RE: 14-00203-CV TWELFTH COURT OF APPEALS

TRIAL COURT CASE: 12-1808-D SMITH COUNTY TEXAS

IN THE MATTER OF FILED IN COUP! OF APPEALS THE MARRIAGE OF 12thCouri rAoi strict LINDA C. TATE I • i

Mil fj5 2015 III AND /ill] / \L-—•• LARRY DONELL REDDIC SR. CATHY S. LL'k ' CLEfK \

MOTION FOR LEAVE TO FILE ANSWER

TO THE HONORABLE TWELFTH COURT OF APPEALS NOW COMES Appellant Linda C. Tate (pro se, with a head injury, limited disabilities askthe Courts to forgive if not in proper form) brings this Motion for Leave to File Answer in support to show the Courts the following reason to be Granted: On 6/27/2012 a. The suit for this trial court case 12-1808-D was filed on June 27, 2012 by Appellant Linda C. Tate in pursuit of the required dissolution inthe 13 of 19 year Marriage (Now) of Linda C. Tate and Appellee Larry Donell Reddic Sr. at the advice of the Social Security Administration. IRS Code 6013 Section Publication 501. TFC 2.401

Linda C. Tate states that husband abandoned their 11 year marriage of 17 (then).

Husband left and disappeared after leaving the residence in Winona, Texas. TFC 6.005 Weeks later Linda C. Tate heard that husband Larry Donell Reddic Sr. stood in a church house with a woman he met off the internet saying "he do", he do what? Without divorcing through the judicial system like the IRS and the Social Security Administration and Law says must do. TFC 6.202,Tex. R. Civ. P. 504a(4)(c) Section 25.01 Penal Code On 7/11/2012 (1) Linda C. Tate hired counsel Fletcher a. Counsel was given on 1st day of hire over 100+ documents retrieved from home in Winona, Texas, mostly High Seals of Authority documentations due to her being a US Veteran and husband being an employee of the State of Texas. b. The 100+ documents given day of hire were expected to be filed with the courts in case of fire, lost, or destroyed. Today technology of e-file filing can be done from an office. c. Linda C. Tate hired counsel to dissolve marriage and protect her interest in her community assets. d. Counsels of Linda C. Tate after 18 months recently found and unaware of three (3) Scheduled Orders. Linda C. Tate was only informed by counsel of the missed 4/16/2013 and 1/14/14 Scheduling Orders. She wasn't or had no knowledge of the Scheduling Order 8/20/2013. See Scheduling Orders of trial court case 12-1808-D e. $18,800 paid by Linda C. Tate to her counsel from 7/2012-12/2013, although counsel wanted/demanded an additional $15,000 (requested by lead counsel) by 12/16/2013, and (co-counsel requested) an additional $25,000 ifthere was a need to go to trial which was weeks away on 1/14/14. f. Counsels stated to Linda C. Tate if they didn't get the requested excessive amount they would have to walk off the case. $40,000 in weeks of trial. Linda C. Tate did give co-counsel the $500 that her son had sent her from overseas at war for Christmas in hope that he would stay on the case. g. Linda C. Tate could not meet neither request she being disabled and on a fixed income.

h. Linda C. Tate has Borrowed Out from a lot of people regarding this case and to find out key evidence (Texas State 2002 employee tax statement with Winona, Texas 75792 on it) was being held from client, i. Once the return of the 100+ given evidence on 12/23/2013 from Fletcher, she later found goingthrough everything Ifound the Texas State W-2 awayfrom its original presentation on the next to the last page in Linda C. Tate's Deposition that was held 7/16/2013 as if hidden, j. Knowing that Larry Donell Reddic Sr. had to produce the Texas State 2002 employee tax statement with its original presentation during request of production, what Linda C. Tate wants to know is how long her counsel Fletcher had that information that had been hid from client, k. The Internal Revenue Service Code 6013 Publication 501, Orders of the Court and their Authority has been disregarded, laws and Rules by counsels, TFC 2.401, Social Security Administration and the Law.

On 7/16-17/2013 a. Oral Depositions through the Orders of the Court was taken Under Oath of Linda C. Tate and Larry Donell Reddic Sr.

On 12/18/2013 (3). The Discovery Completion Order was to be complied by 12/18/2013. Linda C. Tate still had legal counsels on 12/18/2013. The Final Mediation Order was also on 12/18/2013. See Scheduling Order for 3rd Setting of 1/14/2014. a. Husband counsel Tina Brumbelow knew Linda C. Tate still had counsel b. Lead counsel of Linda C. Tate withdrew on 1/6/2014 c. Co-counsel of Linda C. Tate withdrew on 1/8/2014 d. No Notice or Motion to the Courts for the noncompliance of Scheduling Order in the Discovery Completion on 12/18/2013 was ever entered byTina Brumbelow.

The Motion for NO Evidence Summary Judgment should have went to hired counsels of Linda C. Tate based on time frame, still had hired counsels.

1. The Final Mediation Order was also on 12/18/13 to be held at (Appointed Mediator) Beau Sinclaire Law Office, located at 400 Broadway Ave., Tyler, Texas 75702 2. Neither counsel, Tina Brumbelow, Fletcher, Healy or Larry Donell Reddic Sr. complied to the Courts Order on 12/18/2014 3. Tina Brumbelow, did not tell Judge Carole Clark about her noncompliance of the Scheduling Order for the Final Mediation also on 12/18/2013 held at (Appointed Mediator) Beau Sinclaire Law Office, 400 Broadway Ave., Tyler, Texas 75702. Neither counsel nor Larry Donell Reddic Sr. Complied with any of the Scheduling Orders on 12/18/2013.

4. Linda C. Tate was the only one showed appearance for the Scheduling Order for the Final Mediation on 12/18/13. She had no knowledge of the Discovery Completion compliance at all.

5. Mr. Sinclaire stated to Linda C. Tate that he had been waiting on counsels Brumbelow and Fletcher and Healy to contact him to confirm their appearance of Order but no contact was made by either counsel on the Order of the Courts.

On 12/23/2013 a. Linda C. Tate received in the return of most of the 100+ documents given to counsel Is day of hire to be filed and presented to court, the proof to the existence of 13 year Marriage of 19 in order to achieve the dissolution in such matter. b. Upon the review of returned items witnesses statements and photos were not returned and Leslie lead counsel of Linda C. Tate's assistance said she would call once found but to this day no call or notice c. Linda C. Tate found the Texas State 2002 W-2 employee tax statement of Larry Donell Reddic Sr. that he produced in discovery (key document) that had Linda C. Tate's residence address of 16397 CR 363, Winona, Texas 75792 on it. d. Husband Larry Donell Reddic Sr. stated under oath inthe Court Ordered Deposition held on 7/17/2013 that he never lived at 16397 CR 363 Winona, Texas 75792, stated that he never received mail there. That 2002 is the attachment to their signed return filed with The Internal Revenue Service under the status "Married Filing Joint". Copy of the original filed with attachments. Linda C. Tate had a copy of 2002tax return but no attachments.

On 1/6/2014 a. Linda C. Tate lead counsel withdrew from trial court case 12-1808-D.

On 1/8/2014 a. Pre-trial... six (6) days of Scheduled trial on 1/14/14. b. Co-counsel withdrew from trial court case 12-1808-D. c. Linda C. Tate officially became Pro Se. d. Linda C. Tate filed the 100+ documents of High Seals of Authority from State of Texas, US Department of Treasury Internal Revenue Service, Veterans Affairs, Social Security Administration,TexasState Office of Attorney General, Texas Department of Public Safety,Texas Rehabilitation Commission, Texas State Troopers Association, Pre-filed sealed documents, Notarized witness statements, copies of pages of deposition under oath with responses to perjury of husband were among the filings on 1/8/2014. Tex. R. Civ. P. 902 e. Linda C. Tate prepared three (3) black bindersfor the Courts (which she filed), three (3) for husband's counsel Tina Brumbelow and three (3) for herself. f. Linda C. Tate tried to give Brumbelow her three (3) binders but her office refused Linda C. Tate from bringing her the copies to her office which is a block from Smith County Court House. g. Linda C. Tate waited for Tina Brumbelow's approval outside Smith County Court House for hours to take her the binders but she never did and the sleet was beginning to fall is why she went back and file the 3 for the Courts On 1/14/2014 a. Trial date of Third (3rd ) Setting of trial court case 12-1808-D

On 2/14/2014 a. TWO MONTHS LATER, Husband's counsel Tina Brumbelow filed a Motion for No Evidence Summary Judgment against Linda C. Tate according to Motion for the noncompliance to the Scheduling Orders ofthe 321st Dist. Court on 12/18/2013. b. The Discovery Completion Order was to be complied by 12/18/13 when Linda C. Tate had legal counsel Fletcher and Healy. c. This Motion is days from beingtwo months after the noncompliance of the order on 12/18/2013 and should have been place on Fletcher and Healy counsels of noncompliance to the order before their withdrawal dates of 1/6/2014 and 1/8/2014. d. "Judicial Bullying" attack on pro se litigant, with comprehension limitations (now), disabled spouse seeking for her rightful entitlements according to Law On 2/19/2014 a. Linda C. Tate sent certified via return receipt from the USPS to husband counsel Tina Brumbelowon 2/19/2014. The three (3) black binders that Linda C. Tate had been trying to get to her after she avoided every attempt from Linda C. Tate. Receipt Return shows Tina Brumbelow received the three(3) black binders and a letter stating to Brumblow about the filing of Linda C. Tate on 1/8/2014 on 2/20/2014 USPS recording.

On 3/10/2014 a. The No Evidence Summary Judgment Hearing held at the 321st District Court. This Motion should have not been allowed before the Courts on the grounds of Entrapment b. There were filing of 100+documents mostly of High Seals of Authority filed by Linda C.

Tate on 1/8/2014 but was denied during NESJ because Judge Carole Clark stated that all three (3) binders of High Seals of Authority given to Court, taken into 321st Dist. Court possession, returned back to her at a later date of 1/14/2014 by 321st Dist. Court clerk Sara clerk were not accepted into the Courts because of an affidavit. Tex. R. Civ. P. 901a(7), Rule 902(1)(2)(4)(5)(8)(10)(11) c. In the trial court case: 12-1808-D Index Discovery Document No. 236 posted-ins by Court clerk Sara stated that "Mrs. Reddic filed a lot of exhibits along with her divorce decree but not on docket)-Sara-(was on this morning docket on 1/8/2014. d. Judge Carole Clark asked Linda C. Tate did she "respond", to the Motion for No Evidence Summary Judgment, she stated "No". Linda C. Tate wasn't aware of which one the responsewas addressed to, The Courts or Tina Brumbelow counsel for her husband Larry Donell Reddic Sr. Linda C. Tate having a head injury her processing ability is somewhat limited. Tex. R. Civ. P. 902(1)(2)(4)(5)(8)(11), Rule 705(a), Rule 801e(3), Rule e. Linda C. Tate did send the filing by her on 1/8/2014 to Tina Brumbelow on 2/19/2014 by USPS certified return receipt on 2/20/2014. f. Linda C. Tate mistake was thinking the filing of 1/8/2014 had been recorded after given back and the filing was okay to be presented before the Courts. g. She didn't understand what the Judge wastalking about or who she was referring to.

She do know that she filed on 1/8/2014 and sent Tina Brumbelow her copies (3) black binders on 2/19/2014 by certified return receipt. h. Final Judgment Entry for the Motion for No Evidence Summary Judgment was entered in husband Larry Donell Reddic Sr.'s favor but violates TFC 2.401. Tex. R. Civ. P. 166a(i), IRS Code 6013 Section 501 Publication On April 2014 a. Linda C. Tate's son of 18 months of war overseas hired Allen Law Firm of Dallas Texas for his mother to assist in the needed dissolution in her 13 year marriage of 19 to Larry Donell Reddic Sr.

On 5/30/2014 b. Allen to ask the Courts to grant Linda C. Tate a New Trial, Motion to Reconsider No Evidence Summary Judgment, Motion to Leave to File Answer, Motion for Expedite Hearing before June 3, 2013 c. Upon Allen's request to the courts she sent all the filing of requested Motionsto Larry Reddic Sr. served by authorized server as required by law. d. Because of the request of Linda C. Tate, Tina Brumbelow at Larry Donell Reddic Sr.'s request to file a Sanction against Cynthia Allen and Linda C. Tate for requesting the Motions to the Courts that was presented only in the pursuit of Justice and Law, not to harass or cause increase in cost of husband.

On 6/3/2014 The Final Judgment on Motions for New Trial, Motion to Reconsider No Evidence Summary Judgment, Motion to Leave to File Answer, Motion for Expedite Hearing before June 3, 2014 and the Sanction against Linda C. Tate and Cynthia Allen counsel for Linda C. Tate filed by Larry Donell Reddic Sr.'s counsel, T. Brumbelow at his request in trial case number: 12-1808-D was entered on 6/3/2014.

a. Tina Brumbelow stated to Judge Carole Clark that Linda C. Tate and Allen request was frivolous in seeking Justice b. Tina Brumbelow stated to Judge Carole Clark that Linda C. Tate and her counsel had husband Larry Donell Reddic Sr. properly served by an authorized server was in violation because they knew she was Larry Donell Reddic Sr's counsel c. Judgment Entry for trial court case: 12-1808-D was entered on 3/10/2014 d. There was No Notice of Appearance of Tina Brumbelow to the Courts after Judgment Entry of 3/10/2014 according to 321st Dist. Court Coordinator Vicki Dunn e. According to the Discovery Document Filed on 11/21/2012 of Larry Reddic Sr.'s Response to Linda Tate's Rule 194 Request for Disclosure on page 12, question #4 states " attorney fees with cease to accrue when the final judgment entry is entered in this matter" which was on 3/10/2014 f. Linda C. Tate and counsel had every right to serve Larry Donell Reddic Sr. as required by Law.

On 7/3/2014 Linda C. Tate went to the 321st District Court, Smith County, Texas on 7/3/2014 to file appeal with the courts at 4:32p.m.

a. Two Smith County Deputies denied Linda C. Tate entry into the Smith County Court House because everyone had gone home they stated to her due to the observance of Independence Day on Friday 7/4/2014 they said. b. Closure hours of Smith County Courts were on normal Business Hours 8-5pm for 7/3/2014. Most employees left early. c. Linda C. Tate did not know the Courts would be closing early before 5:00 pm. on 7/3/2014. Some employees were still there, only a few cars around the Court house It wasn't 5:00 p.m. Linda C. Tate had over twenty-five minutes to file her appeal according to the scheduled closing time of the Smith County Court House at 5:00p.m. d. She sat outside of the Court House with Smith County's newest hired clerk of the 321s as she waits for her ride.

On 7/72014 Linda C. Tate had to wait to file her Appeal to the 321st District Court on Monday 7/7/2014.

The Smith County library clerk stated to Linda C. Tate "that she stayed until 5:00p.m.Thursday 7/3/2014 nor was she aware of everyone above her had left early for the day on 7/3/2014, they never tell her anything" when asked about closing hours on 7/3/14.

Linda C. Tate, have tried within her due diligence to do her best being pro se with learning disability due to head injury and lack of knowledge in the civil procedure.

Never has she intentionally neglected any process in this proceeding in pursuit of justice which has consumed her daily life since 2012 along with health issues.

FACTS

1. Linda C. Tate filed the petition for the divorce on 6/27/2012 at the advice of the Social Security Administration Regional Manager of the Texas Northeastern Div. on 6/26/2012.

2. Linda C. Tate could have taken the same document the 2002 joint tax return of Larry Donell Reddic Sr. and Linda C. Tate given to her from the Internal Revenue Service Office and presented it into the courts herself.

3. Federal and State laws requires the lawful termination of the marriage it should be finalized.

4. Linda C. Tate hired counsel to protect and stop the abuse against her interest in their community property in the dissolution of marriage but received neither.

5. The request of more extreme excessive amounts of monies is what Linda C. Tate has received from hired counsel Fletcher.

6. Linda C. Tate paid $28,800 total in pursuit of Justice and Law regardingthe required by law dissolution of Marriage in this Matter which shows that Fraud with the intent to delay justice has consumed this case.

7. The Texas Family Code 2.401, The internal Revenue Service Code 6013 Section 501 Publication status filing "Married Filing Joint", the Social SecurityAdministration also states a divorce from the legal judicial system is needed.

8. Linda C. Tate had to become an attorney, a. go through all filings of 18 months, b. prepare a case with no information for former counsels on what they didn't do, c. know the Rules of Civil Procedure in two months, d. know everything licensed attorneys with years of schooling don't know about the procedures required e. Iam onlya disabled wife with a head injury tryingto seek justice and the reliefinthe dissolution of the marriage between Linda C. Tate and Larry Donell Reddic Sr.

According to the TFC 2.401, a. Agreed to be married b. Co-habitation c. Holding out Internal Revenue Service Code 6013 Publication 501 on status "Married Filing Joint" states that when couples file under the status of "Married Filing Joint" they are agreeing that they are legally married and all information is accurate and both must sign. As husband and wife they did so for years. Social Security Administration warns that Linda C. Tate and Larry Donell Reddic Sr. must divorce and if Linda C. Tate choose to commit bigamy like husband she too would be guilty of the same, also they would have to have a copy of the top page of the divorce decree in order to terminate the marriage between Linda C. Tate and Larry Donell Reddic Sr. out their system.

APPELLANT, LINDA C. TATE, prays that this Honorable Court will grant this Motion as a Matter of Law and Justice.

Respectfully submitted,

Or )A C. TATE-PRO-SE

16397 CR 363

WINONA, TEXAS 75792 (903) 312-7446 Email: [email protected]

Certificate of Service

I certify that a true copy of the above was served on each attorney of record or party in accordance with the Texas Rules of Civil Procedure on January 15, 2015. .inda C. Tate, Pro Se

Payment Receipt

Healy Law Offices, P.C.

113 E. Houston St Tyler, TX 75702-8130

Received From: Tate-Reddick, Linda Tate, Linda

4ft Date Received 12/16/13 Payment Amount $500.00 Payment Method Check Check/Ref. No. 1301

Invoices Paid

Date Number Amount Applied 07/18/13 2013-303 -$500.00

e+v,-\M <\5f

Page 1 CAUSE NO. 7 dUS'" 0-

C ^&kzMi,dMj(L-- IN THE DISTRICT COURT

32,"57 JUDICIAL DISTRICT sy\ -0 /J';rJ--f' % SMITH COUNTY. TEXAS SCH EPIJUNG ORDER

Based on !he information available to the Court, the following schediilinsi order shall apply to this case unless modified by the Court. If no date is given below. the Item is goverv/t'ifyy ,bit'^'vxi^vkthv^^)'!rZ''^'}, 9,i\vew!/uK..

THIS CASE IS DESIGNATED LEVEL jf -&0~ i3_DISCOVERY COMPLETED BYTHIS DATE - Attorneys may by agreement extend discovery; however, the trial dale shall remain firm. ? i. B-mo- . MEDIATION AND SETTLEMENT CONFERENCE COMPILED BY THIS DATE - If the case involved a Parent-Child Relationship. "PUTTING 'KIDS FIRST' MUST BE COMPLETED BY THIS DATE. Also, ifcustody "is an issue a full day of mediation is required.

$i in® /'? (r STATUS CONFERENCE will be held af/ O'clock .M.

P'fcETWi *xLC»HIr'EWL'>VC1E -mVi 'r..e YreAs!. a't C^o ^ •^^ -O ClOCI 7T .M. Trial counsel are ORDERED to attend and be prepared lo discuss all contested aspects of the suit and trial 5. f lb~l£ FI.NALTRIAL will be held ;u ty'.#> O'clock ^ /t ,M.

6. Absent agreement. fc.m&t% , M'^^^Ms appoinje d mediator in this case. You hYiysi' cvwrtVixY said mediator by

SIGHED rVMD E.CTLWLQ,'««,'l?Hvf?ft, W ./iiuy^iCI <&• M \

JUDGE PRESIDING IE SO. /&*/<&*-& § IN THE DISTRICT COURT § 52fSr/uTJfCLA£ DfSTRfCr tddtls^A. I SMITH COUNTY. TEXAS.

SCHEDULING ORDFk

Based on he information available to the Court. the following scheduling order shall apply to this case unless modified bv [he Coun [f no dare Is given below &ejtes&&groaned ty fte'fejitt States*gCivil ProecdaR: THIS CASE IS DESIGNATED LEVEL • DISCOVERY —'---'-''-•-- • -w"-1 COMP1 FTRJIRYT^ifc t_*-Mviri_.cji_i,» riATc 3i uiio OAJ >- E —Attorneys may cv agpsoneafi tsand^imay.tamc^^traA fere s'naV; remain firm. fr

fl • ED BY THIS DATE -- [f me case involved aParent-Child Relationship "PUTTING <IDS FIRST" MUST BE COMPLETED BY trfs HATE Also 7iL**> is an sssue a ti ll Jay of mediation is required. j. __ STATUS CONFERENCE will be held at r>-'ciock KJ

,J 4$m€j frJetS PRETRIAL CONFERENCE will be held at 7'*^ O'clock C-: '3 ' ^Z /f ..M. Trial counsel are ORDERED tn attend £mJ fee swani .v> v*^- • - ai! contesied aspects of die suit and trial.

;-e He '•" . O CtOCK ~ .Jvi.

4W &,iLa/3 o. Adsent agreement.,. — is appoirted mediator in this case. You must contaci s.aid mediator"hy

SIGNED AND ENTERED on (his the j^_ _ day of

JUDGE PRESIDING CAUSE SO. P~ IU^-<-

§ IN THE DISTRICT C*fcVf Itfl §

y SCHEDULING ORDER

order shall apply to this case unless modified by the Court. Ifno date is given below.

Jt^VTHIS CASE IS DESSGS'ATEOLEVEL .

0J^ S &\ a^jee ment extend di scovexv:. bow'e.ver...tha trial, dare shall tssBmmJmxL.. ^ JM&. {±£^0J3 MEDIATION AND SETTLEMENT CQKEESEM^ COMPILED' BY THIS DATE -- It the case involved a Parent-Child Relationship. •FC Ji T\\u 'tODS FIRST WC51 BE COMPLETED BY THIS DATE. Also, ifcustody "is an is si is a lull day of mediation'is required.

S, H^'i'3,9-0B STATUS OXVFEREIVCE wrtT 6e lieitfat "/' >SO O'clock C .M.

4- U* $£. :3 PRETRIAL CONFERENCE will be held at # '-^ 0 O'clock U T~ -M- Trial counsel are ORDERED to attend and beprepared to discus.* all contested aspects of the suit and trial.

/?' 5lJfrvJf£dJ3 FINAL TRIA]_ w5j] be held at Y,\3D O'clock A .M.

6. Absent agreement,<&±t ^ ; ''^H appointed mediator in this case. You SIGNED AND ENTERED £» Ms the (jj &r gf ^iflf<M.(wu &Q&

J.. ,-,, r j JUDGE PRESIDING^ NO. 12-1808-D

IN THE MATTER OF § IN THE DISTRICT COURT THE MARRIAGE OF § 3*lst 9iatCXAl,QlS.T8XCT LINDA C. TATE § AND § LARRY REDDIC, SR. § SMITH COUNTY, TEXAS INDEX - PLEADINGS

NO. Date Document 1. 06/27/2012 Petitioner's Original Petition for Divorce - L\h<U> 2. 06/27/2012 Civil Case Information (do not haveX - Ltndtu 3- 06/27/2012 Citation Issued (do not have) - JU/t«*-*> 4- 07/05/2012 Respondent's Original Answer 5- 07/06/2012 Citation Returned Served (do not have) 6. 09/^8/2012 Appearance (do not have) :.': ^.7---C ii/i'5/2012 Rule ii Agreement (do not Have) 8. 12/07/2012 Motion (do not have) : 9....-"":: 12/14/2012 Scheduling Order 10. 02/13/2013 Letter (do not have) 11. '•'.: 63/15/(20x5 •rvevnrest AV/ory- Trial (da not haw} 12. 04/03/2013 Motion for Continuance (do not have) KpZfafofof 13. 04/08/2013 Motionfor Continuance (do not have) / (E>rb,n\bel6& H- 04/10/2013 Scheduling Order (do not have) 15- 05/10/2013 Mediation Letter (do nothaye) 16. 06/28/2013 Petitioner's 1stAmended Petition for Divorce •"• ;i7-^'-: 08/06/2013 Joint Motion for Continuance -- ft&fah** 18. 09/17/2013 Scheduling Order 19- 09/18/2013 Letter (do not have) 20. 12/23/2013 Motion to Withdraw (do not have) — "f(x^h^ 2X- jV.27/2013 Motion for Continuance (do not have) 22. 01/03/2014 Docket (do not have) 23. 01/06/2014 Order to Withdraw (do not have) - ^(/thlf^tr 24. 01/0B/2014 Docket Sheet (do not have) 25- 01/08/2014 Motionto Withdraw (do not have) —' tfa&aA* G****f4, 26. 01/08./2Q14 Order to Withdraw (do nothave) - MvAjq - &* <Ow&tJ , / Index Pleadings - Page 1of 2 In the Matter ofthe Marriageof Linda C. Tate and LarryReddic, Sr. - No. 12-1808-D Petitioner Respondent Joint Docs Court Unidenfied Party 27. 01/08/2014 Petitioner's Judgment Entry Decree of Divorce (not on docket) 28. 01/14/2014 Notice of Setting - Jury Trial (3/11/2014) 29. 02/14/2014 Respondent's Motion for No Evidence Summary Judgment 30. 02/14/2014 Respondent's. (Qvdesi Setting,fJearAn^ojo. Motion,fox No. Esodfmrjt Summary Judgment) 31- 03/^2014 Court's Events and Orders of the Court 32. 04/09/2014 1Petitioner s Mbtibn for New Trial 33- 04/09/2014 Petitioner's Motion for Leave to File Answer and to Reconsider Motion for No Evidence Summary Judgment 34- 04/10/2014 Petitioner's Correspondence to Court requesting Hearing Date 35- 04/14/0214 Petitioner's Notice of Hearing (Motion for Leaveto File Answer and to Reconsider Motion for No Evidence SummaryJudgment) 36. 04/15/2014 Petitioner's (Attorney Cynthia Woolen Allen's Notice ofVacation or Unavailable Dates) 37- 05/12/2014 Petitioner's (AttorneyDarlene Darensburg Noticeof Vacationor Unavailable Dates) 3s. oshSi'ao&q Petitioner's Motion to Setteide FhxdJudgmenton No Evidence Motion Summary Judgment Pursuant to TX Rules of Civil Procedure 3o6(a)(3)(4) and Request for Expedited Hearing Prior to June 3, 2014 39- 05/:i4/2oi4 Citation Return - Service on Larry Reddic 40. 05/230/2014 Lany Reddic's Motion for Sanctions 4i- 06/02/2014 Petitioner's Response to Motion for Sanctions

Index Pleadings - Page 2 of 2 Inthe Matter of the Marriage of Linda C. Tate andLarry Reddic, Sr. - No. 12-1808-D Petitioner Respondent Joint Docs Court Unidenfied PartV NO, 12-1808-D

IN THE MATTER OF § IN THE DISTRICT COURT THE MARRIAGE OF § LINDA C. TATE § 321ST JUDICIAL DISTRICT AND § LARRY REDDIC SR § SMITH COUNTY, TEXAS

LARRY DONNELL REDDIC SR.'S RESPONSES TO LINDA C TATE'S RULE 194 REQUESTS FOR DISCLOSURE

To: Linda C.Tate, by and through her attorney ofrecord, Natalie Fletcher.

In accordance with the Texas Rules of Civil Procedure, Larry Donnell Reddic Sr. serves the written Responses to Rule 194 Requests for Disclosure pursuant to Rule 194 of the Texas Rules ofCivil Procedure on the party named above.

Tina High Brumbelow '^ggpr P.O. Box 7677 Tyler, TX 75711-7677 Tel: (903) 533-1339 Fax: (903) 592-6684 [email protected]

faA/- Tina High Brumbelow; State Bar No. 24031890 Attorney for Larry Donnell Reddic Sr.

Certificate of Service

I certify mat a true copy of the above was served on each attorney of record or parry in accordance with the Texas Rules ofCivil Procedure on November 21,2012.

Tina High Brumbelow

Larry Donnell Reddic Sr.'s Role 194 Request for Disclosure Pagel Cause No. 12-1808-D: 1TMOTMO Reddic 6. the nature and length off the professional relationship with the client: and 7. the experience, reputation, and ability of the lawyer or lawyers perforating tiie services.

Further, Larry Donnell Reddic Sr. may rely upon any and all legal theories and, in general, tiie factual bases ofthe claims or defenses ofLinda C Tate that may benefit Furthermore, Larry Donnell Reddic Sr. reserves the right to supplement and/or amend this discovery response, in accordance with the Texas Rules of Civil Procedure, with additional information and/or documentation, if any, as it becomes available.

4. State the amount and any method ofcalculating economic damages.

Larry Donnell Reddic Sr. has incurred legal fees reasonable and necessary to prosecute and/or defend this suit Attorney's fees will continue to accrue until the entry of final judgment in this matter. Copies ofredacted statement will be made available for copying and inspection upon reasonable notice to Tina Hfeh Brumbelow at210 S. Broadway, Suite #200, Tyler, TX 75702. ^^ Larry Donnell Reddic Sr. said attorney's fees, court costs, and aU otiier damages are within the jurisdictional limits of tiie court. The method of calculating these ^ESA'T1 mutophed J" *eofSCt by the house f6e performed work for °f ** byattonM*' Pa^tegM, the attorney, or support paralegal staff or support staff. Said fees continue to increase over time.

Further, Larry Donnell Reddic Sr. reserves the right to supplement and/or amend tinsdiscovery response, in accordance with the Texas Rules ofCivil Procedure, with additional information and/or documentation, if any, as it becomes available.

5. State the names, addresses, and telephone numbers ofpersons having knowledge of relevant fects, and give abrief statement ofeach identified person's connection with the case.

1. Larry Donnell Reddic Sr. c/o: Tina Brumbelow P.O. Box 7677 Tyler, TX 75711 (903)533-1339

Larry Donnell Reddic Sr.'s Role 194 Request for Disclosure Came No. 12-1808-D; 12-lMfLn- 1TMOTMO rrunmtn Reddic »~a*~ p-^« r*8e ** CaaseNo.

CAUSE NO. 12-1808-D

IN THE MATTER OF § IN THE DISTRICT COURT THE MARRIAGE OF § § 321st JUDICIAL DISTRICT LINDA C.TATE § AND § LARRY REDDIC, SR. § TYLER COUNTY, TEXAS DISCOVERY INDEX MEDIATION

No. Pleading Served Response 1. MEDIATION NOTICE - FROM SINCLAR LAW OFFICES 04/10/2013 TO NATALIE FLETCHER AND TINA BRUMBELOW (5/9/2013 @ 8:00 AM) 2. DISPUTED ISSUES CHECKLIST 05/2013 3- CONFIDENTIAL INFORMATION SHEET 05/2013

ST RESPONDENTS i AMENDED MOTION TO COMPEL DISCOVERY RESPONSES - PAGE 1 DF-i3-04i47-S-255th ITMOTMO: Mark Cooks v.Cyntiiia Cooks U.S. Posta! Serv'ce-*.

CERTIFIED MAIL** p- <a (Domesf/c Mail On)>; ivo /nswawa Coverage froviaea) m rq For delivery information visit our website at www.usps.comg m TY@ |P7fai| £ § i*4 8 **S j*a p» m p- P- _o j Postage S $0.98 0712 Certified Fee Certified Fee $3.30 Oi a Postmark 2 Return Receipt Fee a Return Receipt Fee E3 (Endorsement Required) a (Endorsement Required) $2.70 Here a Restricted Delivery Fee &0.00 KDt-iO^ -far q Restricted Delivery Fee (Endorsement Required) a (Endorsement Required) 16.98 P* Total Postage &Fees j$ p- Total Postage & Fees $ 02/19/2014 r^ m Sent lb- m ^"TTn*. 6rtAr*6cUc«J a L'n0u Gru™b*i'>ii} /LfatJ &i\1?.^:.. a p- '3SSS,7iptNai . si or PO Box Ho. jCJto j. 5^^^^.£f£. r- SENDER: COMPLEX • Complete items1,2, and3. Alsocomplete item 4 if Restricted Deavery Is desired. • Printyour name and address on the reverse so that we can return the cardto you, • Attach thiscard to the backofthe maiipiece, OB. ltaJjflUanyi«jWMi^JTrai«,,|iiffll|,.lj)teTI1^y Ofte 11. JMIulfa46iHiHiyMHrifttTr CTWr TTnoL. 'Bnxmbtlo^ |_flmi OP?«» „• lib' S. Sfwdftfc*) 5-fe.'HP /m /^Tr^yoa. 3. ServicoType ,gCertifledMaB P Depress MaH CTRagfatered • Return Receipt fwMerchandise D Insured Mafl Pc.fiD. ' * 4. Restricted Delivery? (Bdra Fee) Q Yes 2. Article Number ffa<Mfer/)w>sefvfoefa6ep 7013 1710 0000 lb73 52flb j PSForm 3811, February 2004 DomesticReturnReceipt —" lOSSfrOMMMO:

SENDER: COMPL • Complete items 1,2, and 3. Also complete item 4 if Restricted Delivery is desired. • Printyour name and address on the reverse so thatwe can return the card to you. • Attach thiscard to thebackofthemallplece, B. Recetadby' S^ • Agere D Addressee

or crithe frorrttf space p^rrrrite. v 2$% 1. Article Addressed to: D. t3otfivBryacatessdBwsrt fromHam 1? PYfes lfYE&entardellveryadrJres3below: DNo Ima, 3rum be/t<J Uu)b&> \^ ltd <s. $w*w si- t*° aType I CortiQodMaS a D Registered P Return ReceptorMerchandise D InsuredMafl Oaoj, /••-••- 4. Restricted Defray? (Btoaffeej a\es 2, Article Number Qtensfcr from service label) 7013 1710 0000 lb?3 1367 PS Form 3811, February 2004 Domestic Return Receipt 10258S-02-M-154Oi

• Complete Items 1,2, and 3.Also complete tern4 if Restricted Osfiwsy fe desired. D Agent • Print yournameandaddress onthe reverse D Addressee sothatwecanreturn thecard to you. • Attach this card totheback ofthemallplece, Q. Date of Delivery or on the frontIfspace permits.

1- ArUda Addressed ta D.lsdeSveryadi±es3o3lBrBmiiornrtarn1? Ptts IfYES, enterdettvery addressbelow: Plto !< ej

a^nvteeTypo ^Certified MaS •Express Mafl P Registered D Return Receipt tar Merchandise

Z. ArticleNumber (TfenarBrftwHsenfcchtiet) j PSForm 381I.February 2004 -0-1-3_i7iLQ D0D0 it?3 i3«m rjomestleReturn Receipt""" *--•••>• 102685KK*HS40: ~*Sofi2-18Q9-D Linda CTatc-Reddic 16397 cr 363 Winona, TX 75792 (903)312-7446

Dear Ms Brambele**.

Iam responding toyour Motion for Ho Evidence Summary Judgment; and Order Settling Hearing on Motion for f<?0 Evidence Summary Judgment setfor March 10,2014 at 9;30a.m. '' r Jtji. -3 +

,- -T»f^-«Jf-«a4 v - ^-—.a- r- ^. ^.^^ - „^_^ ^^.j^s: ^1%-iJiaviB rnadese\'eralattempts to'give^ou my evidence Kut youdidn*t show'upfo/me j-

^ S?^^45^?*»^^s^ s l«mv^uid^Bofe>uf^:## /O-£••' • •' -A^ •''3 '-'~d " '•-''

ij s.-i't..:.••] .,• /'/ /f+r/fcssJ 9'01- &z-74-tjc

U)tAC '• <2. :¥Uw(k£n^

\Jt, ant AJUifttuL<AUL 'O Jf-"u^) <- n 6. _fy '•jLU* / T

^6. JLk«*. nuJ'u*'** ffrrfj^ title! fiU^ £i«djl4LOU kef***} ^"^ ^j. ',

<U*. d% 1

/o <b Complete items 1.2, and 3. Also complete item 4 if Restricted Delivery Is desired. .E your name and address on the reverse so that wecan return the cardto you. B. Receh/ed by(Printed Name) C. Date of Delivery BAfecX card to the back ofthe mallplece, 7/7 ' - oron thefront if space permits. DIs delivery address differentfrom item 17 OYes - " • tf YES. enter delivery address below: LJ no ArticleAddressed to: t .

3. Service Type JrfCertified Matt8 D Priority Mail Express" D Registered D Return Receipt for Merchandise • insured Mail D Collecton Delivery l) HtfT11£« O* kfQetK.I *J W¥. &&&% "4 Restricted Denver/? (ExtraPee; DYes -4) APT <u*i6e»*Cl£ L " 2. ArticleNumber (Transfer from sendee tebej) : PSForm 381I.July 2013 No. Type of Document t*4&r *T/ Post-It Notations later become an issue.

236. Binder (black) - Linda C. Tate-Reddic (Plaintiff) - •Mrs. Reddic filed a bunch ofexhibits Continuous of Exhibits in with her "Judgment Entry Decree of Divorce)—Sara (was on this mornings docket 01/08/2014) 237- Oral Deposition ofLinda Tate • Lotsa post-it notes July 16,2013 Volume I of II 238. Oral Deposition of Linda Tate •

JJi%ir^]2affiD3 239. Oral Deposition of Larry Reddic • Deposition summary July 17,2013 Volume I of I

\£)6-<>MMU*J' ULkjliLt^ V^l (iMj^L^^p*^ BILLING DATE (MM/DD/YY): 03/08/03 SEQUENCE NUMBER: 0095021624 CASE NUMBER: 4568814451 CAUSE NUMBER: 972731D MEMBER ID: 02855158 #ttut tft tijc Storm? Enteral Utate of Qfexatf Chilb Support ©itriBion Greg Abbott Attorney General NCP 0095021624 030803 0000570 00194608 ll...i.l.l.l...ll.l....l.l.l.l.l,..l...lll,„ll,l„l,„l,l„ll LARRY REDDIC 16397 COUNTY RD 363 WINONA, TX 75792-5717

| IThe following are your child support obligations: CHILD SUPPORT PAYMENT PLAN 1 MONTHLY

Pay this amount for April: S420.00 MESSAGES TOTAL PRINCIPAL TOTAL INTEREST TOTALARREARS FUTUREPAY AMOUNT 5801.25 50.00 S801.25 S0.00 YOU ARE RESPONSIBLE FOR REMITTING YOUR CHILD SUPPORT PAYMENT UNTIL YOUR EMPLOYER BEGINS WITHHOLDING.

BULLING STATEMENTS WILL NOW REFLECT INTEREST OWED IFYOU £\€8H4DA PAST DUE SMjWCE ISTATE LAW PROVIDES THAT INTEREST ISOWED WHENEVER ANY CHILD ; SUPPORT PAYMENT IS OVER 30 DAYS LATE. | ALLPAYMENTS DUE AFTER SEPTEMBER 1.1991 WILL ACCRUE ! INTEREST IF NOT PAID ON TIME.

VF"fWttK^ttWT3CCSTiar^T<ETSHR^ INTEREST OR ARREARS OWED. PLEASE CONTACT THE OFFICEOF THE ATTORNEY GENERAL AT 1-800-252-8014 OR YOUR LOCAL CHILD SUPPORT UNIT. - EXHIBI

Menial Revenue Service ^ United States Department ofthe Treasury sss

This Product Contains Sensitive Taxpayer Data Account Transcript Request Date: 11-02-2012 Response Date: 11-02-2012 Tracking Number: 100147669809 FORM NUMBER: 1040 TAX PERIOD: Dec. 31, 2002

TAXPAYER IDENTIFICATION NUMBER: XXX-XX-XXXX SPOOSE TAXPAYER IDENTIFICATION NOMBER: XXX-XX-XXXX

LARRY D REDDIC « LINDA C TATE

ANY MINOS SIGN SHOWN BELOW SIGNIFIES A CREDIT AMODNT ACCOUNT BALANCE: 0.00 ACCRUED INTEREST: 0.00 AS OF: Sep. 03, 2007 ACCRUED PENALTY: 0.00 AS OF: Sep. 03, 2007

ACCOUNT BALANCE PLUS ACCRUALS (this is not a payoff amount): 0.00

** INFORMATION FROM THE RETURN OR AS ADJUSTED **

EXEMPTIONS: 05 FILING STATUS: Married Filing Joint ADJUSTED GROSS INCOME: 49,538.00 TAXABLE INCOME: 32,688.00 TAX PER RETURN: 3,212.00 SE TAXABLE INCOME TAXPAYER: 0.00 SE TAXABLE INCOME SPOUSE: 0.00 TOTAL SELF EMPLOYMENT TAX: 0.00

RETURN DUE DATE OR RETORN RECEIVED DATE (WHICHEVER IS LATER) Apr. lz, 2.

PROCESSING DATE

TRANSACTIONS

CODS EXPLANATION OF TRANSACTION CYCLE BA22 g&s&zm- 150 Tax return filed 20032008 05-26-2003 $4,112.00 n/a 18221-082-81104-3 806 W-2 or 1099 withholding 04-15-2003 -$7,673.00 846 Refund issued 05-26-2003 $3,561.00 This Product Contains Sensitive Taxpayer Data

CWA0093 ij U ••fciifii5' yj '~±' -<•;

,/<L 1040 U.S. Individual Income Tax Return 2002 (99) WSUsaOrty—Oon«wril» orH3* Intro sp»ca.

Rpyti»yBirJw.VO«.3l.aK^orctf^taiawbaflrWno .M0a.«na%i9 .20 OUSNo. 15454)074 abel T Your fist Mino sod taflbl Last name i Your socbl security Bumbar LARRY REDDIC ! XXX-XX-XXXX •f a joint catun\ cpousete fist LastnsiDM Spousal social ncmtty nurabw xucoons.)

LINDA TATE XXX-XX-XXXX the IRS Horw3doYen(mnabaandsteeq.tf>ouha«aP.abatseeiis«ng8ons. Apt no. Important!

PO BOX 130040 You must enter sse print Can iwn or postafltoe.state, and ZIPcode. 8 youtew a foreign address, see instructions. yourSSN(s) VPe.

TYLER TX 75713 sfttafflat V You cttoftCampaign k Not*. Ctredongnrer^ notcternge your iaxw n ly] n rj] ie instructions.) f Doyou.ofyewspouseif<ffingaJoirtre»un\viartS3togoaai{stunii7 » Li Yes liu Mo UYeslfhlNo ifJSirtgle 4|j Head of household (with qualifying person), gee fnstr.) ling Status • ^uaffy<aj p*y<oft is^craMbutiK^^rOiirocpcngBn^ wttr 1X1 Married CHng jointly(even ifonly onehad income) tttts ohAfs <*aroc hore. •*• eckonly 3 pi Married fBng separately. Enterspouse's SSNabove sbat L_l and full name here. •» sQ QliatrfyingvndaN(er)'r^depe spouse dted »» ).(Seeinstrs.)

6a fx] Yourself. If your parent (or someoneelse) can ctaim you as adependent on his or hertax cmcksdon -.emptions f—, return, do not checkbox 6a b [XJ Ho. of chBdren Dependents: (2) Oopondofifs onGcwtto: sooorisecuitpnumbar IQlJIiomHpIO ft) Firs ram* Last ram* VOU * thr*d*r&iyou 2 SHALINDRIA TATE XXX-XX-XXXX Daughter tore than ftve KIRBY TATE dMnosihra wBSt - jenaents, XXX-XX-XXXX Son you Am to dtvttti s instructions. LAVASIO TATE XXX-XX-XXXX Son

d Total number of e>emptions daaned 30-"e Wages, sa&ries. tips, etc MaehFtamMmt TawMe interest. Attach Schadule B if required act>- rmsW-2and b Tax-exempt interest Do notinclude on tine8a 18b | 0 2Ghere. 9 OroTrarydwMends-AttacnScheoUtte 8 ffrequired a attach 10 TaxaMe refunds. etBdfls. oroffsets of stateandlocal income taxes(see instructions) 10 rm(s)1099-R 11 Aimany resented 11 «W3S 12 Business income or (toss). Attach Schedule C or C-EZ . . . 12 hhetd.

13 Capital gain or(toss). AttachScheo^DtTmturre& Ifnot require^ *• Q 13 14 Othergainsor(tosses). AttachForm4797 1* outfidnot 15a IRAolstivnitlons |1Saj Jb Taxable amount(see instructions) 15b a W-2. : insbuctions.

16a Pensions andanmiities 116a j 0| b Taxable anwunt (see instructions) 16b 17 Recrtal real estate,re^atties, partnerships. Scwpor^^ 17 dose, but do 18 Farm income or(loss).AtiachStiieduleF 18 attach, any •merit Abo, 19 Unemployment compensation 19 3seuse 20a Social security benefits, |20a| | b Tawbtearnount (see instructions) •m104O-V. 21 Otherincome. Listtype and amount(see rhstructtbns) 22 AodtrwarttourttsintherarrigMccninuifbrfi^ 23 Educate expenses (see irrstnictmns) Ijusted 24 lr^otocHK^(fjee instructions) some 25 Student loan interestdeduction (see instructions) 26 TutUon and fees deduction (see tnstructioris) 27 Archer MSA deduction. Attach Form 8853 28 Movingexpenses. Attach Form 3903 29 On&te» of sa&enrjjJoyment tax AttachSchedule SE 30 Setf-employedhealthinsurancededuction(see instrac&tms) 31 Serf-emptayedSEP. SIMPLE, andaaHfed plans 32 Penalty on eanyvdhdnawai of savings 33a Alimonypaid b Recipients SSN »- 34 Add Eries 23 through 33a Subtract Ene 34 from fine 22.Thisis your adjustedgross income ForDisclosure, Privacy Act and PaperaorkRtMtuc^

CWA0094 DGlfSS^ ^CP] NO. 12-1808-D 2013 km -6 PH «: 02 IN THE MATTER OF § IN THE DISTRICT COURT THE MARRIAGE OF SM1TH c;0' IMTY TEX3S BY_ § LINDA C. TATE-REDDIC TpOtT 321ST JUDICIAL DISTRICT AND § LARRY REDDIC, SR. § SMITH COUNTY, TEXAS JOINT MOTION FOR CONTINUANCE

This Motion for Continuance is brought by Linda C. Tate-Reddic, Petitioner, and Larry Reddic, Sr., Respondent, who show in support: 1. This case is set for trial on August 20, 2013.

2. The parties and attorneys attended a mediation on May 09, 2013 with Beau Sinclair as mediator. The mediation was halted to allow the parties time to gather more information and to schedule depositions.

3. The depositions have been completed and the parties are ready to resume the mediation.

4. This continuance is not sought solely for delay but that justice may be done.

Linda C. Tate-Reddic and Larry Reddic, Sr. pray that the Court grant the Motion for Continuance.

NATALIE FLETCHER S. Vine Avenue Tyler, TX 75701 Tel: (903) 592-0055 Fax: (903) 592-6677 s^^1 N&eftie' Fletcher <2*z- State Bar No. 24058362 Attorney for Petitioner

Signed on. ?U/i3 TINA HIGH BRUMBELOW P.O. Box 7677 Tyler, TX 75711 Tel: (903) 533-1339 Fax: (903) 592-6684

r.^h^J^nM^^ By: Tina High Brumbelow State Bar No. 24031890 Attorney for Respondent, Signed on. f^y/3 I, the undersigned attorney of record, swear under oath that the above Motion for Continuance is true and correct.

Attorney for Linda CITate^R R eddic

SIGNED under oath before me on $J(& /*) VmIl£oLZ^ Notary Public, State of Texas I, the undersigned attorney of record, swear under oath that the above Motion for Continuance is true and correct. ^ Tina High Brumbelow Attorney for Larry Reddic, Sr.

SIGNED under oath before me on W/3 s .

Notary Public, State of Texas