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j.\ -'\\ _ f) \l D - ~ LCounty Court at Law
In re Aransas County, Texas
Bill of Review
TO THE HONORABLE COURT: Jennifer Flores-Lamb and David Sibley respectfully file this Bill of Review. Facts 1. Judge Adams made a series of corrupt orders on October 11, 2010. 2. These Orders include the following: 1) He sanctioned Jennifer Flores-Lamb and/or her attorney for believing her own child. She was entitled to believe her child, and there was no reason to not believe her child. Judge Adams dishonestly stated that the child's statements were not investigated. The statements were investigated. Judge Adams created nonexistent law stating that children are "fantasizers" and the statements of children amount to "no evidence." The child's statements weI€: corroborated in several ways and were believable. 2) He sanctioned Jennifer Flores-Lamb for subpoenaing witnesses to a very important event. She was entitled to do this. Judge Adams was corruptly attempting to conceal relevant evidence. 3) He sanctioned Jennifer Flores-Lamb for subpoenaing a document. She was entitled to subpoena the document. The document was a book written by William Dudley. Two witnesses testified the book existed and a courtroom observer said it was "common knowledge." 4) He quashed an extremely relevant subpoena, and when the evidence was obtained from an alternative source he held the evidence was irrelevant. Specifically, he concealed the fact that a primary care giver was homicidal, suicidal, hallucinatory, psychotic, heavily drugged, etc. This primary care giver had attempted suicide and been hospitalized for mental problems.
5} He made various false statements of facts in his orders designed to disparage Jennifer Flores-Lamb and her attorney falsely. 3. The big picture is that Judge Adams corrupted the legal proceeding. He did this through fraudulent corrupt orders. No reasonable lawyer would believe that it is
frivolous for a parent to believe her child; that there was no evidence of the crime committed by William Dudley, Lanette Joubert, and affiliates; that all children are fantasizers; that is sanctionable to subpoena witnesses to a very important evident, that is sanctionable to subpoena professional writings of a professional witness. Crimes 4. The child said that William Dudley, Lanette Joubert, and others met with the child at a
restaurant and told the child to lie about his mother. Specifically, they told the child to say that his mother "touched" him (with a sinister twist). Further, the child said that he was told to lie and say that he saw his mother and her lawyer in bed together. These lawyers had been making that false accusation for months and had repeatedly tried to deny the mother legal representation based on that false accusation (several motions to disqualify were denied). 5. The child had no known v'./ayto known way to know about that false accusation other than through the crime at issue. The child probably did not know the import of what he was asked to say (the child was innocent not knowing the implication from being in bed together). These lawyers tried to involve a child in their corruption designed to deny the child's mother an attorney. This strongly corroborates the truthfulness of what the child said. 6. Two waiters testified that the father and the child were at the restaurant when the child said and even at the table the child said. The waiters testified that additional adults in suits and ties were there (although they could not identify the additional adults). The father had denied being at the restaurant at any relevant time. Everybody necessary to commence criminal charges were present including a police officer and a judge. The GPS on the police officer's car was turned off at the relevant time (the car was not just parked somewhere because the car jumped according to GPS a SUbstantial difference while GPS turned off). 7. This conduct described by the child obviously if true amounts to criminality in multiples of ways including soliciting perjury, tampering with witnesses, obstruction of justice, etc. This was a dishonest and criminal fraud designed to corrupt the court proceeding in progress. Judge Adams' Orders had no basis in law or fact. He was corrupt. 8. These lawyers have a long history of making false sexual abuse allegations. They made at least 14 against a man named Stanley Rains. They denied him access to his child
s.. pbstantially for over a decade based on a long series of frauds and evasions. Stanley Rains was arrested based on bogus criminal charges (he was acquitted and dismissed). 9. There are others. In one instance, Lanette Joubert accused a Craig D of being a child molester because his child's diaper had poop in it.. Supposedly, the child said that her daddy had "tickled" the poop or something absurd like that. There are numerous similar examples .. Lanette Joubert is a close affiliate of William Dudley. It is OK for them to believe children even children in diapers yet if a child reveals one of their frauds the child is a fantasizer. 10. The State Bar of Texas is a co conspirator in these frauds. It has ignored numerous complaints of extreme lack of ethics by these lawyers. It doesn't even investigate. It ignores complaints as serious as fabrication of evidence. It doesn't care that these lawyers are frauds and criminals. In has more than once done more than ignored the frauds and crimes of these attorneys - it acts as henchmen to attack anyone who complaints about their frauds and crimes. In one instance, James Ehler who is in charge of ethics for the region personally observed William Dudley lie to a tribunal. He did nothing to William Dudley. He was operating the video camera at the proceeding. He was clearly smirking and grinning. He obviously
thought it was funning that William Dudley had lied to the tribunal and got caught. 11. In the proceeding at issue, the State Bar essentially became part of the litigation. It accepted the fraudulent and corrupt positions of Lanette Joubert and William Dudley (no reasonable lawyer would accept these obviously corrupt and fraudulent positions). It sent
letters designed disturb and coerce Jennifer Flores-Lamb's attorney during the course of the litigation. It tried to coerce her lawyer into not believing her. It actively sought to corrupt the attorney client relationship by inf!!Ylidating her lawyer into not believing her (or her child). The State Bar made itself a corrupt and fraudulent part of the litigation. The regional office of the State Bar has long been part of the local family law fraud and corruption. 12. William Dudley and Lanette Joubert work through intimidation. They file a motion to -sanction with nearly every pleading. They obvious allude to special privilege with the bar, and this is one truthful thing they say. They obviously do have special privilege. Local lawyers know that if they actually represent their client, the bar is very likely to attack them. The bar takes fraudulent and corrupt positions of law and fact; it also ignores corruption and frauds. 13. The bar in a "pile on" case supports a corrupt lawyer named Larry Adams who stole a child through blatant dishonesty, corruption, and fraud all documented in writing. The bar has C! pattern of attacking anyone who stands up to these corrupt dishonest lawyers and thereby supporting their fraud and corruption. A lawyer cannot stand up to these lawyers yet these
lawyers are allowed free immunity to slander, lie, defraud, abuse, and even assault people. Most pertinent here, they are allowed to engage in obvious blatant corruption. Jennifer FloresLamb was entitled to an attorney who actually advocated her interests and did not submit to the corrupt lawyers (William Dudley and Lanette Joubert who were abusing her). By the way, the reason another key lawyer involved is not mentioned is a settlement is being honored. 15. The Bar took blatantly untrue and frivolous positions obviously conspiring with the fraudulent corrupt attorneys at issue and the fraudulent corrupt judge at issue. 16. At one point in the triai, the homicidal, psychotic woman through a big fit when she didn't like a question asked her. During the ensuing break, the homicidal psychotic woman get in Jennifer Flores-Lamb's face (her attorney was out of the courtroom at the time). Two "ladies" believed to be from the bar approached the bailiff and said something to him. When her lawyer returned into the courtroom, the bailiff threatened the lawyer and when the judge returned the judge threatened the law. It is believed the bar ladies said falsehoods to the bailiff. The bar actively involved itself in the corrupt lawless proceeding having no basis in law whatsoever. The lawyer was no allowed to address relevant matters or even diffuse the commotion that the homicidal psychotic had caused because the judge lawlessly threatened him with jail. Bill of Review .,; 17. A Bill of Review is an equitable remedy to address the situation where a litigant
through no fault of his own was denied a meritorious cause of action or defense through not fault of his or her own due to fraud. There was blatant fraud with the judgment at issue. 18. Fraud vitiates every transaction tainted by it even solemn judgments of courts of record. The Judge who rendered the corrupt judgment at issue was operating under extreme conflict of interest. Specifically, this judge had been planning to change custody for years. He was waiting for the right time. He hired William Dudley by his own testimony around this time. Several substantial controversies were occurring with his ex wife around this time. The controversies were so substantial that the police were involved and the judge was allegedly having himself drug tested (he could have easily used a false hair sample). 19. William Dudley was the attorney for Judge William Adams. William Dudley was accused of wrongdoing by the child. In other words, the child accused Judge Adams' own attorney of wrongdoing. Obviously, William Dudley had an interest in being exonerated.
Further, he had an interest in receiving money. Judge Adams exonerated William Dudley with a corrupt order (Judge William Adams dishonestly stated there was no evidence of the wrongdoing and in fact sanctioned the parent and/or lawyer asserting the wrong doing).
Further, Judge Adams gave his own attorney judgment for money. Judge Adams also gave Lanette Joubert money (a close affiliate of William Dudley). The Sanctions Orders were corrupt, fraudulent and lawless on their face. Further, the Order stating it was irrelevant that a C'hild care provider was homicidal, suicidal, psychotic, etc. was corrupt and lawless on its face. Further, the denial of obviously relevant discovery was corrupt and lawless on its face. 20. These sanctions were designed to corruptly destroy Jennifer Flores-Lamb's attorney or cause him to not fully represent her. They were designed to corruptly disparage her and her attorney. They were designed to paint her in false light and disrupt litigation in progress. The sanctions did not have even an arguably basis in fact and were obviously corrupt. 20. William Dudley committed fraud by not disclosing his relationship with Judge Adams as his attorney. Judge William Adams committed fraud by not disclosing that William Adams was his attorney. Judge William Adams was relying on William Dudley to get custody of his child, and this was never disclosed. Obviously, this amounts to a huge conflict of interest. Obviously, if Jennifer Flores-Lamb had known about this conflict of interest she would have asked for recusal (or asked that the case be assigned to a different court from the start at the time it was transferred from Nueces County). This was fraud and very substantial fraud. This is very similar to confficts of interests in other cases involving these lawyers. These lawyers always have some scam working including their visitation center and mediation scams. 21. The fraud at issue is "extrinsic" because it prevented Jennifer Flores Lamb and her attorney from knowing about their rights and having fair opportunity of presenting them. Specifically, it prevented them from asking for recusal (or assignment to another court). This fraud corrupt the proceedings to the core (the tribunal was not impartial).
22. The Judge and these lawyers had an ethical duty to disclose the huge conflict of interest at issue. They both acted extremely unethically by concealing the conflict of interest. If a party through lack of notice is deprived of a meritorious defense without negligence on his part bill of review relief may be appropriate. Jennifer Flores-Lamb and her attorney had no notice that Bi" Dudley was Judge Adams' attorney until early November or late October 2011. They had no notice of that this relationship went back over a year (putting this relationship back to the time of the October 11, 2010 hearing until November 21, 2011). This Bill of Review was requested within 1 business day after learning of that fact. 23. By analogy, X accuses Y intentionally assaulting him breaking his jaw. Unknown to X, Y is the Judge's Attorney in connection with a matter of extreme importance (e.g. child custody). Obviously, that is simply not acceptable. It is corrupt.
to the Judge
Appeal Not Available 24. Jennifer Flores lamb and her attorney did not have funds to purchase the entire transcript and pursue an ordinary appeal. They had been beaten down by years of frivolous and abusive litigation (also, by harassment by the corrupt bar association). They were beat down not only financially but emotionally. Further, there is real evidence of corruption at the appellate level. She filed an Application for Writ of Mandamus with the Thirteenth Court of Appeals. It seems to have been denied almost immediately. Her attorney went to get more
copies of the transcript. It was denied by the time he got back. The Court of Appeals denied it before it had time to read it. Appeal was not available as a meaningful potential remedy. Besides, the prime complaint in thls Bill of Review was not known until 11/21/2011 long after the time for appeal had expired. It was known that Judge Adams signed some corrupt orders before that date but it wasn't known that William Dudley was his attorney. Diligence 25. Jennifer Flores Lamb and her attorney acted with extreme diligence however they have been attacked by a fraudulent combination of powerful corrupt fraudulent forces. They have done all that could be expected of them. The harassment was so severe that at times Jennifer Flores-lamb's attorney seriously considered escaping to Belize. There are limits to
what can be done particularly there were not financial or emotional resources for appeal. Conditions Precedent
26. All conditions precedent have been performed or have occurred . Parties 27. The necessary parties are Andrew Mata, lanette Joubert, and William Dudley
because they are all beneficiaries of the corrupt fraudulent orders at issue. It is believed they will all appear and answer without necessity for formal service. It is believed that Judge William Adams although he was intimately involved in the fraud and corruption at issue is not a necessary party because he is not "interested" in the fraudulent orders in a legal sense (he is undoubtedly interested in the fraudulent orders in other senses). Another attorney was a beneficiary of the fraudulent orders at issue but settlement was reached with him. Requested Relief 28. The Court should set aside the corrupt fraudulent orders at issue both the corrupt fraudulent sanctions orders designed to conceal and cover up the crimes committed by William Dudley, lanette Joubert, and others but the custody order itself. The mother was prevented from obtaining any discovery. She was not allowed to subpoena witnesses. She
was not allowed to subpoena documents.
Her lawyer was corruptly threatened and
harassed both by the bar and the court interfering with quality representation. The bar literally sent a letter designed to incite him just 2 business days before trial. Additional Facts 29. The child stated his positions multiple times including to a child psychologist and to the mother recorded on videotape. Everybody involved testified that the child was intelligent and honest. The child confirmed his statements at trial (recorded on videotape). Lanette Joubert aggressively stated "I wasn't at the restaurant was I." The child responded "Yes, you were." It is a total lie that there was no evidence of what the child said. It is a total lie that there was no investigation. The waiters were interviewed. The child was interviewed by a child psychologist. Extensive efforts were made to find a surveillance video recording and other things. The Order signed by Judge Adams that it there was no evidence or no investigation was a bald face lie. He is a liar. These lawyers conspired in his dishonesty. It is also a bald face lie that these lawyers were not asked for input (this is suggested in Judge Adam's dishonest corrupt order). They were asked and t they never responded. The corruption of this proceedinq is beyond what a civilized society can tolerate. The corruption extends to both the bar and the judiciary who have been retaliatory. It must be addressed.