Richard Thompson, 610-436-5582, P.O. Box 463, West Chester, PA 19380
In the Twelfth Court of Appeals
1517 W. Front St., Suite 354
Tyler, Texas 75702
Tel 903 593 8471, Fax 903 593 2193
Appeal: 12-15-00226-CV
From: Cause No. 2014-0349-CCL2
Richard Thompson (heir in Estate of Wm. McGeorge) FILED INCOUT 0= AP°EALS
12t!- Co.;-. :' Appeals 3isr3
vs.
Blackberry LC (aka Bob Anderson, Esq.) fax 903 232 1881
Letter To: Barbara Duncan, Clerk, District Court, Gregg County, TX
Re: Bill of costs, 2014-0349-CCL2 ($320)
Subject: Redirection to Plaintiff/Appellee (the initiator)
Dear Ms. Duncan:
Please redirect your 5 Nov 15 Bill of Cost, EXH A, to the moving party, Plaintiff/Appellee, Bob Anderson
who generated it. I believe he will acknowledge his obligation and his need to have the record
submitted as he has already begun his defense in the Twelfth Court of Appeals. I am advising him to pay
it through a copy of this letter.
In the alternate, trial court should absorb the costs which are of its own making - there was no
cause of action against me as I had never been approached by Bob Anderson to sell my share of
property, there was no appraisal and no offer - had there been, I might have agreed - at a fair
price. As it was, the court denied my motion for dismissal for lack of cause.
Again, when I praeciped to strike an ex-parte order authorizing sale of property 5/26/15, the
Clerk ignored the relief to which I was entitled. The court held a sham trial in disregard of the
uncontested facts I properly filed and which are now the jurisdiction of Appeals Court.
Consequently, the Longview CCL2 has aided and abetted Bob Anderson in the taking of
property under the false claim it had little or no value, and did so by creating the Bill of Cost he
had threatened upon his victims. Said Bill of Cost is the extortion inherently implied in any
lawsuit - it is proof Anderson has the ways and means of carrying out a threat. (This is not a
legal right, he is acting outside the law - not merely beyond it, and you should not participate).
Your Bill of Cost does not itemize what you charge for, presumably copying pleadings ($320 /
$.10 = 3200 pages?). The docket is public, Appeals Court can view as well as r/e speculators.
The hearing was unnecessary and a travesty as the court ignored my written appearance,
nonetheless I ordered a transcript (for my expense) that was never provided.
On top of the $320 you are billing me, (I acknowledge this is a discount from the $455 you
originally quoted) I had to pay $205 just to get into Appeals Court; $525. This is the cost
Anderson threatened, and how all the heirs have been frightened away or why they abandoned
their rightful claims
Furthermore, the docket has been corrupted: no party identification is given to any pleading,
nor the topic, let alone the actual captions, EXH. B. Without proper listing of motions and
pleadings the hearing was corrupted, defendants prejudiced and appellate rights violated.
I respectfully request the record be corrected to state the actual captions submitted by the
parties and their names. Listing documents by date alone conceals the true nature of case and
covers up how property was taken without just compensation.
Please correct the docket and submit the entire file without delay - work it out with Bob
Anderson - maybe find the money in court registry - or forgive it, there was no cause against me
and the cost a fabrication to take property under color of law. There is still no appraisal and no
dispute that the County assesses taxes at twice the price forwhich Anderson took it.
Note to Bob Anderson:
I believe these are properly yours, notwithstanding the District Clerk normally bills the Appellant in a
typical case, but this is not a typical case.
You opted for a surprise public accusation and trial against me without any prior contact or
conversation whatsoever, I was not heard, you took a property for $75,000 that I valued at $507,300
conservatively, and you never produced an appraisal. You misinformed the Estate on the value of the
property, initiated a lawsuit behind my back and are by necessity a de facto moving (and indispensable)
party on appeal because your taking was the product of collusion with the Receiver and cannot be
sustained, it is null and void on its face for conflict of interest evidenced by his admitted inability to
make an independent appraisal, for "ethical reasons."
The Clerk has never mailed me copies of the docket, which I requested, and am entitled. The hearing
was absolutely unnecessary as my pleadings were more than sufficient to dismiss. You generated these
costs, not me, to prove your ability to carry-out threats of civil suit to penalize defendants.
As you have already begun defense of your taking, I am sure you will want to expedite correction and
submission of your record in Longview. Appeals court has granted you until Dec 2 to submit your
record, I have submitted mine.
Served by First Class Mail hereby certified to the three parties addressed, 11/15/15.
Verified true and correct under penalty of law.
Richard Thompson
11/15/15
cc: Bob Anderson, Plaintiff/Appellee/Defendant
V Katrina McClenny, Chief Deputy Clerk, Twelfth Court of Appeals
Addendum to my Memo of Law on Surface rights of 10/21/15:
This bill is a fruition of the tacit threat that resistance will result in a cash penalty. Billing court costs to
victims of malpractice is a common strategy in collusive malpractice. Plaintiff persuaded heirs to sell
their small shares in exchange for avoiding legal costs that would exceed his offer- having no other legal
advice than Anderson 's, they were compelled to accept his checks.
b*H
STATEMENT
BILL OF COST
BARBARA DUNCAN
DISTRICT CLERK
GREGG COUNTY
LONGVIEW, TEXAS
DATE: November 05, 2015
CAUSE NO. 2014-0349-CCL2
BLACKBERRY, LC
VS
ETHELWYNN BOWEN ET AL
RICHARD THOMPSON
P 0 BOX 463
WESTCHESTER PA 19380
++-l~l-l-t-+-l-+-l-+++++++++-H-++++ H—t—t—I—J—I—I—I—I—I—I—I—1—1—I—I—1—I—I—I—t—I—I—I—I—I—i—I—»—I—I—i—I—I—I—1—I—I-
Total for Clerk's Record on Appeal $ 320.00
PAY THIS AMOUNT $ 320.00
PLEASE SEND PAYMENT ON OR BEFORE NOVEMBER 12, 2015.
FAILURE TO DO SO WILL HINDER THE SUBMISSION OF THE CLERK'S
RECORD TO THE 12™ COURT OF APPEALS.
PLEASE RETURN COPY WITH REMITTANCE.
THANKS FOR YOUR COOPERATION,
BRITNIE MINOR
DEPUTY CLERK FOR
BARBARA DUNCAN
DISTRICT CLERK
P.O. BOX 711
LONGVIEW, TX 75606
Page 1 of 4
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REGISTER OF ACTIONS
Case No. 2014-0349-CCL2
t^tf- u
BLACKBERRY, LC VS ETHELWYNN BOWEN ET AL Case Type: Partition Suit
Date Filed: 02/18/2014
Location: County Court at Law 2
Judicial Officer: Dulweber, Vincent, DC
PARTY INFORMATION
Lead Attorneys
Defendant BOWEN, ETHELWYNN ProSe
Defendant CALLAHAN, TIMOTHY JOHN W. MOORE
Retained
903-236-3500(W)
Defendant ECKENRODE, LEE
Defendant ECKENRODE, TIMOTHY
Defendant FRANK, CHRISTINA
Defendant GAETH, BONNIE
Defendant KLIMCZACK, JOSEPH, Jr.
Defendant KLIMCZACK, ROBERTA
Defendant KOBAN, LUCY
Defendant Roling, TONY
Defendant TAYLOR, ELLEN
Defendant THE UNKNOWN HEIRS OF ANY OF THE JOHN W. MOORE
ABOVE NAMED DEFENDANTS WHO ARE Retained
DECEASED 903-236-3500(W)
Defendant THE UNKNOWN HEIRS OF JOHN WILLIAM JOHN W. MOORE
SHOEMAKER Retained
903-236-3500(W)
Defendant THE UNKNOWN HEIRS OF MARY CLARK JOHN W. MOORE
MCGEORGE Retained
903-236-3500(W)
Defendant THE UNKNOWN HEIRS OF WILLIAM M. JOHN W. MOORE
MCGEORGE, JR Retained
903-236-3500(W)
Defendant THOMPSON, RICHARD ProSe
Defendant YOCOM, THOMAS
Plaintiff BLACKBERRY, L C Bob Anderson
Retained
903-232-1880(W)
Events & Orders of the court
http://beta.co.gregg.tx.us/OdysseyPA/CaseDetail.aspx?CaseID=1444713 11/16/2015
Page 2 of4
DISPOSITIONS
05/19/2014 Dismissed (Judicial Officer: Dulweber, Vincent, DC)
PartyO
OTHER EVENTS AND HEARINGS
02/18/2014 Plaintiffs Original Petition (OCA)
02/24/2014 Citation By Certified Mail
BOWEN, ETHELWYNN Served 02/27/2014
Response Received 03/10/2014
Returned 03/03/2014
YOCOM,THOMAS Unserved
TAYLOR, ELLEN Served 02/27/2014
Response Due 03/24/2014
Returned 03/03/2014
THOMPSON, RICHARD Returned Unserved 06/09/2014
Returned 06/09/2014
ECKENRODE, LEE Served 03/01/2014
Response Due 03/24/2014
Returned 03/04/2014
ECKENRODE, TIMOTHY Served 03/07/2014
Response Due 03/31/2014
Returned 06/05/2014
GAETH, BONNIE Served 02/26/2014
Response Due 03/24/2014
Returned 03/13/2014
KOBAN, LUCY Served 02/27/2014
Response Due 03/24/2014
Returned 03/03/2014
FRANK, CHRISTINA Served 02/27/2014
Response Due 03/24/2014
Returned 03/03/2014
KLIMCZACK, JOSEPH, Jr. Served 03/14/2014
Response Due 04/07/2014
Returned 03/17/2014
KLIMCZACK, ROBERT A Served 02/27/2014
Response Due 03/24/2014
Returned 03/03/2014
03/03/2014 Citation Return Registered Mail
03/03/2014 Citation Return Registered Mail
03/03/2014 Citation Return Registered Mail
03/03/2014 Citation Return Registered Mail
03/03/2014 Citation Return Registered Mail
03/04/2014 Citation Return Registered Mail
03/10/2014 Defendant Original Answer
03/13/2014 Citation Return Registered Mail
03/17/2014 Citation Return Registered Mail
04/17/2014 Citation By Certified Mail
YOCOM, THOMAS Served 05/26/2014
Response Due 06/16/2014
Returned 06/04/2014
04/17/2014 Return Of Service
04/23/2014 Motion To Dismiss
04/24/2014 Notice
04/24/2014 Litigation Control Order
05/14/2014 Motion To Dismiss
05/14/2014 Motion
05/14/2014 Letter
05/19/2014 Order
06/04/2014 Motion for Alternate Service
06/04/2014 Letter
06/05/2014 Citation Return Registered Mail
06/05/2014 Order Substitute Service
06/05/2014 Citation Return Registered Mail
06/09/2014 Citation Return Effort Registered Mail
06/11/2014 Reply
06/19/2014 Affidavit
06/19/2014 Letter
06/23/2014 Order
06/24/2014 Citation
06/25/2014 Citation Publication
CALLAHAN, TIMOTHY Returned Unserved 07/17/2014
Returned 07/17/2014
06/25/2014 Letter
07/03/2014 Waiver
07/17/2014 Citation Publication
CALLAHAN, TIMOTHY Served 09/08/2014
Response Due 10/27/2014
THE UNKNOWN HEIRS OF JOHN WILLIAM
Unserved
SHOEMAKER
THE UNKNOWN HEIRS OF MARY CLARK
Unserved
MCGEORGE
Unserved
http://beta.co.gregg.tx.us/OdysseyPA/CaseDetail.aspx?CaseID=1444713 11/16/2015
Page 3 of 4
THE UNKNOWN HEIRS OF ANY OF THE ABOVE
NAMED DEFENDANTS WHO ARE DECEASED
THE UNKNOWN HEIRS OF WILLIAM M.
Unserved
MCGEORGE, JR
07/17/2014 Return Of Service
09/08/2014 Citation by Publication Returned Sheriff
09/09/2014 Order Appointing Attorney Ad Litem
09/09/2014 Letter
09/11/2014 Designation of Expert Witness
10/07/2014 Amended Petition
10/07/2014 Notice Of Hearing
10/17/2014 Letter
10/22/2014 Supplemental Pleading
10/23/2014 Non-Jury Trial (10:00 AM) 0
10/23/2014 Supplemental Pleading
10/23/2014 Affidavit
10/23/2014 Affidavit
10/24/2014 Exhibit
10/24/2014 Statement Of Evidence
11/12/2014 Letter
11/24/2014 Order Of Sale
11/26/2014 Motion
01/08/2015 CANCELED Pre Trial (3:00 PM) 0
Other
01/12/2015 CANCELED Jury Trial (9:00 AM) 0
Other
01/15/2015 Motion
01/26/2015 Order
01/26/2015 Objection
02/02/2015 Objection
02/24/2015 Motion
03/23/2015 Report
03/23/2015 Proposed Order
03/26/2015 Amended Response
04/13/2015 Notice Of Hearing
04/24/2015 Application For Sale Of Real Property (11:00 AM) 0
04/24/2015 Order
05/26/2015 Motion To Strike
06/03/2015 Response
06/05/2015 Order Denying New Trial
06/09/2015 Motion To Strike
07/31/2015 Motion
08/03/2015 Docket Sheet
08/03/2015 Order
08/05/2015 Receipt
08/06/2015 Receipt
08/07/2015 Receipt
08/10/2015 Receipt
08/14/2015 Notice of Appeal
08/17/2015 Receipt
08/18/2015 Letter
09/15/2015 Letter
09/15/2015 Appeal
09/16/2015 Letter
09/16/2015 Letter
09/29/2015 Letter
10/02/2015 Letter
10/09/2015 Letter
11/04/2015 Letter
11/05/2015 Bill Of Costs
Financial Information
Applicant READER, MIKE
Total Financial Assessment 10.00
Total Payments and Credits 10.00
Balance Due as of 11/16/2015 0.00
01/26/2015 Transaction Assessment 2.00
01/26/2015 e-Filing Receipt # 001120-2015-DC READER, MIKE (2.00)
04/13/2015 Transaction Assessment 2.00
04/13/2015 e-Filing Receipt* 005035-2015-DC READER, MIKE (2.00)
04/24/2015 Transaction Assessment 2.00
04/24/2015 e-Filing Receipt # 005662-2015-DC READER, MIKE (2.00)
06/05/2015 Transaction Assessment 2.00
06/05/2015 e-Filing Receipt # 007848-2015-DC READER, MIKE (2.00)
08/03/2015 Transaction Assessment 2.00
08/03/2015 e-Filing Receipt* 010535-2015-DC READER, MIKE (2.00)
http://beta.co.gregg.tx.us/OdysseyPA/CaseDetail.aspx?CaseID=1444713 11/16/2015
Page 4 of4
Plaintiff BLACKBERRY, L C
Total Financial Assessment 1,041.00
Total Payments and Credits 1,041.00
Balance Due as of 11/16/2015 0.00
02/18/2014 Transaction Assessment 995.00
02/18/2014 Payment Receipt # 001336-2014-DC Anderson, Bob (995.00)
06/04/2014 Transaction Assessment 2.00
06/04/2014 e-Filing Receipt # 004805-2014-DC BLACKBERRY, L C (2.00)
06/19/2014 Transaction Assessment 2.00
06/19/2014 e-Filing Receipt # 005366-2014-DC BLACKBERRY, L C (2.00)
06/25/2014 Transaction Assessment 10.00
06/25/2014 e-Filing Receipt* 005514-2014-DC BLACKBERRY, L C (10.00)
06/30/2014 Transaction Assessment 22.00
06/30/2014 e-Filing Receipt # 005644-2014-DC BLACKBERRY, L C (22.00)
07/03/2014 Transaction Assessment 2.00
07/03/2014 e-Filing Receipt* 005816-2014-DC BLACKBERRY, L C (2.00)
09/11/2014 Transaction Assessment 2.00
09/11/2014 e-Filing Receipt # 007972-2014-DC BLACKBERRY, L C (2.00)
10/07/2014 Transaction Assessment 2.00
10/07/2014 e-Filing Receipt # 008872-2014-DC BLACKBERRY, L C (2.00)
10/07/2014 Transaction Assessment 2.00
10/07/2014 e-Filing Receipt # 008873-2014-DC BLACKBERRY, L C (2.00)
03/27/2015 Transaction Assessment 2.00
03/27/2015 e-Filing Receipt # 004246-2015-DC BLACKBERRY, L C (2.00)
http://beta.co.gregg.tx.us/OdysseyPA/CaseDetail.aspx?CaseID=1444713 11/16/2015