Preview
NOTICE: THIS DOCUMENT CONTAINS SENSITIVE DATA
Cause Number 0) C -Q0b 42 ) ]
Complete this top part so that it looks exactly like the Petition filed in your case.
—
In the (check one):
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Motion to Transfer Venue | Nove to Another tour
Print your answers.
—
1 My name is: Enka » “Sateebs.
First Middle Last
2. lamthe [%{ Plaintif’Petitioner (1 Defendant/Respondent in this case.
‘ourt to transfer venue because: (Check all that apply.)
Neza thern Oistect
enue is not proper in the current court. Venue is proper in ot [exes bede‘al Court|
(Write the County)
County, Texas, because it is: i] Co Coamervey
lam l4S2
( Mandatory in that court al us) x
‘e of the general venue statute
ecause of the permissive venue statute
752432.
According to:
v
VS.o1) 1 bel Clanker or nodasian ch Pie ry) Vex tis |, ky
(White the law that instructs 7
xP
Jenue is proper in another county because it is mandate fory, orundel r the general
ermissive venue statute.)
Suriae damages 20 | bel Slander tg Noasiag
A
ar Div
Shall be. bree hie ahd a oMu te maltyuny, ay{ athe = Coufal
wh iMate putts ppc) bel ot Ge ae He aus
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convenient for the parti 's and the witnesses an cin the le interest of justice faces
in
County, Texas, according to Tex. Civ.
(Write the County)
Prac. & Rem. Code § 15.002(b).
Geborh Be WoThee: of hearly
© TexasLawHelp
Motion to Transfer Venue and Notice of Hearing, June 2017
Page 1 of4
/’
(Write the reason that affidavits support that you need
to transter venue, that you cannot get a fair and impartial trial in the current county, any other sufficient
(necessary) a ) \
y Ce oat + have attached WZ aet
Gh ay hee (as eC wi L De Pudi Gel rh tA
eurt Gad VN Sort of [au 1G.o1 7 Libel, le Ache
c Al i LOAUbGipa et Pe
| have attached to this Motion my affidavit and the affidavits of other
(Write the #, 3 or more)
people that live in this County to support this Motion.
nnteeins
Ci urt to.> OFFant my Motion to Transfer Venue and transfer the case to a rele ral © fad sh Y
Stentere
court in La 4S County, Texas.
pisnct or
tent ead at Law) (County)
Respect lly sumitted,
D Gar (At
Your Sigi ajure J Date
G=2H
Hour Fist
toXbSato bs 02) +f 34- Fle
Phone,
LC
wating fox (
252
nee mie ld CL &CO2 |
State Zip
SeACEAL wt2.O) Cutloolita
Email Address Fax Number (if available)
TexasLawHelp
Motion to Transfer Venue and Notice of Hearing, June 2017
Page 2 of 4
IN THE DISTRICT COURT OF
DALLAS COUNTY, TEXAS
298™ JUDICIAL DISTRICT
ERIKA JACOBS, CASE NO. DC-2003277
PLAINTIFF,
VS.
GREYHOUND BUS LINES
CORPORATE OFFICE,
DEFENDANT.
Plaintiff's Affidavit
Comes Now the Plaintiff in the above styled case to state her reason for venue change and or removal of
case to another court. The reason for the removal of the case is because of the prejudice experienced in
this court. As well as the conversion of the case by the Defendant into libel, slander and invasion of
privacy with the accusation of the Plaintiff being a vexatious litigant. Pursuant Texas laws; Tex. R. Civ.
Proc. §§ 257-259 and 15.017. LIBEL, SLANDER, OR INVASION OF PRIVACY.:
1. The Plaintiff was not given the proper response time for the Defendant’s submittal of
CERTIFICATE OF CONFERENCE TO DEFENDANT'S MOTION TO DEEM PLAINTIFF VEXATIOUS.
The Defendant submitted the Motion on August 14, 2020. The court rendered the Defendant’s a
hearing on August 19, 2020. That is less than 7 -30 days of response time deemed for the
Plaintiff. Per Texas law 2.07 no hearing should have been given:
Certificates of Conference Motions without certificates of conference in compliance with Local Rule 2.07
will not be set for hearing by the clerk. Certificates of conference must be attached to all motions,
except those excluded by the Local Rules, i.e., motions for summary judgment. CERTIFICATES OF
CONFERENCE THAT DO NOT CONFORM SUBSTANTIVELY TO LOCAL RULE 2.07 WILL NOT BE ACCEPTED.
The Plaintiff sent a certified mail response to the Defendant’s motion on 8-19-20.
Simple laws such as the above are not being adhered to.
2. The Defendant has submitted information about the Plaintiff from states that he cannot even
confirm the Plaintiff have lived in. How does the defendant know where the Plaintiff has lived?
How did the defendant know what county | resided in based on a PO Box? Yet, in still the
Defendant’s attorney has not presented 5 or 12 cases that show | am a vexatious litigant. This
trial has gone to libel, slander, and invasion of privacy per the defendant's action. The court still
does not respond to the Plaintiff. The court only complies with the defendants’ request. Thus,
based on the information present above what good would a hearing be from this current court.
The Plaintiff submitted a case on the violation of her consumer rights by Greyhound on a
continual basis with supporting evidence which is unconstitutional. Thus, the Defendant has
turned this case into a libel, slander, and invasion of privacy case by falsely accusing the Plaintiff
of being a Vexatious Litigant.
The Plaintiff is not a vexatious litigant and has never been one. This is the definition of a
vexatious litigant:
A vexatious litigant is someone who files multiple lawsuits against another person for
the purpose of “burying him in paper.” For example, a vexatious litigant is inspired to
file a lawsuit against another person so as to harass that person, or to otherwise quiet
him on an issue.
How has the Defendant proved that the Plaintiff is a vexatious litigant? This does not
need a hearing. The Defendant is trying to by time from the real issues of the case of
merit with worthless false accusations of the Plaintiff being a vexatious litigant.
Pursuant Texas law: Sec. 15.017. LIBEL, SLANDER, OR INVASION OF
PRIVACY. A suit for damages for libel, slander, or invasion of
privacy shall be brought and can only be maintained in the county
in which the plaintiff resided at the time of the accrual of the
cause of action, or in the county in which the defendant resided
at the time of filing suit, or in the county of the residence of
defendants, or any of them, or the domicile of any corporate
defendant, at the election of the plaintiff.
The Plaintiff wants the case to be moved to a higher court for proper and fair trial. The
Plaintiff wants the case to be move to federal court with no charge to the Plaintiff (the
Plaintiff has a poverty affidavit on file). The Federal Courts address is as follows: (Please
include all motions, orders, and correspondence of the case to the Federal court listed below)
United Stated District Court
Northern District of Texas
1100 Commerce street
Room 1452
Dallas, TX 75242
This court even set trial date for Jan. 2020 and it has been rescinded on based on what the
defendant request.
Please remove the case to federal court for a trial by jury.
This 24" day of August 2020.
Erika Jacops
PO Box 6252
Broomfield, CO 80021
602-434-3107
Jeneencat2@outlook.com
Unsworn Declaration (Texas Civil Practice and Remedies Code, Section 132.001)
| declare under penalty of perjury that: 1) | am the person asking to transfer venue, 2) | have read this
Motion to Transfer Venue , and 3) the statements in this Motion to Transfer Venue are within my
personal knowledge and are true be correct. My name is:
Eon Saedhs my address is:
Ox 6952 Street Address City State
Zip Code and tek A } ('p §002
Country Formally signed under penalty of perjury in | Ay te a Sa {4 ounty,Lalls(oat V
Ce
County Stai on this date g yOH / 2D Month Day Year
Signature of Party Asking to Transfer Venue Notice of
and | am not'req sting an hearing.
Certificate of Service
| will give a copy of this document to each party in this case, orif a party is represented by a lawyer to
the party’s lawyer, on the same day this document is filed with (turned in to) the Court as follows: If I file
this document electronically, | will send a copy of it to the party or the party’s lawyer through the
electronic file manager if possible. If not possible, | will give a copy to the party or the party’s lawyer in
person, by mail, by commercial delivery service, by fax, or by email. If | file a paper copy of this
document, | will give a copy of it to the other party or the other party’s lawyer in person, by mail, by
commercial delivery service, by fax, or by email
\\ Date 8-24-20
sna ote Party requesting venue transfer
DSS
Chor ®r
tee, Smith, SharpeVitullo ip
Texas A torneys
Dallas Austin Houston
Three Galiena Tower 13155 Noe! Road Suite 1000. Dallas. Texas 75240 P ae
F 972-9 20
77-FEESMITH feesmith.com
Christopher C. Sisk
csisk@feesmith.com
972-616-7619 Direct Dial
August 19, 2020
NOTICE OF HEARING
Via Electronic Service, Regular Mail
And Certified 9214 8969 0099 9790 1208 4199 43
Erika Jacobs
P.O.Box 6252
Broomfield, CO 80021
Re: Cause No. DC-2003277; Erika Jacobs v. Greyhound Bus Lines Corpor
ate Office;
In the 298th District Court, Dallas County, Texas
Our File No.: GRY.12103
Dear Ms. Jacobs:
This is to confirm that Defendant’s Motion to Deem Plaintiff Vexatious
is set for hearing
on Friday, September 11, 2020 at 3:00 p.m. This hearing will be conduct
ed via telephone
conference. Please use the following conference call-in number:
1 Dial the toll-free #1-888-204-5987
2 Enter the access code 6980413 #
3 Press (#) to connect to the call
Per the court, we will then connect, via telephone, with the Judge.
Thank you.
Very truly yours,
DL Onf
oe
Christopher C. Sisk
CCS/LMP
cc: Coordinator, 298" Judicial District
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Preview
NOTICE: THIS DOCUMENT CONTAINS SENSITIVE DATA Cause Number 0) C -Q0b 42 ) ] Complete this top part so that it looks exactly like the Petition filed in your case. — In the (check one): DAK Jota s ef District Co Bist 2,2, Court Number oo Se O County Court E. a FOC, AO, OF Dy % oO Loreube oft ie_- Dull dS Cou 2 ASha se 2 DeFenkank, & Motion to Transfer Venue | Nove to Another tour Print your answers. — 1 My name is: Enka » “Sateebs. First Middle Last 2. lamthe [%{ Plaintif’Petitioner (1 Defendant/Respondent in this case. ‘ourt to transfer venue because: (Check all that apply.) Neza thern Oistect enue is not proper in the current court. Venue is proper in ot [exes bede‘al Court| (Write the County) County, Texas, because it is: i] Co Coamervey lam l4S2 ( Mandatory in that court al us) x ‘e of the general venue statute ecause of the permissive venue statute 752432. According to: v VS.o1) 1 bel Clanker or nodasian ch Pie ry) Vex tis |, ky (White the law that instructs 7 xP Jenue is proper in another county because it is mandate fory, orundel r the general ermissive venue statute.) Suriae damages 20 | bel Slander tg Noasiag A ar Div Shall be. bree hie ahd a oMu te maltyuny, ay{ athe = Coufal wh iMate putts ppc) bel ot Ge ae He aus thE ouse et, US scohwoh feseR at the tiie ob tf, TA He GeuAty + The Loren dur Surty st 2 Pleuse, 7> Vv (J venue is more tt dau} yer MMip et convenient for the parti 's and the witnesses an cin the le interest of justice faces in County, Texas, according to Tex. Civ. (Write the County) Prac. & Rem. Code § 15.002(b). Geborh Be WoThee: of hearly © TexasLawHelp Motion to Transfer Venue and Notice of Hearing, June 2017 Page 1 of4 /’ (Write the reason that affidavits support that you need to transter venue, that you cannot get a fair and impartial trial in the current county, any other sufficient (necessary) a ) \ y Ce oat + have attached WZ aet Gh ay hee (as eC wi L De Pudi Gel rh tA eurt Gad VN Sort of [au 1G.o1 7 Libel, le Ache c Al i LOAUbGipa et Pe | have attached to this Motion my affidavit and the affidavits of other (Write the #, 3 or more) people that live in this County to support this Motion. nnteeins Ci urt to.> OFFant my Motion to Transfer Venue and transfer the case to a rele ral © fad sh Y Stentere court in La 4S County, Texas. pisnct or tent ead at Law) (County) Respect lly sumitted, D Gar (At Your Sigi ajure J Date G=2H Hour Fist toXbSato bs 02) +f 34- Fle Phone, LC wating fox ( 252 nee mie ld CL &CO2 | State Zip SeACEAL wt2.O) Cutloolita Email Address Fax Number (if available) TexasLawHelp Motion to Transfer Venue and Notice of Hearing, June 2017 Page 2 of 4 IN THE DISTRICT COURT OF DALLAS COUNTY, TEXAS 298™ JUDICIAL DISTRICT ERIKA JACOBS, CASE NO. DC-2003277 PLAINTIFF, VS. GREYHOUND BUS LINES CORPORATE OFFICE, DEFENDANT. Plaintiff's Affidavit Comes Now the Plaintiff in the above styled case to state her reason for venue change and or removal of case to another court. The reason for the removal of the case is because of the prejudice experienced in this court. As well as the conversion of the case by the Defendant into libel, slander and invasion of privacy with the accusation of the Plaintiff being a vexatious litigant. Pursuant Texas laws; Tex. R. Civ. Proc. §§ 257-259 and 15.017. LIBEL, SLANDER, OR INVASION OF PRIVACY.: 1. The Plaintiff was not given the proper response time for the Defendant’s submittal of CERTIFICATE OF CONFERENCE TO DEFENDANT'S MOTION TO DEEM PLAINTIFF VEXATIOUS. The Defendant submitted the Motion on August 14, 2020. The court rendered the Defendant’s a hearing on August 19, 2020. That is less than 7 -30 days of response time deemed for the Plaintiff. Per Texas law 2.07 no hearing should have been given: Certificates of Conference Motions without certificates of conference in compliance with Local Rule 2.07 will not be set for hearing by the clerk. Certificates of conference must be attached to all motions, except those excluded by the Local Rules, i.e., motions for summary judgment. CERTIFICATES OF CONFERENCE THAT DO NOT CONFORM SUBSTANTIVELY TO LOCAL RULE 2.07 WILL NOT BE ACCEPTED. The Plaintiff sent a certified mail response to the Defendant’s motion on 8-19-20. Simple laws such as the above are not being adhered to. 2. The Defendant has submitted information about the Plaintiff from states that he cannot even confirm the Plaintiff have lived in. How does the defendant know where the Plaintiff has lived? How did the defendant know what county | resided in based on a PO Box? Yet, in still the Defendant’s attorney has not presented 5 or 12 cases that show | am a vexatious litigant. This trial has gone to libel, slander, and invasion of privacy per the defendant's action. The court still does not respond to the Plaintiff. The court only complies with the defendants’ request. Thus, based on the information present above what good would a hearing be from this current court. The Plaintiff submitted a case on the violation of her consumer rights by Greyhound on a continual basis with supporting evidence which is unconstitutional. Thus, the Defendant has turned this case into a libel, slander, and invasion of privacy case by falsely accusing the Plaintiff of being a Vexatious Litigant. The Plaintiff is not a vexatious litigant and has never been one. This is the definition of a vexatious litigant: A vexatious litigant is someone who files multiple lawsuits against another person for the purpose of “burying him in paper.” For example, a vexatious litigant is inspired to file a lawsuit against another person so as to harass that person, or to otherwise quiet him on an issue. How has the Defendant proved that the Plaintiff is a vexatious litigant? This does not need a hearing. The Defendant is trying to by time from the real issues of the case of merit with worthless false accusations of the Plaintiff being a vexatious litigant. Pursuant Texas law: Sec. 15.017. LIBEL, SLANDER, OR INVASION OF PRIVACY. A suit for damages for libel, slander, or invasion of privacy shall be brought and can only be maintained in the county in which the plaintiff resided at the time of the accrual of the cause of action, or in the county in which the defendant resided at the time of filing suit, or in the county of the residence of defendants, or any of them, or the domicile of any corporate defendant, at the election of the plaintiff. The Plaintiff wants the case to be moved to a higher court for proper and fair trial. The Plaintiff wants the case to be move to federal court with no charge to the Plaintiff (the Plaintiff has a poverty affidavit on file). The Federal Courts address is as follows: (Please include all motions, orders, and correspondence of the case to the Federal court listed below) United Stated District Court Northern District of Texas 1100 Commerce street Room 1452 Dallas, TX 75242 This court even set trial date for Jan. 2020 and it has been rescinded on based on what the defendant request. Please remove the case to federal court for a trial by jury. This 24" day of August 2020. Erika Jacops PO Box 6252 Broomfield, CO 80021 602-434-3107 Jeneencat2@outlook.com Unsworn Declaration (Texas Civil Practice and Remedies Code, Section 132.001) | declare under penalty of perjury that: 1) | am the person asking to transfer venue, 2) | have read this Motion to Transfer Venue , and 3) the statements in this Motion to Transfer Venue are within my personal knowledge and are true be correct. My name is: Eon Saedhs my address is: Ox 6952 Street Address City State Zip Code and tek A } ('p §002 Country Formally signed under penalty of perjury in | Ay te a Sa {4 ounty,Lalls(oat V Ce County Stai on this date g yOH / 2D Month Day Year Signature of Party Asking to Transfer Venue Notice of and | am not'req sting an hearing. Certificate of Service | will give a copy of this document to each party in this case, orif a party is represented by a lawyer to the party’s lawyer, on the same day this document is filed with (turned in to) the Court as follows: If I file this document electronically, | will send a copy of it to the party or the party’s lawyer through the electronic file manager if possible. If not possible, | will give a copy to the party or the party’s lawyer in person, by mail, by commercial delivery service, by fax, or by email. If | file a paper copy of this document, | will give a copy of it to the other party or the other party’s lawyer in person, by mail, by commercial delivery service, by fax, or by email \\ Date 8-24-20 sna ote Party requesting venue transfer DSS Chor ®r tee, Smith, SharpeVitullo ip Texas A torneys Dallas Austin Houston Three Galiena Tower 13155 Noe! Road Suite 1000. Dallas. Texas 75240 P ae F 972-9 20 77-FEESMITH feesmith.com Christopher C. Sisk csisk@feesmith.com 972-616-7619 Direct Dial August 19, 2020 NOTICE OF HEARING Via Electronic Service, Regular Mail And Certified 9214 8969 0099 9790 1208 4199 43 Erika Jacobs P.O.Box 6252 Broomfield, CO 80021 Re: Cause No. DC-2003277; Erika Jacobs v. Greyhound Bus Lines Corpor ate Office; In the 298th District Court, Dallas County, Texas Our File No.: GRY.12103 Dear Ms. Jacobs: This is to confirm that Defendant’s Motion to Deem Plaintiff Vexatious is set for hearing on Friday, September 11, 2020 at 3:00 p.m. This hearing will be conduct ed via telephone conference. Please use the following conference call-in number: 1 Dial the toll-free #1-888-204-5987 2 Enter the access code 6980413 # 3 Press (#) to connect to the call Per the court, we will then connect, via telephone, with the Judge. Thank you. Very truly yours, DL Onf oe Christopher C. Sisk CCS/LMP cc: Coordinator, 298" Judicial District pe 30 392 gs eRe Qne ev ye SS = STE —|2 BS BH Ni == pp2somc =Zcgmo, Ef 90 Bze” OSC 2012 4 8 om> 30 301