Anthony Moore and Joann Moore v. David Subia
Anthony Moore and Joann Moore v. David Subia
Opinion
iS • , t
5 December2017 X 201] DEC-5 AM 9:21 Court of Appeals Fourth Court of Appeals District ^ ^ /// ' Cadena-Reeves Justice Center y'V V/\ C r^'tCk Dolorosa, Suite 3200 '. ^M ' ATTN: Court Clerk ^ •'' •' " San Antonio, TX 78205-3037 RE: Appellant BRIEF Appendix Updates for Court of Appeals Number 04-16-00786-CV Sir/Mam, 1. The enclosed information updates three areas regarding this case. Appellants have incurred additional out of pocket expenses and hours dedicated to defense of this case in the last four (4) months of AUG/SEP/OCT/NOV that are not reflected in Appellant's Affidavit of Case Preparation Administrative Hours as of 1 AUGUST 2017. and Affidavit of Case Expenses as of AUGUST 2017 resulting from an unexpected additional three and a half (3 Vi) months of extended litigation. These affidavits were filed with the Court as a BRIEF Appendix as well as part of Appellant's 18 AUG 2017 letter very respectfully submitting them as solemn affirmation statements declaring personal knowledge as described therein. Appellant will gladly declare same under oath for each as a sworn affidavit if directed by this Court.
2. Out of pocket expenses now exceed . Over hours have been invested in defense of this improperly instituted cause of action for which Appellants requested in their BRIEF Prayer for Relief a minimum remuneration "in equity" of S10.00 per hour totaling which this Court may deem to be much too low as appropriate compensation.
Appellee counsels are entirely and solely responsible for the Appellant's avoidable continued needless and wasteful out of pocket expenses and hours dedicated to defending this case.
3. No objection has been raised bv Appellee in over three and a half (3 V2) months to these requested awards. All "findings" by the Jury and Judge of the Trial Court have been challenged by Appellants as being invalid. Appellants expect to prevail in this case. As of Appellee's filed BRIEF on 6 NOV 2017 in response to Appellant's BRIEF, two challeneed issues of award of attorney's fees and unpaid rent arrearage allegation have been withdrawn bv the AppeUee leaving only the issue of proper notice in question that can be verified and decided in merely five (5) minutes as articulated in Appellant's REPLY BRIEF.
4. Appellants cannot be "repaid" for countless needlessly wasted hours of "lost time " of their "lives"—over seven and one half (7 (4) months of40-hour work weeks—and out of pocket expenses in defending their legal rights that would not have been wasted if Appellee counsels had not unethically pursued retaining unlawful attomev's fees of $5,000.00 and alleged unpaid rent—that have now 18 months later been withdrawn by Appellee counsel.
5. Appellee trial court counsel Kenneth E. Grubbs was content with unlawfully requesting and unethically imposing $5.000.00 in attornev^s fees debt against the Appellants that he was not entitled to receive—until the 6 NOV 2017 Appellee BRIEF therein voluntarily withdrawing the claims in response to Appellant's BRIEF. Appellee Appeal counsel Christopher Deeves could have easily made this same ethical decision of acknowledging withdrawal of entitlement in JAN 2017 when hired by Appellee, and review of this case, but did not. He is therefore complicit by agreement by also allowing the unlawful awards to continue to stand since his review of this case as of JAN 2017. Appellee counsels are entirely and solely responsible for the Appellant's continued needless and wasteful out of pocket expenses. Much damage has been done to the Appellants that cannot be "undone" by simple withdrawal.
6. It can sometimes be very difficult to collect a money judgment in Texas. Appellants requested remuneration and compensation as stated in their BRIEF Prayer for Relief to satisfy any judgment, of which nothing has been objected to by Appellee in over three (3'/i) months. In this case. Appellee David Subia is virtually judgment proof per his counsel's declaration within his BRIEF of Appellee's financial status. This provides little assurance that any voluntary payment of any judgment by Appellee will be made. Appellants provide this Court the enclosed Case Activity Inquiry sheet from the Bexar County Registry as of 1 DEC 2017 that reflects a total of $3.800.00 in funds deposited into the "fund" regarding this case.
7. Two amounts of $200.00 each within this total are Justice and County Court Appeal deposits.
This $400.00 actually belongs to the Appellants as it is not rental funds paid to the Appellee, and should appropriately be returned to the Appellants regardless of the outcome of this Appeal.
Appellants feel the remaining balance of $3.400.00 as of 1 DEC 2017 should be released and applied to satisfy any monetary judgment as addressed in their BRIEF Prayer for Relief. There are also two money orders for $200.00 each in the Court Evidence Folder that could be released to the Appellants as well to satisfy a portion of any monetary judgment against Appellee.
Respectfully submitted.
Appellant<^ro Se P. O. Box 340096 San Antonio, TX 78234 210-848-6250
Ends 1. Amendment of Affidavit of Case Preparation Hours.
2. Amendment of Affidavit of Case Expenses with copies of receipts.
3. Case Activity Inquiry information from Bexar County Court Registry.
AMENDMENT AS OF 5 DEC 2017 DUE TO EXTENDED LITIGATION TO; The below Rule 301 JUDGMENTS text and notice provided to Appellee within the Appellant's BRIEF on page 48 above the same quoted text as above. This claim for remuneration is reflected in Appellant's BRIEF Prayer for Relief. No objection has been raised by Appellee in over three and a half (3 ¥2) months. All "findings" by the Jury and Judge of the Trial Court have been challenged by Appellants as being invalid. As of Appellee's filed BRIEF on 6 NOV 2017 in response to Appellant's BRIEF, two challeneed issues of award of attorney's fees and unpaid rent arrearage allegation have been withdrawn b\ the Appellee leaving only the issue of proper notice in question. Appellants expect to prevail in this case.
AFFIDAVIT of CASE PREPARATION ADMINISTRATIVE HOURS AS OF 1 AUGUST 2017 AND "WAGES IN EQUITY" EXPLANATION The Pro Se Appellants respectfully submit to this Court the following claim for remuneration that they feel they are absolutely entitled to as "pecuniary damages" incurred in defending this cause.
The Pro Se Appellants' research determined "pecuniary damages" to be those that can be estimated and monetarily compensated. For example, actual lost hours of the Pro Se Appellant's life—approximately 31 weekslover seven and one half (7 V2) months of40-hour work weeks— dedicated to defense of this improperly instituted lawsuit litigation that they have termed "wages in equity." The Texas Rules of Civil Procedure Rule 301 JUDGMENTS is clear regarding the award of "equity." The following text is quoted. "The judgment of the court shall conform to the pleadings, the nature of the case proved and the verdict, if any, and shall be so framed as to give the oartv all the relief to which he mav be entitled either in law or CQUitv. Provided, that upon motion and reasonable notice the court mav render judgment non obstante veredicto if a directed verdict would have been proper, and provided further that the court may, upon like motion and notice, disresard any iurv finding on a question that has no support in the evidence." INO mandatory or timely received notices by §24.005, §91.001, Rule 21a(a)(b)(l), Rule 501.4(a)(2), and NO compliance with Rule 510.11 or §24.006 for award of attorney's fees. The Pro Se Appellants had also filed a Motion for JNOV, but the Judge would not hear of it.]
Appellants cannotbe "repaid" for countless needlessly wasted hours of "lost time" of their "lives"—over seven and one half (7 V2) months of40-hour work weeks—while defending their legal rights that would not have been wasted if Appellee counsels had not unethically pursued retaining unlawful attorney's fees of $5.000.00 and alleged unpaid rent—that have now months later been withdrawn by Appellee counsel. Appellee counsel Kenneth E. Grubbs was content with unlawfully requesting and imposing an improper award of $5.000.00 in attorney's fees debt that he was not entitled to receive—and Appeal Appellee counsel Christopher Deeves as well—until the 6 NOV 2017 Appellee BRIEF voluntarily withdrawing the claims. Appellee counsel Christopher Deeves could have easily made this same ethical decision in JAN 2017 when hired by Appellee but did not.
The below text reflects the amended addition of hours necessitated by Appellee for four (4) months of AUG/SEP/OCT/NOV 2017 dedicated to defense of this case. Two entries of originally submitted document are included for continuity purposes.
AFFIDAVIT OF HOURS EXPENDED
The undersigned to this affidavit states I have committed the below identified hours on these dates to the research of data, collection of data, assembling and preparation of data for correspondence and/or pleadings and mailing, travel to mail documentation by regular and certified mail, travel to Justice court to accomplish several tasks, travel to County Court to file documents and accomplish related tasks, travel to the Court of Appeals to file documents and accomplish related tasks, check hearing date status, make monthly rental payment into the Court registry, etc, in defense of the Justice Court forcible eviction and detainer case #41E1602559. new County Court case #2016CV04165. new Court of Appeals case #04-16-00786-CV. involving DAVID SUBIA, 5547 Bronco Billy, San Antonio, TX 78222. The undersigned states this is a true and accurate description of expended hours dedicated to defense of this improperly instituted legal action.
Very respectfully submitted.
Anthony is^ore Appellant; Pro Se P. O. Box 340096 San Antonio, TX 78234 210-848-6250
CUMULATIVE DATE HOURS HOURS JUL 13% 1,0221/2 AUG 16'/2 1,039 Below AUG/SEP/OCT/NOV 2017 hours i AUG 8 1,047 AUG 1 1,048 AUG 9 1,057 AUG 4'/2 1,061 1/2 AUG 13% 1,075 % AUG 8 1,083 % AUG 17% 1,101 AUG 14 1,115 AUG 11 % 1,126% AUG 1 1,127% AUG '/2 1,128% AUG % 1,129 SEP % 1,129% 18SEP 1 1,130% 19SEP V2 1,131 % SEP 4 1,135% SEP 9 1,144% SEP 4 1,148 % NOV 1 '/4 1,149'/2 lONOV lP/4 1,161 % NOV 8% 1,170 NOV 9'/2 1,179'/2 NOV 10 '/4 1,189% NOV 6'/2 1,196% NOV 1014 1,206% NOV % 1,207% DEC % 1,208 DEC 7 1,215 DEC 3% 1,218% DEC
31 JUL/Monday Spent 13 % hours continuing research, gathering information, organizing, assembling, and creating Appeal BRIEF. Updated index of authorities, appendix, proofread entire BRIEF and all enclosures, gathered documents for copying, etc. Below AUG/SEP/OCT/NOV 2017 actions are not reflected in the filed BRIEF Appendix.
1 AUG/Tuesday Spent 16 '/2 hours finalizing all editing of all documents, printing and photocopying ($71.45).
2 AUG/Wednesday Spent 8 hours finalizing all editing of all documents, printing and photocopying ($42.61), travel to and back from the courthouse to file BRIEF and pay the monthly $200.00 bond deposit/lot lease payment into the County Court registry. Also mailed a copy of the BRIEF by certified mail #7016 2710 0000 8328 8061 ($15.09) to Appellee attorney Christopher Deeves.
11 AUG/Friday Spent i hour on amending BRIEF directed by the Court.
12 AUG/Saturday Spent 9 hours on amending BRIEF.
13 AUG/Sunday Spent 4 '/2 hours on amending BRIEF.
14 AUG/Monday Spent 13 % hours on amending BRIEF.
15 AUG/Tuesday Spent 8 hours on amending BRIEF.
16 AUG/Wednesday Spent 17 Va hours on amending BRIEF.
17 AUG/Thursday Spent J4 hours on amending BRIEF.
18 AUG/Friday Spent 11 % hours on finalizing all editing of all documents, printing and photocopying ($45.21), travel to and back from the courthouse to file BRIEF. Also mailed a copy of the BRIEF by certified mail #7016 2710 0000 8328 8078 ($14.49) to Appellee attorney Christopher Deeves.
19 AUG/Saturday Spent i hour editing BRIEF after discovery of correcting a computer glitch that had somehow shifted most all page numbers making all cited citation references inaccurate. Called both the Court of Appeals and Appellee attorney Christopher Deeves' office informing them of the computer printing error and a corrected copy would be filed Monday morning, and this was done. Also prepared a letter to the Court informing them of this and my actions. No harm was expected as being mailed and discovered over a weekend and immediately re-mailed to Appellee counsel. Appellee counsel has never offered any objection in over three and a half (3'/2) months.
20 AUG/Sunday Spent hour travel, printing ($31.05), proofreading three copies of the corrected BRIEF for correctness, and preparation of certified mail to Appellee counsel.
21 AUG/Monday Spent % hour travel to courthouse to file corrected BRIEF and letter of explanation. Also mailed a copy of the corrected BRIEF by certified mail #7016 2710 0000 8328 8030 ($9.18) to Appellee attorney Christopher Deeves.
1 SEP/Friday Spent % hour going to the courthouse to pay the monthly $200.00 lot lease payment into the County Court registry.
18 SEP/Monday Spent 1 hour preparing letter to attorney Christopher Deeves about his client, David Subia, threatening us again on 5 SEP 2017 necessitating calling San Antonio Police again. SAPD Incident Report #2017-0967564.
19 SEP/Tuesday Spent A hour travel to courthouse to file letter at Court of Appeals with attached SAPD Incident Report #2017-0967564 regarding Appellee's threats. Mailed a copy of the letter by certified mail #7016 0600 0001 1412 3927 ($3.84) to Appellee attorney Christopher Deeves.
22 SEP/Friday Spent 4 hours preparing, printing, assembling, mailing, and filing a detailed Motion to Denv Appellee Motion for Extension of Time to File Brief as he has already missed several previously Court ordered deadline dates, and has not yet filed any request for extension. Mailed a copy of the motion by certified mail #7006 2150 0005 6650 8089 ($6.80) to Appellee attorney Christopher Deeves.
28 SEP/Thursday Spent 9 hours preparing Motion to Reverse Per Curiam Decision. It took this long to research, gather and consolidate the information, and clarify many misrepresentations made to the Court by Appellee counsel.
29 SEP/Friday Spent 4 hours finalizing motion plus printing ($12.65), assembling, mailing, and filing with the Court. Paid the monthly $200.00 lot lease payment into the County Court registry. Mailed a copy of the motion by certified mail #7016 0600 0001 1412 2852 ($6.80) to Appellee attorney Christopher Deeves.
I NOV/Wednesday Spent 1 Va hour going to the courthouse to pay the monthly $200.00 lot lease payment into the County Court registry. Discovered a second motion to extend time to file Appellee BRIEF had been filed. Filed a handwritten motion objecting to any more extensions due to apparent disregard for the Court by missing four (4) previous deadlines established by the Court.
Mailed a copy of the motion by certified mail #7016 2710 0000 8262 6802 ($6.92) to Appellee attorney Christopher Deeves.
10 NOV/Friday Spent 11 Va hours reviewing Appellee's BRIEF received Thursday. Made notes and began gathering information to prepare REPLY BRIEF to Appellee's BRIEF.
11 NOV/Saturday Spent 8J4 hours continuing preparation of REPLY BRIEF.
12 NOV/Sunday Spent hours continuing preparation of REPLY BRIEF. Finished P' draft. Reviewed and edited pages 1-12.
13 NOV/Monday Spent 1014 hours editing P" draft and typing changes to pages 12-24.
14 NOV/Tuesday Spent 6 '/2 hours continuing to edit and typing changes to pages 12-24.
Proofread 2"^ draft.
15 NOV/Wednesday Spent 1014 hours finalizing and proofreading 2"'' draft for editing before printing ($12.28). Created Certificate of Service and Certificate of Compliance for REPLY BRIEF. Hours included travel to print copies, organize, assemble, and prepare for filing and mailing.
16 NOV/Thursday Spent % hour travel to, at, and return from courthouse for filing the REPLY BRIEF and mailing a copy by certified mail #7016 0600 0001 1412 2869 ($7.92) to Appellee attorney Christopher Deeves.
1 DEC/Friday Spent % hour going to the courthouse to pay the monthly $200.(K) lot lease payment into the County Court registry.
2 DEC/Saturday Spent 7 hours preparing letter to the Court of explanation of Affidavit Updates, case expenses affidavit update, and hours affidavit update.
3 DEC/Sunday Spent 3_% hours finalizing the updates.
4 DEC/Monday Spent jg^hours finalizing the updates, travel to print copies ofcase expenses update, hours update, and letter to the (Tourt of explanation of Affidavit Updates, organize, assemble, prepare for filing, plus travel to, at, and return from courthouse for filing.
Respectfully submitted.
AnthonyMpdre Appellant<Tro Se P. O. Box 340096 San Antonio, TX 78234 210-848-6250 > Top Of roquoated caao Hat Bexar County Caah Infozmatlon Syateoa 1270i/26i7. ^ Toxaa Caao Activity Inquizy 14;13:i7 DPW Off: CO Sol: CA Opt: P_ Qual: Caao 8: 2016CV0416S_ Data: 02-01-2017 Case balancoa: Refunds . -oo AG Ho: Doc Typo R Ho. 22875S3 Archived Trust 3800.001^ CCaaiEHTS: Roceivablos .00 Act _ Style-Plaintiff DAVID SUBIA^ va Style-Dofondant ANTHOm, MOORE ET AL Court 3 Ln Date Type Document Referenco Amount Espl Adjusts Ad Data PA4 07-26-2016 BECP 2251563 242.00 38738 RD 08-02-2016 RECP 2253119 fiSft 200.00 38738 CS 08-02-2016 RBCP 2253129 1.00 38738 CS 08-05-2016 RECP 38193 CK 08-18-2016 RECP 2256292 40.00 38193 RO 09-02-2016 RECP 2259240 200.00 38738 MO 09-30-2016 RECP 2264667 200.00 38193 MO 10-07-2016 RECP 2265966 17.00 38738 CS 11-03-2016 RECP 2270882 200.00 38193 CS 12-02-2016 BECP 2276797 200.00 38193 ' CS 12-30-2016 BECP 2281623 200.00 38275 CS 02-01-2017 RECP 2287553 200.00 37724 CS 02-24-2017 RECP 2292110 6.00 37441 CS 03-03-2017 RECP 2293343 200.00 37724 CS 03-06-2017 BECP 2293800 5.00 38275 CS 03-06-2017 RECP 2293801 4.00 38275 CS 03-06-2017 RECP 2293806 -5.00 38275 2293800 03-06-2017 RE 03-31-2017 BECP 2298739 200.00 38275 CS 05-03-2017 BECP 2304729 200.00 38275 CS 05-24-2017 BECP 2309004 200.00 38864 CS 06-01-2017 BECP 2310252 200.00 38864 CS 06-30-2017 RECP 2315746 200.00 38864 CS 08-02-2017 RECP 2321765 200.00 38864 CS 08-02-2017 RECP 2321767 -200.00 38864 2321765 08-02-2017 RE 08-02-2017 RECP 2321768 200.00 38864 CS 09-01-2017 BECP 2327559 200.00 38864 CS 09-29-2017 BECP 2332373 200.00 38864 CS 11-01-2017 BECP 2338561 200.00 38864 CS 12-01-2017 BECP 2344146 200.00 10794 CS
Enter-PFl PP2- -PF3— •PF4 PPS- -PP6 PP7 PP8 PF9 PPlO—PPll—PP12 Holp Main Bknd Prwrd Exit AMENDMENT AS OF 5 DEC 2017 DUE TO EXTENDED LITIGATION TO; AFFIDAVIT OF CASE EXPENSES AS OF 1 AUGUST 2017
The undersigned to this affidavit states I have committed personal funds to the below identified expenses on these dates to travel to conduct research of data, collection of data, assembling and preparation of data for correspondence and/or pleadings; travel and to mail documentation by regular and certified mail; travel to Justice court to accomplish several tasks; travel to County Court to file documents and accomplish related tasks; travel to the Court of Appeals to file documents and accomplish related tasks, check hearing date status, make monthly rental payment into the Court registry, etc, in defense of the Justice Court forcible detainer and eviction petition case #41El602559. new County Court case #2016CV04165. new Court of Appeals case #04-16-00786-CV. involving DAVID SUBIA, 5547 Bronco Billy, San Antonio, TX 78222. Photocopies of receiptable items are enclosed. I.e., parking meters>no receipt, etc. These out of pocket expenses necessitated by Appellee counsels for Appellants to defend their legal rights would not have been necessary or wasted if Appellee counsels had not unethicallv pursued retaining unlawful attomev's fees of $5.000.00. and alleged unpaid rent— that have now—18 months later—been withdrawn by Appellee counsel. Appellee trial court counsel Kenneth E. Grubbs was content with unlawfullv requesting and unethicallv imposing $5,000.00 in attorney's fees debt against the Appellants that he was not entitled to receive— and Appeal Appellee counsel Christopher Deeves as well—until the 6 NOV 2017 Appellee BRIEF voluntarily withdrawing the claims. Appellee counsel Christopher Deeves could have easily made this same ethical decision of acknowledging withdrawal of entitlement in JAN 2017 when hired by Appellee, and review of this case, but did not. He is therefore complicit by agreement by also allowing the unlawful awards to continue to stand since his review of this case as of JAN 2017. Appellee counsels are entirely and solely responsible for the Appellant's continued needless and wasteful out of pocket expenses.
Black's Law Dictionary defines Actual damages as—An amount awarded to a complain ant to compensate for a proven injury or loss: damages that reoav actual losses. The Pro Se Appellants provide the below detailed listing of actual out of pocket expenses during this extended litigation. [This claim for remuneration is reflected in Appellant's BRIEF Prayer for Relief. No objection has been raised by Appellee in over three and a half (3'/2) months. The below text reflects the amended addition of case expenses necessitated by Appellee for four (4) months of AUG/SEP/OCT/NOV 2017 dedicated to defen.se of this case. Two entries of originally submitted document are included for continuity purposes.]
30JUL $ 2.18 Photocopies for BRIEF.
30 JUL $ 10.00 Fuel used for necessary travel to, at, and back from courthouse, make photocopies, and accomplish other administrative tasks.
TOTAL SI.276.05 Below AUG/SEP/OCT/NOV 2017 expenses are not reflected in the filed BRIEF Appendix.
1 AUG $71.45 Photocopies of Appellant's BRIEF and enclosures for filing at Court of Appeals.
2 AUG $42.61 Additional photocopying of Appellant's enclosures for filing at Court of Appeals.
2 AUG $ 15.09 Certified mail #7016 2710 0000 8328 8061 to Appellee attorney Christopher Deeves providing a copy of Appellant's BRIEF and enclosures and 5 Motions.
3 AUG $15.00 Replace fuel used for necessary travel to, at, and back from courthouse to make photocopies, pay rent into Court Registry, mail certified mail, and accomplish other administrative tasks.
18 AUG $45.21 Photocopies of amended BRIEF for filing and mailing.
18 AUG $14.49 Certified mail #7016 2710 0000 8328 8078 to Appellee attorney Christopher Deeves providing a copy of Appellant's BRIEF.
20 AUG $31.05 Photocopies of corrected amended BRIEF for filing and mailing.
21 AUG $9.18 Certified mail #7016 2710 0000 8328 8030 to Appellee attomey Christopher Deeves providing a corrected copy of Appellant's BRIEF.
25 AUG $10.00 Replace fuel used for necessary travel to, at, and back from courthouse to make photocopies, mail certified mail, and accomplish other administrative tasks.
19 SEP $ X.XX Photocopies of seventh warning letter to attomey Christopher Deeves that he needs to advise his client David Subia to stop making threats to us. (Lost receipt) SEP $ 3.84 Certified mail #7016 0600 00011412 3927 to Appellee attomey Christopher Deeves providing a copy of seventh warning letter that he needs to advise his client David Subia to stop making threats toward us.
22 SEP SXX.XX Photocopies of Appellant's Motion to Deny Appellee's Motion To Extend Time to File his Brief for filing and mailing. (Lost receipt) SEP $ 6.80 Certified mail #7006 2150 0005 6650 8089 to Appellee attomey Christopher Deeves providing a copy of Appellant's Motion to Deny Appellee's Motion To ExtendTime to File his Brief.
25 SEP $20.00 Replace fuel used for necessary travel to, at, and back from courthouse to make photocopies, mail certified mail, and accomplish other administrative tasks.
29 SEP $12.65 Photocopies of Motion to Reverse Per Curiam Decision for filing and mailing.
29 SEP $ 6.80 Certified mail #7016 0600 0001 1412 2852 to Appellee attomey Christopher Deeves providing a copy of Appellant's Motion to Reverse Per Curiam Decision.
1 NOV $ 2.00 Photocopies at the Courthouse of Appellee's Second Motion to Extend time.
3 NOV $ 1.55 Photocopies of Appellee's Second Motion to Extend Time and my Motion to Deny for mailing.
1 NOV $6.92 Mailed a copy of my motion by certified mail #7016 2710 0000 8262 6802 to Appellee attorney Christopher Deeves.
10 NOV $20.00 Replace fuel used for necessary travel to, at, and back from courthouse to make photocopies, mail certified mail, and accomplish other administrative tasks.
12 NOV $4.24 Photocopies of 1" draft of REPLY BRIEF for review and editing.
15 NOV $12.28 Photocopies of REPLY BRIEF for filing and mailing.
16 NOV $7.92 Certified mail #7016 0600 0001 1412 2869 to Appellee attorney Christopher Deeves providing a copy of Appellant's REPLY BRIEF.
16 NOV $10.00 Fuel used for necessary travel to, at, and back from courthouse to make photocopies, mail certified mail, and accomplish other administrative tasks.
TOTAL S 1.645.13
4 DEC s Photocopies of letter to the Court of explanation of Affidavit Updates, case expenses update, and hours update.
TOTAL
I certify the above is a true and accurate record of actual out of pocket expenses incurred during defense of this legal action.
Anthonj Appellant, Pro Se P. O. Box 340096 San Antonio, TX 78234 210-848-6250 TPi4864409it-O01 CORNER STORE 1027 5239 RIGSBV CO SftN RNTONIO ^TS 7822 OS CJN -g s r~ m *;;1 ,< ^ [if ••'.
0 o> 0 s*-' O' (O 0 C0 g-. 1 tZ-^o :C M ' DftTE 08/03/17 rMM e = ' V</>. — CO TIME 7:5l| RM •'4'. CO ft-K I i» scr Oj,1 1— •)g=^^= V.'e)-' RUTH# 2396J<9 • .2.- C|I , -I w c;^ • Vi^ ,.tl.j to i- oi.3j F* M PIN US« y r- o —t- -H Of ro ja» ^ .-jj to ig r3 3 01 ;•'> ' .. oT 0 DEBIT y (A- 1
MOORE /JO RHH ' I* ;; 01 CO 1= :^:s y ^-d j,;i /'-I tJl 1 i: ui, S;m PUMP PRODUCT PPG -g c^= 3i". ! ? ?i 00;
r#Co (71 tn 10 UHLD $2,199 ,-. u ".Jl.o 0 0 o 0 (J> •Xj -ON Cf» 09 CJT 0\ GRLLOMS FUEL TOTAL 6.822 j, $15.00 rI Ia^ ^ m ui O O o o -g ON ;r -• & •; ^ 5^ 5J 5^3'* c; r.! o. ,--
ARSENAL O O -HI =• Q) O IWO S LAREDO ST Qi Vl 3 3" &> SAN ANTONIO la ^ rn«c/5 o o fO TX A-Q 3-f 3" X <D 3> O Q> CJlO'-f II — C "O — Z 3 < 7820'1-9998 (OC : fl> 3 ® to (D SCO ) D. Ift O 3" ^ V) 4879520204 *o 5 ) Q.
Q| © ^ Z ^ r4 08/18/2017 (800)275-8777 5:09 PM o f09 ) < Q.rooo Z oor- M -g o CO (D O* O II CO CO 00 z coc \ — g*^ N> (/> »JO a^n o — o o 3> cn Product Sale Fina O s CO < •x. <0 • O)* -3 11 w roho I IZI—mj Description Qty Pric ui:d .•-* K) 3 o »-* 1(^0(0 II t f l f o t o 0:0 zmi— 0)0 o II I O (O »-HO : ^ C3 N CO II co^CO 00 Utl Mir 10,5" 1 " $1.19 ro-^ q; w < to c-> II II ^ (/> xl6" •<NnJ to I. -g —4 (Unit Price:$l.l9) I PM 1-Day 1 $7.20 .^O 1-^ |i (Domestic) •(O.Oj! <J\\ . . ^31 1 It It cn (SAN ANTONIO. TX 78232) —'Oi Ol <oi CO *^l tol — — 3 IT M (Welghtrl Lb 1.20 Oz) 0 Q> — i |i z |i (Expected Delivery Day) (Saturday 08/19/2017) Certitled 1 $3.35 (OeuSPS Certified Mail «) (70162710000083288078) Return 1 $2.75 Receipt (0iUSPS Return Receipt #) (95909402168^053612022) ••> - i 3> —I — in < < CJ ON o^ 3k C/> :0 C3 C/I •g eg ui' r - $14.49 "D 09 » <3 ON fO rrl O O 3- 0 S Z O O •0 O e *0 $15.00 < o o D « ^ o so ($0.51) 3 OO C TO e ro TJ 3-' o o » o tn (/) 3 -t> O tt. c». O) t/> in m: (s». o 00 3 •— C ^ UI rtt o CL nt ^ o r— 0 tfi Description •_ CO ^ o w o c ni C 0- tn ^ ^ ^ ^ 3 to vD ft 01 Ci a 49 a - IM •— X — e 3 c •w cn PREPAY CA #04 G 0 . (/) !
0^ Subtotal 10.00 Tax 0.00 '^»^^TOTAI_ lO.OO ui OJ M ro —' fO 00 00 4^ Corner Store 2464 O cr> o cj) M -g OS M ro CO 1703 N New Braunfel CO
San Antonio, TX Corner Store 2464 Corner Store 2464 ST# 2464 TILL XXXX DR# 1 IRAN# 1026815 08/25/17 18:28:01 PAcelt ARSENAL 3sS .ei# jp - 1140 S LAREDO ST ARSENAL SAN^ANTONIO TX 1140 S LAREDO ST SAN ANTONIO ?rio;i San (iSiifjf? 3®8):33356«f :"' I 78204-9998 TX . 4879520204 78204-9998 ;d9729728;if7;_4iti9 jiioi'.ir.' I iwfijv' yOliuC! ri;.V •-...•rit... . j 08/21/2017 {800>275-8777 9:07 AM 4879520204 i lilii in 09/22/2017 (800)275-8777 2:30 PM Product Sate Final 2TVTYA4PUX5BBYUUU Description Qty Price Product Sale Final Description First-Class U $3.08 Qty Price SALE . \.;'2'3¥d-^r89l'7^^^ Mail First-Class' i $0:70" 163061. InP|ression, BUS .
Large Envelope Mail i6;Vo.i2,!:,'|;;;;:;fe;i (Domestic) Letter 4 You Pay 1.92SS; • (SAN ANTONIO. TX 78232) /2> (Domestic) (Weight-.O Lb 10.50 Oz) (SAN ANTONIO, TX 78^32 167060 BU SS.iLetter . • (Expected Delivery Day) (Height:0 Lb 1.30 Oz) 27 e 0.14 3.78 (Wednesday 08/23/2017) (Expected Delivery Day) You Pay 3.78SS Certified 1 $3.35 (Monday 09/25/2017) 5.99 SS 997542 FMW.CLASP,6x9, (ggUSPS Certified Mail «) Certified l $3.35 (70162710000083288030) (iSUSPS Certified Mail #) ^ .iSdyotal: 11.69 Return 1 $2.75 (70062150000566508089) Sales Tax: 0.96 .
Receipt Return 1 $2.75 Tdfal: 1 12.65 (88USPS Return Receipt #> Receipt 20.00 (9590940216866053612121) (SSUSPS Return Receipt #) , (9590940219366123463839) Total $9.18 CHANGE: (7.35) Total $6.80 Cash $20.00 Change ($10.82) ~$io76o" AMF SAN ANTONIO Change ($3.20) 10250 JOHN. SAUNDERS RD SAN ANTONIO , TX J FRANK DOBIE • ' ^78246-9998 4950.E HOUSTON ST , 4879500240 09/29/2017 (800)275-8777 7:42 PM 78220-9998 4879620220 Product Sale Final 09/19/2017 (800)275-8777 10:54 AH Description ^nJty * Amount Description Qty Price PREPAY CA #06 ^ ^ 20.00 $0.70 Product 'Sale Final Mail Description Oty Price Letter Subtotal 20.00 (Domest i c) First-Class 1 $0.49 (SAN ANTONIO. TX 78232) Tax 0.00 Mail (Weight:0 Lb 1.80 Oz) Letter 20.00 (Expected Delivery Day) (Domestic) 20.00 (Monday 10/02/2017) (SAN ANTONIO, TX 78232) Certified 1 $3.35 (WeightrO Lb 0.70 Oz) (S0USPS Certified Hail #) , (Expected Delivery Day) Corner Store 1027 (70160600000114122852) (Thursday 09/21/2017) 5239 Rigsby Avenue Return 1 $2.75 Certified 1 $3.35 San Antonio TX Receipt (SSUSPS Certified Mail ») T# (027 TILL XXXX OR# 1 TRAN# 1014449 (90USPS Return Receipt #) (701^0600000114123927)' > (9590940216866053612145) 6 09/25/17 11:52:26 Total $3.84 Total $6.80 IsToo" Cash $50.00 Change ($1.16) Change ($43.20) CD C? y.tn- • ^ U(/>rC U < CM 'CMi>CM- V O
rTCeived from nmt/'W DOLLARS OEOR RENT W"— Cffpi'KA CASH ACCOUNT
PAYMENT i FI^OM MONEY a i ORDER I BAL DUE ©card'^ I bV ilV| DATE. liTL No. 553766 FORT SAM HOUSTON 1$ \ .Q0 2492 STANLEY RD RECEIVED FROM. JBSA FT SAM HOUSTON TX nO-- .DOLLARS P/OR RENT/^fy^l*^^\ ylO/ao/i-T 1^, '•-^^^^'^'^4879570234 11/01/2017 {800)275-8777 12:42 PM Qcash I ACCOUNT Product Sale Final iSjcHECK ^ .TO, Description Qty Price PAYMENT 1. CD ©SS lynvi/O Folk Art PSA # 1 $0.61' BAL. DUE 10 {Unit Price I$0.61) First'^^Class 1 $0.70 Mail Description Qty Amount (SAN ANTONIO, TX 78232) CM.' iO PREPAY CA #05 20.00 (Height:0 Lb 1.30 Oz) (Expected Delivery Date) (Friday 11/03/2017) _ Subtotai 20.00 Certified 1 $3.35 M a.,/ Tax 0.00 (80USPS Certified Mail #) TOTAL 20.00 (70162710000082626802) Return 1 $2.75 $ 20.00 RocslpX (90USPS Return Receipt #) kEH# 'Corner Store 2293 (9590940233107196286891) •3603 SE Miiitary Dr Affixed 1 ($0.49) Postage ....a San Antonio, TX (Affixed Amount:$0.49) Qf-tn ST# ^293 TILL XXXX OR# 1 TRAN# 1033689 :CSH: 2 /cyv&^ju^ 11/10/17 14:17:07 Total $6;92' Cash $10.00" Change ($3.08) HIGHLAND HILLS SAN ANTONIO 3918 CLARK AVE SAN ANTONIO TX -i ^ 78223-9998 4879610223 3b-.0006 11/16/2017 (800)275-8777 8:34 AM !i;)l iOi ? SSSSSSSSSSSSSSSS5SS5SSSSSSSSSSSSSS==== =S===5SSS55S5S5SSSSdSSSSSS=S==: San Antonio - (210) 333-6400 • ^ Product Sale Final 11/15/201,7 8:42 PM , Description Oty Price First-01 ass 1 $1.82 so:"' "I TaflPRHX345YBEU Large Envelope (Dontestlc) SftLE 2350-<-5690-882151^r7i8'.2' (SAN ANTONIO, TX 78232) (HeightrO Lb 5.00 Oz) 167060 BUSS Letter' " n G (Estimated Delivery Date) e 0.15 12.15 (Saturday 11/18/2017) Bulk 60.14 -0.81 Certified 1 $3.35 (KUSPS Certified Mai) #) You Paa 11.34SS " (70160600000114122869) Subtotal: 11.34 Return 1 $2.75 ..Sales-Tax;^, , 0.94 Receipt {891ISPS Return Receipt #) (9590940216866053612138) Total $7.92 ^7.f- SSBh $20.00 Ctiange ($12.08)
Description (^L Qty Amount PREPAY CA HOI 10.00 c>fiFpce:.^]c Subtotal 10.00 'f J)e<7 Tax 0,00 TOTAL I D . GO caasiP $ 10.00 Corner Store 2292''^ ^ 3151 3W White Rd San Antonio TX SID 2292 TILL XKXX DRS I TRAN# 1037932 CSH: 9 11/16/17 08:11:47
Case-law data current through December 31, 2025. Source: CourtListener bulk data.