Request For Admissions 9842
User Manual: 9842
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WILLIAM MICHAEL JOHNSON by William-Michael Johnson c/o 191 Duck Pond Road McDade, Texas 78650 CAUSE NO. 9842 In the Admiralty COUNTY OF BASTROP ET AL, PLAINTIFF, vs. WILLIAM MICHAEL JOHNSON, DEFENDANT. § § § § § § § IN THE 21ST JUDICIAL DISTRICT COURT BASTROP COUNTY, TEXAS DEFENDANT'S FIRST REQUEST FOR ADMISSIONS TO PLAINTIFF To: Plaintiff, as alleged, COUNTY OF BASTROP et al, by and through attorney of record, Lee Gordon, alleged State Bar #08212500, MCCREARY, VESELKA, BRAGG & ALLEN, P.C. Defendant via, William Michael Johnson, respondent serves these requests for admissions on Plaintiff, et al, as allowed by Texas Rule of Civil Procedure 198. Plaintiff must admit or deny each request, in writing, within 30 days after service. Definitions 1. "Plaintiff" or "defendant," as well as a party's full or abbreviated name or a pronoun referring to a party, means the party, and where applicable, the party's agents, representatives, officers, directors, employees, partners, corporate agents, subsidiaries, affiliates, or any other person acting in concert with the party or under the party's control, whether directly or indirectly, including any attorney. 2. "You" or "your" means Plaintiff, COUNTY OF BASTROP, et al, successors, predecessors, divisions, subsidiaries, present and former officers, agents, employees, contractors and all other persons acting on behalf of Plaintiff, COUNTY OF BASTROP et al, or successors, predecessors, divisions, and subsidiaries. 3. “District” means [the] Bastrop County Appraisal District. 4. "Person" includes corporation, organization, government or governmental subdivision or agency, business trust, estate, trust, partnership, association, and any other legal entity. (Texas Government Code § 311.005. GENERAL DEFINITIONS (2)) 5. "Communication" means any oral or written communication of which plaintiff or plaintiff’s attorneys have knowledge, information, or belief. Cause 9842 DEFENDANT’S FIRST REQUEST FOR ADMISSIONS TO PLAINTIFF 1 6. Clarifications may be requested but do not extend time. 7. Unless otherwise said all requests contained in this request pertain particularly to this Cause 9842 matter as captioned above. Instructions: Admit or deny the following requests, non-response will be deemed admittance, a response of “vague” and/or “unintelligible” is not acceptable unless responsive explanation is offered, and as these requests are directed to an alleged governmental organization and its alleged attorney both of which are presumed to know the law – an objection response that read “calls for legal conclusions” (or similar) is therefore non sequiter and, unless responsive explanation is offered, will be deemed admitted. These requests for admissions do concern the 9842 captioned matter as said above. REQUEST # 1. This matter is properly captioned as showing above. Admit / Deny REQUEST # 2. Assessments are lawfully performed on income producing property. Admit / Deny REQUEST # 3. Owners of private non-income producing private home on private property are not required to render property. Admit / Deny REQUEST # 4. A private “home” on private property is not subject to taxation. Admit / Deny INTERROGATORY # 1 If you deny this then what are the characteristics of private “home” property / land that make it taxable? REQUEST # 5. Men and women on [the] land are not required to render private land. Admit / Deny REQUEST # 6. The land at issue in this Cause 9842 matter is private land. Admit / Deny Cause 9842 DEFENDANT’S FIRST REQUEST FOR ADMISSIONS TO PLAINTIFF 2 REQUEST # 7. Private property ownership is a right. Admit / Deny REQUEST # 8. “The State cannot diminish the Rights of the people.” See, Hertado v. California, 110 US 516 Admit / Deny REQUEST # 9. “Where Rights secured by the Constitution are involved, there can be no rule making or legislation which would abrogate them.” See, Miranda v. Arizona, 324 US 436, 491. Admit / Deny REQUEST # 10. “The claim and exercise of a constitutional Right cannot be converted into a crime.” See, Miller v. US, 230 F 486 at 489. Admit / Deny REQUEST # 11. “There can be no sanction or penalty imposed on one because of the exercise of a constitutional right.” See, Sherer v. Cullen, 481 F. 946. Admit / Deny REQUEST # 12. “The assertion of federal rights, when plainly made, is not to be defeated in the name of local practice.” See, Davis v. Wechsler, 263 US 22, at 24. Admit / Deny REQUEST # 13. “Federal Law & Supreme Court Cases apply to State Court Cases.” See, Howlett v. Rose, 496 U.S. 356 (1990). Admit / Deny REQUEST # 14. The land at issue in this Cause 9842 matter is not considered “Resident Homestead” pursuant to Section 11.13(j) and (o) of the Property Tax Code. Admit / Deny Cause 9842 DEFENDANT’S FIRST REQUEST FOR ADMISSIONS TO PLAINTIFF 3 REQUEST # 15. The land at issue in this Cause 9842 matter does not exist “in this state” as defined in Section 151.004 of the Property Tax Code. Admit / Deny REQUEST # 16. The land at issue in this Cause 9842 matter does not exist in this “state” as defined in Chapter 311 Government Code. Admit / Deny REQUEST # 17. The District is lawful Texas Government agency. Admit / Deny REQUEST # 18. The District’s chief appraiser is the party responsible for all activity of the District. Admit / Deny REQUEST # 19. The District’s chief appraiser is the party responsible for all contracts of the District. Admit / Deny REQUEST # 20. The District’s chief appraiser approves and works closely with all contractors with the District. Admit / Deny REQUEST # 21. There appears no bonding of this cause 9842 matter. Admit / Deny REQUEST # 22. There appear no fide-jussio or fide-jussor for the plaintiff. Admit / Deny REQUEST # 23. The District’s chief appraiser is responsible for all bonding of this Cause 9842 matter. Admit / Deny REQUEST # 24. Regarding the District all authority is delegated through and by the chief appraiser. Cause 9842 DEFENDANT’S FIRST REQUEST FOR ADMISSIONS TO PLAINTIFF 4 Admit / Deny REQUEST # 25. There appears no legal nexus between the man William Michael Johnson and the District or the District’s chief appraiser. Admit / Deny REQUEST # 26. An original petition in this matter was lawfully filed on or about the 17th day of the month of October in the year 2006. Admit / Deny REQUEST # 27. The District’s chief appraiser is responsible for the filing of this Cause 9842 action. Admit / Deny REQUEST # 28. The alleged defendant did not consent to this Cause 9842 action. Admit / Deny REQUEST # 29. The alleged defendant is not a corporation – nor becoming one. Admit / Deny REQUEST # 30. The Sixth Edition of Black’s Law Dictionary defines “property” quite adequately on pages 1216, 1217 and 1218. Admit / Deny INTERROGATORY # 2: If your response to for Request # 30 is "denied," please proffer the definition of “property” that is pertinent and controlling to this matter. REQUEST # 31. The Sixth Edition of Black’s Law Dictionary defines property tax as an ad valorem tax. (Page 1218.) Admit / Deny REQUEST # 32. The term “ad valorem” means according to value. Admit / Deny REQUEST # 33. The Cause 9842 suit is about collection on an alleged debt. Cause 9842 DEFENDANT’S FIRST REQUEST FOR ADMISSIONS TO PLAINTIFF 5 Admit / Deny REQUEST # 34. The District’s chief appraiser is responsible for the claim of debt in this matter. Admit / Deny REQUEST # 35. The District’s chief appraiser is responsible for the debt alleged in this matter. Admit / Deny REQUEST # 36. The alleged tax is a debt burdened onto the defendant. Admit / Deny REQUEST # 37. The District’s chief appraiser was duly acting in the course and scope of his employment when instigating this matter. Admit / Deny REQUEST # 38. The District’s chief appraiser was duly acting in full accord with all applicable law relating to this Cause 98842 matter. Admit / Deny REQUEST # 39. The named attorney was duly acting with specified authority in the course and scope of his employment when instigating this matter. Admit / Deny REQUEST # 40. All lawful and legal prerequisites were accomplished before the filing. Admit / Deny REQUEST # 41. All lawful and legal prerequisites were accomplished at the time of the filing. Admit / Deny REQUEST # 42. This suit is compliant with the Texas Constitution. Admit / Deny Cause 9842 DEFENDANT’S FIRST REQUEST FOR ADMISSIONS TO PLAINTIFF 6 REQUEST # 43. As it may pertain this suit is compliant with the federal constitution. Admit / Deny REQUEST # 44. This suit and relating action is compliant with the Texas Rules of Civil Procedure (T.R.C.P). Admit / Deny REQUEST # 45. As it may pertain this suit and relating action is compliant with the Texas Code of Criminal Procedure. Admit / Deny REQUEST # 46. The Texas Business and Commerce Code Uniform Commercial Code is applicable in this Cause 9842 matter. Admit / Deny REQUEST # 47. The Cause 9842 appears to lack verification. Admit / Deny REQUEST # 48. The man William Michael Johnson is the titled land owner of the property at issue. Admit / Deny REQUEST # 49. The property at issue is duly recorded and posted as private property. Admit / Deny REQUEST # 50. “THE STATE OF TEXAS” has no interest in the land at issue in this Cause 9842 matter. Admit / Deny REQUEST # 51. The District is biased against private ownership. Admit / Deny REQUEST # 52. The District’s Board of Directors is biased against private ownership. Admit / Deny Cause 9842 DEFENDANT’S FIRST REQUEST FOR ADMISSIONS TO PLAINTIFF 7 REQUEST # 53. The District’s chief appraiser is biased against private ownership. Admit / Deny REQUEST # 54. The District’s employees are biased against private ownership. Admit / Deny REQUEST # 55. The Cause 9842 petition satisfies all lawful requirements. Admit / Deny REQUEST # 56. The Cause 9842 petition is true, correct and accurate. Admit / Deny REQUEST # 57. The Cause 9842 petition fully identifies real party of interest. Admit / Deny REQUEST # 58. The Cause 9842 petition affords full disclosure. Admit / Deny REQUEST # 59. The petition document found in the folder of the Cause 9842 matter is a genuine copy of that petition document. Admit / Deny REQUEST # 60. The single page document attached to said petition and showing as “SCHEDULE A” is true, correct and complete. Admit / Deny REQUEST # 61. The single page document attached to petition, as said, and showing as “SCHEDULE A” is fully disclosed. Admit / Deny REQUEST # 62. Said “SCHEDULE A” fully identifies real party of interest. Admit / Deny REQUEST # 63. Said “SCHEDULE A” is factually true, correct and complete. Admit / Deny Cause 9842 DEFENDANT’S FIRST REQUEST FOR ADMISSIONS TO PLAINTIFF 8 REQUEST # 64. Said “SCHEDULE A” shows undefined numbers. Admit / Deny REQUEST # 65. Said “SCHEDULE A” shows numbers of no consequence. Admit / Deny REQUEST # 66. Said “SCHEDULE A” shows, “ACCOUNT NUMBER”. Admit / Deny INTERROGATORY # 3: Please proffer any and all information concerning alleged “ACCOUNT NUMBER” such as, and not limited to, who opened said account, who is responsible for it, its lifespan, who controls it, can it be closed, modified, etc. REQUEST # 67. Said “SCHEDULE A” shows, “ASSESSED NAME: JOHNSON, WILLIAM MICHAEL”. Admit / Deny REQUEST # 68. Said “SCHEDULE A” does not define “ASSESSED NAME: JOHNSON, WILLIAM MICHAEL”. Admit / Deny REQUEST # 69. Said “SCHEDULE A” shows, “ABSTRACT FEES”. Admit / Deny REQUEST # 70. Said “SCHEDULE A” does not define “ABSTRACT FEES”. Admit / Deny REQUEST # 71. Said “SCHEDULE A” shows, “AMOUNT DUE”. Admit / Deny REQUEST # 72. Said “SCHEDULE A” does not define “AMOUNT DUE”. Admit / Deny REQUEST # 73. Said “SCHEDULE A” shows “TOTAL DUE”. Cause 9842 DEFENDANT’S FIRST REQUEST FOR ADMISSIONS TO PLAINTIFF 9 Admit / Deny REQUEST # 74. Said “SCHEDULE A” does not define “TOTAL DUE”. Admit / Deny REQUEST # 75. Said “SCHEDULE A” shows, “TEXAS LAW MAKES YOU RESPONSIBLE FOR THE PAYMENT OF THESE FEES. Admit / Deny REQUEST # 76. Said “SCHEDULE A” does not define “TEXAS LAW”. Admit / Deny REQUEST # 77. Said “SCHEDULE A” does not define “YOU”. Admit / Deny REQUEST # 78. Said “SCHEDULE A” does not define “PAYMENT”. Admit / Deny REQUEST # 79. Said “SCHEDULE A” does not define “FEES”. Admit / Deny REQUEST # 80. This Cause 9842 action is in line with and pursuant to the MANIFESTO OF THE COMMUNIST PARTY, a/k/a [the] Communist Manifesto, [showing] as authored by Karl Marx and Friedrich Engels (English edition of 1888, edited by Friedrich Engels) (see, http://www.gutenberg.org/catalog/world/readfile?fk_files=165453&pageno=1) Admit / Deny REQUEST # 81. A proper, true and correct citation was issued about the 23rd day of the month of October in the year 2006. Admit / Deny REQUEST # 82. Said petition and citation was duly served on the 2nd day of the month of February in the year 2007. Admit / Deny Cause 9842 DEFENDANT’S FIRST REQUEST FOR ADMISSIONS TO PLAINTIFF 10 REQUEST # 83. Process server was competent. Admit / Deny REQUEST # 84. Service was timely. Admit / Deny REQUEST # 85. Service meets all requirements. Admit / Deny REQUEST # 86. Process server had authority to serve on the land that is subject of this Cause 9842 matter. Admit / Deny REQUEST # 87. Plaintiff inappropriately named defendant in plaintiff's original petition. Admit / Deny REQUEST # 88. A verified original answer appears in the folder of this matter. Admit / Deny REQUEST # 89. A request, pursuant to Texas Rules of Civil Procedure Rule 194, for disclosure was served on plaintiff. Admit / Deny REQUEST # 90. Said request is lawful. Admit / Deny REQUEST # 91. A request, pursuant to Texas Rules of Civil Procedure Rules 193 and 196, for production was served. Admit / Deny REQUEST # 92. Said request is lawful. Admit / Deny REQUEST # 93. McCreay, Veselka, Bragg & Allen, P.C. show to be and are the Attorneys for the alleged Plaintiff. Cause 9842 DEFENDANT’S FIRST REQUEST FOR ADMISSIONS TO PLAINTIFF 11 Admit / Deny REQUEST # 94. One Shelburne (Shelly) J. Veselka appears to be the lead attorney in this particular matter. Admit / Deny REQUEST # 95. One Lee Gordon, alleged State Bar #08212500, appears as an attorney in this matter. Admit / Deny REQUEST # 96. A counterclaim and citation was properly served to the same Lee Gordon. Admit / Deny REQUEST # 97. A counterclaim and citation was properly served to McCreay, Veselka, Bragg & Allen, P. C. Admit / Deny REQUEST # 98. A counterclaim and citation was properly served to the alleged “COUNTY OF BASTROP”. Admit / Deny REQUEST # 99. One Lee Gordon, alleged State Bar #08212500, appears to have monetary interest with this Cause 9842 action. Admit / Deny REQUEST # 100. One Lee Gordon, alleged State Bar #08212500, appears to lack standing in this Cause 9842 matter. Admit / Deny REQUEST # 101. One Lee Gordon, alleged State Bar #08212500, appears to lack law practice license. Admit / Deny Cause 9842 DEFENDANT’S FIRST REQUEST FOR ADMISSIONS TO PLAINTIFF 12 REQUEST # 102. One Shelburne (Shelly) J. Veselka does not represent the alleged defendant. Admit / Deny REQUEST # 103. One Lee Gordon, alleged State Bar #08212500, does not represent the alleged defendant. Admit / Deny REQUEST # 104. McCreay, Veselka, Bragg & Allen, P.C. does not represent the alleged defendant. Admit / Deny REQUEST # 105. One Shelburne (Shelly) J. Veselka does not have authority of or to conversion of private property in this Cause 9842 matter. Admit / Deny REQUEST # 106. One Lee Gordon, alleged State Bar #08212500, does not have authority of or to conversion of the private property at issue in this Cause 9842 matter. Admit / Deny REQUEST # 107. McCreay, Veselka, Bragg & Allen, P.C. does not have authority of or to conversion of private property in this Cause 9842 matter. Admit / Deny REQUEST # 108. The alleged Plaintiff appears not to have any monetary interest in the property at issue in this Cause 9842 matter. Admit / Deny REQUEST # 109. The alleged Plaintiff appears not to have any proprietary interest in the property at issue in this Cause 9842 matter. Admit / Deny REQUEST # 110. The alleged Plaintiff does not own the land at issue. Cause 9842 DEFENDANT’S FIRST REQUEST FOR ADMISSIONS TO PLAINTIFF 13 Admit / Deny REQUEST # 111. The alleged Plaintiff does not own the property at issue. Admit / Deny REQUEST # 112. There appears no legal nexus between the man William Michael Johnson and the Property Tax Code. Admit / Deny REQUEST # 113. The alleged assessment as is subject of this Cause 9842 action is compliant with the federal constitution. Admit / Deny REQUEST # 114. The alleged debt as is subject of this Cause 9842 action is compliant with the federal constitution. Admit / Deny REQUEST # 115. The alleged assessment as is subject of this Cause 9842 action is compliant with the Texas Constitution. Admit / Deny REQUEST # 116. The alleged debt as is subject of this Cause 9842 action is compliant with the Texas Constitution. Admit / Deny REQUEST # 117. The said constitutions act upon those who choose to be in an agreement with it, such as public officials and their employees. Admit / Deny REQUEST # 118. All those who claim to be acting for the Plaintiff have taken the Constitutionally mandated oaths. Admit / Deny REQUEST # 119. The District is obliged to a foreign authority. Admit / Deny Cause 9842 DEFENDANT’S FIRST REQUEST FOR ADMISSIONS TO PLAINTIFF 14 REQUEST # 120. The named Attorneys relating to this instant matter are agents of a foreign authority. Admit / Deny REQUEST # 121. Excluding the alleged defendant none of the other named parties as found in the record of this matter have been convicted of a felony or a crime involving moral turpitude. Admit / Deny REQUEST # 122. Excluding the alleged defendant none of the other named parties as found in the record of this matter have been formally indicted or otherwise accused or charged with a felony or a crime involving moral turpitude. Admit / Deny REQUEST # 123. The alleged “COUNTY OF BASTROP” is a lawful entity. Admit / Deny REQUEST # 124. The alleged “COUNTY OF BASTROP” is one and the same as “County of Bastrop”. Admit / Deny REQUEST # 125. The alleged “COUNTY OF BASTROP” is a lawful entity with proper charter. Admit / Deny REQUEST # 126. Bastrop county and the alleged “COUNTY OF BASTROP” are not the same. Admit / Deny REQUEST # 127. The alleged attorneys in this matter have full confidence and authority to act, bind and commit the alleged “COUNTY OF BASTROP” in any way relating to this matter. Cause 9842 DEFENDANT’S FIRST REQUEST FOR ADMISSIONS TO PLAINTIFF 15 Admit / Deny REQUEST # 128. The alleged “COUNTY OF BASTROP” is a different entity than the District. Admit / Deny REQUEST # 129. Law is contract. Admit / Deny REQUEST # 130. Contract makes the law. Admit / Deny REQUEST # 131. “The state citizen is immune from any and all government attacks and procedure, absent contract.” See, Dred Scot vs. Sanford, 60 U.S. (19 How.) 393 (1857). Admit / Deny REQUEST # 132. Defendant did not execute a written contract with plaintiff. Admit / Deny REQUEST # 133. Defendant did not execute a written contract with plaintiff for adequate consideration. Admit / Deny REQUEST # 134. Defendant did not authorize to sign or otherwise enter the man William Michael Johnson into contract with alleged Plaintiff. Admit / Deny REQUEST # 135. Defendant is not under any contractual obligation with the alleged plaintiff. Admit / Deny REQUEST # 136. The alleged Plaintiff appears not to have any contractual interest in the property at issue in this Cause 9842 matter. Admit / Deny Cause 9842 DEFENDANT’S FIRST REQUEST FOR ADMISSIONS TO PLAINTIFF 16 REQUEST # 137. There appears no voluntary nexus between the man William Michael Johnson and the alleged Plaintiff. Admit / Deny REQUEST # 138. Defendant did not harm or damage the alleged Plaintiff in this matter. Admit / Deny REQUEST # 139. Plaintiff did not make a written demand for the sum sought in plaintiff's original petition more than 30 days before plaintiff filed suit. Admit / Deny REQUEST # 140. Defendant did not refuse to pay plaintiff the sum sought in the written demand. Admit / Deny REQUEST # 141. The man William Michael Johnson is not subject to the federal constitution. Admit / Deny REQUEST # 142. The man William Michael Johnson is not subject to the Texas Constitution. Admit / Deny REQUEST # 143. The District’s Chief Appraiser did not certify the property so identified subject of or in this Cause 9842 action. Admit / Deny REQUEST # 144. The attorneys in this matter are acting as debt collectors. Admit / Deny REQUEST # 145. The Fair Debt Collection Practices Act is applicable in this matter. Admit / Deny Cause 9842 DEFENDANT’S FIRST REQUEST FOR ADMISSIONS TO PLAINTIFF 17 REQUEST # 146. City of Houston v. Morgan Guar. Intern. Bank (App. 1 Dist. 1983) 666 S.W.2d 524, ref. n.r.e, certiorari denied 105 S.Ct. 1185, 469 U.S. 1213, 84 L.Ed.2d 332 does have influence upon this mater. Admit / Deny REQUEST # 147. There appears no legal nexus between the man William Michael Johnson’s recorded private property and the Property Tax Code. Admit / Deny REQUEST # 148. In order for a tax to be levied the “thing being taxed” must be “located in this state” meaning that the “thing being taxed” must be both “doing business and be domiciled in Texas” Admit / Deny REQUEST # 149. Absent some manner of voluntary consent or fully disclosed contract a man or a woman in Texas cannot be mandated / forced into paying a tax. Admit / Deny REQUEST # 150. This Cause 9842 matter involves private copyright law. Admit / Deny REQUEST # 151. Respondent does not have right to use or access private copyright law. Admit / Deny REQUEST # 152. This Cause 9842 matter involves trespass of private property. Admit / Deny REQUEST # 153. This Cause 9842 matter involves conversion. Admit / Deny REQUEST # 154. “WILLIAM MICHAEL JOHNSON” is private property. Admit / Deny Cause 9842 DEFENDANT’S FIRST REQUEST FOR ADMISSIONS TO PLAINTIFF 18 REQUEST # 155. Plaintiff lacks use authorization for the “WILLIAM MICHAEL JOHNSON”. Admit / Deny REQUEST # 156. Named Attorneys in this Cause 9842 matter lack use authorization for the “WILLIAM MICHAEL JOHNSON”. Admit / Deny REQUEST # 157. “WILLIAM MICHAEL JOHNSON” is an attempt to create a colorable persona (conversion) under colorable law. Admit / Deny REQUEST # 158. Conversion is unlawful activity. Admit / Deny REQUEST # 159. Perpetuation of this Cause 9842 matter is extortion. Admit / Deny REQUEST # 160. The perpetuation of this Cause 9842 matter is misappropriation of public money. Admit / Deny REQUEST # 161. The perpetuation of this Cause 9842 matter is misappropriation of public trust. Admit / Deny REQUEST # 162. This Cause 9842 matter is an act in contradiction to Penal Code Art. 1.04. [2] [3] Due course of law No citizen of this State shall be deprived of life, liberty, property, privileges or immunities, or in any manner disfranchised, except by the due course of the law of the land. Admit / Deny REQUEST # 163. This Cause 9842 matter is an act in correspondence with the elements found in Penal Code Art. 39.03 Official Oppression. Cause 9842 DEFENDANT’S FIRST REQUEST FOR ADMISSIONS TO PLAINTIFF 19 Admit / Deny REQUEST # 164. This Cause 9842 matter is an act in correspondence with the elements found in Penal Code Art. 39.02 Abuse of Official Capacity. Admit / Deny REQUEST # 165. This Hale V. Henkel case is applicable to the Cause 9842 matter: "The individual may stand upon his constitutional rights as a citizen. He is entitled to carry on his private business in his own way. His power to contract is unlimited. He owes no such duty to the State, since he receives nothing therefrom, beyond the protection of his life and property. His rights are such as existed by the law of the land [Common Law] long antecedent to the organization of the State, and can only be taken from him by due process of law, and in accordance with the Constitution. Among his rights are a refusal to incriminate himself, and the immunity of himself and his property from arrest or seizure except under a warrant of the law. He owes nothing to the public so long as he does not trespass upon their rights." Hale v. Henkel, 201 U.S. 43 at 47 (1905). Admit / Deny Respectfully submitted by order of the WILLIAM MICHAEL JOHNSON. // // // // // // // // // // // // // // Cause 9842 DEFENDANT’S FIRST REQUEST FOR ADMISSIONS TO PLAINTIFF 20 Date: _________ day of June, 2007 ________________________________________________________ William Michael Johnson, unrepresented c/o 191 Duck Pond Road McDade, Bastrop county Texas uSA 512-273-2396 no telecopier number // // // // // // // // CERTIFICATE OF SERVICE “I hereby certify that a true and correct copy of the foregoing DEFENDANT'S FIRST REQUEST FOR ADMISSIONS TO PLAINTIFF was sent on June _________, 2007 to Lee Gordon, alleged State Bar #08212500, MCCREARY, VESELKA, BRAGG & ALLEN, P.C.; P.O. Box 26990, Austin, Texas 78755 via prepaid USPS Certified Mail, Article # 7006 2760 0002 0863 9448 Domestic Return Receipt PS Form 3811 used.” ________________________________________________________ William-Michael Johnson Bastrop county Texas 512-273-2396 // // // // // // // // // // // Cause 9842 DEFENDANT’S FIRST REQUEST FOR ADMISSIONS TO PLAINTIFF 21
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