLC
Order Of:
Pay: TWO THOUSAND FIVE HUNDRED DOLLARS AND 00 CENTS $** 2,500.00 **
Dra-r: JPMORGAN CHASE BANK, N.A.
Do nol write outside this box
c:..---;> ---')
n~ i(t'-_ ·~\\·, ,.,' f' · / I -___1\.;__'- /,J 1/ ., .,,.. ·)' _Nn£ 9 ~ ____________________ _
Memo· - - · ..1. ·' ----L J ,., · _j ·1 ·- ----· _ v . .._ 1- ·Jr< __ ,_,-----
Ryan A. Crowley, Managing Director
Note: For information only. Comment has no effec on bank's payment.
JPMoman Chase Bank, NA
Columbus, OH
EXHIBIT 32
68
Office of Dallas District Clerk, Felicia itre Certified Mail Tracking No.: Request For Clarification
Office of Chief Clerk, Claudia McCoy 7018 1830 0000 3897 5712 Invoice Dated February 25, 2019
5th Court of Appeals
BRIGETTA D'OLIVIO
800 PEBBLECREEK CT., APT. 120
PLANO, TX 75023
214-733-7204
VIA CERTIFIED MAIL
7018 1830 0000 3897 5712
February 28, 2019
Gay Denise Lane
Document Production, Lead lerk
F
I
Office of Felicia Pitre
Dallas County District Clerk
600 Commerce St. Suite 145
Dallas, TX 75202
214-653-6549
Re: Invoice dated February 5, 2019
Tr. Ct. Cause No.: DC-1 -05606
Dear Ms. Lane,
Multiple attempts made by ppellant, Brigetta D'Olivio have been made to the Dallas County
District Clerk's Office rega ing request for clarification ofinvoice(s).
This is no exception. This I voice attached to an email dated February 25, 2019 with the Invoice
dated the same, lacks any re erence as to what this invoice is attributable to.
Please reference what suppl mental request made by Pro-Se Appellant, D'Olivio's request this
Invoice supports.
Your immediate response is required.
I of 1
Certified Letter dated February 28, 2019
7018 1830 0000 3897 5712
2/25/2019 Gmail - Supplemental Clerk record payment invoice
M Gmail Brigetta D01ivio
Supplemental Clerk record pa
Gay Lane Mon, Feb 25, 2019 at 12:52 PM
To: "Beautifulhomesbybrigetta@gmail.com" < eautifulhomesbybrigetta@gmail.com>
Cc: Shelia Bradley , Gay Lane
Dear Brigetta D'olivio,
Please remit payment for the supplemental clerk record prepared for the cause no DC-16-05606 styled: Greg Fox, et al vs
Brigetta D'Olivio.
Please see attached invoice
Gay Denise Lane
Document Production, Lead Clerk
Office of Felicia Pitre
Dallas County District Clerk
600 Commerce St. Suite 145
Dallas Texas 75202
214-653-6549
gdlane@dallascounty.org
~ dc-16-05606clersk record payment i voice.pdf
429K
1/1
FELICIA PITRE
ALLAS COUNTY DISTRICT CLERK
600 Commerce Street, Suite 101
Dallas, Texas 75202-4604
IN ACCOUNT WITH
DATE: February 25, 2019
BRIGETTA D'OLIVIO
3800 PEBBLECREEK CT
PLANO TX 75023
INTERNAL REVENUE SERVICE
IDENTIFICATION No.: XX-XXXXXXX
Cause No. DC-16-05606
Style of Case
GREG FOXet al
vs.
BRIGETTA D'OLIVIO
Pages: 993
Supplemental Clerk's Reco d Fee- $993.00
Transcript Fee- $ 25.00
Attorney Copy Fee- N/A $ 0.00
Total Fee- $1018.00
Supplemental Clerk's Rec d will be delivered to the Court of Appeals upon payment.
Please forward payment with invoice in the next 3 business days.
Please return a copy of this tatement with remittance.
Thank you.
GAY LANE
Cc:
Lisa Matz
Clerk of the Court, Court of ppeals
Fifth District of Texas at Dall s
George L. Allen Sr. Courts B ilding
600 Commerce Street, Suite 2 0
Dallas, Texas 75202
EXHIBIT 33
69
BRIGETTA D'OLIVIO
3 00 PEBBLECREEK CT., # 120
PLANO, TX, 75023
214-733-7204
MARCH 4, 2019
5thCourt of Appeals
c/o Chief Clerk, Claudia
600 Commerce St, Suite
Dallas, TX 75202
Re: NO. 05-18-00868
Dear Ms. McCoy:
Appellant Pro Se, Brigett D'Olivio, is filing her 3rd Amended Motion To Extend
Time To File Appellant's Amended Brief. Said Amended Brief was due on March
7, 2019. Appellant is req esting an extension of time to file her Amended Brief to
March 28, 2019.
Appellant has not been se ed Appellees' "Objection To Appellant's Motion To
Extend Tim Ti File Appel ant's Amended Brief' dated February 27, 2019, and nor
has she been served Appe lees' "Amended Objection To Appellant's Motion To
Extend Tim To File Appe ant's Amended Brief', dated March 1, 2019.
The reasons Appellant is tling this 3rd Amended Motion to Extend Time To File
Appellant's Amended Bri f include, but are not limited to the following:
1. There are thirt -ei t 38 records that have been requested from the Court
Clerk since as far b ck as December 31, 2018, which have not been sent up
to the Court of App als.
2. There are at least si (6) records that had been previously filed with the 191 st
District Court, and hich have also been requested from the court clerk that
are missing and/or ave been removed from the Court Portal without a Court
Order.
1
3. The Court Clerk, Felicia Pitre, and Deputy Court Clerk, Ms. Canejo, have
been unresponsiv to Appellant's multiple requests for Invoices, corrections
to the clerk's rec rd and improper, untiled invoices, and inquiries as to what
requested records have been sent up to the Court of Appeals. Since
Appellant has fil d a letter addressed to Ms. Pitre with the 191 st District
Court, the court p rtal references to Appellant's supplemental requests for
clerk's records ha e been changed.
4. There are also ou standing requests to the Court Reporter, Melba Wright,
which have also een ignored by Ms. Wright.
Said above-referenced~ cords are material to Appellant's Amended Brief.
That said Appellant's 3r Amended Motion To Extend Time To File Appellant's
Amended Brief is suppo ed by documented evidence.
Appellant Pro Se, Brige a D'Olivio, is requesting that Appellant's 3rd Amended
Motion To Extend Time To File Appellant's Amended Brief is reviewed and
granted prior to March , 2019.
Thank you for your time and consideration to this urgent matter.
I
~;~~LI~,:~~
Brigetta D'Olivio I
2
EXHIBIT 34
70
No. DC-16-0S606
FILED
19FEB 12 PH 3: t.O
GREG FOX IN THE DIST•~mK
OA.LLAS CO .. TEXAS
v. DALLAS COUNTY, TE~purv
BRIGETTA D'OLIVIO 191sr JUDICIAL DISTRICT
I
A~PELLANT'S CORRESPONDENCE
!
TO
COURT .PORTER for the 19t•t DISTRICT COURT
i
I 9151 District Court February 12, 2019
Court Reporter:
Wright Reporter's, LLC
c/o Melba Wright
600 Commerce St.
7th Floor
Dallas, TX
Dear Ms. Wright,
i
Appellant, D'Olivio, filed "Ap_pellant's Request For Supple111enta1 Reponer's Record" on
I
January 16, 2019@ 1:35 pm. i
!
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In said request, Appellant requ~ted the Reporter, Wright Reporter's LLC, to prepare a
I
Supplemental Reporter's Recotd, to include the following:
• Defendant's Motion Toi compel Hearing held on November 16, 2017
i
• Defendant's Motion Fot Continuance & Sanctions Hearing held on August 23, 2017
!
• Defendant's Motion TolQuash Hearing held on September 22,, 2017
I
On Friday, January 18, 2019 ~ 11:44 am, Appellant D'Olivioreceiveda voicemail from Melba
"App,lla,,J; R,q,,,,, /l
,
:
I of3
Plus
S.,,,,,.""""/ - · , /1,coni", -Jan- I~ 2019 {2 .....)
Wright of Wright Reporter's~ LLC, official court reporter for the 191 st District Court.
, I
Melba Wright stated that tw1 of the requested Hearings were previously transcribed, thank-you.
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Melba Wright further stated ~t one of the Hearing transcriptions was incorrect and that she
I
would notify the Court of A~s to let them know and how to proceed.
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To date, Appellant D'Olivio ~as not heard from nor received any correspondence nor copies, if
any, regarding her notifying te I
Court of Appeals.
Appellant is requesting the ftjllowing to take place immediately:
i
1. Forward to Appellant ID'Olivio, the correspondence filed, with file stamp and date
I
!
attached, with the Co1lrt of Appeals regarding the incorrect transcription of the
Hearing(s ).
2. Forward to Appellant P'Olivio, the response, if any, from the Court of Appeals regarding
your correspondence i~d.icating that there needs to be a correction to the transcripts.
I
3. Forward to Appellant ~'Olivio, the correction of the record to reflect that reflects the
corrections, any and 1· I
to the transcript.
4. Forward to Appellant l)'Olivio, any and all corrections to Appellant D'Olivio
5. immediately.
I
Pl~ find attached the folIO\rng:
1. Appellant's Request F~r Supplemental Reporter's Record dated January 16, 2019, file
I
stamped January 16, 2919.
Sincerely,
cc: Court of Appeals
CERTIFICATE OF SERVICE
On this day, February 12l 2019, a copy of the above document was served via Certified Mail
I
(7018 1830 0000 3897 1~68) service on the following attorney of record:
I
David M. Kleiman 1
Vincent Serafino Geary Waddell Jenevein, P.C.
1601 Elm Street, Suite 4100
I
Dallas, TX 75201 :
I
THIS SfACE LEFT INTENTIONALLY BLANK
!
3 of3
Plus
"Appel/an/ 's Req est For Supplemental Reporter's RHcord", dated January 16, 2019 (2 pages)
f
FILrr,1c-16-os606
,.r
Greg Fox 19 JAN 16 Pl\ ,,~i 1n the District Court t '11
v. , FEL1CIA Pl~TURE., Dallas County Texas
1 OJSTRICT C I'
Brigette D'Olivio DALLAS CO., AS
!
A(r,£-Lb*ff1 '$ UC[
I IIR"FOR SUPPLEMENIAL
REPQBDB'S RECQBD
I
i
TO MELBA WRlfHT, THE OFFICIAL COURT REPORTER:
Appellant, Brige D'Olivio, files this request for preparation of the reporter's
rerord for appeal f the above case. Spccifica\ty, Appellant request ( l) Defendant's
Motion~ I~~ November 16, 2017 (2) Deli:ndaot's Motion fut
Cantin eh g4b'B'Kugust 23, 20 J7; and, (3) Defendant's Motion to Quash
r 22, 2017. The undersigned will pay the required deposit
been determined by the court reporter.
Respectfully Submitted,
Brigetta D'Olivio, Appellant
3800 Pebblecreek Ct.
Apt 120
Plano, TX 75023
214.733.7204
CERTIFJCATE OF SERVJCE
On this day, a cop~ of the above document was served via certified mail 7016 0910 0001
ff
7703 4541 on the llowing attorneys of record:
David Kleiman II
VINCENT SE~O GEARY WADDELL JENEVEIN, P.C.
1
1601 EJm Street, Suit.e 4100
Dallas, TX 7520 -3703
1 of 2
CERTIFICATE OF SERVICE
I, Brigetta D'Olivio, Ap ellant in the above-caption case, do certify that on the
4th day of March 2019, I served David M. Kleiman, who is the attorney for
Appellees Greg Fox and aura Fox, the within "Appellant's 3rd Amended Motion
To Extend Time To File ppellant's Amended Brief'', dated March 4, 2019. Said
service was made via ce ified mail service, cc#, 7018 1830 0000 3897 5255
the last known address fo David M. Kleiman at 1601 Elm St. Suite 4100 Dallas,
TX 75201.
72
No. 05-18-00868
N THE COURT OF APPEALS
FOR HE FIFTH DISTRICT OF TEXAS
Brigetta D'Olivio
Defendant-Appellant
V.
Greg Fox and Laura Fox
Plaintiff-Appellee
On peal from the 191 st Judicial District Court
Dallas County, Texas
Tr. Ct. No. DC-16-05606
CE TIFICATE OF CONFERENCE
I, Brigetta D'Olivio, Appell tin the above-captioned Appeal, do certify that to the 4th day of
March, 2019, do affirm that a conference and/or attempt(s) of more than once but not less than
three times to conference wit counsel for Appellee's, David M. Kleiman of Vincent Serafino
Geary Waddell Jenevein PC, 601 Elm St Suite 4100, Dallas, TX 75201, in regards to,
Appellant's 3rd Amended Moti n To Extend Time To File Appellant's Amended Briefdated
March 4rd, 2019. The contact umber for attorney, David M. Kleiman is 214. 979.7400.
Brigetta D'Olivio, Appellant, Pro Se
3800 Pebblecreek Ct.
Apt.120
Plano, TX 75023
214.733.7204
bea utifu lhomesbybrigetta@gma iI.com
71