August 21, 2009
Texas Attorney General
Greg Abbott
Public Information Office
General Counsel Davison
Mr. Reg Hargrove
Post Office Box 12548
Austin, Texas 78711- 2548
Re: Open Records Request “C” for August 21, 2009 and demand for payment of COST plus attorney fees and expert fees and the firing of KAREN MATLOCK FOR CAUSE.
Mr. Hargrove:
The undersigned requestor has filed various complaints against attorney KAREN MATLOCK and her “special friends” [co-conspirators] under the RICO and common-law theories in court and with the OFFICE OF THE TEXAS ATTORNEY GENERAL and your office is reckless and negligent and has not fired KAREN MATLOCK as of this writing. This breach of duty is UNACCEPTABLE and TEXAS ATTORNEY GENERAL GREG ABBOTT is required by law to stop playing games because that is what he is doing and his actions personally meet the RICO statue of a criminal chain conspiracy and that his ‘governmental’ business practices are not authorized or mandated by anything other than self dealing- I intend to disgorge attorney fees paid to the government lawyers and any others who obstructed justice and came to a federal court case to exact RETALIATION and do effect the same ignored the Texas Constitution about a TEXAS DOUBLE STANDARD where KAREN MATLOCK “risked her law license” and is allowed by her continued employment further the criminal RICO chain conspiracy where she murder my friend, hurt my father and MY CHILDREN and that is just the tip of the ice berg.
Damages sought and intended to be sought treble damages under the RICO claims that included: (a) fraud on the court and obstruction of justice (b) mail and wire fraud, (c) receiving funds taken by fraud, (d) transporting persons to defraud among other related criminal activity including a bevy of state and federal violations. Common-law claims included: (a) fraud, (b) knowing participation in breach of fiduciary duty, (c) conversion, (d) theft, (e) conspiracy, and (f) negligence. Requested are documents connected to the resignation or the intent to fire attorney KAREN MATLOCK for cause and or for the professional misconduct described herein. Put another way; fire KAREN MATLOCL T O D A Y and provide me confirmation it will facilitate a settlement and immediately lessen the work load that I have intended for this office.
October 25, 2004 (at 67) KAREN MATOCK, David Talbot JR., Edward D. Burbach, and GREG ABBOTT violated the Texas Constitution and interfered in a federal civil rights case absent legal authority; (a) fraud, (b) negligence, (c) conspiracy to violate RICO, and (d) conspiracy to commit fraud, and those violations led to the murder of a federal witness namely Melinda “Lindy Harrison” Honerkamp. As you are aware requestor/plaintiff has provided this office ample opportunity via OPEN RECORDS ACT ( FOIA) to produce a basis in fact and law where there is a very good possibly your office wasted over twenty million dollars of state revenues to exact revenge and RETALIATE against two women [were not only married to state officials] but federal information sources one of which is recognized the other by confidential agreement and the OFFICE OF THE TEXAS ATTOREY GENERAL ignored its own opinion as it relates to dealing with federal information sources. (Emphasis added).
The Office of the Texas Attorney General posture to deny costs may be imposed directly on the party when the allegations lack factual support. Skidmore Energy, Inc. v. KPMG, 455 F. 3d 564, 568 (5th Cir. 2006). The demand for cost [not actual or punitive damages] to plaintiff and her witnesses are estimated to exceed $ 511,000.00 plus attorney fees and expert fees and your check for the same is demand TODAY. Please submit a copy of this Request for Cost of $ 511,00,00 to be paid through the appropriate channels and requested are documents where you have complied with the demand for payment of cost and the cost is estimated at 100.00 per day since the commencement of the State Bar of Texas grievance hearings attorney Betty Barrett Homminga Yarter and Carla Roberson Cummings- Texas poster child for lying and frivolous litigation, and the “unlicensed investigations” victim that was a licensed by the Texas Board of Private Investigators.
Melinda “Lindy Harrison” Honerkamp was a successful and proven federal information source – credible and this is not the case of some inept attorney filing pleadings without the client’s knowledge! KAREN MATLOCK actions were intended to harm and cause eventual death and her behavior is absent remorse and stayed the same even to this date where her continued denial is aiding and abetting the continued RICO criminal chain conspiracy described by the requestor in 4:03-CV-HO-02395 and 4:08-CV-HO-028. KAREN MATLOCK and the other co- conspirators should bear the costs she/they imposed on PLAINTIFF / REQUESTOR ETAL unnecessarily.
Requestor by OPEN RECORDS ACT requests costs- and your response is incomplete (emphasis added). These are the costs for the entire events albeit illegal connected to the “CAPIAS” client which commenced August 03, 1996 upon the issuance of a private investigator licensed to CHERYL YATES WEBB. KAREN MATOCK does not and cannot dispute the illegal dissemination or that she and the Texas Attorney General entered a court case to protect the illegal RICO business of billionaire attorney JOHN M.O’QUINN and neither move to prohibit the requestor’s investigation or speech.
Due to the illegal actions of KAREN MATLOCK the issue is whether her fees for professional services are reasonable under the circumstances and where ‘attorney’. Karen Matlock produced and examined thousands of documents, prepared for and attended several depositions, and responded to meritorious allegations of plaintiff /requestor since October 25, 2004 and even participated in a trial asking the court to introduce her as “just Karen Matlock” because that is what she preferred and she is still not fired is- NOT WORKABLE and in furtherance of the RICO chain conspiracy complained about – she is currently destroying government records and the offer of proof is in your responses to my request of document again -- NOT WORABLE.
The Texas Attorney General Office has been involved in litigation absent legal authority since October 25, 2004 –and that period has extended to over nearly five (5) years of litigation. All of the costs and fees requested are reasonable to learn and you have not produced them and or your production is incomplete and I am unable to calculate my damages, the damages to Lindy’s estate, the tort interference, and the qui tam reward attached to my name for the RICO court victims previously identified in 4:08-CV-HO-02395 (emphasis added).
KAREN MATLCOK’S lack of a proper foundation would have been disclosed by a reasonable investigation, careful of the facts, but she argued at my second deposition “the mark of a good prosecutor was to put actually innocent citizens/ people in jail and it has been detected KAREN MATLOCK is EVIL (emphasis added). KAREN MATLOCK’S claims her actions / illegal activity does not justify imposing costs on her and the Texas Attorney General ETAL- she and the TEXAS ATTORNEY GENERAL – ARE WRONG.
KAREN MATLOCK reliance on her faulty investigation and ‘professional’ illegal billable hour program ignores another part of her bad faith; she threw serious and baseless legal claims at two (2) actually innocents citizens/witnesses and federal information sources and by doing so one of the actually innocents citizens/witnesses and federal information sources met an unlawful death August 5, 2005-that being Melinda “Lindy Harrison” Honerkamp.
Experience suggests that the quality of a pleading is inversely proportional to the volume of legal theories it attaches to an events in litigation where KAREN MATLOCK violated the Texas Constitution to advance the RICO enterprise of billionaire attorney JOHN M. O’QUINN. KAREN MATLOCK [with taxpayer revenue] made no attempt to marshal facts pursuant to the mission statement of the OFFICE OF THE TEXAS ATTORNEY GENERAL clearly proving your office violated the Texas Deceptive Trade Practice Act (emphasis added). KAREN MATLOCK’S assertion are desipient and of these claims in a federal civil rights litigation was unprincipled – ranging from reckless to malicious and she must pay for the harm she has done and she must pay with her life – requester has and will continue to seek the death penalty.
Bottom line, KAREN MATLOCK must pay for the harm she he has done since she entered a court case October 25, 2004 filed IN THE SDTX Carol Ann Davis v. City of Jersey Village ETAL numbered 4:03-CV-HO-02395 . Requestor warned of its intent to seek sanctions in a letter dated August 30, 2006 and before the first attempt to vacate the verdict in a trial where KAREN MATLOCK had no business and still has no business except now as a defendant to a MURDER. KAREN MATLOCK knew then not only that her case certainly lacked merit but that sanction was a distinct possibility and requested are documents to demonstrate you have met your obligation connected to the Rules of Professional Conduct and reported the violations of state and federal law to the Texas State Auditor and the State Bar of Texas ( even though they are complicit with DPS Special Crimes and KAREN MATLOCK as it relates to Melinda Honerkamp video testimony connected to the crimes of CARLA HENDRICKSON ROBERSON CUMMINGS – and the reckless and negligent referral of attorney Joe Jamal and where Lindy said an illegal deal was made “not to depose the well-site guy” so that the lawyers could perfect a RICO scheme and bilk innocent shareholders. These are the same characters/actors where DPS Special Crimes with the O’QUINN LAW FIRM [ and an ex- trooper Charles Soechting disseminated the TCIC.NCIC TLETS government data bases not pursuant to the Texas Government Code Subchapter”F” and you are aware represented in the “CAPIAS” client that was not expunged like KAREN MATLOCK repeatedly advise the court in her ‘motion’ and before the bench. KAREN MATLOCK lied to a FEDERAL COURT JUDGE – and know before this investigation is over [ where she is desipient to think otherwise] it is intended to be learned how many other cases did KAREN MATLOCK LIE TO A FEDERAL COURT JUDGE because she has found the federal courts to such a comfortable place to spin baseless litigation. As a precautionary matter the action of firing KAREN MATLOCK is requested in no uncertain terms today.
Finally requested are the August 21, 2009 9:40 AM tape recordings of the requester articulating the RICO crimes of KAREN MATLOCK.
Respectfully submitted,
Original Emailed Aug 21-09 9:47 AM
Carol Ann Davis
25311 Sugar Valley Lane
Spring, Texas 77373
281-350-2943/713-560-5940
Copies to:
Judge Ewing Werlein JR.
Attorney Jerry S. Payne
Texas State Auditor [-Lucy Cantu]
(512) 936-9554 facsimile (512) 936-9812
Friday, August 21, 2009
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