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Cause No. 2012-24678 PATRICIA POTTS, individually, and as next friend to Minor, A.M. W. Plaintiffs, vs. TEXAS DEPARTMENT OF FAMILY AND PROTECTIVE SERVICES, et al Defendants.

§ § § § § § § § §

Filed 12 August 7 P1:51 Chris Daniel- District Clerk Harris County ED101J017012456 By: Wanda Oakley

IN THE DISTRICT COURT OF HARRIS COUNTY, TEXAS

257TH JUDICIAL DISTRICT

PARTIES AGREED (APPELLATE) RECORD PURSUANT TO TRCP RULE 34.2, and TRCP RULE 34.5(B) REQUEST FOR ADDITIONAL ITEMS COMES PRO SE PLAINTIFF POTTS, individually and as next friend to minor A.M.W., to file this TRCP Rule 34.2 “Parties Agreed Record” and TRCP Rule 34.5 “Request for Additional Items” to give written stipulation to Clerk for content of the Appellate Record. No Defendants have yet been served process in this lawsuit; therefore Adult and Minor Appellants are the only Parties to this appeal. Appellant-Parties agree to the following content for appellate record: 1.

Pauper’s Oath and Original Petition for Bill of Review (with exhibits A thru E) e-filed April 27, 2012.

2.

1st amended petition for bill of review (with exhibits A thru E) efiled May 09, 2012.

3.

Order for Stay and Dismissal of Lawsuit pursuant to Civ. Prac. & Rem. Code 11.103(b) signed by Judge Warne on May 10, 2012.

4.

Notice of Intent to Compel Production from Non-Party Attorney Frank Knight efiled on May 11, 2012, mailed thru usps on May 14, 2012.

5.

Notice of Intent to Compel Production from Non-Party Beverly Ellis efiled on May 11, 2012, mailed thru usps on May 14, 2012.

6.

Notice of Intent to Compel Production from Non-Party Darlene Forville efiled on May 11, 2012, mailed thru usps on May 14, 2012. Page 1 of 3


7.

“Objection and Request for Order Directing District Clerk to Stop Depriving Plaintiff of Right to Proceed Informa Pauperis in this Lawsuit” efiled May 18, 2012.

8.

“Objection to Order for Stay and Dismissal of Lawsuit pursuant to Civ. Prac. & Rem. Code 11.103(b) and Motion to Vacate the Same” efiled June 01, 2012, mailed thru usps on June 05, 2012.

9.

2nd amended petition for bill of review (with exhibits A thru E) efiled June 04, 2012.

10. “Objection to Notice to Dismiss for Want of Prosecution, and Request for Online Access to Lawsuit and for Online Discovery thru Email” (with attached Exhibits A thru H and “Notice of June 15, 2012 Hearing” (for all Plaintiffs’ filed motions and requests)) efiled on June 11, 2012. 11. Final Default Judgment of Dismissal filed June 15, 2012 and signed June 18, 2012. 12. “Notice of Hearing Rescheduled to June 22, 2012, And Additional Support for Requests for Orders Vacating Stay and Directing Clerk to Serve Defendants (Total 16 pages with attachments) efiled June 19, 2012. 13. “Notice of Appeal” (with attached Pauper’s Oath) efiled June 21, 2012. 14. “Objection to Judge’s Refusals to Rule, and Objection to Defendant Clerk’s Continuing Failure to Serve Notice of Judgments to Plaintiffs” (and proposed order) mailed thru usps, file-stamped July 05, 2012. 15. “Verified Motion to Reinstate Lawsuit Dismissed for Want of Prosecution” (and proposed order) mailed thru usps, file-stamped July 05, 2012. 16. “Request for Hearing on Motions to Reinstate Lawsuit, to Vacate Order for Stay and Dismissal, and for Order Directing Clerk to Serve Process to Defendants and to Serve Notices of Judgment to Plaintiffs” (and proposed order) efiled July 18, 2012. 17. “First Amended Notice of Appeal” (with copy of Pauper’s Oath submitted June 21st) efiled July 26, 2012. 18. Court Docket Sheet for cause #2012-21678. Page 2 of 3


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PATRICIA A. POTTS  

WHISTLEBLOWER PRO SE LITIGATION

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