4:03-CV-02395 Judge Lynn Hughes



Jurisdiction This court has continued jurisdiction pursuant to the Federal Rule of Civil procedure to take judicial notice of facts as they relate to matters before the court i.e. agent Edwin Paul Wilson and Dr. Jacques Jaikran and other matters as outlined herein. Parties 1. 2. Dr. Jaikaran is the plaintiff. U.S. Bank NA ETAL are defendants.

The above reference cause of action and this ADVISORY has been filed by the undersigned pro se due to the outcries of Dr. Shirley Pigott M.D. Dr. Shirley Pigott M.D. is a victim of a sham peer review, a whistle blower and similar to Carol Ann Davis a RICO victim of a vast government conspiracy {Dr. Pigott formally represented by Attorney Jeffery C. Grass but now represented by attorney Jerry S. Payne} as it relates to a false arrest in Wharton County by Texas DPS troopers engaged in an illegal a mission to arrest Dr. Pigott. Dr. Pigott has been vocal and outspoken about violations of the Racketeer Influenced and Corruption Act [RICO] of the Texas Medical Board and Texas Department of Public Safety i.e. interagency corruption. Officer Andrew Hunzicker is Dr. Pigott expert as it relates to the illegal search and seizure of Dr. Pigott. Officer Hunzicker also knows JUDGE LYNN HUGHES IS a GREAT JUDGE- and actually he advised Carol Ann in 2003 “I wish we had Judge Hughes” but Carol Ann Davis has a GREAT JUDGE – she has Judge Ewing Werlein Jr. The undersigned herein after “Carol Ann” has assumed the responsibility for explaining court operations to RICO victims, lay persons [the public] in the Internet World Wide Web due to misrepresentations in litigation by lawyers, private lawyers, city lawyers, rural lawyers, county lawyers, state lawyers, federal lawyers, appeal lawyers due to the expert opinion of former Texas District Court Harris County Family Court Judge Charles Dean Huckabee “Lawyer are lazy, lawyers lie”. In addition to material misrepresentations in litigation, misrepresentations in the Open Records Act, Freedom of Information Act, Opens Meetings Act and even a “on-site septic facility” in the organized Hays County RICO crimes against a 67 year old female goat farmer because somebody in Hays County found somebody that they could take something away from namely Carolyn Logan are pervasive and oppressive. This Honorable Judge is unaware other RICO victims have been named in the undersigned disclosure filed with Judge Werlein and Judge Hittner and under revision pursuant to a percolating Rule 60 (b) (6) and other related motions including the “Pink Slip” motion and where the requested hearing has not been denied by Judge Werlein Jr. while he patiently waits on his plaintiff to comply and speak to him in a motion implementing a vocabulary familiar to the court – and sign her name with signature on a rule 60 (b) (6) motion and file it with the Court. After Carol Ann outlines for Judge Werlein [and Mr. Payne] the evidence that John O’Quinn has rigged the Fifth Circuit operations then plaintiff will move to vacate a verdict that was obtained on Sept. 15, 2005 by corrupt means and the “behind the scenes” activities that Judge Werlein told the lawyers he did not like—nor would he tolerate. Carol Ann strenuously objects to the United States District Judge Lynn Hughes taking a bad rap in the Internet world for rulings based on the presentations of attorney Jeffery Grass – the damage to this Courts reputation to other citizens across the United States of America are unfamiliar and do not know “Judge Hughes is the greatest judge in the whole world next to Judge Werlein” which is oppressive to plaintiff when soliciting support in the public interest to address the crimes of the Southern District of Texas lawyers and their “long arm” in Harris, Montgomery, Panola, Gregg, Hays, Travis Counties dressed up in interagency and interdivisional fraud to conceal RICO and gross lawyer misconduct, the O’Quinn Law Firm hiring of the former Houston FBI Director Don Clark as stated by the former United States

Attorney Ronald G. Woods who is CREDIBLE and unexplained in Carol Ann’s case is FBI Special Agent Al Tribble who has withheld evidence connected to 282-A- HO- 59712 connected to “Lindy” and her driver Joseph S. Stell. Genuine issues of fact regarding any material misrepresentations in this case to support a finding that attorney Jeffery C. Grass has violated Judge Hughes Orders compromising Dr. Jacques Jaikaran constitutional rights when he advised a doctor in California as it relates to court operations in JUDGE LYNN HUGHES court and JUDGE LYNN HUGHES PLAINTIFF, Dr. Jacques Jaikaren, and a proper motion specifically a writ of habeas corpus application and order “Why don’t you file a writ of habeas corpus” “Sent from my Verizon Wireless Blackberry” is information Judge Lynn Hughes needs to know – Carol Ann suggests there must be something the lawyers do not know about Judge Hughes and lawyers misconduct when hit hurts the Judge’s plaintiff . [i] (Plaintiff /defendant) Dr. Jacques Jaikaren is unfamiliar with the court vocabulary, court procedures and or the law even in his desipient NOTICE OF INTENT TO SUE [AT 318] followed by “Dear Judge Hughes: Please take notice that I have developed some health problems” a plea for help and where this most Honorable Court Judge Lynn Hughes will likely find to demonstrate its inherent power and all of its greatness to suspend Dr. Jaikaren confinement for medical treatment in a private hospital and for the reasons presentation herein. [ii] Background In 1991 Carol Ann was solicited by the Department of Justice Federal Bureau of Investigation Special Agent Ron Stern to collect criminal evidence as it relates to a “probe” and where attorney Jerry S. Payne and Judge Ewing Werlein Jr. were taken by surprise due to Carol Ann being placed so far back “in the field” to collect criminal evidence for the DOJ was injured and unable to communicate to her lawyer and HER JUDGE, Judge Ewing Werlein Jr. “ My name is Carol Ann Davis, FBI Agent Ron Stern solicited me to collect criminal evidence – Agent Stern provided a contract and issued a government tape recording device.”

Carol Ann and Harris County RICO victim Beverly F. Thompson have delivered the criminal evidence to attorney Jerry S. Payne related to government lawyer misconduct of attorney Karen Matlock Law Enforcement Division, Texas Attorney General‘s Office risked her law license and came to court on a request of “private counsel” instead of legal authority Section 44 and Section 51 of Article III of the Constitution of Texas. There is a substantial likelihood that plaintiff will prevail on the merits because plaintiff has a meritorious claim and because the conduct did in fact occur and Stefanie Orr, Ramon Viada, and Carol Ann’s attorney James “Jim” Supkis were silent when Judge Werlein asked them “ Is the video tape of Lindy Honerkamp altered? Ms. Orr’s response “NO”. [See Doran v. Salem Inn, Inc., 422 U.S. 922, 931, 95 S. Ct. 2561, 2568 (1975); U.S. v. Microsoft Corp., 147 F.3d 935, 943 (D.C. Cir. 1998);

Carol Ann intends for these lawyers to embrace the consequence for lying to HER JUDGE about Lindy Honerkamp’s testimony and their participation in a criminal chain conspiracy to deny due process. The courts have continuing jurisdiction because these events are of a “live” RICO criminal chain conspiracy and the unfolding of DOJ probe that was misdirected by attorney John M. O’Quinn and ex- trooper Charles Soechting and where a former United States Attorney Laurence D. Finder plays a role unbecoming and where ethics are overridden by the self-dealing ‘billable hour ‘ program and illegal enterprise connected to all cases of a constitutional dimension to increase the revenues of corrupt lawyers in violations of state and federal law and moreover Disciplinary Rule 1.06 and demonstrated in the Erik Ibarra v. Harris County civil rights false arrests case where John M. O’Quinn, Charles Soechting, and Lawrence D. Finder have found the federal courts to be a comfortable environment to spin harassing litigation and bootstrap the citizens of the State of Texas and Texas Attorney General come to court and cover up the violations of a constitutional dimension connected to the “CAPIAS “ client. “Total police power” corresponds with the former United States Attorney Finder and the O’Quinn Law Firm- and their ‘billable hour’ contracts with Harris County- Harris County is the target of the genesis probe and the misdirected probe where San Marcos Mercury Brad Rollins met Carol Ann‘s inquiry connected to legitimate court operations with a www.greatlawyer@live.com and he says “Little miss Carol Ann Davis rocks” and she hopes the court recognizes even though the presentation came from “behind the scenes”. Judge David Hittner referred the matter of Carol Ann Davis v John M. O’Quinn and Guy Marshall Caskey connected to Travis County 480-735 prosecution team back to Judge Ewing Werlein Jr. to re visit based in part on; The “Capias” client – because it is fabricated character comprised by tampering with government data bases, the purported “expungment” of the “Capias” client file in Travis County by O’Quinn’s Charles Soechting- because it is not expunged. The false assertion about the ‘only connection is a car wreck case’- material lie (See 1 & 2). Judge David Hittner pronounced, Mr. O’Quinn has pled his best case and it is time to arrest him and the other co-conspirators for the murder of a federal witness namely Melinda “Lindy Harrison” Honerkamp. The evidence says Mr. O’Quinn and his law firm have made material misrepresentation in litigation in more than federal court case to evade and obstruct justice because he did not know Carol Ann would secure “tape recordings” of the events in New Orleans where the great lawyer @ live .com runs the show in court from “behind the scenes”. JUDGE WERLEIN does not like it when lawyers hurt his plaintiff – and pronounced “Mr. Viada you have all the money do not hurt plaintiff”. The harm faced by Judge Werlein’s plaintiff outweighs the harm that would be sustained by the defendant Dr Jacques Jackarin if the the DOJ FBI information source did not come forward and say “ I am going to tell Judge Hughes” in the same fashion when she motions her judge – The Honorable Judge Ewing Werlein Jr. that Judge David Hitter pronouncement that John M. O’Quinn has pled his best case and everything of John M. O’Quinn’s is mine and the United States governments –-----E V E R Y T H I N G. [See Yakus v. U.S., 321 U.S. 414, 440, 64 S. Ct. 660, 675 (1944); Johnson v. California State Bd. of

Accountancy, 72 F.3d 1427, 1430 (9th Cir.1995); O’Connor’s Federal Rules, “Balance of hardship,” ch. 2-D, §2.2.3, p. 70.] The Offer of Proof delivered to Jerry S.Payne. Carol Ann respectfully request this Honorable Court to file mark this advisory and place it amongst the papers in Dr. Jaikaren case and to take notice of misunderstanding and misrepresentations in litigation not by accident but on purpose and if it pleases the court to consider a full hearing and judicial investigation / and Carol Ann ‘s citizen intervention connected to “behind the scenes “ lawyer misconduct on violations of state and federal law and protected by the State Bar of Texas, and Texas Governmental Agencies connected to self-dealing and professional misconduct of biblical proportion intergovernmental agency corruption compounded by interdivision Texas Attorney General corruption where “Carol Ann “ is the offer of proof- and former FBI Agent Ron Stern presently under a “live” subpoena. “Touhy letter” requirement has been met is near ripe for presentation of a criminal complaint and presentation nor does -- Plaintiff have funds to sustain legal counsel. Due to Carol Ann’s admiration and deep respect to this Honorable Court as it relates to agent Wilson’s case “stuck her nose into” assisting JUDGE LYNN HUGHES and learned attorney Jeffery Grass when questioned about a Writ of Habeas Corpus for Dr. Jaikaren by Dr. Rene Umalia (1-530-917-1156) was advised “Why don’t you file a writ of habeas corpus” “Sent from my Verizon Wireless Blackberry”. This citizens advisory is intended that Judge Hughes will learn and find “Why don’t you file a writ of habeas corpus” “Sent from my Verizon Wireless Blackberry” unacceptable and clearly lawyer misconduct—“Why don’t you file a writ of habeas corpus” “Sent from my Verizon Wireless Blackberry” is not pursuant to the rules, regulations and law. Dr. Jaikarn unaware of the fraud on the Court, and the Court unaware of the fraud on Plaintiff is contributory to the protracted and strained court operations relations between the Court and its plaintiff and moreover disrupts court operations and a violation of the Rules of Professional Conduct and notwithstanding Judge Hughes can no more get off the bench and practice for his plaintiff than Judge Werlein can. Requested is a trial on the issues in this citizen’s advisory application and, after the hearing issue a permanent injunction against anyone who make material misrepresentations in litigation TO JUDGE LYNN HUGHES or to his plaintiff Dr. Jaikaren is punished severally. H. Prayer For these reasons, Carol Ann Davis respectfully asks that the court do the following: · May God protect and save Judge Lynn Hughes and the other members of the court from the public’s general misunderstanding about this case where Dr. Jaikaren is plaintiff and may God shed his light on this court’s adoption of former Harris County Judge Charles Dean Huckabee, also a great judge for the State of Texas for honesty and integrity being forthright and honest in his vast professional experience that “Lawyer are lazy, lawyers lie …”

· Acknowledge the Department of Justice and FBI Special Agent Ron Stern contract that bears the name of Carol Ann Davis to collect criminal evidence as it relates to a Department of Justice “probe” that was misdirected by the former United States Attorney Lawrence Finder et al and as it relates to the evidence Lindy collected that “I believe” is connected to Agent Edwin Paul Wilson and his claims of actual innocence. · Disqualify attorney Jeffery C. Grass and other related relief this Court deems reasonable including an Order to sever the case of attorney Grass and if the court so Orders Carol Ann to make a presentation to this Court connected to lawyer misconduct. · Grant any other relief this Court deems appropriate and recognize Carol Ann has filed this advisory in good faith and her intention is to please the Court.

Respectfully submitted,

Carol Ann Davis pro se 25311 Sugar Valley Spring, Texas 77373 281-350-2943 713-454-3506 CERTIFICATE OF CONFERENCE I certify that I attempted to confer with Kate Hill at 713-250-5036. August 4, 2009 9:53 AM Kate Hill returned conference call advising “Not in any way involved in this case” and that it is another Kate Hill. Attorney General Karen Matlock is prohibited from objecting or doing anything except securing private legal counsel. Frank Sanders for Harris County stated in conference January 14, 2009 he was “Definitely opposed” to Plaintiff would remind this court to visit Judge Kenneth Hoyt Order signed the 29th day of April, 2009, as it relates to Harris County attorney Frank Sanders, and his “close ties” to Mr. John M. O’Quinn Charles Soechting, and Mr. Lawrence D. Finder. Frank Sanders objects in spite of his knowledge Judge Rynd who found on March 6, 2008 as it relates to the denial of necessities pursuant to Texas Family code Section § 2.501 and § 2.502 “Judge Squiers fault” . Judge Hoyt found in the Ibarra matter “they are impervious to the truth. “ I certify that on August 4, 2009, I conferred with attorney Stephen A. Leyh , and he does not he opposes Carol Ann telling Judge Hughes anything as described in this advisory.

I certify that I attempted to confer with {name of opposing counsel} by {specify manner, i.e., telephone or letter, number of attempts, and dates attempted}, but counsel has not responded to my attempts. Accordingly, I cannot represent to the court whether counsel opposes or does not oppose {name of motion}. I certify that I was unable to confer with attorney Jeffery C. Grass about the merits of this advisory motion before filing because the undersigned discovered that there was not enough time to contact opposing counsel due to emergency basis of advisory in addition he was advised by his former client accidently on purpose that his practice did not comply with the Rules of Professional Conduct and that Dr. Pigott would conduct an independent investigation into the same once she learned the lessons in agent Edwin Paul Wilson’s case , adopted the expert opinion of former Harris County District Judge Charles Dean Huckabee “Lawyers are lazy , lawyers lie” and retain attorney Jerry S. Payne.

_________________________ CAROL ANN DAVIS

CERTIFICATE OF SERVICE COPIES SENT TO: Filed with Judge Werlein The “CAPIAS” client “Mr. Davis” Attorneys John M. O’Quinn and Charles Soechting Certified mail

Delivery #_____________

_____________ The Lyric Center Tel. 713-223-1000 Fax 713-223-8160 Fax transfer #_____________ Personal delivery _____________

Charles Dean Huckabee Plaintiff’s expert represented by Jerry Payne [Plaintiff’s former lawyer] Memorial Drive Piney Point, Texas Texas Attorney General Karen Matlock

Certified mail #_____________

Delivery P.O. Capitol 11505 _____________

[i] Did attorney Jeffery C. Grass try to conceal from Judge Hughes [and plaintiff] lawyer misconduct as it relates to Dr. Rene Umali “Why don’t you file a writ of habeas corpus “Sent from my Verizon Wireless BlackBerry. Moreover, is this sort of lawyer misconduct becoming a habit for attorney Jeffery C. Grass? Among the questions District Judge Ewing Werlein Jr will be asked to consider in a hearing for Plaintiff Carol Ann Davis, sentenced to $ 40,000 in fines and probation in 1999 for allegedly attempting to operator an “Unlicensed Investigations” company and allegedly took money from Carla Roberson Cummings [a false crime victim] absent the knowledge of attorney Betty Homminga Yarter and the DISCOVERY THAT CHERYL YATES WEBB WAS A LICENSED UNDERCOVER PRIVATE INVESTIGATOR AND WHERE FEDERAL COURT REPORTER CHER BARRON engaged in court reporter misconduct and also surprised about Carol Ann coming out from being “in the field”. The alleged conduct took place in Panola and Gregg Counties in East Texas in the summer months of 1995 where troopers Barry Washington, Ronnie Porter, Sgt. Swen Spjut were retained by attorney Betty Homminga Yarter all of which testified at the original 480-735 etal trial- RETALIATION for my testimony in the BRAZOS COUNTY trial where Lindy was a Plaintiff and sued ‘Dr. John Vernon Kinross Wright- that ROA diskette, notes and cassettes from December 1996 were never reduced to writing but is hidden in a Catholic Convent with ‘Sister’ Judge Carolyn Ruffino. For the crimes I told DPS Special Crimes Randy Haltum about January 1997 connected the Harris County Courts and ‘judge’ James Douglas Squire and the crimes he committed against the children of the State of Texas as to relate to my children the Thompson children and other children that were subjected to Squier’s self dealing and judicial misconduct. There are many victims of lawyer misconduct in the SDTX of biblical proportion and Carol Ann directs the federal court to examine the case of BRENT SALTER and AL JOHNSON and the others similarly situated –RICO victims of lawyer misconduct. According to documents filed in federal court Carol Ann Davis alleges Travis County prosecutors, DPS Special Crimes, Texas Board of Private Investigators failed to disclose to Carol Ann Davis original trial team the fact that the state's key witness, “Mr. Davis” and Carol Ann Davis “co-defendant’ who actually was a fictitious character comprised by an ex-trooper “command decision” to tamper with governmental data bases, specifically TCIC,NCIC, and TLETS to create a fake identity of “Mr. Davis” with commingling identifiers from three different black men ( citizens) who are unaware that their private information was used in a “vast government conspiracy’ to deny Due Process, and where the same has led to the murder of a federal witness, and where you have omitted material statements of witness that are complicit in the crime . In Travis County Sgt. James Douglas Wrentz exaggerated his training and agreed with Travis County about how to lie about his professional experience while testifying that he had evidence of “Unlicensed Investigations” on Carol Ann Davis and “Mr. Davis” that proved to him they were engaged ‘Unlicensed Investigations”. Genuine criminal evidence and a basis in fact and law to prosecute plaintiff for “Unlicensed Investigations” with the Travis County D.A.'s Office, [attorney prosecutor John Lipscomb however, has argued that he had a lot of problems with the first Grand Jury – Harris County who found May 27, 1997 “All the troopers, attorneys for the Private Securities violation are accomplices as a matter of law”. Mr. Lipscomb argues he and the others in the prosecution team did nothing improper or illegal and that the collection of false evidence about “FOX INVESTIGATIONS” from a convicted DPS communications operator [ Janie Braune married To Fred Braune Harris Co. Special Crimes investigator ] in an effort to advance Ms. Braune her and the collection of a private investigator statement under

indictment for 35 pounds of marijuana in Panola County that contained details about Carol Ann Davis background – documents the prosecution hide a trial and by attorney Charles Soechting of the O’Quinn Law Firm and were later discovered by Lindy Honerkamp was completely justified. Central to the argument that Travis County and its prosecution team 48-0735 acted inappropriately – that they either knowingly encouraged Janie Braune and Peggy Sockwell to lie after a Harris County Grand Jury and to present false evidence yet key to the prosecution of Carol Ann Davis and the ‘successful’ conviction that Texas Attorney General argued in the Stidman case. In the case Carol Ann Davis intends Judge Werlein to recognize that the state had "acted willfully in failing to disclose the statements" to Carol Ann Davis, and in the case of “Unlicensed Investigations” to conclude the evidence the state withheld was material – and had it been disclosed and used effectively, it would have placed the State's punishment case in such a different light as to undermine the confidence in the verdict and give rise to a reasonable probability of a different outcome and that the case should have never been prosecuted after a Harris County Grand Jury found “All the trooper, attorneys and witne4ss for the Private Security Violations are accomplices as a matter of law" written by HC “Special Crimes Prosecutor John Brook. [ii] Carol Ann Davis has taken on numerous roles in Texas litigation voluntarily and involuntarily and herein referred to as “Carol Ann” A] Carol Ann commenced her career in the courts as Harris County Courts as a ‘forgery’ defendant because Cypress Bank ‘s Billy Wayne Chester in 1981 was engaged in a criminal episode and Harris County Det. Walter Johnson found someone he could take something from- Carol Ann Davis money and liberty for self-dealing – case dismissed by Judge Pat Lykos. Money collected by lawyers paid by Carol Ann not refunded damages to Carol Ann on a un- sustainable charge to boost an actually innocent citizen. B] As a result of Harris County boosting of Carol Ann it destroyed her marriage which led to her induction into the Harris County Family Courts in 1984-18422. Due to crimes committed against the children in case 84-18422, January 1997 Carol Ann defending her posture in a ‘Special Crimes’ investigation based on a an anonymous letter deposited into the U.S. Mail by Cheryl Yates Webb who contended she was a ‘paralegal’ to conceal various state and federal crimes of Judge James Douglas Squier and other related criminal evidence “Lindy” presented to the State Bara of Texas reporting the same among other reasons Carol Ann became a ‘Defendant’ connected to Travis County 480-735 prosecution of “unlicensed investigations” but oppressed with a ‘co-defendant ‘that is actually a “fanciful” identity comprised by the “command decisions” of The O‘Quinn Law Firm assessing and tampering with TCIC/NCIC TLETS data bases not pursuant to the Texas Government Code, Subchapter “F”. Plaintiff was arrested 2/18/2001, 5/29/2001 and 7/9/2001 and over 35 days in two Texas county jails and extradited to Travis County started in her living room because she was in possession of criminal evidence [not wielding a canister of mace] on the State of Texas and State Bar officials under subpoena to attend a schedule hearing to re- sentence Feb. 20 2001 on the illegal dissemination of identifiers to RETALIATE.

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