STATEMENT OF JURISDICTION

The Supreme Court has jurisdiction to issue a Writ of Prohibition/Mandamus against a district judge under Section 22.002(a) of the Government Code and Article V. Section 3 of The Texas Constitution.  

ISSUES PRESENTED

ISSUE ONE  

            Is it an abuse of discretion for Judge Fry to order a Rule 3.12 TRDP restitution of funds to Complainant Collins from WorldPeace when Complainant Collins is barred by res judicata from suing for restitution and therefore the Commission is also barred from suing for restitution for the Complainant under Rule 4.06A TRDP?  

ISSUE TWO  

            Is it an abuse of discretion for Judge Fry to order a Rule 3.12 TRDP restitution of funds to Complainants Lang, Fraser-Nash, and Williams in the underlying lawsuit when no funds issue were submitted to the jury regarding TDRPC Rule 1.14(a), 1.14(b) and 1.14(c)?  

ISSUE THREE  

            Is it an abuse of discretion for Judge Fry to award a Rule 3.12 TRDP restitution of funds as sanctions regarding Complainant Lang after severing WorldPeace’s counterclaims for fees against Lang from the underlying disciplinary petition? 

TO THE HONORABLE JUSTICES OF THIS COURT:

STATEMENT OF FACTS

On June 20, 2000, WorldPeace sued Collins in Cause Number 2000-31108; John WorldPeace v. Johnell Collins, 281^st District Court, Harris County, Texas.  (Record “7”)

On October 27, 2002 , Collins filed her First Amended Answer and Counterclaim which did not include a counterclaim for restitution but only claims for Declaratory Judgment and Sanctions against WorldPeace.  (Record “1”)

On September 20, 2002 , the WorldPeace v. Collins lawsuit went to trial.

On March 10, 2003 , the Judge of the 281^st District Court signed and entered a final nunc pro tunc judgment for Collins.  (Record “31”) There was no reference in the Final Judgment to any claims by Collins against WorldPeace for restitution because Collins made no such claims.  (Record “31”)

On April 14, 2003 , the underlying Commission for Lawyer Discipline v. WorldPeace lawsuit went to trial on the Commission’s Second Amended Petition.  (Record “12”)

On April 23, 2003 , Judge Fry signed a Judgment for Disbarment

On June 23, 2003 , Judge Fry signed an Order Setting Aside the April 23, 2003 , Judgment for Disbarment.

On August 27, 2003 , Judge Fry signed a Judgment for Disbarment against WorldPeace.  (Record “126”)  In that Judgment for Disbarment, Judge Fry awarded restitution of funds to Complainants Collins, Fraser-Nash, Williams and Lang.  (Record “5,6”)

On August 27, 2003 , Judge Fry signed an Order of Severance severing out WorldPeace’s counterclaims against Lang for attorneys fees. (Record “133”)

There was a finding of Rule 1.14(a), 1.14(b) and 1.14(c) TDRPC violations by the jury regarding Complainant Collins.  (Record “48”)

There was no questions submitted to the jury regarding Rules 1.14(a), 1.14(b) or 1.14(c) for Complainants Lang, Fraser-Nash or Williams. (Record “43”)

On September 26, 2003 , WorldPeace filed WorldPeace’s Second Amended Motion to Vacate or Modify Judgment of Disbarment of August 27, 2003 . (Record “197”)

On September26, WorldPeace filed Respondent WorldPeace’s Third Amended Motion for New Trial and Motion for JNOV Regarding the Court’s August 27, 2003 , Judgment for Disbarment. (Record “134”)

On November 7, 2003 , after a hearing Judge Fry signed an Order on WorldPeace’s Second Amended Motion to Vacate or Modify Judgment of Disbarment of August 27, 2003 . (Record “239”)

On November 7, 2003 , after a hearing Judge Fry signed an Order on WorldPeace’s Third Amended Motion for New Trial. (Record “238”)

REQUIREMENTS FOR MANDAMUS

1)  There is no remedy on appeal because per Rule 3.14 Texas Rules of Disciplinary Procedure (Appendix) a Judgment for Disbarment cannot be superseded or stayed. 

2)  Judge Fry’s actions in the underlying disciplinary petition as presiding judge are a clear abuse of discretion. 

3)  The Texas Disciplinary Rules of Professional Conduct affect over 67,000 attorneys in Texas and so WorldPeace’s Application for Writ of Mandamus regarding the underlying disciplinary petition is important to the jurisprudence of the state.  Further, this Application involves the construction and validity of a statute; Rule 3.12, Texas Rules of Disciplinary Procedure as it relates to Rules 1.14(a), 1.14(b), and 1.14(c) Texas Disciplinary Rules of Professional Conduct.

ISSUE ONE  

            Is it an abuse of discretion for Judge Fry to order a Rule 3.12 TRDP restitution of funds to Complainant Collins from WorldPeace when Complainant Collins is barred by res judicata from suing for restitution and therefore the Commission is also barred from suing for restitution for the Complainant under Rule 4.06A TRDP?  

ISSUE TWO  

            Is it an abuse of discretion for Judge Fry to order a Rule 3.12 TRDP restitution of funds to Complainants Lang, Fraser-Nash, and Williams in the underlying lawsuit when no funds issue were submitted to the jury regarding TDRPC Rule 1.14(a), 1.14(b) and 1.14(c)?  

ISSUE THREE  

            Is it an abuse of discretion for Judge Fry to award a Rule 3.12 TRDP restitution of funds as sanctions regarding Complainant Lang after severing WorldPeace’s counterclaims for fees against Lang from the underlying disciplinary petition?

AUTHORITIES:  ABUSE OF DISCRETION – GENERAL

“A trial court “abuses its discretion when it reaches a decision so arbitrary and unreasonable as to amount to a clear and prejudicial error of law.”  Johnson v. Fourth Court of Appeals, 700 S.W. 2d 916, 917 (Tex. 1985, orig. proceeding).”

            Crouch v. Gleason, 875 S.W. 2d 738, 739 (Tex. App. – Amarillo 1994)

“On the other hand, review of a trial court’s determination of the legal principles controlling its ruling is much less deferential.  A trial court has no ‘discretion’ in determining what the law is or applying the law to the facts.   Thus, a clear failure by the trial court to analyze or apply the law correctly will constitute an abuse of discretion and may result in appellate reversal by extraordinary writ…

            Walker v. Packer, 827 S.W. 2d 833, 839-40 (1992) (citations omitted).”

            Hartford Accident & Indemnity Company v. Abascal, 831 S.W. 2d 559, 563 (Tex. App. – San Antonio 1992)

            “Aside from the “clear abuse of discretion” threshold set forth in Walker , supra, the supreme court has also stated that mandamus will lie to correct a “gross” abuse of discretion by the trial court.  State v. Sewell, 487 S.W. 2d 713, 718 ( Tex. 1972).  “The relator must establish, under the facts of the case, that the facts and law permit the trial court to make but one decision.”  Johnson v. Fourth Court of Appeals, 700 S.W. 2d 916, 917 ( Tex. 1985).  Put differently: “[A] clear abuse of discretion, when utilized as the basis for an original mandamus proceeding, refers to the unique situation wherein the lower court, exercising a ‘discretionary’ authority, has but one viable course to follow and one legitimate way to decide the question presented, but instead issues a contrary ruling.”  Cessna Aircraft Co. v. Kirk, 702 S.W. 2d 321, 323 (Tex. App. – Eastland 1986, orig. proceeding).”

            Monroe v. Blackmon, 946 S.W. 2d 533, 536 (Tex. App. – Corpus Christi 1997)

Texas Rules of Disciplinary Procedure

Rule 3.12 Restitution

            In all cases in which the proof establishes that the Respondent’s conduct involved misapplication of funds and the judgment is one disbarring or suspending the Respondent, the judgment must require the Respondent to make restitution during the period of suspension, or before any consideration of reinstatement from disbarment, and shall further provide that a judgment of suspension shall remain in effect until proof is made of complete restitution.

Texas Disciplinary Rules of Professional Conduct

Rule 1.14 Safekeeping Property

            (a) A lawyer shall hold funds and other property belonging in whole or in part to clients or third persons that are in a lawyer’s possession in connection with a representation separate from the lawyer’s own property.  Such funds shall be kept in a separate account, designated as a “trust” or “escrow” account, maintained in the state where the lawyer’s office is situated, or elsewhere with the consent of the client or third person.  Other client property shall be identified as such and appropriately safeguarded.  Complete records of such account funds and other property shall be kept by the lawyer and shall be preserved for a period of five years after termination of the representation.

(b) Upon receiving funds or other property in which a client or third person has an interest, a lawyer shall promptly notify the client or third person.  Except as stated in this rule or otherwise permitted by law or by agreement with the client, a lawyer shall promptly deliver to the client or third person any funds or other property that the client or third person is entitled to receive and, upon request by the client or third person, shall promptly render a full accounting regarding such property.

(c) When in the course of representation a lawyer is in possession of funds or other property in which both the lawyer and other person claim interests, the property shall be kept separate by the lawyer until there is an accounting and severance of their interest.  All funds in a trust or escrow account shall be disbursed only to those persons entitled to receive them by virtue of the representation or by law.  If a dispute arises concerning their respective interests, the portion in dispute shall be kept separated by the lawyer until the dispute is resolved, and the undisputed portion shall be distributed appropriately.  

ARGUMENT REGARDING RESTITUTION

NO RULE 1.14 TDRPC ISSUES TO THE JURY TO SUPPORT

RULE 3.12 TRDP RESTITUTION REGARDING COMPLAINANTS

LANG, FRASER-NASH, AND WILLIAMS OF RESTITUTION  

Rule 3.12 TRDP (Appendix) allows the trial court to award restitution if there is a misapplication of funds.  The term funds in Rule 3.12 relate to Rule 1.14 TDRPC (Appendix) regarding the safekeeping of a client’s property.  The funds referred to in Rule 3.12 are very specifically defined in Rule 1.14 TDRPC.  

Relator WorldPeace’s position is that without a finding of a Rule 1.14 (a, b or c) violation from the jury in the underlying disciplinary petition, the judge of the trial court cannot award Rule 3.12 TRDP restitution.

Relator brought this to the attention of Judge Fry with regards to Complainants Lang, Fraser-Nash and Williams in Respondent WorldPeace’s Third Amended Motion for New Trial and Motion for JNOV Regarding the Court’s August 27, 2003, Judgment for Disbarment (Record “226”) and WorldPeace’s Second Amended Motion to Vacate or Modify Judgment of Disbarment of August 27, 2003 (Record “163”).

WorldPeace would show the court that it was an abuse of discretion for the court to arbitrarily find that there was a misapplication of funds when the issue was never submitted to the jury.  Since the question was not submitted to the jury, Judge Fry had no discretion to arbitrarily award restitution.

THE COMMISISON WAS BARRED BY RES JUDICATA FROM PROCEEDING AGAINST WORLDPEACE FOR RESTITUTION REGARDING COMPLAINANT COLLINS

WorldPeace would show the court that he sued Complainant Collins in Cause Number 2000-31108; WorldPeace v. Collins, 281^st District Court, Harris County, Texas.  (Record “7”) WorldPeace would show the court that Collins did not sue for restitution in her Answer and Counterclaim. (Record “1”)

WorldPeace would show the court that a Final Judgment (Record “31”) was entered in the WorldPeace v. Collins lawsuit on March 10, 2003 , a month before trial began in the underlying disciplinary petition against WorldPeace on April 14, 2003 . 

Per Rule 4.06A, (Appendix) the Commission is placed in privity with a Complainant and steps into the shoes of a Complainant with regards to all of Complainants common law rights. 

If the Complaint has no common law rights, then the Commission had no common law rights.  If Collins is barred by res judicata from suing WorldPeace for restitution, then the Commission is barred as well.

WorldPeace would show the court that this issue also relates to the “suit within a suit” requirement of a malpractice suit.  The commission must prove that Collins could have won a suit for restitution.  Since the only basis for restitution is in Rule 4.06A TRDP which grants the Commission the Complainants common law rights, at the least, a Complainant must have a common law right of restitution. 

In the underlying disciplinary petition, Collins could not have won such a suit because she was barred under Rule 97a TRCP from bringing such a suit due to the fact that she had not filed a compulsory counterclaim in the underlying WorldPeace v. Collins lawsuit.

Wherefore, premises considered, Judge Fry abused his discretion by awarding restitution to Complainant Collins and the violations of Rule 1.14 (a, b and c) regarding Collins should be stricken from Judge Fry’s August 27, 2003, Judgment for Disbarment.

SEVERANCE CASES

SEVERANCE Abuse of Discretion CASES  

We find the trial court further erred in severing appellant’s cross action because same is based upon identical facts and issues growing out of and connected with appellee’s cause of action against him.  Such cross action or counterclaim is styled ‘compulsory counterclaims,’ under (a), Rule 97, Texas Rules of Civil Procedure.  It is mandatory to file such action in the cause of action set up by the opposing party in order to avoid circuity of action, inconvenience, expense and consumption of the court’s time in trying said cross action in an independent suit.  We deem if it is necessary to file such cross action that it is also imperative to try it in the same cause.  See notes under Rule 97, sec. (a).

We do not find, as contended by appellee, that section (b) under Rule 174, T.R.C.P., is sufficiently broad to grant a trial court authority to sever causes of action relating to the same subject matter, such as the one before this court.

            Judgment of the trial court is reversed and the cause remanded for another trial not inconsistent with this opinion.

            Ulmer v. Mackey, 242 SW2d 679, 682 (Tex. App. – Fort Worth, 1951)

            We deem if it is necessary to file such cross action that it also imperative to try it in the same cause. ‘This same case also points out that the purpose of rule 97(a) is to ‘avoid circuity of action inconvenience, expense and consumption of the court’s time in trying said cross action in an independent suit’.

            Bolding v. Chapman, 394 SW2d 862, 864 (Tex. App. - Austin, 1965)

            We are of the opinion that appellants’ contention must be sustained.  As we construe the pleadings of the parties, they do not present two distinct lawsuits subject to a severance under the Rules of Civil Procedure No. 41.

            The whole controversy grows out of but one transaction and should be tried in one case.

            ***Our courts have always frowned upon piecemeal trials, deeming the public interest, the interests of litigants and the administration of justice to be better served by rules of trial which avoid a multiplicity of suits.***

            We have direct authority that it was error for the trial court to sever the cross action of defendants Ulmer v. Mackey, Tex.Civ.App., 242 SW2d 679.

            *** We find the trial court further erred in severing appellant’s cross action because same is based upon identical facts and issues growing out of and connected with appellee’s cause of action against him.  Such cross action or counterclaim is styled ‘compulsory counterclaims,’ under (a), Rule 97, Texas Rules of Civil Procedure.  It is mandatory to file such action in the cause of action set up by the opposing party in order to avoid circuity of action, inconvenience, expense and consumption of the court’s time in trying said cross action in an independent suit.  We deem if it is necessary to file such cross action that it is also imperative to try it in the same cause.  See notes under Rule 97, sec. (a).***

            Since the trial court erred in granting a severance in this case, it is our opinion that the judgment of the trial court should be reversed and the cause remanded to that court for another trial.

Spangler v. Hickey, 401 SW2d 721, 723 (Tex. App. – Tyler, 1966)

A counterclaim meets the provisions of Rule 97(1), T.R.C.P., which states:

‘Compulsory Counterclaims.  A pleading shall state as a counterclaim any claim within the jurisdiction of the court, not the subject of the pending action, which at the time of filing the pleading the pleader has against any opposing party, if it arises out of the transaction or occurrence that is the subject matter of the opposing party’s claim and does not require for its adjudication the presence of third parties of whom the court cannot acquire jurisdiction.

The trial court abused its discretion in severing the Bank’s claim from Bohart’s compulsory counterclaim arising out of and turning upon the same facts.

We hold the compulsory counterclaim of Bohart and the Bank’s claim involve identical facts, issues, and subject matter, and are so interwoven a severance would occasion unnecessary litigation and a multiplicity of suits.  As stated in 3 McDonald , Texas Civil Practice § 10.25 (1970).

“…The trial court should not sever the plaintiff’s claim from the defendant’s compulsory counterclaim, or a cross-claim between defendants, arising out of and turning upon the same facts…”

The granting of the severance was an abuse of discretion.  Bates v. First National Bank of Waco , 502 SW2d 181 (Tex.Civ.App. – Waco 1973, no writ).

We can find nothing in the record to cause us to change the judgment heretofore entered.  The motion for rehearing is overruled.

Bohart v. First National Bank in Dallas , 536 SW2d 234, 235-6 (Tex. App. – Eastland, 1976)

“For a severance to be proper, the following elements are necessary: (1) the controversy must involve more than one cause of action, (2) the severed cause must be one that would be the proper subject of a lawsuit if independently asserted, and (3) the severed causes must not be so intertwined as to involve the same identical facts and issues.”  Straughan v. Houston Citizens Bank & Trust Co., 580 SW2d 29, 33 (Tex.Civ.App. – Houston [1^st Dist.] 1979, no writ).  Broad discretion is given to the trial court to determine joinder of parties and severances, and a trial court’s ruling will not be disturbed absent a showing of an abuse of discretion.  Squires v. Squires, 673 SW2d 681, 684 (Tex.App. – Corpus Christi 1984, no writ).  Severance is appropriate if the controversy involves two or more distinct causes of action, Duke v. Merkin, 599 SW2d 877 (Tex.Civ.App. – El Paso 1980, no writ); however, an order that splits a single cause of action, or that serves compulsory counterclaims from the primary suit, will constitute an abuse of discretion.  See Nueces County Hospital District v. Texas Health Facilities Commission, 576 SW2d 908 (Tex.Civ.App. – Austin 1979, no writ).

These pleadings clearly illustrate that the alleged personal injury and property claims arose from a single wrongful act and should not be severed.

In light of these findings, we hold that the order entered by the respondent on May 13, 1985, severing personal injury claims from property claims, was improper and therefore an abuse of discretion.

Ryland Group, Inc. v. White, 723 SW2d 160, 161-2 ( Tex. App. – Hous. (1 Dist.) 1986)

Although the trial court has broad discretion in ordering severances, the severance of a compulsory counterclaim which arises out of the same contract or issue that is the subject of the suit, constitutes an abuse of discretion and is reversible error.  Ryland Group, Inc. v. White, 723 SW2d 160 (Tex. App. – Houston [1^st Dist.] 1986, no writ).

Mathis v. Bill de la Garza & Associates, P.C., 778 SW2d 105, 106-7 (Tex. App. – Texarkana, 1989)

The Restatement of Judgments also takes the transactional approach to claims preclusion.  It provides that a final judgment on an action extinguishes the right to bring suit on the transaction, or series of connected transactions, out of which the action arose.  Restatement of Judgments § 24(1).  A “transaction” under the Restatement is not equivalent to a sequence of events, however, the determination is to be made pragmatically, “giving weight to such considerations as whether the facts are related in time, space, origin, or motivation, whether they form a convenient trial unit, and whether their treatment as a trial unit conforms to the parties’ expectations or business understanding or usage.”  Id. § 24(2).

We conclude that the transactional approach to claims preclusion of the Restatement effectuates the policy of res judicata with no more hardship than encountered under rule 97(a) of the rules of civil procedure.  Modern rules of procedure obviate the need to give parties two bites at the apple, as was done in Griffin , to ensure that a claim receives full adjudication.  Discovery should put a claimant on notice of any need for alternative pleading.  Moreover, if success on one theory becomes doubtful because of developments during trial, a party is free to seek a trial amendment.

We reaffirm the “transactional” approach to res judicata.  A subsequent suit will be barred if it arises out of the same subject matter of a previous suit and which through the exercise of diligence, could have been litigated in a prior suit.  For these reasons, the judgment of the court of appeals is reversed and that of the trial court is affirmed.

Barr v. Resolution Trust Corp., Sunbelt Federal Savings, 837 SW2d 627, 631 ( Tex. 1992)

Rule 41 of the Texas Rules of Civil Procedure vest the trial court with broad discretion to sever and order separate trials of causes of action.  Guaranty Federal Sav. Bank v. Horseshoe Operating Co., 793 SW2d 652, 658 (Tex. 1990); U.S. Fire Ins. Co. v. Millard, 847 SW2d 668, 671 (Tex. App. – Houston [1^st Dist.] 1993, orig. proceeding).  The trial court’s discretion is not unlimited, however.  Id. Thus, the trial court’s decision to sever a claim is reversible error if the trial court abused its discretion.  Horseshoe Operating Co. , 793 SW2d at 658.

An order that severs a compulsory counterclaim from the main suit, however, is an abuse of discretion.  Ryland Group, Inc. v. White, 723 SW2d 160, 161 (Tex.App. – Houston [1^st Dist.] 1986, orig. proceeding). 

Goins v. League Bank and Trust, 857 SW2d 628, 630 ( Tex. App. – Hous. (1 Dist.) 1993)

Rule 41 of the Texas Rules of Civil Procedure states that any claim against a party may be severed and proceeded with separately.  Tex.R.Civ.P.41.  The rule grants the trial court broad discretion in the matter of severance of causes.  A trial court’s decision to sever will be reversed only upon finding an abuse of discretion.  Id.   However, courts have long recognized that it is an abuse of discretion to grant a severance that splits a single cause of action.

A “cause of action” consists of a plaintiff’s primary right to relief and the defendant’s act or omission that violates that right.

Duncan v. Calhoun County Navigation District, 28 SW3d 707, 709-10 ( Tex. App. – Corpus Christi 2000)

ARGUMENT REGARDING SEVERANCE

In addition to the fact that no jury question was submitted to the jury regarding WorldPeace’s violation of Rule 1.14 with regards to Complainant Lang, Judge Fry in pretrial severed WorldPeace cause of action for attorney fees against Lang. (Record “39”)   This was memorialized in Judge Fry’s August 27, 2003 , Order of Severance.  (Record “133”) WorldPeace counterclaim for fees against Lang was a Rule 97a TRCP compulsory counter claim.

The transaction upon which Judge Fry awarded restitution to Lang is the same transaction upon which WorldPeace based his counterclaim for attorney fees. 

Under Rule 41 TRCP or Rule 174(b) TRCP and the supporting case law above severing or having separate trials in the Lang matter was an abuse of discretion.

PRAYER

WHEREFORE, premises considered, WorldPeace moves this court to order Judge Fry to modify his August 27, 2003 , Judgment for Disbarment to eliminate the award of Restitution with regards to Complainants Lang, Fraser-Nash, Williams, and Collins and for such other and further relief at law or in equity as this court may deem proper.

Respectfully submitted,

_______________________________
John WorldPeace
2620 Fountain View, Suite 106
Houston , Texas 77057
Tel. 713-784-7618
Fax. 713-784-9063
TBA No. 21872800  

CERTIFICATE OF SERVICE  

            I certify that a true and correct copy of the foregoing pleading was forwarded to opposing counsel and Judge Fry on November 19, 2003 , by fax and to the Clerk of the Supreme Court of Texas on November 19, 2003 , via EXPRESS MAIL.  

                                                                                                                                                                       John WorldPeace  

CERTIFICATE OF CONFERENCE  

            Opposing Counsel opposes the RELATOR’S APPLICATION FOR MANDAMUS.  

____________________________________
                                                                        John WorldPeace

APPENDIX  

EXHIBIT       DESCRIPTION  

A.  August 27, 2003              Judgment for Disbarment  

B.  August 27, 2003              Order of Severance  

Rule 3.12  Texas Rules of Disciplinary Procedure

Rule 3.14  Texas Rules of Disciplinary Procedure

Rule 4.06(a)  Texas Rules of Disciplinary Procedure

Rule 1.14(a)  Texas Disciplinary Rules of Professional Conduct

Rule 1.14(b)  Texas Disciplinary Rules of Professional Conduct

Rule 1.14(c)  Texas Disciplinary Rules of Professional Conduct

Rule 41  Texas Rules of Civil Procedure

Rule 97(a)  Texas Rules of Civil Procedure

Rule 174(b)  Texas Rules of Civil Procedure

NO. ________________

IN THE SUPREME COURT

OF TEXAS

______________________________

IN RE:

JOHN WORLDPEACE

______________________________

Re:  Cause No. 2002-42081; Commission for Lawyers Discipline v. John WorldPeace, 269^th District Court

Harris County , Texas

______________________________________________________________________

AFFIDAVIT OF JOHN WORLDPEACE, ATTORNEY AT LAW

______________________________________________________________________

STATE OF TEXAS
COUNTY OF HARRIS  

BEFORE ME, the undersigned authority, on this day personally appeared the affiant, John WorldPeace, who being by me first duly sworn, on his oath stated:  

My name is John WorldPeace, I am over 21 years of age, of sound mind, capable of making this affidavit and fully competent to testify to the matters stated herein, have personal knowledge of each of the matters stated herein, and the facts contained in this affidavit are true.           

The exhibits in the Appendix and Record attached to RELATOR’S Application for Writ of Mandamus are true and correct copies of the originals.  

Further affiant sayeth not.”  

__________________________________
                                                                        John WorldPeace  

SUBSCRIBED AND SWORN TO BEFORE ME on this _______ day of _________________, 2003.

____________________________________
                                                                        NOTARY PUBLIC IN AND FOR THE 
                                                                        STATE OF TEXAS

RECORD  

A.  October 27, 2000             FIRST AMENDED ANSWER AND COUNTERCLAIM FOR DECLARATORY JUDGMENT  

B.  November 8, 2000           WORLDPEACE’S THIRD AMENDED ORIGINAL PETITION  

C.  January 16, 2003              SECOND AMENDED DISCIPLINARY PETITION  

D.  March 10, 2003                AMENDED TAKE NOTHING JUDGMENT AND AWARD OF RULE 13 SANCTIONS  

E.  April 14, 2002                  Reporter’s Record of pretrial regarding Lang and Apodaca Grievance  

F.  April 24, 2003                   JURY CHARGE  

G.  July 21, 2003                    DEFENDANT’S SEVENTH AMENDED ORIGINAL ANSWER AND COUTNERCLAIMS AND THIRD PARTY CLAIMS  

H.  August 27, 2003               JUDGMENT FOR DISBARMENT  

I.  August 27, 2003                 ORDER OF SEVERANCE  

J.  September 26, 2003         RESPONDENT WORLDPEACE’S THIRD AMENDED MOTION FOR NEW TRIAL AND MOTION FOR JNOV REGARDING THE COURT’S AUGUST 27, 2003, JUDGMENT FOR DISBARMENT  

K.  September 26, 2003        WORLDPEACE SECOND AMENDED MOTION TO VACATE OR MODIFY JUDGMENT OF DISBARMENT OF AUGUST 27, 2003  

L.  November 7, 2003            ORDER ON WORLDPEACE’S THIRD AMENDED MOTION FOR NEW TRIAL  

M.  November 7, 2003          ORDER ON WORLDPEACE’S SECOND AMENDED MOTION TO VACATE OR MODIFY JUDGMENT OF DISBARMENT AUGUST 27, 2003

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